United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPAIRODIR08-91/052
September 1991
i>E'rz- 167'YDC
<>
.r
oEPA
Superfund
Record of Decision:
Broderick Wood Products
(Amendment), CO
Hazardous Waste Colfectfon
information Resource Center
US EPA Region 3
Philadelphia, PA 19107
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50272-101
REPORT DOCUMENTATION 11. REPORTNO.
PAGE EPA/ROD/R08-91/052
~
II1II 8ubthI8
JPERFUND RECORD OF DECISION
Broderick Wood Products, CO
First Remedial Action - (Amendment)
7. AuIhor(a)
I ~
3. R8c1pient'a Acceulon No.
5. R8port D8t8
09/24/91
6.
8. Performing OrgllftlZ8t1on Rept. No.
J
"
8. PiIrtonning OrglllnlDllon ...... IIftd Add....
10. Proj8CtlTMklWOI'k Unit No.
11. ContNc1(C) or Gr8nt(G) No.
(C)
(G)
1~ Spon8oI1ng Org8lllz8llon ...... IIftd AddN88
U.S. Environmental Protection
401 M Street, S.W.
washington, D.C. 20460
13. Type of R8POft & PerIod Covered
Agency
800/000
14.
15. SUppI8m8nt8Iy No..
16. Ab8tract (Umlt: 200 -....)
The 64-acre Broderick Wood Products (BWP) site is a former wood treatment facility in
Adams County, Colorado. Land use in the area is predominantly industrial. The site
is one-half mile south of Clear Creek, a perennial stream. The nearest residences
are less than one-eighth mile north of the site. From 1947 to 1981, BWP used the
site for treating power poles, fence posts, railroad ties, and other wood products.
rocess wastes from the onsite plant were disposed onsite in two unlined surface
~mpoundments in the northwest corner of the site. Waste seepage occurred just north
of the site and was burned off starting in 1955. Also, four other ponds were
periodically used for this purpose, and several fires have occurred on site. In 1981,
BWP submitted a RCRA permitting application and obtained interim status to operate
its facility, but ceased operations because of economic conditions. As a result of
the waste disposal practices at BWP, a number of investigations were conducted by EPA
and the State. In 1981 and 1982, EPA noted several violations of RCRA requirements;
and other site investigations identified possibile contamination of a trench near the
surface impoundments that had reportedly been used for the disposal of solid waste,
and ground water contamination downgradient of the surface impoundments.
..
(See Attached Page)
17. Docum8nI An8ly8la .. Dnc:rIptor8
Record of Decision - Broderick Wood Products, CO
First Remedial Action - (Amendment)
Contaminated Medium: sludge
Key Contaminants: VOCs (toluene, xylenes), other organics (dioxin, PAHs), metals
(lead)
b. Id8ntltl8r8l~ T8fI1I8
Co COSA TI Fl8lcUGroup
\vlllabiity S\aIemenI
19. Security Cia.. (Thla Report)
None
20. Security Cia.. (Thla Page)
NnnA
21. No. 01 Pages
64
n PrIce
(SM ANSl-Z39.18)
See IntllTucliontl on Reverse
2n (4.77)
(Formetly NTlS-35)
DepsrbnenlolConvnerce
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EPA/ROD/R08-91/052
Broderick Wood Products, CO
r ~t Remedial Action - (Amendment)
Abstract (Continued)
Additionally, a fire in 1985 damaged the treatment plant building. Water that was used
"to fight the fire has been contaminated with asbestos and remains in the basement of the
o building. A 1988 Record of Decision (ROD) addressed interim source control treatment of
onsite sludge, as Operable Unit 1 (OUl), and provided for excavation and onsite
incineration of impoundment sludge, onsite incineration or stockpiling of visibly
, contaminated soil found beneath the sludge, and treatment of water in the impoundments
and buildings. Based on new technical data and cost information EPA has decided against
using incineration as treatment in OUI. This ROD amends the 1988 remedy for sludge
treatment. A future ROD will address the final remedy for the site by providing
treatment of contaminated soil, debris; and surface and ground water, as OU2. The
primary contaminants of concern affecting the sludge are VOCs including toluene and
xylenes; other organics including dioxin and PAHSi and metals including lead.
The amended remedial action for this site includes excavating and preparing 950 cubic
yards of solid sludge, 1,220 cubic yards of liquid sludge, and 500 gallons of oil
collected from the sludge from temporary storage cells within the impoundments area; and
transporting sludge and oil to a permitted recycling facility to reclaim creosote for use
at other wood treating facilities, followed by offsite incineration of recycler residues,
and offsite disposal of incinerator ash in a permitted landfill. The estimated total
cost for this remedial action ranges from $2,058,200 to $2,191,000. O&M costs are
included in the capital costs because treatment will occur offsite.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific sludge clean-up goals are based on
'A land disposal restrictions and include lead 0.51 mg/l, toluene 28 mg/kg, and
_~enes 33 mg/kg.
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30)
AMENDMENT TO JUNE~ 1988
RECORD OF DECISION
BRODERICK WOOD PRODUCTS
ADAMS COUNTY, COLORADO
OPERABLE UNIT 1 . IMPOUNDMENTS SLUDGES
SEPTEMBER 1991
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DECLARATION STATEMENT
FOR 30)
AMENDMENT TO JUNE,11988
RECORD OF DECISION
BRODERICK WOOD PRODUCTS
ADAMS COUNTY, COLORADO
OPERABLE UNIT 1 . IMPOUNDMENTS SLUDGES
SITE NAME AND LOCATION
Broderick Wood Products
Adams County (unincorporated), Colorado
STATEMENT OF BASIS AND PURPOSE
This decision document is an amendment to the Record of Decision (ROD) signed June 30,
1988 and presents the new selected remedial action for treatment of sludges from the
impoundments. at the Broderick Wood Products (BWP) Superfund site. The BWP site is
located at 5800 Galapago Street in unincorporated Adams County, Colorado. This ROD
Amendment is undertaken pursuant to the requirements delineated in Section 300.435 (c)(2)(ii)
of the National Contingency Plan (NCP) and Section 117 of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA).
This decision document explains the basis for selecting a different remedy for the
impoundments sludges at this site than that selected in the June 1988 ROD. The information
that forms the basis for this remedial action decision is contained in the Administrative Record
for this site and is summarized in the attached Decision Summary.
The State of Colorado concurs with the new selected remedy for treatment of sludges from the
impoundments at the BWP site.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action selected in this ROD, may present an imminent and
substantial endangerment to public health, welfare, or the environment.
DESCRIPTION OF NEW REMEDY FOR IMPOUNDMENTS SLUDGES
The BWP site has been divided into two operable units: interim actions/source control (OU 1)
and final remedy (OU 2). In June 1988, EPA issued a ROD for OU 1 to address source control
and the direct contact exposure pathway. The major components of the June 1988 ROD were
restriction of site access, excavation and on-site incineration of sludge, stockpiling or on-site
incineration of visibly contaminated soils beneath the impoundments, and treatment of water in
the impoundment and buildings. Based on new technical data and cost information obtained
subsequent to the June 1988 ROD, EPA has reconsidered its decision to employ on-site
incineration as a source control measure for OU 1. New data evaluated by EPA included
technical data on the interaction of contaminants and groundwater received from continuing
RIfFS activities for OU 2 and cost information for on-site incineration received during remedial
design for OU 1. Other components of the June 1988 ROD are not affected by this new
information. .
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The selected remedy presented in this ROD Amendment addresses the sludge from the
impoundments that contribute to contamination of environmental media at the BWP site. The
sludge contains elevated concentrations of pentachlorophenol (PCP), polynuclear aromatic
hydrocarbons (PAHs), volatile organic compounds, and chlorinated dioxins and furans.
Inhalation and ingestion of, and direct contact with these contaminants have been determined
to pose the principal threat to human health from the sludges. Remediation of the sludge is
intended to mitigate these exposure pathways.
OU 2 will address the final remedy for the site and includes contaminated soils, surface water
and ground water, and buildings, vessels and drums. The ROD for OU 2 is expected some
time later in 1991. .
The new remedial action for interim action/source control (OU 1) selected by EPA for treatment
of the sludges involves off-site reclamation of the useful components of the sludge, and
incineration and disposal of the residues. The major components of the selected remedy
include: .
.
removal and preparation of liquid and solid sludges from temporary storage cells within the
impoundments area; .
.
transportation of the sludges and oil collected from the sludges to a permitted recycling
facility;
reclamation 01 creosote for use at other wood treating facilities; and
.
.
treatment via incineration and disposal of residues by the recycler in a permitted landfill.
DECLARATION OF STATUTORY DETERMINATIONS
The newly selected remedy embodied in this ROD Amendment is protective of human health
and the environment, complies with federal and state requirements that are legally applicable or
relevant and appropriate to the remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment or resource recovery technologies. to the
maximum extent practicable, and satisfies the statutory preference for remedies that employ
treatment that reduces toxicity, mobility, or volume as a principal element.
Because this interim remedy will result in haZardous substances remaining on-site above
health-based levels, a review of this remediation will be conducted within five years after
commencement of the remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment.
~~~I
Date
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DECISION SUMMARY
FOR
JO}
AMENDMENT TO JUNE" 1988
RECORD OF DECISION
BRODERICK WOOD PRODUCTS
ADAMS COUNTY, COLORADO
OPERABLE UNIT 1 - IMPOUNDMENTS SLUDGES
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DECISION SUMMARY
TABLE OF CONTENTS
Page
-1
1
2
3
6
10
12
12
o
I. INTRODUCTION
II. COMMUNITY PARTICIPATION SINCE THE JUNE 1988 ROD
III. SITE ACTIVITIES SINCE THE JUNE 1988 ROD
IV. DESCRIPTION OF THE ALTERNATIVES
V. EVALUATION OF THE ALTERNATIVES
VI. STATUTORY DETERMINATIONS
VII. DOCUMENTATION OF MINOR CHANGES
VIII. REFERENCES
U&t of Tables
Table 1 TREATMENT STANDARDS FOR LAND DISPOSAL
OF INCINERATED KOO1 ASH
Table 2 COSTS FOR OFF-SITE RECLAMATION
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DECISION SUMMARY
for
AMENDMENT TO JUNE 1988
RECORD OF DECISION
BRODERICK WOOD PRODUCTS
ADAMS COUNTY, COLORADO
OPERABLE UNIT 1 . IMPOUNDMENTS SLUDGES
I. INTRODUCTION
This document summarizes the information that forms the basis for EPA's selection of a new
remedial action for treatment of sludges from the impoundments at the BWP site. This ROD
Amendment will become part of the Administrative Record pursuant to Section 3oo.825(a)(2) of
the NCP. The original ROD which was signed June 30, 1988 is attached hereto and made a
part hereof as Exhibit 1, and should be referred to for further information regarding the site
description, history of operations, enforcement activities and community participation prior to
the June 1988 ROD, characteristics of the sludge contaminants, and risks associated with the
BWP site.
In June 1988, EPA issued a ROD for the BWP site based on the Phase I and II RifFS efforts.
The June 1988 ROD identified interim actions to control the major source of contamination at
the site and to address risks from direct contact exposure to site contaminants (OU 1). The
major components of the June 1988 ROD were: 1) restriction of site access, 2) excavation and
incineration of impoundments sludges, 3) incineration or stockpiling of visibly contaminated
soils found beneath the sludges, and 4) treatment of water in the impoundments and buildings.
These interim actions were selected to meet the remedial action objectives of source control
and elimination of the direct exposure pathways.
Site Access (ROD Action No.1) has been restricted through construction of a fence. ROD
Action NO.3 was deferred to OU 2 when it was determined that the volume of visibly
contaminated soils was significantly greater than the volume estimated in the Phase II RifFS
report. ROD Action NO.4 was also deferred to OU 2 because cost evaluations conducted as
part of remedial design indicated that it would be more cost-effective to treat the water during
the remedial actions for OU 2.
Implementation of ROD Action No.2 was to have begun in the Fall of 1990. EPA determined
that treatment of the sludges should be delayed until the alternatives for treatment could be
reevaluated when information provided by one Potentially Responsible Party (PRP) Broderick
Investment Company (BIC), and ongoing investigations showed the costs of incineration had
increased signfficantly and other equally protective alternatives appeared to be available.
II. COMMUNITY PARTICIPATION SINCE THE JUNE 1988 ROD
Community interest at the BWP site generally has been low, to date, with involvement primarily
from residents and businesses located in the vicinity of the site as well as from state and local
officials. Further detail of community involvement at the BWP site is presented in the
Responsiveness Summary of this ROD Amendment. The public participation requirements as
specified in CERCLA Section 113 (k)(2)(B)(i-v) have been met as described below.
In mid..January 1991, EPA prepared a "Summary Document - Post-ROD Activities" (EPA, 1991)
which summarized and described the data and findings of cleanup investigations that led to a
reevaluation of the sludge treatment remedy selected in the June 1988 ROD. This document
was placed in the Administrative Record files at the information repositories.
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On January 15, 1991, EP A sent a fact sheet to 162 persons on the mailing list that included
residents, business owners, and public officials. This fact sheet described the Proposed Plan
to amend the June 1988 ROD for treatment of impoundment sludges. The fact sheet also
described opportunities for public involvement including the public meeting and the public
comment period for the Proposed Plan. Also, on January 15, 1991, EPA placed a quarter-page
public notice in the Rocky Mountain News announcing a public comment period from January
18, 1991 to February 18, 1991 for comments on the Proposed Plan for sludge treatment. The
notice also announced the public meeting, and informed the public of the availability of all
pertinent information at the information repositories.
The public meeting to discuss the new Proposed Plan was held on February 5, 1991 at the Inn
at the Mart located near the site. A transcript of the meeting was prepared for placement in the
Administrative Record files at the information repositories. At the meeting, which was attended
by fifteen community members, only one oral comment was received. This comment
concerned potential health effects to children and adults residing near the site from past and
ongoing exposure to site contamination. In response to this comment, EPA met with some
concerned residents on February 11, 1991 to discuss potential health effects to people living
near the site. In attendance were an EPA toxicologist, a representative of the Agency for Toxic
Substances Disease Registry (ATSDR), the EPA Remedial Project Manager, the EPA
Community Relations Coordinator for the site, and six concerned residents. During the public
comment period for the Proposed Plan for treatment of impoundment sludges, EPA received
written comments only from BIC. Responses to official public comments are presented in the
Responsiveness Summary of this ROD Amendment.
The present repository locations housing the Administrative Record file and hours of availability
are listed below:
EPA Superfund Record Center
999 18th Street
Denver, CO 80202
(303) 293-1807
Hours:
M, Th 1 :00 pm - 8:00 pm
T, W, F, As 10:00 am - 5:00 pm
Adams County
Public Ubrary
Commerce City Branch
7185 Monaco Street
Commerce City, CO 80022
(303) 287-0063
Hours: M-F 8:00 am - 4:30 pm
III. SITE ACTIVITIES SINCE THE JUNE 1988 ROD
In January of 1989, site access was restricted through construction of a fence. In the early part
of the same year, EPA sought access to the site to implement the remedy of the June 1988
ROD, but was denied by BIC due to indemnification concerns. In March of 1989, EPA
requested and was granted an Order in Aid of Access from the Federal District Court.
In August 1989, the design to implement the June 1988 ROD was finished. The design
indicated that incinerating the contents of the main and secondary impoundments on-site
might cost three to five times more than was originally estimated due to changes in the
incineration market and increased transportation costs. Costs for incinerating the sludges and
oil, and treating the water in the impoundments were estimated to be $1.4 - 2.2 million in the
June 1988 ROD while the Corps of Engineers estimated the costs to be $9 - 11 million in their
final design document in August 1989. Over the 14-month period between the ROD signing
and the final design document, the market for mobile thermal incinerators Increased from an
average $550 per cubic yard to about $2,759 per cubic yard. Part of this increase was al50 a
result of higher transportation costs to mobilize and demobilize the incineration operations.
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In January of 1990, BIC requested reconsideration of the portion of the June 1988 ROD calling
for incineration of the sludges at the site. EPA denied BIC's request in April 1990. However,
since the volume of soils was significantly greater than expected, EPA decided to defer removal
or treatment of the visually contaminated soils (ROD Action No.3) to OU 2. This deferment
further impacted the estimated costs of incinerating the contents of the impoundments. Loss of
economy of scale occurred due to the relatively small volume of material to be incinerated at
the site.
In May 1990, BIC filed a petition for reconsideration of the June 1988 ROD with the Regional
Administrator of Region VIII. EPA decided to reconsider the June 1988 ROD due to the cost
information acquired during design of the remedy and new technical data on the interaction of
contaminants and groundwater from the OU 2 RifFS activities. EPA had determined that
removal and storage of the sludges would be necessary under any alternative selected. As a
result, EPA requested and BIC agreed to proceed with removal of the sludges from the two
impoundments for temporary storage. The sludge removal operations were conducted in
October and November 1990 and the sludges are currently stored in two on-site lined cells.
IV. DESCRIPTION OF THE ALTERNATIVES
The specific remedial action objectives for sludges in the Impoundments remain the same as
stated in the June 1988 ROD. These are: 1) addressing the sludge as the greatest
concentration of contaminants on-site, i.e., source control; and 2) mitigating risks or pathways
for ingestion and inhalation of, and direct contact with, the sludges. In addition to the remedial
alternatives, the NCP requires that a no-action alternative be considered at every site. The no-
action alternative serves primarily as a point of comparison for other alternatives. As in the
June 1988 ROD, the no-action alternative remains unacceptable because it is not protective of
human health and the environment. EPA's reevaluation of the remedial alternatives identified
three alternatives that are compatible with the remedial action objectives and current site
conditions. The three alternatives include: 1) On-site Incineration, which was the remedy
selected in the June 1988 ROD; 2) Off-Site Incineration; and 3) Off-site Reclamation, with
incineration of residues. Long-term monitoring costs for all alternatives will be incorporated
into the monitoring program for OU 2.
The amount of sludges needing remediation is approximately 950 cubic yards of solid sludge,
currently stored in the solid storage cell and approximately 1,220 cubic yards of liquid sludge,
stored in the liquid storage cell. In addition, about 500 gallons of oil collected from the sludge
stockpile and from oil collected in the sump of the solid storage cell have been stored in 55-
gallon drums on-site. Approximately 50 cubic yards of debris (fence posts, railroad rails and
ties, poles, pipes, scrap metal, and a mattress) were stockpiled (ReTec, 1990b) and will be
remediated as part ofOU 2.
1)
On-site Incineration (Originallv selected in June 1988 ROD)
This alternative for treatment is unchanged from the June 1988 ROD except that the
previous range of costs have increased due to market conditions. The current range of
costs is based on estimates provided to EPA by the COE in their final design
documents and by BIC in their petition for EPA to reconsider the June 1988 ROD
(Holland & Hart, 1990). The estimated cost for this alternative is $4,530,000 (from the
BIC petition) - $11,000,000 (from the COE). These costs are detailed In the Summary
Document (EPA, 1991). Operation and maintenance costs are minimal due to the short
duration of this remedy. Long-term monitoring costs would be part of the ROD for OU
2. The sludge in both the liquid and solid storage cells would be removed and
incinerated on-site using a mobile thermal incinerator. Some stabilization of the sludge
might be required to facilitate handling and loading of the sludge. Following removal of
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the sludges, the surface impoundments including the liquid and solid storage cells
would be closed as part of the remedy selected for au 2. It is expected that this
alternative would take six to eight months to complete.
State and federal regulations on Incineration of RCRA/hazardous waste found at 6 CCR
1007-3, Part 264 Subpart 0 and 40 CFR 264 Subpart 0 (264.340-352), respectively, and
40 CFR 270.62 would be applicable to on-site Incineration of the sludges which are
K001 listed hazardous wastes. Similarly, RCRA Land Disposal Restrictions (LDRs)
would apply to disposal of treatment residues, which will need to meet treatment
standards in 40 CFR 268 Subpart D. The substantive requirements of the state
Particulate Emission Control Regulation for Incinerators (5 CCR 1001-3, Regulation No.
1, III. B) would also apply to operating and controlling the incinerator.
The residue (ash) from this process would be tested to assure that it meets treatment
standards for land disposal and then would be shipped to a permitted hazardous waste
landfill. For the residue from Incineration of K001 wastes to meet the standards, the
maximum for any single grab sample must not exceed concentrations listed below in
Table 1.
Table 1
TREATMENT STANDARDS FOR LAND DISPOSAL
OF INCINERATED K001 ASH
Constituent
Concentration in
the Waste 1
(mg/kg)
Concentration in
the Waste Extract 2
(mg/l)
Naphthalene
Pentachlorophenol
Phenanthrene
Pyrene
Toluene
Xylenes
Lead.
1.5
1.5
1.5
1.5
28
33
NA
NA
NA
NA
NA
NA
NA
0.51
Sources:
1 Table CCW 40 CFR Part 268.43 as revised in June 1990
2 Table CCWE 40 CFR Part 268.41 as revised In June 1990
The ability of the incineration ash to meet these levels would be confirmed during a test
burn of the sludge. It is possible that some stabilization of the ash would be required if
the levels are not achievable without stabilization.
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2)
Off-site Incineration
Off-site incineration was evaluated in the June 1988 ROD. However, this alternative was
not selected because at that time its cost of $4,800,000 was greater than on-site
incineration due to transportation of the materials to the off-site incinerator. The present
cost for off-site incineration of the sludge from the storage cells is $4,750,000 based on
information provided in the BIC petition (Holland & Hart, 1990). Because treatment
would occur off-site, operation and maintenance costs are included in the capital costs.
Long-term monitoring costs will be part of the subsequent ROD for OU 2. The treatment
method for this alternative would be similar to on-site Incineration except that sludge in
both the liquid and solid storage cells would be removed and shipped to an off-site
incinerator. The sludge would be solidified as n$eded for transport. Off-site
incineration would be performed at the nearest permitted incinerator. The surface
impoundments including the liquid and solid storage cells would be closed as part of
the OU 2 final remedy. This alternative would be completed in approximately six
months.
Federal regulations on incineration of RCRA/hazardous wastes are found at 40 CFR 264
Subpart 0 (264.340-351) and 40 CFR 270.62. Under these regulations, incinerators
burning KOO1 sludge are required to achieve a destruction removal efficiency of 99.99%
for each principal organic hazardous constituent (including dioxin). In accordance with
EPA off-site policy (OSWER Directive 9834.11 a), a RCRA Facility Assessment (RFA) or
equivalent investigation requirement must be met at the RCRA treatment facility in order
for CERCLA wastes to be accepted at the facility. LDRs as specified in Table 1 would
apply to disposal of treatment residues (ash). RCRA requirements (40 CFR 262 and
263) would apply to manifesting and transporting the waste. Department of
Transportation (DOT) requirements are Incorporated by reference in the RCRA
generator/transporter regulations.
3)
Off-site Reclamation and Incineration of Residues
The off-site reclamation alternative proposed in this ROD Amendment differs
significantly from the reclamation alternative evaluated in the June 1988 ROD. As
evaluated in the June 1988 ROD, the sludge was to be separated into creosote, water,
and solids in. an on-site centrifuge. The creosote would then have been sold on the
open market, the water would have been evaporated, and the solids disposed off-site
without treatment. EPA rejected this alternative because on-site incineration, at that
time, was comparable in cost, there was no assurance that the creosote recovered via
this method would be saleable, there was no assurance dioxins would be properly
managed, and the solids were to be land disposed without treatment.
The off-site reclamation alternative evaluated in this ROD Amendment addresses the
concerns expressed in the evaluation of the reclamation alternative in the June 1988
ROD. The range of costs for this alternative are estimated to be from $2.06 - $2.19
million based on preliminary information provided by BIC (ReTec, 1991). Operation and
maintenance costs are included in the capital costs because treatment would occur off
site. Long-term monitoring costs will be part of the ROD for OU 2.
The sludge in both the liquid and solid storage cells would be removed, prepared and
shipped to a permitted recycler with a proven record of recycling KOO1 sludge. The
estimated recovery rate is 80 percent. The sludges would be excavated and hauled to
an on-site mixing tank for heating with a solvent (Le., creosote) to make the mixture
pumpable. The mixture would then be transferred and placed in rail tank cars. Next,
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the mixture would be shipped to the permitted recycler. At the facility, the mixture would
be filter pressed, dehydrated, distilled and blended with virgin creosote (Le., creosote
with no PCP or dioxins). The final recycled product would be classified as' a creosote
containing PCP and dioxins to be used by wood treaters only.
The residues from the recycling process, which contain PCP and dioxins, would be
treated to LDR standards in an incinerator permitted to burn KOO1 sludge. The
incinerator ash would be disposed in a permitted RCRA landfill. The surface
impoundments, including the liquid and solid storage cells, would be closed as part of
the remedy for OU 2. Completion of this alternative would take six to eight months.
Product from the recycling process would not be subject to RCRA regulations. In
accordance with EPA off-site policy (OSWER Directive 9834.11 a), a RCRA Facility
Assessment (RFA) or equivalent investigation requirement must be met at the recycling
facility in order for CERCLA wastes to be accepted at the facility. RCRA tank, manifest
and transport requirements would apply as well as regulations for incineration as cited
previously for alternatives 1 and 2. LDRs as specified in Table 1 would apply to treated
residues (ash from incineration) from reprocessing the KOO1 sludge. This remedy
would be required to meet all local and state air emissions standards. This remedy is
easily implemented since the sludge is already in storage cells which facilitate removal
and transportation from the site.
V. EVALUATION OF THE ALTERNATIVES
Overall Protection of Human Health and the Environment
The criterion addresses whether a remedy provides adequate protection and describes how
risks posed through each pathway are eliminated, reduced, or controlled through treatment,
engineering controls, or institutional controls. All the alternatives are protective of human
health and the environment.
Alternatives 1 and 2 achieve protection by removal of the sludges from the temporary storage
cells and destruction, by incineration. Alternative 3 achieves protection by removal of the
sludges, reclamation of usable products from the sludge, and destruction, by incineration, of
the residues from reclamation.
The analysis of this criteria in the June 1988 ROD stated that reclamation may not be
protective. Off-site reclamation as proposed in this ROD Amendment would be protective
because the final recycled product would be sold to and used by wood treaters only. Also, any
residues would be treated to meet LDR standards before disposal.
Compliance With Applicable or Relevant and Appropriate Reauirements
This criterion addresses whether a remedy will meet all of the ARARs of other federal and state
environmental laws. All alternatives will meet all ARARs.
The June 1988 ROD stated that it was questionable whether reclamation would comply with
ARARs. In particular, it was unclear whether LDRs would be met. Since this is an off-site
activity the LDR standards are not technically ARARs. However, LDRs pertain to the off-site
action and must be met. Reclamation as proposed in the June 1988 ROD did not specify that
the residues would be treated thereby resulting in uncertainty over whether LDRs would be
met. Off-site reclamation as proposed in this ROD Amendment includes treatment of the
reclamation residues by incineration to comply with any LDRs.
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Lona-Term Effectiveness and Permanence
This criterion refers to expected residual risk and the ability of a remedy to maintain reliable
protection of human health and the environment over time- once cleanup goals have been met.
All alternatives provide long-term effectiveness and permanence by removal and destruction of
the sludges or reclamation of the sludges into a usable product, with any residues from the
reclamation process being destroyed by incineration.
Reduction in Toxicitv. Mobilitv. and Volume Throuah Treatment
This criterion refers to the anticipated performance of the treatment technologies a remedy may
employ. All three alternatives involve treatment methods which significantly reduce the toxicity,
mobility, and volume of the sludges.
Alternatives 1 and 2 employ destruction of the contaminants as a principal element. The
destruction efficiency will be greater than 99 percent. Alternative 3 employs reclamation as the
principal element with destruction of residues as a secondary element. It is estimated that 80
percent of the sludge will- be reclaimed. The destruction efficiency for the residues will be
greater than 99 percent. All the alternatives are essentially equivalent in reducing toxicity,
mobility and volume.
Short-Term Effectiveness
This criterion addresses the period of time needed to achieve protection and any adverse
effects on human health and the environment that may be posed during the construction and
implementation period, until cleanup goals are achieved. All three alternatives create some
short-term risk in disturbing and handling the sludges. Alternative 3 involves risks associated
with on-site preparation 01 the sludges for transportation and reclamation. This risk is believed
to be minimal because the on-site work only involves heating the sludges and creosote at low
temperatures and no significant volatilization would occur. Alternatives 2 and 3 involve risks
associated with off-site transportation of the sludges. These risks are believed to be minimal
given the characteristics of the sludges and the fact that transportation of hazardous waste is
carried on daily in the United States with few accidents. All alternatives involve risks associated
with air emissions when the wastes or reclamation residues are incinerated. However, all
alternatives would be required to meet local and state air emission standards. Each alternative
would require six to eight months to implement. All the alternatives have similar short-term
risks.
Implem~ntabilltv
This criterion addresses the technical and administrative feasibility of the remedy, including
availability of materials and services to implement a particular option. All the alternatives are
technically implementable.
The implementation 01 Alternative 2, off-site incineration, could be delayed because 01 the
unavailability of an off-site incineration facility. Only recently, the two facilities that could have
incinerated the sludges became unavailable and it is unknown if either of these facilities will be
available in the near Mure. It is expected that a new incinerator will come on-line in the near
future. However, if that facility does not become available the sludges would have to be held in
the storage cells until a facility becomes available.
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At the present time, EPA has identified only one facility in the country that can reclaim the
sludges. This is the Allied Signal facility in Birmingham, Alabama. This facility has tentatively
been identified as acceptable under EPA's Off-Site Policy to accept CERCLA wastes.
Cost
Cost factors include estimated capital and operation and maintenance costs, as well as present
worth costs. Alternative 3, off-site reclamation, is the least costly of the three alternatives at
$2.06 - $2.19 million. Alternative 2, off-site incineration, is the next least costly at $4.75 million.
Alternative 1, on-site incineration, is the most costly at $4.5 to 11 million.
State Acceptance
The State of Colorado agrees with the remedy selected by EPA, provided that a facility can be
found that is permitted to accept the waste, and that the facility has no ongoing significant
environmental problems. EPA shall assure that the Allied Signal facility meets these conditions
as required by EPA's Off-Site Policy prior to shipment of any wastes. .
Community Acceptance
. This criterion addresses the public's general response to the alternatives described in the
proposed plan. The residents interviewed supported either of the off-site alternatives. The
residents specifically opposed on-site incineration.
New Selected Remedy - Off-site Reclamation
Based on the information available following the June 1988 ROD and EPA's reconsideration 01
the treatment alternatives for the sludges, EPA has selected Off-site Reclamation (Alternative 3)
as the remedy for treating the sludges at the BWP site. The selection of this remedy is based
upon the comparative analysis of alternatives presented above, and provides the best balance
01 tradeoffs with respect to the nine evaluation criteria. It is estimated that 950 cubic yards of
solid sludge and 1 ,220 cubic yards of liquid sludge will be removed from the storage cells and
transported, along with the 500 gallons of oil collected from the sludge, to a permitted facility to
recover creosote for use at wood treating facilities. Preliminary cost estimates for the selected
remedy were prepared by BIC (ReTec, 1991) and verified by EPA. These costs are summarized
in Table 2.
The overall objective of any remedial action at the BWP site Is to protect human health and the
environment. Any remedial action must also comply with other requirements of CERCLA (as
amended by SARA) and the NCP.
Specific goals for remediation of sludge at the site involve the following:
1.
addressing the contents of the impoundments as the greatest concentration 01
contaminants on the site (i.e., source control);
mitigating the risks/pathways associated with a) ingestion of hazardous substances in
the impoundments, b) direct contact with hazardous substances in the impoundments,
and c) inhalation of airborne hazardous substances. .
2.
By removing the sludges from the site and recycling the sludge, exposure to the contaminants
by ingestion, inhalation and direct contact will be eliminated and the associated risk will be
significantly reduced. Furthermore, this will eliminate the major source of continuing
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Table 2
COSTS FOR OFF-81TE RECLAMATION
Item
801ler and
Steam Coli
Cost ($)
Electric
Immersion
Heater
Cost ($)
Heating Mechanism 6,700 14,800
Fuel Tank 3,300 NA
Mixer 18,500 18,500
Pumps 7,600 7,600
Hose 8,700 8,700
Power Screen 30,1 00 30,1 00
Dump Trucks 4,700 4,700
Front End Loader 6,200 6,200
Vacuum Truck 8,000 8,000
Controls 2,000 2,000
Site Work 44,000 44,000
Labor 105,000 105,000
Boiler Fuel (No.2 Fuel Oil) 6,000 NA
Electrical 21,800 139,600
Water 200 NA
Water Treatment Chemicals 900 NA
Diesel Fuel 600 600
Creosote 96,400 96,400
. * 1,419,000 1,419,000
By-Product Disposal
SUBTOTAL 1,789,700 1 ,904,800
Contingency (15%) 268,500 285,700
TOTAL 2,058,200 2,191,000
* Includes transportation and reclamation fee.
ReTec, 1991
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contamination at the site. Remediation of the soils and ground water already affected by the
impoundments will be addressed as part of au 2.
VI. STATUTORY DETERMINATIONS
EPA's primary responsibility at Superfund sites is to select remedial actions that are protective
of human health and the environment in accordance with Section 121 of CERCLA. CERCLA
also requires that the selected remedial action for the site comply with applicable or relevant
and appropriate standards established under federal and state environmental laws, unless a
waiver is granted. The selected remedy must also be cost-effective and utilize permanent
treatment technologies or resource recovery technologies to the maximum extent practicable. -
The statute also contains a preference for remedies that Include treatment as a principal
element. The following sections discuss how the selected remedy for treatment of the
. impoundment sludges at the BWP site meets these statutory requirements.
Protection of Human Health and Environment
Based on the risk assessment developed for the site, exposure to dioxins, PCP and PAHs in
the sludge through ingestion, inhalation and direct contact are the principal risks associated
with the BWP site. The selected remedy will eliminate these risks and provide protection of .
human health and the environment by removal of the sludge from the site, reclaiming any
usable portion of the sludge, and destroying by incineration, the residues from reclamation.
This remedy will not pose unacceptable short-term risks or cross-media impacts to the site, the
workers, or the community.
Compliance With Applicable or Relevant and Appropriate Requirements of Other Laws
Under Section 121 (d)(2) of CERCLA, remedial actions must attain standards, requirements,
limitations, or criteria that are "applicable or relevant and appropriate" under the circumstances
of the release at a site. All ARARs would be met upon completion of the selected remedy.
Chemical-Specific ARARs
No chemical-specific ARARs were identified.
Action-Specific ARARs
The RCRA Tank regulations, 40 CFR Part 264 have been identified as action-specific ARARs for
the on-site activities connected with the selected remedy. Depending upon additional activities
necessary for preparing the sludge for transport, other requirements may be ARARs. Any such
ARARs will be identified during remedial design and would be complied with during remedial
action.
The following requirements apply to the off-site activities connected with the selected remedy.
The off-site shipment of the K001 sludge to the recycling facility would comply with all
applicable Department of Transportation requirements found in the Hazardous Materials
Transportation Act and regulations promulgated pursuant to that Act, 49 USC Sections 1801-
1806, 1808, 1811; 40 CFR Part 263; 49 CFR Parts 171-174, as well as the RCRA generator and
transporter requirements, 40 CFR Part 262; 6 CCR 1007-3, Part 262, and 40 CFR Part 263.
Disposal of residues from the reclamation of the sludges would be subject to the LDRs. The
residues would meet the LDR BDAT Standards (Table 1) before being land disposed at a
permitted facility.
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Location-Soecific ARARs
No location-specific ARARs were identified.
To Be Considereds
No To Be Considereds (TBCs) were identified.
Coat-Effectiveness
The selected remedy is cost-effective. Cost-effectiveness is determined by evaluating long-
term effectiveness and permanence, reduction of toxicity, mobility, or volume. through
treatment, and short-term effectiveness to determine overall effectiveness. Overall effectiveness
is then compared to cost to determine cost-effectiveness. All three alternatives evaluated in
this ROD Amendment are comparable in terms of overall effectiveness. Therefore, off-site
reclamation, which is the least expensive alternative at a cost of $2.06 - $2.19 million is the
most cost-effective option.
Utilization of Permanent Solutions and Alternative Treatment Technologies or Resource
Recovery Technologies to the Maximum Extent Practicable
EPA believes the selected remedy represents the maximum extent to which permanent
solutions and treatment technologies can be utilized in a cost-effective manner for treatment of
the sludges at the BWP site. Of the alternatives that are protective of human health and the
environment and comply with ARARs, EPA has determined that the selected remedy provides
the best balance of trade-offs in terms of long-term effectiveness and permanence; reduction in
toxicity, mobility or volume achieved through resource recovery and treatment; short-term
effectiveness; implementability; and cost, and also considering the statutory preference for.
treatment as a principal element, and considering state and community acceptance.
Although all of the alternatives are protective of human health and the environment and comply
with ARARs, and will achieve significant reductions of toxicity, mobility and volume, there are
significant differences in the cost of the alternatives. Off-site reclamation is the least costly at
less than half the cost of off-site incineration and five times less than the highest estimates of
the cost for on-site incineration. Therefore, the criterion that provides the basis for this
selection decision is cost. The selected remedy is the least costly of equally protective
alternatives that were reconsidered.
State and Community Acceptance
The State of Colorado concurs with the selected remedy. The Proposed Plan for the BWP site
was released for public comment in January 1991. The Proposed Plan identified off-site
reclamation as the preferred remedy for the sludges. The community accepts this alternative.
EPA reviewed all written ~nd verbal comments submitted during the public comment period.
Upon review of these co ments, EPA determined that no significant change to the remedy
originally identified in the Proposed Plan was necessary. The Responsiveness Summary for
this ROD Amendment pr vides more detail regarding the comments received and EPA's
responses to these comments.
Preference for Treatment as a Principal Element
By removing the sludge from the site and recovering the useful components of the sludge
through a' reprocessing facility, the selected remedy addresses the principal threat of
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Inhalation, ingestion and direct contact of contaminants in the sludge through the use of
treatment technologies. Residues from the reclamation process will also be treated prior to
disposal. Therefore, the selected remedy satisfies the statutory preference for remedies that
employ treatment as a principal element.
VII. DOCUMENTATION OF MINOR CHANGES
The remedy selected in this ROD Amendment, Alternative 3 - Off-site Reclamation, was the
preferred alternative presented in the Proposed Plan. However, the cost of $2,720,000 for
Alternative 3 presented in the Proposed Plan differs from the cost of $2,058,200 - $2,191,000
presented in this ROD Amendment. In addition, some on-site preparation of the sludges not
discussed in the Proposed Plan would be required. .
The total cost in the Proposed Plan was calculated by applying the unit costs for off-site
reclamation (Exhibit E - Attachment 2) provided in the SIC Petition (Holland & Hart, 1990) to the
liquid sludge and applying the unit costs for off-site incineration (Exhibit E - Attachment 7) to
the solid sludges. For this ROD Amendment, the cost for reclamation was based on more
recent information provided by SIC (ReTec, 1991). The cost for incinerating the residues from
the recycling process are included in the reclamation fee charged by the facility. This
difference does.not change EPA's evaluation of the alternatives. It further supports the cost-
effectiveness of reclamation.
To facilitata transfer of the sludges from the rail tank cars at the recycling facility, the sludges
from the storage cells at the BWP site would be heated and mixed with virgin creosote in an
on-site tank to make the mixture pumpable before transportation. This increased on-site
activity may increase short-term risks. However, any additional risks associated with on-site
preparation of the sludges are believed to be minimal because the mixture will be heated at low
temperatures and no significant volatilization will occur.
VIII. REFERENCES
EPA, 1990. Unilateral Administrative Order for Remedial Action, Broderick Wood Products
Superfund Site (U.S. EPA Docket No; 91-01). U.S. EPA, Region VIII, October 18, 1990.
EPA, 1991. Summary Document for Post-ROD Activities. Prepared by Jacobs Engineering
Group Inc. on behalf of U.S. EPA, Region VIII, January 1991.
Holland & Hart, 1990. Petition for Re-Evaluation for 1988 ROD. Holland & Hart, May 1990.
ReTec, 1990a. Letter from Ann M. Colpitts to Jacobs Engineering Group Inc., Projected Costs
to Complete the Impoundment Sludge Removal and Storage. ReTec, Inc., December 7,
1990.
ReTec, 1990b. Removal and Storage of Main and Secondary Impoundment Sludge. ReTec,
Inc., December 18,1990. .
ReTec, 1991. Broderick Sludge Disposition Design. ReTec, Inc., April 26, 1991.
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COMMUNITY INVOLVEMENT AND RESPONSIVENESS SUMMARY
The purpose of this community involvement and responsiveness
summary is to document community involvement activities and
issues during the investigation of contamination at the Broderick
Wood Products (BWP) Superfund site in Adams County, Colorado.
The summary is divided into the following five chapters:
A.
Executive Summary
This chapter presents an overall summary of community
involvement activities conducted at the BWP site, the
public's reaction to t~a interim remedy proposed by the
u.S. Environmental Protection Agency (EPA), and EPA's
responses to those comments.
B.
Introduction and Background
This chapter provides a brief introduction to the site
and EPA's proposed interim remedies for the BWP site.
C.
Community Relations Background
This chapter provides a summary of the community
involvement activities conducted for the BWP site.
D.
Summary of Public Comments and EPA Responses
This chapter presents individual comments received on the
cleanup activities at the BWP site, particularly the
proposed plan, and EPA responses to these comments.
E.
Summary of BIC Comments and EPA Responses
The Broderick Investment Company (SIC), the only
potentially responsible party named to date, has
conducted much of the study at the site. BIC has also
sQbmitted substantial comments on the Phase II RI/FS and
proposed remedy, and those comments have been addressed
separately in this section.
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A. EXECUTIVE SUMMARY
In the process of overseeing,the investigation and cleanup of the
Broderick Wood Products Superfund site near Denver, Colorado, the
U.S. Environmental Protection Agency (EPA) has been carrying out
a community involvement program to keep nearby residents and
other individuals with an interest in the BWP site informed about
the ongoing studies and proposed remedies. These community
involvement activities have been carried out in compliance with
the requirements of both CERCLA and the NCP. .
This program has consisted of many community involvement
activities, including maintenance of a mailing list, meetings
with residents and government officials, establishing information
repositories, distributing news releases of site-related events,
mailing out fact sheets and an announcement of EPA's proposed
plan for the site, conducting a public comment period and a
public meeting and responding to comments received.
In February, '1988, EPA published for public review and comment a
plan of specific remedies proposed to be implemented at the site.
The public comment period extended from February 10 to March 4,
1988. A public meeting on the subject of the proposed plan was
held near the site on February 22, 1988.
The BWP site has generated a relatively low level of interest
from the general public, due primarily to its location in an
industrial area of metropolitan Denver. The major concerns
raised by property owners adjacent to the site and others have
included the potential for contamination to migrate off-site, the
potential for the proposed remedy to exacerbate this migration,
the need to address contamination already off-site, the impact of
Fisher Ditch on contaminant migration, and the preference to
proceed quickly with the Phase III remedial i~vestigation and
feasibility study.
EPA concurred with most of the concerns expressed by the public
and believes that the selected remedy will address them. EPA
believes that the selected remedy will decrease the opportunity
for off-site miqration of contaminants by eliminating the major
source of contaminants, and that the disposal of treated water in
the incinerator quench process will eliminate its potential to .
augment off~site miqration. EPA agrees that the relationship
between Fisher Ditch and the ground water regime needs to be
reexamined and that the Phase III RI/FS should proceed as quickly
as possible.
Comments on the proposed remedy and new information were also
submitted by BIC, both during and after the public comment
period. BIC asked EPA to consider new information concerning the
use of biodegradation to treat contaminated soils and sludge.
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EPA reviewed the new information and concurred that biodegra-
dation should be thoroughly evaluated in the Phase III RI/FS as a
remedy for contaminated soils. EPA has also minimized the volume
of visibly contaminated soils under the impoundments th~t would
be subject to incineration to assure that biodegradation would be
included in evaluations of remedies to address large volumes of
contaminated soils. However, EPA also concluded that the new
information was not sufficient to justify significant changes in
the selected remedy for the impoundment sludge.
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B. INTRODUCTION AND BACKGROUND
In this chapter, the history of the
Company will be summarized briefly.
is required, the reader is referred
of the Record of Decision.
Broderick Wood Products'
If a greater level of detail
to Chapters A-C of Section II
The U.S. Environmental Protection Agency (EPA) has been involved
in the investigation of contamination at the Broderick Wood
Products site in Adams County, Colorado, since 1980. The owner
of the site, the Broderick Investment Company (BIC), has been'
studying the site to determine the nature and extent of the
contamination, and to study ways to clean it up. EPA has been
overseeing the BIC study.
The Broderick Wood Products site is located in Adams County,
Colorado, approximately one mile west of Interstate 25 and one
mile north of the corporate boundary of the City and County of
Denver. The Broderick Wood Products Company operated a wood
treatment pla~t on this 64-acre site from 1947 to 1981 using
creosote and pentachlorophenol in their treatment process.
The Broderick Wood Products Company was dissolved in 1982 and
Broderick Investment Company (BIC) became its successor. The
partners in SIC are various trust funds managed by two banks in
Denver as trustees.
The site is bordered on the north by Fisher Ditch, which carries
water east from Clear Creek to Copeland Lake. The site is
bordered on the southwest by the Colorado and Southern Railroad
and on the southeast by the Denver and Rio Grande Western
Railroad. South Ditch, a buried water pipeline, crosses the
eastern portion of the property. The United Water Company Ditch
crosses the southern corner of the site and drains into Dewey
Lake about one-half mile to the east.
Koppers Company, Inc., an active wood treating facility is
located east of the site across the railroad tracks. The area
north of Fisher Ditch is owned by Brannan Sand and Gravel
Company. This area was extensively used for gravel mining and
was later used for a landfill operation.
Eleven residences (of which ten are to the north) were identified
within a half-mile, and a subdivision is within one mile
southeast of the site. The nearest residences are about one-
quarter mile north of the site. Some residences north of the
site use ground water wells for domestic or irrigating purposes.
EPA first became involved at the BWP site in 1980 under the
Resource Conservation and Recovery Act (RCRA). EPA later invoked
its authority under Superfund and conducted a preliminary
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assessment and site investigation, finding pentachlorophenol in
soils and ground water on and off the site. The site was
proposed for the National Priorities List (NPL) in September 1983
and placed on the list in September 1984.
In late 1983 and early 1984, BIC performed some preliminary site
investigation activities which are now referred to as the Phase I
Remedial Investigation. During 1984 and 1985, EPA and BIC
negotiated over conducting further studies, concluding those
negotiations with a partial consent decree (PCD) which was
approved by the federal district court in 1986. The PCD required
BIC to conduct a Phase II RI/FS to define the extent of
contamination and develop remedies to address the problem.
Additionally, a Phase III RI/FS would be required if EPA
concluded that the Phase II RI/FS did not sufficiently address
the problem.
BIC submitted a draft Phase II RI/FS report in December 1986.
After reviewing the report, EPA concluded that further (Phase
III) RI/FS studies would be required. The Phase III RI/FS will
define the full nature and extent of contamination associated
with the site, and develop remedies to address that contamina-
. tion. After the Phase III RI/FS is completed, a remedy will be
selected to address the remaining contamination.
However, EPA also concluded that the draft Phase II report was
complete insofar as the information in the report was sufficient
to support implementation of certain interim remedies while the
Phase III RI/FS is conducted. EPA was particularly interested in
those remedies relating to source control and the direct contact
pathway. EPA believed that implementation of these remedies
would be consistent with future studies and remedies at the site.
BIC agreed to revise the Phase II report to address interim
remedies in an operable unit and the revised report was submitted
in July 1987. After reviewing the revised report, EPA concluded
that, with certain modifications, the report would be able to
support certain interim remedies. In an August 26, 1987 meeting,
EPA informed BIC that EPA would develop the proposed modifica-
tions in a supplemental RI/FS report. The supplemental RI/FS
report was completed November 5, 1987.
In February, 1988, EPA published a proposed plan based on the
RI/FS studies and information to that date. EPA concurrently
initiated a 21-day public comment period to invite comments on
the proposed plan. A public meeting was held on February 22,
1988, and comments were received through the end of the comment
period. The proposed plan included the following preferred
remedies:
erecting a security fence around the entire site;
posting warning signs around the perimeter;
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excavating and incinerating the impoundment sludge and
oil;
treating the contaminated water in the main impoundment
with carbon adsorption and disposing of it on-site;
excavating and either incinerating or stockpiling the
visibly contaminated soils under the impoundments;
filtering the "firewater" to remove asbestos fibers,
treating the filtered water in the carbon adsorption unit
and disposing of the treated water on-site;
demolishing the treatment plant and shop buildings; and
monitoring the performance of the remedies.
The final remedy was to be developed after completion of a Phase
III RI/FS. This RI/FS would include characterization of the full
extent of contamination related to the Broderfck site.
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C.
EPA'S COMMUNITY INVOLVEMENT PROGRAM FOR THE BWP SITE
In compliance with the requirements of CERCLA and the NCP, EPA
and the State of Colorado have conducted a program to keep nearby
residents and other individuals with an interest in the BWP site
informed about the ongoing studies and proposed remedies. This
program has included the following:
1 O.
1 .
Developing a list of all nearby residents and other
persons interested in activities at the site.
2.
Working with municipal and other local agencies to keep
government officials informed about site issues and
activities.
3.
Establishing repositories 'of key information relating to
the site, including RI/FS reports, the proposed plan,
comments, responses and other documents so that the
public would have ready access to the information.
4.
Preparing and distributing news releases of significant
events during the ongoing activities at the site.
5 .
Meeting with nearby residents, neighbors and local
officials to discuss any concerns that they may have.
6.
Mailing two Fact Sheets to all individuals on the mailing
list. The first Fact Sheet, in January 1987, described
the site and ongoing RI/FS activities. The second Fact
Sheet, dated December 1987, announced EPA's proposed plan
for an interim remedy at the BWP site.
Announcing the proposed plan in a local newspaper so that
persons not on the mailing list might, be informed.
7.
8.
Conducting a public comment
The comment period was from
1988. A public meeting was
February 22, 1988.
period on the proposed plan.
February 10 through March 4,
held near the site on .
9.
Responding to the comments received during the public
comment period and at the public meeting.
Conducting a domestic well sampling program to determine
whether any site-related contaminants had reached any of
the off-site wells.
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D.
SUMMARY OF PUBLIC COMMENTS AND EPA RESPONSES
This chapter summarizes the community's reaction to the proposed
. plan and other aspects of the BWP site. In general, the level .of
interest in the community about the BWP site has been relatively
low. This has been due primarily to the industrial character of
much of the surrounding properties and the relatively sparse
residential population nearby.
- "
Approximately 25 people attended the public meeting during the
comment period on the proposed plan. Written comments on the
proposed plan were received from only a few individuals and/or
companies. These comments showed that community concerns were
generally related to the following major topics:
1 .
Much concern has been voiced by owners of property
immediately adjacent to the BWP site because of their
concern about impacts from the site. Of particular note
was the concern that either current site conditions or
some component of the preferred remedy would exacerbate
the potential for ground water or other contamination to
move off-site to the north. These concerns were related
to, among other things, the proposal to dispose of
treated water on-site through evapo-transpiration.
2.
Another significant concern was that contamination that
may have already moved off-site should be addressed as
soon as possible, and that the interim remedies being
considered should not interfere with Phase III studies
and remedy implementation.
3.
There were also some concerns about the impact of Fisher
Ditch on the site, both as an impediment and as an aid to
off-site migration of contaminants.
Oral and written comments concerning the site were received
during the public comment period of February 10 through March 4,
1988. Most of the comments were received during the public
meeting of February 22, 1988. Specific comments and EPA's
responses are presented below and are categorized by topic.
Phase I aDd II Investigations
Comment t1:
Response:
Were any samples taken beyond Fisher Ditch to the
north and what were the results of these samples?
How far north have samples been taken?
Yes. Contamination was originally discovered in a
well (monitoring well 9) on BFI property. This well
is located close to the BWP property line.
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Comment t2:
Response:
Also, at surface water sampling location 5 (SW-S), a
seep showed relatively high levels of creosote and
pentachlorophenol-related contaminants.
The Colorado Department of Health also conducted a
survey of private wells used for drinking and
irrigation north of the site. Samples taken from
these wells were analyzed for pentachlorophenol,
total volatiles, and total organics. Contamination
was not detected in any of the wells sampled.
(Monitoring locations are presented in Chapter C of
the Record of Decision.)
Clarify the differences between Phase I and II.
Phase I included preliminary studies conducted in
1983 and 1984 which did not lead to any selection of
remedy.
BIC began Phase II studies in late 1985 which led to
a recommendation to consolidate contaminated
material in the impoundments and cover them. EPA
concluded that this remedy would not be sufficient
but asked BIC to revise the Phase II report to
develop some interim remedies that would be
supported by the Phase II report. BIC then
recommended an interim remedy that included fencing
known areas of contamination, pumping the firewater
into the secondary impoundment, demolishing the
treatment plant building and monitoring the
performance of the interim remedy and ground water.
After reviewing the Phase II reports, EPA developed
a supplemental report which provided more informa-
tion to address an interim remedy. Based on the
Phase II reports and the supplemental information,
EPA developed and published the proposed plan.
Off-Site Contamination
Comment '3:
Response:
Fisher Ditch feeds into Copeland Reservoir to the
east, and Dewey Reservoir is directly adjacent to
the Koppers property. How would EPA's proposed
remedy address off-site contamination?
Phase I and II investigations were not sufficient to
define the extent of contamination, particularly for
off-site contamination. Hence, the proposed plan
does not directly address off-site problems. This
will be addressed during Phase III.
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Comment '4:
Response:
Comment '5:
However, enough information was available from the
Phase II report to address an interim remedy that
would be consistent with a final remedy.
Remedial alternatives are now being discussed and
implemented without sufficient investigation as to
the extent and severity of off-site contamination.
EPA acknowledges a visibly contaminated area north
of the site across Fisher Ditch that is believed to
be the result of seepage from beneath the waste
lagoon on the Broderick property.
It is important that the remedial alternatives now
implemented in no way inhibit or preclude remedial
actions necessary to address off-site contamination.
More importantly, these on-site measures should not
exacerbate or enhance the movement of contaminants
off-site. .
EPA has proposed an interim remedy that would be
consistent with a final remedy. See also responses
to Comments 7 and 8.
The continued operation of the Fisher Ditch unlined
is a concern, because it appears that Fisher Ditch
will create some sort of ground-water mounding which
may aggravate the continued seepage of the
contaminants deeper into the unsaturated soils, and
also into the ground water. The effects of the
continued use of Fisher Ditch should be
investigated. The ground-water mound underneath the
ditch when water is running in the ditch may be
acting as a barrier to ground-water flow and
contaminant transfer from the site to the north.
Alternatively, it may be enhancing the visible
seepage of contaminants to the north. .
The top priority in the Phase II remedial cleanup
should be lining Fisher Ditch, or other measures
necessary to prevent further off-site migration.
While the actual risk associated with use of
contaminated Fisher Ditch water is impossible to
quantify, there is no doubt that any potential
problem would be very widespread. The cost of
lining the contaminated portion of Fisher Ditch is
small compared to the benefit of reducing the hazard
to so many individuals. Adams County residents
would best be served by implementation of a quick
and efficient solution to isolation of Fisher Ditch
water from contamination at the Broderick site.
Adams County urges the EPA to proceed during Phase
II, rather than at a later date, in that direction.
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Response:
Comment 16:
EPA concurs that the interaction between Fisher
Ditch and the ground water regime needs to be
examined further. However, EPA does not believe
there is enough information to support selection of
any remedy (including lining) for Fisher Ditch at
this time. EPA expects this issue to be a top
priority for the Phase III RIfFS.
Eleven samples of Fisher Ditch water were collected
and analyzed during the Phase I and II studies. In
three of five samples taken adjacent to the site in
Phase I, pentachlorophenol was detected at concen-
trations of 0.0054 to 0.05 mgfl, well below the
recommended maximum contaminant level of 0.22mgfl.
No wood treating chemicals were detected in samples
taken during Phase II.
Ground water mounding was a phenomenon that BIC's
consultant brought up in the original draft of the
Phase II report. EPA did not see evidence of this
phenomenon after reviewing results of the
piezometers that were installed along a few cross
sections near Fisher Ditch. One or two inches of
mounding were observed which is not a great
differential. In some cases, the mounding was not
measurable.
BIC's consultant also measured flow at certain
points along Fisher Ditch to determine water gain or
loss. The accuracy of these flow measurements was.
plus or minus 10 percent, making it very difficult
to draw any definitive conclusion about whether
Fisher Ditch was gaining or losing water. The
calculations showed both happening with rather
dramatic gains and losses over the length of the
ditch. EPA attributed this to the inaccuracy in the
measurement of the flow.
The selected interim remedy will eliminate the
source of contamination and reduce the migration of
contaminants to off-site areas. This would minimize
potential contamination of water in Fisher Ditch.
EPA stated that a number of samples have been
collected from Fisher Ditch in the past. It is not
clear whether these samples consisted of water or
soil samples. These sample results indicate that
contaminants including pentachlorophenol and
creosote may be within the Fisher Ditch system.
Further definition of present contamination and the
potential for future contamination of the Fisher
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Response:
Comment - t 7 :
Response:
Ditch system including Copeland Lake must be
included within the scope of the Phase III RI/FS to
protect the shareholders of the ditch company. It
was represented that past studies have attempted to
determine whether the Fisher Ditch is gaining or
losing stream. These studies are inconclusive.
Therefore, it remains to be determined whether
contaminants previously found in the Fisher Ditch
arise from ground water infiltration into the ditch
or have entered the ditch system as a result of
surface runoff.
The interaction of Fisher Ditch with the ground'
water regime at the site will be a major concern for
the Phase III RI/FS. See response to Comment 5.
The proposed interim remedy does not take care of
the obvious seep material to the north of Fisher
Ditch on the Brannan property, and why is that
,material not being cleaned up under this remedy? It
is visible contamination that no doubt originated on
the BWP site and remediation of this contamination
is appropriately covered by CERCLA. The seep area
represents an existing source of contamination
which, when left in place and uncontrolled, presents
an imminent and substantial danger to the public
health and the environment. It should be remedied
immediately. If additional characterization of the
seep area is required before remediation commences,
such work should be completed as soon as possible so
that the seep area remediation can be included in
this phase.
If ground-water mounding is occurring beneath Fisher
Ditch and enhancing the seepage of contaminants,
appropriate remediation measures must be taken
(e.g., line or relocate the ditch).
EPA does not have enough information on how far the
contaminants in this area have migrated. The best
method for remediation cannot be determined until
the extent of contamination is known. If there is a
small quantity of contaminated material, it can be
incinerated. If there is a large quantity,
incineration may not be the cost effective remedy.
This concern will be addressed in the Phase III
RI/FS.
EPA's contractor attempted to locate the visible
contamination mentioned here, but was unsuccessful.
See also response to comment 5.
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Comment f8:
Remedy for the Firewater
Response:
Comment '9:
Response:
The secondary impoundment should not be used for
storage (short or long term) of the firewater from
the treatment plant building as proposed for the
interim remedy. Since this impoundment is unlined,
it will create a ground-water mounding problem which
may aggravate the seepage problem because that
seepage will generally go to the north and the
northeast onto the Brannan property. The water
should be treated in place and disposed of so that
no on-site ground-water mounding occurs.
~
The same concern is expressed for the proposed
remedy to treat water from both impoundments and
then discharge the treated water on site. Where
will the water be discharged on site? The water
treated with the carbon adsorption unit should not
be discharged directly to the surface of the site.
If it is discharged near those impoundments or
anywhere on the site, it will create that ground-
water mound which may again aggravate the seepage
problem to the north and northeast onto the Brannan
property. The treated water should be disposed of
so that no on-site ground-water mounding occurs
EPA concurs with these comments that disposing of
treated impoundment water and firewater on the
surface of the secondary impoundment is not the most
environmentally sound method. Consequently, EPA has
changed the selected remedy to include use of the
treated water as quench water for the incinerator.
It is possible that some of the treated water may be
discharged on-site and disposed of through evapo-
transpiration. However, EPA believes that the
discharge can be controlled not to exceed the E-T
rate for the site and that there would be no
negative impact on the site.
Additionally, the water being discharged out of the
carbon adsorption system will be close to non-
detectable levels; therefore there would not be any
contaminants added to the ground water.
EPA seems to be proposing a remedial program without
knowing where and how much firewater there is.
EPA's selection is based on studies performed by
BIC's consultants. Those studies indicate there is
approximately 40,000 gallons of firewater. However,
the location(s) of the firewater have not been fully
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determined. They will be more specifically
identified during the design phase.
Comment t10: How much will it cost to treat the firewater,
including filtering the asbestos?
~
Response:
Remedy Methods
After refining the costs associated with treating
the firewater, EPA now estimates those costs to be
about $2,500.
Comment #11: How will the incineration affect Denver's air
quality, especially the surrounding environment?
Response:
Comment t12:
Response:
EPA expects that the incinerator will not cause any
adverse impact on Denver's air quality, provided the
incinerator meets the RCRA 99.99 percent destruction
removal efficiency (DR E) standards and proper
"emissions control devices are installed and
operated. Before the incinerator is put into
operation, it will need to pass a test burn and
assure that it will pass both state air emissions
and RCRA incinerator standards.
Treatment standards should be established for the
proposed treatment activities (e.g. standards for
water that is to be filtered and/or treated,
standards for incinerator air emissions).
EPA will ensure that state or RCRA standards are
adhered to in all aspects of the interim remedy,
with the possible exception of land treatment
requirements for disposing of treated water. See
also response to comment 11.
Comment '13: Elaborate on the carbon adsorption method.
Response:
The contaminated water is passed at a low velocity
through activated carbon granules. The contaminants
in the water are adsorbed by the carbon granules and
are thereby removed.
Comment t14: What will be the method of disposal for the carbon
from the carbon adsorption system?
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Response:
Comment 115:
Response:
Comment 116:
Response:
Comment 117:
The carbon is burned. This is usually done by the
manufacturer of the activated carbon and not on the
site. The carbon, which comes in canisters, is
replaced when it is spent and sent back to the
manufacturer who reprocesses it.
Would it be cost effective to create a new lined
impoundment, consolidate all of the contaminated
materials into that impoundment while learning more
about the materials and the extent of contamination?
The selected remedy for contaminated soils includes
a decision tree and the possibility that the
suggested remedy may occur. The option of .
temporarily storing visibly contaminated soils in a
lined area within the secondary impoundment would be
implemented if the volume of soils is too great to
be incinerated in the small capacity incinerator
selected for the impoundment sludge. In this case,
other remedies in addition to incineration would be
evaluated during the Phase III RIfFS.
EPA's preference is to address the contaminated
materials permanently in this remedy if it is cost
effective to do so. If the volume of soils is small
it is more cost effective to incinerate them than to
handle them twice. If the volume is great, it may
be more cost effective to store them temporarily.
The on-site stockpiling of excavated impoundment
soils should not be a permanent remedy. Technical
requirements should be established for such
temporary stockpiling to ensure protection of public
health and the environment.
On-site stockpiling of visibly contaminated impound-
ment soils would only be employed temporarily.
Permanent remedies for these soils would be
addressed during Phase III. RCRA has specific
requirements for hazardous waste piles. These
requirements will be adhered to.
Is there any information on the physical
characteristics of the contaminant material (the
creosote and so forth), on how many years it takes
for the existing contaminants to break down, or on
how it breaks down if it were mixed with more dirt?
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Response:
~
The purpose of using creosote and pentachlorophenol
in the wood treatment process is to inhibit
biological activity and extend the life of the wood.
Therefore, they are not that easy to break down, and
have been known to last in excess of 100 years.
There have been some recent advances in biological
remedies for wood treating wastes and EPA
contemplates that this will be a major focus for the
Phase III RIfFS. However, these processes have not
been tested to the point where they can be used at
the BWP site at this time. .
This issue is discussed in greater detail in Chapter
E of this summary.
Comment #18: Has a natural breakdown process been looked at for
the contaminated soils?
Response:
Comment #19:
Response:
.EPA anticipates that this will be addressed during
Phase III when the surface soils will be further
investigated. See response to question '17.
This issue is discussed in greater detail in Chapter
E of this summary.
Has EPA had any discussion with Fisher Ditch on
dumping the treated water into the ditch once it is
filtered rather than filtering it through the
contaminated site again?
EPA has not had any discussions with the company
that owns Fisher Ditch on this issue because such a
discharge to Fisher Ditch or any off-site surface
water body would require a permit and that would
take some time. A permit is not required when the
remedy is done completely on the site, although the
substantive requirements that would apply would have
to be met.
Comment '20: Would a permit be required if the treated water is
discharged on the site and into the ground water?
Response:
EPA's position is that CERCLA does not require a
permit if the remedy is conducted completely on the
site. If there is a discharge off the site, for
instance to Fisher Ditch, a permit would be
required. The substantive requirements that are
required for off-site discharge would still have to
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be met for on-site discharge; only the administra-
tive activities and corresponding time frames for
actually getting the permit(s) are omitted.
Comment #21: When does EPA anticipate it will begin treatment of
the contaminated water? Can a time frame be given?
Response:
This is subject to negotiations with SIC. Now that
the Record of Decision (ROD) has been signed, EPA
will offer the PRP, in this case SIC, an opportunity
to complete the remedy selected in the ROD. If the
negotiations are fruitful, they would be documented
in a Consent Decree (approved by the Federal Court),
and SIC would implement the remedy. If negotiations
are not successful, the Superfund Trust Fund may be
available. In this case, EPA would implement the
selected remedy and try to recover the costs trom
SIC later. If the Superfund were used, the State
would have to match 10 percent of the remedy cost.
Comment #22: Has distillation or boiling of this liquid been
considered as a method of separating the water from
the contaminants?
Response:
Costs
No, that was not one of the alternatives considered.
Most of the remedial alternatives were proposed and
evaluated by SIC in their RI/FS reports. EPA
provided comments on these methods and added to
them. For example, the carbon adsorption system was
proposed by EPA.
Comment #23: What does the cost of the interim remedy ($1.3M to
$4M) include? Are these costs just for on-site
material?
Response:
The estimated costs (which have been revised to a
ranqe of $2.2 M to $3.6 M) include the selected
interim remedy described in the ROD. Because off-
site contamination has not been fully evaluated, a
remedy for this contamination is not included in the
interim remedy. This concern will be addressed in
Phase III.
Comment #24: What is the estimated cost per gallon or cubic yard
to incinerate the sludge?
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Response:
~
Monitoring
Comment .25:
Response:
There are approximately 4,000 cubic yards of sludge
material and 3,000 gallons of surface oils.
Considering the physical properties of the sludge
material and using the cost estimates available from
various incinerator vendors, EPA found a cost range
of $281 to $497 per cubic yard for incineration.
Explain the monitoring that will occur during the
proposed interim remedy, and in particular, the
monitoring that will occur with regard to the
discharge from the carbon adsorption treatment.
The monitoring part of the interim remedy will be
fully addressed in the design stage. The following
issues will be considered: .
Monthly inspections would be made of the fence
to ensure that is has not been breached;
Air emissions from the incinerator would be
monitored to ensure that it meets the required
emissions and efficiency standards;
Sampling would be conducted on a regular basis
to ensure that the carbon adsorption system is
meeting discharge requirements;
There would be no monitoring of contaminated
soils, since a "no action" remedy was selected
for the soils during the proposed interim
remedy.
Comment #26: Has EPA set a monitoring standard?
Response:
The monitoring standard will be developed as the
remedial action design is finalized. At a minimum,
the implemented remedy will comply with those
monitoring procedures required by the ARARs listed
in the ROD.
Potentially Responsible Party
Comment .27: Who are individuals in the Broderick Wood Products
Company and the Broderick Investment Company?
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Response:
The Broderick Wood Products Company was owned and
operated by William S. Broderick until he died in
1962. After he died, the operation of the company
was taken over by two Denver banks (First Interstate
Bank of Denver and Colorado National Bank) as
trustees under certain trusts established by the
wills of William S. Broderick and his wife. BIC is
the successor to BWP. BIC is a partnership in which
the two banks are general partners in their capacity
as trustees.
Comment '28: Is it EPA's position that Broderick an':/or Koppers
should be financially responsible for ~he off-site
contamination and its cleanup? .
Response:
EPA is unable to discuss the financial liabilities
and responsibiliti~s of these two entities, other
than to say EPA's policy is to pursue responsible
parties for recov~ring costs whenever possible.
Comment '29: Will there be any effort by the EPA to trace funds
derived from polluting the grounds to the
beneficiaries of the trusts?
Response:
Comment #30:
Response:
EPA always assumes that there will be a search for
responsible or potentially responsible parties which
would be liable for costs under CERCLA.
It is appropriate that financial responsibility for
determining the extent of off-site contamination
arising from activities on these properties and
remedial efforts required to address such
contamination be expressly assumed by BIC and
Koppers. At the public meeting, counsel for EPA
stated that the EPA's investigation of potentially
responsible parties continues with respect to the
Broderick site. In any event, to protect the
interests of adjacent property owners including
shareholders of the United Water Company and Fisher
Ditch Company, EPA should corne forward and assure
members of the community that remedial actions to
address off-site contamination shall be implemented
if required and all costs for this program borne by
the responsible parties or Superfund.
If contamination to off-site properties is a result
of the wood-treating process at the Broderick site,
this off-site contamination will be addressed in the
final remedy at the Broderick site. The costs of
the remedy will be borne by the either the parties
responsible, the Superfund, or both.
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Comment '31:
""
Response:
What is the position of the PRP with regard to the
proposed interim remedy? Are they absolutely
adamantly against it or are they generally in favor
of it?
EPA will not attempt to characterize the position of
the PRP. SIC has had an opportunity to review the
administrative record and has made formal comments
to EPA on their position. (These comments are
contained in the formal Administrative Record and
summarized in Chapter E of this summary report. )
Comment #32:
Phase III RI/FS
Response:
The ground water contamination should be fully
characterized in the near future. If ground water
contamination is discovered, an appropriate cleanup
approach should be identified and implemented as
. soon as possible in order to prevent the further
dispersion of contaminants in the ground water
aquifer.
Characterizing the full extent of ground water
contamination from the Broderick site will be the
main objective of the Phase III RIfFS.
Comment '33: Does EPA anticipate proceeding with an investigation
of off-site contamination, and will this
investigation be part of the Phase III RI/FS?
Response:
Comment 134:
Response:
Yes. The Consent Decree requires a third phase of
the RI/FS if EPA concludes that Phase II is not
adequate. EPA is presently in the process of
negotiating with SIC on the scope of work for Phase
III investigations. The major focus of this
investigation will be on subsurface contamination
off site to the north and interaction with Fisher
Ditch.
Are the remediation of the seep material to the
north of Fisher Ditch and the general ground-water
contaminant characterization very high priorities in
Phase III?
Yes, they are.
Comment '35: Regardless of the outcome of EPA's negotiation for
the interim remedy, will EPA be going ahead with the
Phase III RI/FS?
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Response:
Comment '36:
Response:
Yes.
This is required by the Consent Decree.
The investigation of the Broderick site undertaken
by EPA pursuant to CERCLA has not been coordinated
with the continuing investigation of the Koppers
site regarding the use of wood preservatives on its
property adjacent to the Broderick site. Given the
present lack of information regarding ground-water
flow in this area, Dewey Lake, located south of the
Koppers property and southeast of the Broderick
site, may have been impacted by activities on. either
or both properties under investigation. These
independent studies undertaken by EPA should be
coordinated to insure that all potential mechanisms
for off-site contamination have been investigated.
At the same time, coordination of these studies
could result in a cost savings to EPA and/or
responsible parties by eliminating duplicative
efforts to define the areas affected by these
properties.
EPA is aware of activities at the Koppers site. The
major sources of potential contamination on each
site are far apart. The direction of the ground
water flow is basically parallel to the Koppers-
Broderick property boundary. Part of the Phase III
investigation will be to address some data gaps
regarding contamination detected near this property
boundary.
Comment '37: What is the schedule for the Phase III RI/FS? When
do you anticipate the Phase III RI/FS to begin?
Response:
As mentioned in response to comment 33, EPA is
presently in the process of negotiating with BIC on
the scope of work for the Phase III investigation.
BIC submitted their first draft of the work plan in
Auqust 1987. EPA and the State provided their
comments in November, 1987. The start date is
subject to negotiation with BIC.
Comment '38: Will the public have an opportunity to comment on
the Phase III RI/FS?
Response:
Yes, CERCLA as amended by SARA requires a public
comment period for this phase.
Comment '39: When will the public comment period occur for the
Phase III work plan?
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Response:
Comment #40:
Response:
Comment #41:
Response:
EPA does not anticipate a formal public comment
period for the Phase III work plan.
Given the interest expressed at the public meeting
regarding the Phase III RI/FS work plan, those
present at the meeting should be given notice by
mail rather than publication of the commencement of
the public comment period upon the proposed work
plan.
As noted previously, EPA will probably not sponsor a
public comment period for the Phase III work plan.
EPA will, however, notify all parties on our mailing
list of key Phase III activities, including the
start of the Phase III RI/FS.
EPA should expedite the work to ensure that the
ground water contamination is sufficiently
.characterized and remedial action plan is put
together as quickly as possible so that the
contamination does not spread any further than it
already has. .
Characterization of the ground water contamination
will be part of Phase III RI/FS. The completion of
these studies is subject to negotiation with SIC.
EPA is concerned with proceeding as soon as
possible.
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E.
SUMMARY OF BIC COMMENTS AND EPA RESPONSES
1 .
INVOLVEMENT OF BIC IN THE RI/FS PROCESS
The Broderick Investment Company (BIC), the only potentially
responsible party (PRP) identified thus far, has been directly
involved in the Superfund activities at the BWP site since BIC
was formed in June 1982. Under the terms of the partial consent
decree, BIC is required to conduct the remedial investigation and
feasibility study at the site. In the course of these studies,
BIC has had frequent contacts with EPA and has often submitted
written comments or other documents pertaining to various aspects
of the study. All of these documents from BIC are contained in
the Administrative Record for this site.
2.
SUMMARY OF BIC COMMENTS ON THE PREFERRED ALTERNATIVE
BIC submitted comments on EPA's preferred alternative both during
and after the February 10 - March 4, 1988 public comment period
for the proposed operable unit remedy.
During the public comment period, BIC sent a letter dated March
4, 1988, containing comments on the preferred alternative.
Appended to the March 4 letter was a copy of a December 18, 1987
letter, also from BIC, to be considered as part of BIC's
comments. The December 18 letter contained BIC's comments on the
EPA supplemental Phase II RI/FS report.
After the public comment period, in letters dated May 9, June 7,
June 15, June 17, June 24 and June 29, 1988, BIC and/or its
consultants submitted further comments or information relating to
the selection of interim remedies at the BWP site.
EPA notes at the outset that BIC's comments included several
issues on which BIC had changed its position to accord with EPA's
preferred remedy. These areas of agreement included the
preference to fence the entire site and the preference to treat
contaminated water with a carbon adsorption system. This
discussion will not address these areas of agreement in detail,
but rather will focus mainly on areas where BIC's position
differs from £PA's position.
EPA also notes that, although BIC has been conducting the RI/FS
for over two years, many of the comments were received well after
the end of the public comment period. However, EPA has decided
to include these documents and data in the Administrative Record
for the Record of Decision and did consider them prior to
selecting the remedy.
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The major points of the EIC submittals include the following:
a.
Incineration of Impoundment Contents
It is BIC's position that incineration of the impoundment
sludge and soils should not be selected as a remedy at this
time. BIC characterizes incineration of wood treating wastes
as experimental and unprecedented, and believes that the
Phase III RIfFS may generate more information, leading to
stabilization, biotreatment, or other technologies that may
be more cost effective than incineration. BIC believes that
selection of incineration at this time will preclude
consideration of these other remedies during Phase III.
To support this contention, EIC recently (June 1988) met with
EPA and submitted data on the biodegradation of creosote and
penta in contaminated soils. These data showed reductions of
carcinogenic polynuclear aromatic hydrocarbons (PAHs) to
levels under 10 ppm in soil.
BIC also submitted information on EPA's selected remedies for
other wood treating Superfund sites. Many of these remedies
included elements of biodegradation technology to address
PAHs in the soils.
EIC notes that there is some uncertainty regarding the amount
of visibly contaminated soils under the impoundments, and
that this uncertainty makes selecting incineration of these
soils infeasible.
BIC believes that the environmental impact of incineration of
the sludge has not been adequately studied.
b.
No Imminent Threat
EIC believes that there is no evidence that remediation of
the impoundments is necessary to protect public health during
the nine to eighteen months that it will take to conduct the
Phase III RIfFS. BIC believes that once a fence is in place
to secure the entire site, direct contact exposure would be
virtually eliminated and ingestion of contaminated ground
water in offsite wells would be the only remaining potential
route ot exposure of any concern.
BIC's consultants have employed a ground water transport
model which has indicated that the contaminant plume is "tens
of years" away from the nearest receptor wells. EIC notes
that sampling of receptor wells by CDB has not shown any
site-related contamination, "eliminating any immediate
concerns about public health impacts."
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Extent of Visible Contamination Under the Impoundments
BIC was interested in knowing the basis for EPA's belief that
the visible contamination may extend only six or twelve
inches into the soils under the impoundments. The experience
of BIC's contractor has been to the contrary.
c.
d.
ARARs
BIC contended that the KOOl sludge in the impoundments is the
only listed RCRA hazardous waste on site. BIC also asserted
that the KOOl sludge is the only hazardous waste present at
the site.
e.
New Interim Remedies
In the June 24 letter to EPA, BIC submitted information
regarding a new option for addressing the impoundment sludge
by dewatering it prior to disposal, storage or incineration.
This technique would significantly reduce the volume to be
. shipped, stored on-site or incinerated, thereby reducing
costs of these options. .
f.
Ability to pay.
Mixed funding.
BIC believes that implementation of the preferred alternative
would not be an effective use of BIC's limited resources,
noting that the total cost of the preferred remedy is beyond
BIC's current liquid assets. BIC also noted that its
obligation to perform the Phase III RI/FS is mandated by the
consent decree and has suggested that EPA use mixed funding
for the interim remedy, thereby minimizing BIC's contribution
to that remedy and assuring sufficient funds for Phase III.
BIC believes that the only way that BIC could obtain adequate
funds for a final remediation would be through cleaning up
and selling portions of the BWP property. Consequently, BIC
believes that remedies to address the facilities area and
surface 50i1 contamination should be given a higher priority
than the impoundments.
- 24 -
-------
3.
EPA RESPONSES TO SIC COMMENTS
EPA's responses to these comments are as follows:
a.
Incineration of Impoundment Contents
Based on the information contained in the Phase II RI/FS
reports, and other supporting documents, EPA believes that
incineration of the impoundment sludge and soils is the most
appropriate remedy that could be selected to address these
segments of the contamination at the BWP site. In particu-
lar, EPA believes that incineration of the sludge is the only
technology that will reliably, effectively and permanently
. eliminate this major source of site contamination.
EPA's major reasons for selecting incineration of impoundment
sludge and soil at this time are as follows:
( 2 )
( 1 )
EPA notes that the main and secondary impoundments are
the major sources of contamination at the site and
believes that the studies of these sources completed
thus far are sufficient to support selection of a remedy
for them. As stated in a letter to BIC dated March 26,
1987, EPA's main objective in revising the Phase II
report was to make use of the information available in
the draft Phase II report to address obvious and
concentrated hazards such as the impoundments and
facilities area. EPA expected that source control and
direct contact remedies would be considered to address
these hazards. EPA believes that the Phase II RI/FS, as
revised and supplemented, provides a sufficient base to
select a remedy for the impoundments, and that no
further (Phase III) RI/FS work needs to be performed to
support these remedies.
The impoundments continue to be in contact with the
ground water regime and are significant contributors of
contamination to that regime. This fact is supported by
historical information which indicates that contaminants
were migrating from the site in an observable fashion
within as little as five years of the construction of
the main impoundment. This information also indicates
that the main impoundment once extended much closer to
the north boundary of the site and Fisher Ditch.
EPA is not asserting that the incineration remedy will
completely address the endangerment posed by the ground
water pathway. However, EPA believes that removing the
major source of contamination into that pathway will be
an effective long-term remedy.
- 25 -
-------
( 6 )
( 7 )
( 8 )
( 3 )
EPA believes that incineration will be the most
effective technology to address the dioxins and furans
in the sludge and oil. Incineration offers destruction
removal efficiencies (OREs) in excess of 99.99% for all
contaminants, including dioxins and furans. EPA is
concerned that any other technology would not be able to
permanently eliminate these contaminants. EPA also
notes that recently proposed RCRA regulations define
Best Demonstrated Available Technology (BDAT) treatment
standards for disposal of KOOl wastes based on the
incineration of the waste.
~
( 4 )
The removal of the impoundment contents will be
consistent with any future remedial actions at the site.
EPA believes that, particularly because of their dioxin
and furan components, the impoundment contents are
fundamentally different from other contaminated media on
the site and that they need to be treated as such.
( 5 )
The removal of pond sludge will also be consistent with
the Phase III RI/FS study of soils. It will be
necessary to remove the impoundment contents to expose
the contaminated soils underneath.
This action is also consistent with similar actions at
other wood treatment Superfund sites. While
incineration of similar wastes has been selected at
other Superfund sites, biodegradation of impoundment
contents with dioxin components has not been
implemented. BIC submitted examples of RODs in which
EPA selected remedies other than incineration for wood
treating contamination. In many of these cases, the
most concentrated contaminants either had already been
or were about to removed for land disposal. Land
disposal of the BWP sludge was not selected both because
it was not cost effective and because it was not likely
to comply with ARARs. .
The impoundments continue to represent a potential fire
hazard. The impoundments once caught fire from the.
sparks of a passing train.
Although BIC has asserted that timing is not a
significant issue for addressing the pond contents, EPA
ia concerned that waiting to remove the contents until
after the completion of the Phase III RI/FS will allow
more contaminants to enter the ground water regime.
BIC's consultant has projected that the Phase III RI/FS
will take from nine to eighteen months to complete. The
basis for EPA's concern is discussed in greater detail
below.
- 26 -
-------
( 9 )
The presence of the oil layer on the main impoundment
means that water falling on that impoundment can't
evaporate. Thus the water continues to provide a head
to push contaminants into the ground water.
EPA reviewed the biotreatment data submitted by BIC and
concluded that there was insufficient cause to change the
remedy for the sludge. In particular, there were no data to
support selection of biotreatment as a reliable, effective
technology to treat dioxin-contaminated sludge. The
application of the technology to sludge would involve mixing
the sludge with less contaminated soils, thereby diluting the
contamination to levels in which the microorganisms would be
effective. EPA is concerned that this technology has not
been proven, and has particular concerns about the fate of
the dioxins in the.sludge during this process.
EPA acknowledges the uncertainty about the exact volume of
visibly contaminated soils under the impoundments. EPA did
not want to make a commitment at this time to large-scale
incineration or biodegradation because it might establish an
on-site plant that would artificially influence the Phase III
engineering sensitivity analysis. Consequently, EPA is
limiting the incineration option of this remedy to only the
small volume of soils that would be compatible with the
small-scale sludge incinerator. In other words, EPA's remedy
provides that visibly contaminated soils will only be
incinerated as part of the interim remedy if the volume of
soils does not exceed 2500 cubic yards. If the volume does
exceed such amount, these soils will be temporarily stored to
allow further study during the Phase III RI/FS.
EPA also aCknowledges that a site-specific assessment of risk
from incinerating the impoundment contents has not been
conducted. However, EPA notes that incineration is a proven,
reliable, much tested remedy, wherein destruction
efficiencies in excess of 99.99% can be expected.
Additionally, studies have shown that increased cancer risks
resulting from inci~eration of similar wastes are expected to
be les8 th~n 1 X 10 for the most exposed individual. In
accordance with the applicable regulations, a test burnl
treatability study will be performed before the remedy is
imple_nted.
b.
No Imminent Threat
EPA has reviewed BIC's assertion, based on a ground water
model, that contaminants are "tens of years" away from
receptor wells. EPA is not convinced of this assertion
because of the following concerns:
- 27 -
-------
( 3 )
( 4 )
( 5 )
c.
( 1 )
The Denver Formation is quite variable in its geology,
containing both fractures and sandstone lenses, making
it difficult to characterize movement of ground water.
This variability also means that ground water and
contaminants could migrate more quickly than through a
homogeneous medium.
( 2 )
The Phase II ground water monitoring program included
only three monitoring wells in the unweathered bedrock.
None of these three wells were downgradient from the
impoundments or off-site to the north. However, all
three wells showed some ground water contamination.
~
EPA believes that the Phase II ground water monitoring
program did not catch the worst of the contaminant plume
migrating offsite. EPA notes that visual or odorous
evidence of contaminants was present in many of the.
geologic logs completed for monitoring well installation
(IT-1, 2, 3, 4, 5, 7, 8, 10), but that only two wells
(IT-4 and IT-7) were screened in the intervals capable
of monitoring the sinking or floating phases of
contamination. Hence, contamination may be migrating
off-site more rapidly than indicated by the model used
by BIC's consultants.
EPA is concerned with some uncertainties in the ground
water model, particularly regarding velocities. The
Phase II draft report included calculations showing
ground water velocities to be three times greater in the
bedrock than in the alluvium, when one would normally
expect the opposite.
EPA notes that the off-site receptor wells were last
sampled in 1986 (by CDH) and that the results of that
sampling program can no longer be relied upon to assure
that contaminants are not reaching those wells. The
wells will need to be sampled on a regular basis
starting with the Phase III RIfFS.
Extent ot Visible Contamination Under the Impoundments
EPA's experience at a similar, but much larger wood treating
facility was that the visible contamination did not extend.
beyond six or twelve inches into the soils under the
impoundments, except for "stringers" of contamination that
followed fractures and other geologic features. EPA is not
assuming that this is the case at BWP, only that this is a
possibility. EPA has designed a decision tree to address
these soils in a way that will be consistent with future
remedies, regardless of the volume.
- 28 -
-------
d.
ARARs
EPA notes that the CERCLA cleanup of the BWP site will
concern itself with all hazardous substances as defined by
CERCLA, not just RCRA listed hazardous wastes. EPA is
concerned that there may be other RCRA hazardous wastes and
other hazardous substances at the site which have not yet
been identified. Identification and characterization of
these wastes will be one of the main objectives of the Phase
III RI/FS.
EPA believes that the sludge is fundamentally different from
the rest of the site because of the higher concentrations of
dioxins and the fact that it is a listed waste.
e.
New Interim Remedies
EPA has reviewed the recently submitted information on
dewatering the sludge prior to disposal, storage or
incineration. While the information will not impact the
selection of incineration as the chief remedy for addressing
the sludge, EPA will consider implementing this remedy prior
to incineration, particularly with respect to volume
reduction and cost savings. This further consideration will
occur during the design stage of remedy implementation.
f.
Ability to pay.
Mixed funding.
EPA notes that, while cost-effectiveness of particular
remedies is a criterion against which remedies are evaluated,
the ability of the PRP to pay for a particular remedy is not.
The only time when the source of funding for a remedy is an
issue is when the cost is so great that it would have a
significant impact on the Superfund Trust Fund. .
EPA intends to explore all options in assuring that the
selected .remedy is implemented.
Regarding the issue of remedies for the facilities area and
surface soils cleanup, the Phase II RI/FS was not sufficient
to addre.. these areas. These areas will be addressed in the
Phase UI RI/FS.
\
- 29 -
-------
EXHIBIT 2
WRITTEN COMMENTS RECEIVED FROM STATE OF COLORADO
\brodrick\bramn 1 0\092391
100'Jb Recycled
-------
(, .
ROY ROMER
Goveruor
JOEL KOHN
IDicrim Execulive Director
4210 &slllth Avenue
Denver. Colorado 80220-3716
Phoae (303) 320.8333
Tcl.(u Numbots:
."aiD BuildiDlI/DtII..,
(303) 322-9016
punr.gm PJac:elDonv.,
':03\ 3::O-15~9
FilSl .';...0001 B.... ButlchngiDeov.,
'303) 355-6559
Grand Junclion Office
',)03) :018.7198
April 4, 1991
Mr. Brian Pinkowski
U.S. EPA, Region VIII
One Denver Place, Suite 500
999 18th Street
Denver, CO 80202
RE:
State Acceptance of ROD Amendment for Broderick Wood
Products
Dear Brian:
As you requested, the Colorado Department of Health (CDH) is
informing you of its decision concerning the proposed ROD Amendment
for the Broderick Wood Products Superfund site. EPA's preferred
alternative is off-site reclamation to a chemical recycling plant in
Birmingham, Alabama.
It is CDH's understanding that~he proposed recipient of the was~e
is to be Allied Signal Co. As I have informed E?A on several
occasions, CDH has one major concern regarding this remedy. That
is, whether EPA has performed a sufficipnt analysis of Allipd Signal
Co. to determine whether or not its RCRA permit is in order, whether
it has been cited for any violations of its permit, or whether the
company has any known environmental problems associa~ed with its
operations.
CDH concurs with EPA's preferred alternative. However, since the
remedy is so closely tied to one commercial facility, we would
reserve acceptance of this choice until the concerns mentioned above
have been addressed fully. If other faci~ities offering the same
service as Allied exist, their viability should be reviewed.
Thank you very much for the opportunity to comment on this project.
If you have any questions, please call.
Sincerely,
~?-l~
@ ",.NId 011 tOcycUd POP"
Roger Schimmel
Project Officer
Hazardous Materials and
Waste Management Division
RS/dm
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\brodrlck\bramn 1 0\092391
EXHIBIT 3
WRITTEN COMMENTS RECEIVED FROM BIC
100% Recycled
-------
, ,
HOLLAND & HART
ATTORNEYS AT LAW
DENVER
DENVER TECH CENTER
COLORADO SPRINGS
ASPEN
BILLINGS
BOISE
CHEYENNE
WASHINGTON, D.C.
SUITE 2900
555 SEVENTEENTH STREET
DENVER. COLORADO
MAILING ADDRESS
PO. BOX B749
DENVER, COLORADO 80201
TELEPHONE 1303\ 295-80c0
TELECOPtER (303) 295-8261
TWX 910.931.0.568
BRENT W.&JTE
13031 295.8371
February 14, 1991
Mr. ~rian Pinkowski
u.s. Environmental Protection
Ag~ncy, Region VIII
One Denver Place
999 Eighteenth street, 6th Floor
Denver1 CO 80202-2405
RE:
Broderick Investment Com~anv's Comments on EPA's
ProDosed Reconsideration of the June 1988 ROD for the
Broderick Wood Products Su~erfund site. .
Dear Brian:
Broderick Investment Company ("BIC") submits the following
comments on the Proposed Plan to amend the June 30, 1988 Record
of Decision ("ROD") for the Broderick Wood Products Superfund
site ("Broderick site"). -
A.
Introduction.
On June 30, 1988, the Regional Administrator of Region VIII
of the u.s. Environmental Protection Agency ("EPA") signed a ROD
creating an interim cleanup remedy for the Broderick sit~ (an
inoperative wood treating facility located in southern Adams
County, Colorado). That remedy, known as "Operable Unit 1,"
called for onsite incineration of waste contained in impoundments
in the northwest corner of the site. EPA has categorized this
waste as "K001 waste": it is a mixture of creosote and
pentachlorophenol contained in the bottom sedirnent sludge that
resulted from the steam wood preserving process employed from
1945 to 1981 at the Broderick site.
BIC is the current owner of the Broderick site. Pursuant to
the Comprehensive Environmental Response, Compensation, and
Liability Act ("CERCLA") and the terms of a Partial Consent
Decree approved by the United States District Court on May 21,
1986, BIC has conducted an extensive Remedial Investigation/
Feasibility Study of the site. The last phase of that study
(Phase III) is drawing to a close and will result in a new ROD
later this year covering cleanup of the portions of the site not
covered by Operable Unit 1. Based on data discovered during the
partially completed Phase III investigation and other new
-------
HOLLAND & HART.
ATIORNEYSATlJ\W
Mr. Brian Pinkowski
February 14, 1991
Page 2
information, BIC filed a Petition for Reconsideration of the June
1988 ROD on May 24, 1990. After review of the Petition (and
after BIC voluntarily removed the KOOl sludge from the unlined
impoundments and stored it onsite in lined storage cells), EPA
issued the January 1991 Proposed Plan to amend the ROD. The
Proposed Plan calls for offsite reclamation of the KOOl sludge at
the Allied wood treating facility in Alabama, which was one of
the alternative remedies that BIC proposed in its Petition for
Reconsideration. .
B.
Althouah BIC believes bioremediation is the best remedy
tor cleanuD of the sludae. offsite reclamation is
clearlY Dreferable to the oriqinallv adoDted onsite
incineration remedY.
1.
Bioremediation.
The Petition for Reconsideration (at pages 15 through 28)
describes the conslderable advantages of biorernediation of the
sludge. As you know, BIC reserves its position that
bioremediation is the most cost-effective remedy for the sludge.
EPA rejects bioremediation in the January 1991 "Summary
Document -- Post-ROD Activities" prepared by Jacobs Engineering
to support ROD reconsideration. That rejection is premised on
assertions that bioremediation could not achieve action levels in
a reasonable period of time and could not satisfy the
requirements for a "no-migration" petition. These cursory
assertions ignore the analysis of the applicability of the
Resource Conservation and Recovery Act ("RCRA") land disposal
restrictions as discussed on pages 26 through 28 of the Petition
for Reconsideration. They also do not specify what aspect of
bioremediation automatically fails the requirements of a no-
migration petition. Thus, they do not justify summary rejection
of bioremediation. .
2.
Otfsite Reclamation.
subject to the reservation of rights described above,BIC
supports EPA's decision to revise the ROD to use offsite
reclamation to treat the sludge. Under the reclamation
alternative, described at pages 28-29 of the Petition for
Reconsideration, the sludge will be transported to the Allied
facility in Alabama. Allied will refine the sludge to produce
relatively pure creosote/pentachlorophenol constituents. It will
then either sell these constituents to a RCRA permitted wood
treating facility or use them in its own wood treating process.
If the material is not recyclable, Allied will blend it as fuel
-------
HOLLAND & HART
ATIORNEYSATLAW
Mr. Brian Pinkowski
February 14, 1991
Page 3
and burn it in properly permitted onsite incinerators to provide
steam for the wood treating process. .
"
This proposal more fully accomplishes the purposes of CERCLA
than the incineration remedy described in the ROD. First, it is
much more cost effective: BIC's consultant, Remediation
Technologies ("ReTeC"), estimates that the cost ~f offsite
reclamation is between 2 and 3 million dollars. This cost is
nearly a five-fold savings over the 11 million dollar onsite
incineration cost estimated in the Army Corps of Engineers' 1989
design document. As indicated in our letter of January 14, 1991
(enclosed as Exhibit I), offsite reclamation also complies with
all RCRA land disposal restrictions, which are the principal
applicable or relevant and appropriate requirements ("ARARS") for
cleanup of the sludge. Reclamation also promotes EPA's.goals of
recycling and pollution prevention by reusing a significant
portion of the sludge. Finally, as the community members that
attended the public meeting regarding the ROD reconsideration on
February 5, 1991 demonstrated, the surrounding community has
serious concerns about incineration. The reclamation alternative
is thus a more acceptable alternative to the community. It is
clearly preferable to onsite incineration.
c.
Preliminary information indicates that EPA should not
include the wood treatina materials remainina in the
buildina, vessels and drums in its DroDosed offsite
reclamation remedy.
Shortly after EPA opened the comment period for
reconsideration of the ROD, EPA and BIC discussed the possibility
of reclaiming the wood treating materials contained in the onsite
building, vessels and drums as part of Operable Unit 1. At that
time,both EPA and BIC speculated that reclamation of this
material as part of Operable unit 1 would be the most cost-
effective treatment alternative (other than bioremediation)
because the volume of this material was small compared to the
volume of the sludge, and thus the marginal cost of reclaiming it
would also be small. EPA requested that BIC investigate
reclamation of this material and, if that investigation confinr:ed
EPA and BIC's initial speculation, provide EPA with the necessary
information to include the building, vessel and drum materials in
the revised Operable Unit 1.
At BIC's request, ReTeC has analyzed reclamation of the
building, vessel and drum wood treating material. Based on
currently available information, ReTeC has concluded that EPA
should not reclaim building, vessel and drum materials as part of
Operable Unit 1. There are two reasons for this conclusion:
first, much of the wood treating materials in the vessels is not
-------
HOLLAND & HART
ATTORNEYS AT LAW
Mr. Brian Pinkowski
February 14, 1991
Page 4 .
readily accessible. Expensive demolition of these vessels is
necessary prior to removal of the wood treating materials.
Because all of the buildings and vessels will probably be
demolished after completion of the Phase III studies, ReTeC has
concluded that demolishing the vessels that contain wood treating
materials at the same time as the other site buildings and
ves~els is both more implementable and more cost-effective.
Second, after discussions with Allied, ReTeC has determined that
the marginal savings associated with treating the building,
vessels and drum contents now is small. Allied charges the same
reclamation fee regardless of the quantity of material reclaimed.
Therefore, even if it were easily removed from its current
containers, it is not more cost-effective to reclaim the
building, vessel and drum material as part of operable Unit 1.
Because it is based on preliminary information, ReTeC's
analysis of this issue is also preliminary. Information that
develops during the remedial design may lead to a different
result. However, based on currently available information, EPA
should not include building, vessel, and drum contents in
Operable unit 1. If you wish to review ReTeC's detailed analysis
of this issue, please let us know.
D.
EPA's Summary Document contains some minor factual
errors.
ReTeC has reviewed the Summary Document on behalf of BIC and
has noted some factual errors. Most of these factual errors are.
minor and are discussed in the enclosed Exhibit 2.
SIC hopes that these comments will prove useful to EPA in
amending the ROD. Please call John Shepherd (295-8309), .Brent
waite (295-8371), or Frank Prager (295-8398) if you have any
questions.
Very truly yo~rs,
1£ ~ oJ:J--
Frank P. Prager
Brent A. Waite
for Holland & Hart
Attorneys for
Broderick Investment Company
BAW/cg
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HOLLAND & HART
ATIORNEYS AT LAW
Mr. Brian Pinkowski
February 14, 1991
Page 5
cc:
Joann G. Ward, Esq.
Francis W. Collopy, Esq.
Andrew C. Middleton, PhD.
Ann M. Colpitts
Roger Schimmel
Richard Sisk, Esq.
Charlotte RObinson, Esq.
Philip Karmel, Esq.
Roy Evans
-------
j
,
~I~
23 Old Town Square
Suite 250
Fort Collins. CO 80524
Telephone: (303) 493-3700
Facsimilie: (303) 493-2328
REMEDIATION
TECHNOLOGIES INC
February 13, 1991
J>
Mr. Frank Prager
Holland and Hart
555 Seventeenth Street
Suite 2900
Denver, CO 80202
Dear Frank:
I have reviewed the "Summary Document - Post ROD Activities - June 1988 to December
1990" for the Broderick Wood Products site as you requested. The document was prepared
by U.S. EP A for public information and provides background and justification for changes
in the June 1988 ROD. Most of my comments are directed at the portions of the document
that deal with the hydrogeological description. Overall, the document is accurate in this
area, however, there are several points that need updating, because the document used draft
data from the draft RI or draft data from meetings with U.S. EPA.
Specifically, the areas that are inaccurately portrayed include the following:
. Page 4, Section 1.2.1, 5th paragraph: The weathered bedrock does not contain vertical
fracturing as indicated here. The sentence should read" The upper seven to 15 feet of the
Denver Formation includes weathered bedrock with broken or fragmented material, which
decreases with depth."
Page 5, Figure 3: The cross sect'ion did not reproduce well. and the reader cannot distinguish
the strata descriptions nor the difference between "odor detected" and "oil in section".
Page 7, Section 2, fifth paragraph: We are not familiar with the December, 1982 inspection
conducted by EP A where a trench was observed at the site. Presently, there is no evidence
of this trench at the site. We have requested a copy of the report from Jacobs Engineering.
Page 11, Section 3.2, first paragraph: This is' an outdated description of the water levels in
the impoundments and how they interact with groundwater. First, the Figure 4 was a draft
figure originally prepared for a meeting with EPA on December 18, 1989 (over one year
ago) and was updated for the Level 2, Draft and Final RI reports. The Final RI report
contains the version that BIC believes accurately portrays the flow between the
impoundment and the groundwater. Second, after the impoundments .were dewatered
Concord. MA . Pittsburgh, PA . Fort Collins. CO . Kent. WA . Austin. TX . Chapel Hill, NC
. EXiiI6IT-
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Page 2 of 2
'.
and the sludge removed in the fall, 1990, it became evident that the sludge was self-sealing
and, in fact, the water level in the impoundment was artificially higher than the groundwater
table because the water could not flow in or out of impoundment. The sludge apparently
clogged the pore spaces of the soil surrounding the impoundment and therefore limited
water movement. .
The recent infomiation obtained on the current water levels around the impoundments
indicates that the water levels in the. impoundments are not higher than the surrounding
groundwater table. Therefore, because of the self-sealing effect described above, the
impoundments could not have exhibited a "mounding" effect and, before the sludge was
removed, could not have created a gradient which would drive contaminants away from the
impoundments. .
Page 11, Section 3.2; second paragraph: The second sentence states that "it was determined
- that the volume of visibly contaminated soil in or beneath the impoundments is much greater
than the quantity in the June 1988 ROD". When was this determination made and what is
the reference for this statement? .
If you have any questions regarding the contents of this letter, please call.
Sincerely yours,
REMEDIATION TECHNOLOGIES, INC.
~ }IL{. 4-Cr Ws
Ann M. Colpitts.
Sr. Hydrogeologist
cc:
A Middleton
D. Morgan
-------
--
Ct
23 Old Town Square
Suite 250
Fort Collins. CO 80524
Telephone: (303) 493-3700
Facsimilie: (303) 493-2328
REMEDIATION
TECHNOLOGIES INC
D
<.;>
February 22, 1990
Mr. Brian Pinkowski (8HWM-SR)
US EnvironmemaI Protection Agency
Region vm
999 18th Street, One Denver Place
Deaver, Colorado 80202
Dear Brian:
Frank Prager with Holland and Hart sent a letter to you dated February 14, 1991 regarding
comments on EPA's proposed reconsideration of the June 1988 ROD. Attached to that.
letter was a February 13, 1991 letter from me to Frank Prager discussing the .Summary
Document - Post ROD Activities". On behalf of Broderick Investment Company and
Holland and Hart, I would like to point out an error in that letter. The last comment on
page 2 of my letter refers to Page 11, Section 3.2 of the Summary Document and the entire
comment should be withdrawn from your consideration. I apologize for any confusion this
may have caused but felt it was important for you to be aware that the comment does not
require a response. Please call me if you have any questions concerning this matter.
Sincerely yours,
REMEDIA nON TECHNOLOGIES, INC.
!iN M'4fdi
Ann M. Colpitts
Sr. Hydrogeologist
cc:
Prager, F.
Middleton, A.
Concord. MA . Pittsburgh. PA . Fort Collins. CO . Seattle. WA . Austin. TX . Chapel Hill. NC . St. Paul. MN
-------
-------
ERRATA
SUMMARY DOCUMENT
POST -ROD ACTlVmES
JUNE 1988 TO DECEMBER 1990
The following changes should be made to the Summary Document. Text to be deleted is
enclosed within brackets. Replacement text is underlined.
1) Page 4, Section 1.2.1, 5th paragraph: The second sentence should read as follows: ''The -
upper seven to 15 feet of the Denver formation includes [are weathered] bedrock with
broken or fraamented material [vertical fracturing], which decreases with depth."
p
v
2) Page 5, Figure 3: This Figure has been reproduced with better clarity and is attached.
3) Page 7, Section 2, 5th paragraph: The reference to the trench should be deleted and the
paragraph modified as follows: "EPA conducted another inspection of the site in
December 1982. This inspection revealed the possibility of serious contamination at BWP~
[. including a 1 O-foot by 50-foot trench that was observed about 40 feet north of the
impoundments. This trench had reportedly been used only for the disposal of solid
wastes; however, a black stain and oily puddle were noted at the bottom of the trench.]
Also, in December 1982, Browning Ferris ...."
4) Page ii, Section 3.2, first paragraph: Figure 4 should be deleted and replaced with the
attached revision. Although outdated, the piezometric levels shown in the original Figure
are similar to those in the replacement Figure. Consequently, the conclusions/hypotheses
presented in the Summary Document are still valid. It should be noted that the piezometric
levels shown in Figures 5 and 6 are intended as conceptual illustrations and do not
represent measured data.
\brodrIck\bramn10\092391
100% Recycled
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~;200
ff\
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F11
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....
-
5075
5050
5025
5225
Entrance
S~ Gate
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5/75
Northern
/propertYo~OUndarY
BWP Site
5/50-
Denver
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\.
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APPROXIMATE SCALE
Horizontal: ,": 300'
Vertical: I": 40"
Figure 3
Schematic GeOlogical Cross Section
of the Broderick W' 'd Products Site
.
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