"
United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EP AlROD/R08-92/057
March 1992
PB93-964401
&EPA
Superfund
Record of Decision:
Broderick Wood Products,
CO
'lJ. S. Environme tiP
Regio~ III Hazard~u~ w~t;ctiOf'l Agency
l~c1hnc. IChallnform&tion C~~t~r
estnut S1 r ~e' at
Philadelphia. PA" ~ 91 07 h Floor
~--....-.......
~
~~--
EP A Report Collection
Information Resource Center
US EPA Region 3
Philadelphia, PA 19107
~
Hazardous Waste Correction
Jnformation Resource Center
US EPA Region 3
Philadelphia" PA 19107
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NOTICE
The aPpendices listed in the index that are not found in this document have been removed at the request of
the issuing agency. They contain material which supplement, but adds no further applicable information to
the content 01 the document. All supplemental material is, however, contained in the administrative record
for this site.
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50272.101
REPORT DOCUMENTATION 11. REPORT NO. 12.
PAGE EPA/ROD/R08-92/057
3. Recipient. AcC8881an No.
4. 11tIe 8l1li Sub...
SUPERFUND RECORD OF DECISION
Broderick Wood Products, CO
Second Remedial Action - Final
7. AuIhor(.)
5. Report Date
03/24/92
6.
8. F8rformlng Organization Rept. No.
II. PWfonnlng Orll8lnlza1l0n Name 8l1li Add....
10. ProjectlTuklWork Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. SponaorIng Organization ....... and Addre..
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13.. Type 01 Report & Period Covencl
Agency
800/000
14.
15. Suppl8m8nl8ry No...
PB93-964401
16. Abatract (Umlt: 200 word.)
The 64-acre Broderick Wood Products (BWP) site is a former wood preserving
facility in unincorporated Adams County, Colorado, located just outside of Denver,
Colorado. Land use in the area is predominantly industrial. There are three aquifers
below the site: the surficial, the Denver, and the Arapahoe. The Denver aquifer
ground water is used for commercial and irrigation purposes, and the Arapahoe is
tapped by several private wells in the area. All residences are currently connected
to a municipal water supply system for household use. From 1947 to 1981, the BWP
Company used the site to operate a wood treatment facility, where both creosote and
pentachlorophenol (PCP) were mixed with carrier oil (fuel oil) and used at the site.
The major site features include two unlined surface impoundments and 23 structures.
Underground structures at the site include the treatment basement building and two
cylinder basements. There are also 16 vessels, including storage tanks, an air
cylinder, and a pressure cylinder onsite, whose capacities range from 2,400 to 50,000
gallons. Approximately 70 drums containing various chemicals, oils, and asbestos are
stored in the process area, and 65 drums of oil from sludge are stored in the
impoundment area of the site. Process waste from the plant was disposed of onsite,
(See Attached Page)
17. ~t AnaJyaIa .. Deacrlptora
Record of Decision - Broderick Wood Products, CO
Second Remedial Action - Final
Contaminated Media: Soil, debris, sediment, gw
Key Contaminants: VOCs (benzene, toluene, xylenes)i other
PAHs, PCP, phenolic compounds); metals (arsenic, lead)
b. IdantlllenlCpen-EndecI Terma
organics (dioxins, furansi
c. COSAl1 ReIdIGroup
18. AVliIablity StaIemanI
19. Security a... (lbi. Report)
None
20. Secwity a... (lbia Page)
Nonp-
21. No. 01 Pagea
106
I
22. Price
See~.18)
See IMllUCtiOM on Re-
-
272 (4-77)
(FonneJ1y NT15-35)
Deper1ment of Conmerce
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EPA/ROD/R08-92/057
Broderick Wood Products, CO
Second Remedial Action - Final
Abstract (Continued)
with a large amount going to the impoundments on the northwest corner of the site. In
1946, the main impoundment was constructed, and in 1956, a secondary one was constructed
for additional evaporation capacity and overflow. In 1962, both impoundments caught fire
and burned for several hours. BWP ceased operations as a woodtreater in 1981.
Investigations were done by EPA and the state under RCRA and CERCLA authorities, which
revealed contamination both onsite and on adjacent properties. In 1988, EPA issued an
interim ROD to control the major source of contamination at the site, including
restriction of site access, treatment of water in the impoundments and buildings,
excavation and incineration of sludge, and stockpiling or onsite incineration of visibly
contaminated soil in the impoundments, referred to as OU1. A petition was filed with EPA
to reconsider onsite incineration: a ROD Amendment was signed in 1991 that provided for
excavation and offsite recycling/incineration of the sludge from the two impoundments.
Two temporary-lined cells were constructed on the property, and sludge was stockpiled
temporarily until the solid sludge storage cell was completed. Approximately 950 cubic
yards of solid sludge and 1,200 cubic yards of liquid sludge have been stored in lined
cells with leachate collection and will be removed to an offsite recycling facility.
This ROD addresses OU2, a final remedy for the BWP site. The primary contaminants of
concern affecting the soil, debris, sediment, and ground water are VOCs, including
benzene, toluene, and xylenes; organics, including PAHs, dioxins, furans, and PCP and
other phenolic compounds; and metals, including arsenic and lead.
The selected remedial action for this site includes treatment of the debris, soil and
sediments, and ground water using the following methods. For debris from buildings,
vessels, and drums, the remedy includes demolishing and decontaminating buildings,
stockpiling debris onsite temporarily, sending building debris and asbestos-containing
materials for offsite disposal at a permitted landfill, decontaminating 225 tons of scrap
metal to be sent for offsite reclamation, pumping/excavating drum and vessel contents to
be transported offsite for reclamation and pumping, stabilizing, drumming, and
transporting approximately 9,500 gallons of contaminated water offsite to a permitted
facility for disposal. For soil and sediments, the selected remedy includes excavation
and bioremediation of approximately 59,000 cubic yards of organic-contaminated soil in an
onsite land treatment unit (LTU) over a 7-year period, excavation and de-watering of
120 cubic yards of Fisher Ditch sediments to be treated in the LTU onsite, excavation and
treatment of 800 cubic yards of metals-contaminated soil via chemical fixation, followed
by disposal at an offsite RCRA landfill, closure of the existing surface impoundments,
and implementation of institutional controls. Approximately 526 million gallons of
ground water and light non-aqueous phase liquids (LNAPLs) will be recovered from the
surficial aquifer using subsurface drain trenches and recovery wells. A two-phase
(ex-situ and in-situ) biological water treatment process will remove the LNAPLs in an
oil/water separator. The LNAPLs will be reclaimed at an offsite recycling facility, with
remaining water treated using a two-phase fixed-film bioreactor, mixed with nutrients and
an oxygenated chemical, then reinjected into the aquifer to stimulate bacterial growth to
promote further breakdown of contamination within the shallow aquifer. Dense non-aqueous
phase liquids (DNAPLs) and ground water will be collected from existing monitoring wells
in the Denver aquifer, treated in the oil/water separator, and sent offsite for
recycling. Ground water in all aquifers will be monitored for 30 years. Additional
monitoring wells will be drilled in the Arapahoe aquifer to further test samples and
assess ground water quality. Institutional controls will be used to control access to
water in the surficial and Denver aquifers. The estimated total present worth cost for
this selected remedy is $15,551,033, including a total O&M cost of $7,400,185.
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EPA/ROD/R08-92/057
Broderick Wood Products, CO
Second Remedial Action - Final
~stract (Continued)
PERFORMANCE STANDARDS OR GOALS: Chemical-specific excavation goals for soil and
sediments were based on health risk clean-up level indices (CLIs) greater than 1.
Chemical-specific soil and sediment clean-up goals are based on health-based criteria
for organic contaminants and RCRA LDR standards for metal contaminants and include
toluene 0.5-10 mg/kg; xylenes 0.5-10 mg/kg; benzo(a)pyrene 15.2 mg/kg, dibenzo(a,h)
anthracene 13.9 mg/kg, 2,3,7,8 TCDD equivalent 0.0006 mg/kg, pentachlorophenol,
naphthalene, and pyrene at 95-99 percent reduction, arsenic 5.0 mg/kg, cadmium 1.0 mg/kg
and lead 5.0 mg/kg. Chemical-specific ground water clean-up goals are based on SDWA
MCLs and the Colorado Basic Standards and include 2,3,7,8 TCDD equivalent 5x10 -5 ug/l,
trichloroethylene at 5.0 ug/l, tetrachloroethylene 1.6 ug/l, carobozole 4.1 ug/l, phenol
623.0 ug/l, pentachlorophenol 1.0 ug/l, pyrene 312.0 ug/l, and naphthalene 41.6 ug/l.
The ability to achieve these clean-up levels cannot be determined until the extraction
system has been bnplemented; therefore, EPA may need to modify the remedy if necessary.
MCL ARARs are waived for the Denver aquifer because of a technical impracticability.
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RECORD OF DECISION
BRODERICK WOOD PRODUCTS
ADAMS COUNTY, COLORADO
OPERABLE UNIT 2 - FINAL SITE REMEDY
MARCH 1992
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DECLARATION STATEMENT
for
RECORD OF DECISION
BRODERICK WOOD PRODUCTS
ADAMS COUNTY, COLORADO
OPERABLE UNIT 2 - FINAL SITE REMEDY
MARCH 1992
SITE NAME AND LOCATION
Broderick Wood Products
Adams County (unincorporated), Colorado
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for Operable Unit 2 (OU
2) at the Broderick Wood Products (BWP) Superfund site which is located at 5800
Galapago Street in unincorporated Adams County, Colorado. The selected remedial
action is treatment of the soils, sediments, and surficial ground water, and demolition
and recycling/landfilling of buildings, and recycling of building contents at BWP. The
remedy was selected in accordance with the Comprehensive Environmental Response,
Compensation, and Uability Act of 1980 (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA) and, to the extent practicable, the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP).
This decision document explains the basis for selecting the remedy for the soils,
sediments, ground water, and buildings and building contents at this site. 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
&~~ .
The State of Colorado concurs with the selected remedy.
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 Record of Decision (ROD), may
present an imminent and substantial endangerment to public health, welfare, or the
environment.
DESCRIPTION OF THE SELECTED REMEDY
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 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 impoundments and buildings. Based on
new technical data and cost information obtained subsequent to the June 1988 ROD,
EPA revised its decision to employ on-site incineration as a source control measure for
au 1. New data evaluated by EPA included technical data on the interaction of
contaminants and ground water received from continuing RI/FS activities for QU 2 and
cost information for on-site incineration received during remedial design for OU 1. A
1
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ROD Amendment for OU 1. issued on September 24, 1991. describes the revised
interim action, which involves off-site recycling of the impoundment sludges.
The selected remedy presented in this ROD addresses the principal threats posed by
the site, They are the soils, sediments, ground water, buildings and building contents
that contribute to contamination at the BWP site and form OU2. These media contain
elevated concentrations of pentachlorophenol, polynuclear aromatic hydrocarbons,
volatile organic compounds, and chlorinated dioxins and furans. A portion of the site
soils also contain elevated concentrations of metals left from pre-8WP operations at the
site. Inhalation and ingestion of, and direct contact with these contaminants have been
determined to pose a threat to human health from the soils, sediments, ground water,
buildings and buildings contents. The final site remedy is intended to mitigate these
exposure pathways and includes the following components:
Soils/Sediments. The selected remedy will use the following technologies and controls
to address contamination in soils and sediments:
.
Approximately 59,000 cubic yards 01 soils most highly contaminated with
organics will be excavated and bioremediated in a land treatment unit (L TU).
The length of the total treatment process is estimated at seven years. Since the
Land Disposal Restrictions (LDRs) will not be met at the time 01 placement in the
L TU, these LDRs are waived under an interim measures waiver. The LDR
treatment standards will be met at the end 01 the remedial action by a soil and
debris treatability variance.
.
Approximately 120 cubic yards of organics-contaminated sediments in Fisher
Ditch will be excavated and treated to remove water, as necessary, in
preparation for subsequent treatment with the organics-contaminated soils.
Approximately 800 cubic yards of soils contaminated with heavy metals will be
treated through chemical fixation to form a chemically and mechanically stable
material. This material will then be disposed at an off-site, RCRA-permitted,
'solid-waste landfill.
.
.
The existing surface impoundments will be closed in accordance with RCRA
requirements.
Exposure to organics-contaminated soils at lower levels remaining after
excavation treatment will be controlled by the use 01 institutional controls, such
as deed restrictions, to prohibit future residential and agricultural use of the site.
Ground Water. The selected remedy will use the following technologies and controls to
address ground water contamination in the three aquifers under the site:
.
.
Approximately 526 million gallons 01 ground water and light (floating) non-
aqueous phase liquids (LNAPL) from the surficial aquifer will be recovered in a
recovery system, such as subsurface drain trenches and recovery wells. A two-
phase (ex-situ and in-situ) biological water treatment process will then remove
LNAPL in an oil/water separator. The LNAPL will be reclaimed by shipping it to
an off-site recycling facility. The remaining water will be treated in a two-stage,
faxed-film bioreactor, mixed with nutrients and an oxygenating chemical, then
reinjected into the aquifer to stimulate bacterial growth to promote further
breakdown of contamination within the shallow aquifer.
2
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.
Small amounts of dense non-aqueous phase liquids (DNAPL) and ground water
will also be collected from existing monitoring wells in the Denver aquifer, treated
in the oil/water separator, and sent to an off-site recycling facility.
Ground water in all three aquifers under the site will be periodically monitored for
thirty years using approximately 10 to 15 wells to assess ground water quality
and migration of contaminants.
.
.
Additional monitoring wells will be drilled in the Arapahoe aquifer to further test
the aquifer and to collect and analyze additional ground water samples to
provide additional information about ground water contamination in this aquifer,
if any.
Institutional controls, such as deed restrictions, will be placed on the property to
control access to water in the surficial and Denver aquifers. Federal and State
ground water standards identified as applicable or relevant and appropriate
requirements (ARARs) are not expected to be met in the Denver aquifer. These
ARARs are waived due to technical impracticability.
.
Buildinqs. Vessels. and Drums. The selected remedy will address contamination in
buildings, vessels, and drums as follows: .
.
Buildings will be demolished and building debris will be decontaminated and
temporarily stockpiled on-site.
Approximately 225 tons of scrap metal will be decontaminated and transported
to an off-site reclamation facility.
.
.
Vessel and drum contents, including an estimated 42,000 gallons of organics
and sludges, will be pumped or excavated, stored temporarily on-site, and then
transported, in drums, to an off-site reclamation facility.
Approximately 9,500 gallons of contaminated water in building sumps or
basements will be pumped, stabilized, drummed and transported to an off-site,
permitted hazardous waste landfill.
.
.
An estimated 850 cubic yards of building debris and 205 cubic yards of
asbestos-containing materials will be disposed in an off-site, permitted landfill.
DECLARATION OF STATUTORY DETERMINATIONS
The selected remedy is protective 01 human health and the environment, complies with
Federal and State requirements that are legally applicable or relevant and appropriate to
the remedial action (or justifies a waiver of any Federal and state ARARs which will not
be met) 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 remedy will result in
hazardous substances remaining on-site above health-based levels, a review of this
remedy will be conducted no less often than each five years after commencement of the
remedial action to ensure that the remedy continues to provide adequate protection 01
human health and the environment.
3
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SIGNATURES
Jac~ . McGraw
U.S nvironmentaJ Protection Agency
Act Regional Administrator, Region VIII
/f'()rM~ :24-) JCj9,-
Date
4
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DECISION SUMMARY
for
RECORD OF DECISION
BRODERICK WOOD PRODUCTS
ADAMS COUNTY, COLORADO
OPERABLE UNIT 2 - FINAL SITE REMEDY
MARCH 1992
".
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TABLE OF CONTENTS
Page
1
5
7
8
9
14
29
42
48
62
69
I. SITE NAME, LOCATION AND DESCRIPTION
II. SITE HISTORY AND ENFORCEMENT ACTIVmES
III. HIGHUGHTS OF COMMUNITY PARTICIPATION
IV. SCOPE AND ROLE OF OPERABLE UNIT
V. SITE CHARACTERISTICS
VI. SUMMARY OF RISKS
VII. DESCRIPTION OF ALTERNATIVES
VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
IX. SELECTED REMEDY
X. STATUTORY DETERMINATIONS
XI. REFERENCES
Ust of Figures
Figure 1 2
Figure 2 3
Figure 3 4
Figure 4 15
Ust of Tables
Table 1A 12
Table 1 B 13
Table 2 21
Table 3 22
Table 4 23
Table 5 27
Table 6 30
Table 7 32
Table 8 38
. Table 9 43
Table 1 0 53
Table 11 58
Table 12 59
Table 13 61
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DECISION SUMMARY
for
RECORD OF DECISION
BRODERICK WOOD PRODUCTS
ADAMS COUNTY, COLORADO
OPERABLE UNIT 2 - FINAL SITE REMEDY
MARCH 1992
I. SITE NAME, LOCATION AND DESCRIP'!I0N
The Broderick Wood Products (BWP or Broderick) Superfund site is located at 5800 Galapago
Street in unincorporated Adams County near Denver, Colorado (Figure 1). The City and
County of Denver corporate boundary is about 3,000 feet south of the site, and Interstate
Highway 25 at 58th Avenue is about one-half mile east of the site. The triangular-shaped BWP
property encompasses approximately 64 acres and is situated in a primarily industrial area. It
is bounded c;m the southwest by a right of way of the Colorado and Southern Railroad, on the
southeast by a right of way of the Denver and Rio Grande Western Railroad, and on the north
by Fisher Ditch. Also southeast of BWP is the Koppers Company, an active wood treating
operation. The 1990 census for the three zip codes nearest the site (80211, 16, and 21, a
radius of approximately three miles) indicated a population of 106,928 in the area surrounding
the site.
The major site features (Figure 2) include two unlined surface impoundments (main and
secondary) and a total of 23 structures. The structures include several storage buildings, the
main office, a change room, a water pump house, two wood fabrication shelters, the treatment
and boiler building, and a shop building. Underground structures at the site include the
treatment building basement and two cylinder basements. In addition, there are 16 vessels
including storage tanks, an air cylinder, and a pressure cylinder on the site. The capacities 01
these vessels range from 2,400 to 50,000 gallons. Approximately 70 drums of a variety 01
chemicals, oils, and asbestos continue to be stored in the process area and an additional 65
drums of oil from sludge are stored in the impoundment area of the site.
The BWP site is located on an elevated alluvial terrace about one-half mile south of Clear
Creek. The site is not within the Clear Creek 100-year floodplain. The surface of the site is
relatively flat but dips gently to the northeast. Surface elevations range from 5,206 feet in the
northeastern corner of the site to 5,227 feet in the southern corner (EPA 1988). There is little
surface run-on, or run-off at the site because of existing topographic restraints and man-made
barriers, such as ditches or railroad cuts or embankments along site boundaries.
Ground water is present in a series 01 three water-bearing geologic units beneath the site.
Surficial eolian deposits, Slocum Alluvium and the weathered Denver Formation comprise the
surficial aquifer. These surficial deposits range in thickness from 1 B to 35 feet. The
unweathered Denver Formation (Denver aquifer), composed of claystones with interbedded
sandstone lenses, underlies the surficial aquifer, constitutes the bedrock at the site, and is
approximately. 150 !eet thick. The upper Arapahoe Formation (Arapahoe aquifer), composed of
interbedded sandstone, siltstone and clay shale, underlies the Denver aquifer, and occurs in
thicknesses of 500 to 600 feet (see Figure 3). The upper two units are recharged by
subsurface inflow and infiltration of surface water. The ground water flow in the surficial and
Denver aquifers is generally towards the north-northeast. The ground water flow in the
Arapahoe aquifer is generally more to the north and recharge is from outcrops approximately
fifteen miles south and west of the site. Some residences north of the site use ground water
wells for irrigation purposes. However, all of these residences are currently connected to a
\brodrick\0u2r0d7\011592
1
100'J1t recycled
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..$'....
.
SITE L.OCATION
I
b DENVER
POOR QUAL\1Y
OR1G\NAL
COLORADO
I
o.
I
3000
BRODERICK WOOD PRODUCTI
~ f
DOC - 2COO
t:SW'HIC SCAL£ ," = rxx:J
GENERAL SITE LOCATION MAP
Figure 1
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1 - IMPOUNDMENT AREA
2 -,PROCESS ~ DRIPTRACK ARE~
3 - ENGINE HOUSE AREA .
4 - STORAGE AREA
5 - LOV USE AREA
Figure 2
Site Plan
, I
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5150
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;."i':';,;".:' '.': ~ ,~',!"':.' ~..~ '.1' ,"J, ".'~!" ,c;t.!,";;i"...t':;,", " ' '\ 1 BWP 51! Flsh.r
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' , "'-:':':',:,:,:,:,:,;."",.,.,.' , , , , , ", -",,"
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NW
Denver
formation
Cia, 810n.' Shal.
aho8
Formation
APPROXIMATE SCALf
Horbontoll "': 300'
Vortlcal' ,"= 40"
Based on Fig, 6-7
Phase III RI, 1990
Schematic Geological CrOBS Sec tlon
of the Broderick Wood Products Site
Figure 3
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municipal water supply system for household use.
Access to the site is presently restricted by a locked, six-foot chain-link security fence topped
with barbed wire and posted with warning signs. The main entrance gate is located at the
southern tip of the site. The main and secondary impoundments are surrounded by a wooden-
slat snow fence approximately three-feet high. The treatment plant building is also surrounded
by a six-foot chain-link fence posted with warning signs.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
Operations History
The BWP Company operated a wood treating facility at this location to treat power poles, fence
posts, railroad ties, and other wood products from 1947 to 1981. Creosote was used as a
wood treating chemical throughout the life of the facility and was mixed with a carrier oil (fuel
oil) for application. Pentachlorophenol (PCP), which was dissolved in a carrier oil, was used on
a limited basis prior to 1953 and regularly between 1953 and 1980.
During the operational life of the facility, process waste from the plant was disposed of on the
site, with much of it going to the impoundments located in the northwest corner of the site. The
waste was conveyed to the impoundments through a ten-inch diameter clay, bell-. and spigot
pipe. Release of contaminants from the impoundments has occurred from leaching through
the underlying soils to ground water as well as volatilization and fugitive dust emissions from
the impoundment surface.
The main impoundment is reported to have been constructed in 1946 by filling in the ends of a
railroad cut. Historical aerial photographs indicate that the main impoundment extended much
closer to the northern site boundary during the early years. In 1956, a secondary
impoundment was constructed west of the main impoundment for additional evaporation
capacity and as an overflow structure for the main impoundment. In 1962, the main and
secondary impoundments caught fire and burned for several hours.
In November, 1981, BWP ceased operations as a wood treater, citing market conditions.
Seven months later, in June 1982, BWP's assets were liquidated into a trust-operated
partnership known as the Broderick Investment Company (BIC), a Colorado limited partnership.
The trustees of the partnership were the First National Bank (now the First Interstate Bank of
Denver) and the Colorado National Bank of Denver. Shortly thereafter, the BWP Company was
officially dissolved, making BIC the successor to BWP Company's business interest.
CERCLA Enforcement History
. The. recent history of the site has included numerous activities and investigations of
contamination on and off the site. Most of these activities have been in response to or in
coordination with regulatory and legal actions by the U.S. Environmental Protection Agency
(EPA) and the Colorado Department of Health (CDH). A detailed history of enforcement
activities was provided in the Summary Document (January 1991) prepared for EPA and placed
in the Administrative Record. Major enforcement activities prior to June 1988 included EPA
investigations under both the Resource Conservation and Recovery Act (RCRA) and the
Comprehensive Environmental Response, Compensation, and Uability Act of 1980 (CERCLA) ,
as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA), which
lead to placement of the BWP site on the National Priorities Ust (NPL) in September 1984.
Remedial Investigation/Feasibility Study (RI/F"S) activities began in 1985 and have been
conducted in three phases. In late 1985, EPA and BIC reached agreement on the terms of a
Partial Consent Decree (PC D) under which the defendants agreed to pay $100,000 for the
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alleged violations of RCRA interim status regulations. The PCD also established a framework
for the defendants to conduct a CERCLA-type RifFS, with a corresponding stay of discovery
and litigation pending completion of the RifFS and selection 01 remedy. The decree covers
conduct of the Phase III RifFS as well as the Phase II RifFS studies. Phases I and II were
sufficient to allow selection of interim actions to remediate the site.
Interim Remedial. Actions
In June 1988, EPA issued a Record of Decision (ROD) for the BWP site based on the Phase I
and II RifFS efforts. This 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. The major components 01 the June 1988 ROD were restriction of site access,
treatment of water in the impoundments and buildings, excavation and incineration of sludges,
and stockpiling or on-site incineration of visibly contaminated soils in the impoundments
(referred to as Operable Unit 1 or OU 1). The ROD also specified that cleanup actions for
buildings, vessels and .surface soils, and monitoring of the effectiveness of the .remedies, would
be determined as a part of Phase III studies for Operable Unit 2 (or OU 2) 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 ground water from the Phase III RifFS activities. EP A had determined that
removal and storage of the sludges would be necessary under any alternative selected. As a
result, EPA requested and BIC agreed in October 1990 to proceed with removal of the sludges
from the two impoundments.
Two temporary lined cells were constructed on the Broderick property in the area of the
secondary impoundment. Sludges from the secondary impoundment were stockpiled
temporarily until the solid sludge storage cell was completed. Approximately 950 cubic yards
of solid sludges have been stored in a single-lined cell with leachate collection in accordance
with 40 CFR, Subpart L - Waste Piles. Approximately 1 ,220 cubic yards of liquid sludges have
been stored in a double-lined cell with leak detection in accordance with 40 CFR, Subpart K -
Surface Impoundments. In addition, a quantity of oil has been collected from the sump of the
solid storage cell and stored in 55-gallon drums. Storage of the sludges is temporary until
implementation of the remedy selected in the OU 1 ROD Amendment. Removal of the sludges
to an off-site recycling facility is the Interim Remedial Action selected in the OU 1 ROD
Amendment. All components of the June 1988 ROD that were not addressed by the ROD
Amendment are being addressed by this ROD.
RemediallnvestigationfFeasibility Study
The Phase III RI was finalized in December 1990. The Phase III RI identified contaminated
ground water, contamination in surface soils, and "hot spots" of contamination at the site
including buildings and vess.els. An Endangerment Assessment was issued in May 1991 and
identified the major pathways for exposure to contamination as ingestion, inhalation, and
dermal contact. Depending on future site use, the populations with the highest potential risk
from exposure to contamination were on-site resident young children, on-site construction
workers, and on-site industrial workers. The Final Feasibility Study, dated June 28, 1991,
identified ten detailed alternatives for cleanup of contaminated soils and sediments, shallow
ground water, and buildings and building contents.
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III. HIGHUGHTS OF COMMUNITY PARTICIPATION
Community interest at the Broderick Wood Products 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. Community interest and concern increased somewhat in 1989
after selection of on-site incineration as the remedial technology to treat contaminated sludges
at the site. Concerns about the RD/RA process again decreased with announcement 01 the
revised plan to treat sludges via reclamation and off-site incineration. There has been some
media coverage of the site, primarily corresponding to key points in the Superfund process or
following meetings with the public or with local officials. Further detail of community
involvement at the BWP site is presented in the Responsiveness Summary 01 this ROD. The
public participation requirements as specified in CERCLA Section 113 (k)(2)(B)(i-v) and Section
117 have been met as described below.
In June 1988, EPA issued the Record of Decision for OU 1. A second volume 01 the ROD, the
community involvement and responsiveness summary, summarized community involvement
activities conducted for the site and provided responses to official public comments on the
Proposed Plan for au 1. Responses addressed both the 41 oral and written comments, as
well as BIC's comments submitted during and atter the public comment period.
Between June 27, 1989 and June 28, 1989, EPA met with six representatives of the community
to identify any new concerns they might have about the RD/RA process. Additionally, on July
11, 1989, EPA held two separate briefings for state and local officials, businessmen, residents,
and concerned community groups to describe the RD/RA process and identify and address
any community concerns.
Major concerns regarding the remedial action expressed at these meetings included concern
about the safety and efficiency of on-site incineration, concern about possible community
opposition to on-site incineration, and concern about potential traffic and road impacts from
the remediation. Other concerns expressed included concerns about potential surface and
ground water contamination off the Broderick property from the site (including the potential for
contamination to migrate into private wells), and continuing site access issues. These
meetings produced requests for more detailed information about the specific incineration
process to be employed at the site, about ongoing RifFS work to characterize and remediate
the entire site, and about other Superfund sites near Broderick.
On May 24, 1990, BIC submitted a petition to the U.S. EPA Regional Administrator for Region
VIII that provided additional information about the site and requested a change in the remedy
from the June 1988 ROD. From May 1990 through December 1990, EPA reviewed this
information and additional information gained in ongoing site investigations, in order to
evaluate whether the decision to employ on-site incineration continued to be the most
appropriate remedial alternative to treat sludges in the surface impoundments. In late 1990,
following a review of all applicable information, EPA reached a decision to prepare a new
Proposed Plan for the treatment of impoundment sludges.
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.
The final Phase III FS Report was completed on June 28, 1991 and an Addendum to the FS
was completed on July 11, 1991. Based on these documents, EPA identified its Proposed Plan
for au 2 and described it in a fact sheet mailed to the public on September 19, 1991. This fact
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sheet was sent to 232 persons on the mailing list. This fact sheet described the Proposed Plan
for treatment of soils, sediments, ground water, buildings, and building contents. The fact
sheet also described opportunities for public involvement including the public meeting and the
public comment period for the OU 2 Proposed Plan.
On September 17, 1991 and September 18, 1991 respectively, public notices were placed in
two Commerce City weeklies, the Beacon and the Express, announcing a public comment
period from September 23, 1991 to October 23, 1 991 for comments on the Proposed Plan for
OU 2. Also, on September 22, 1991, EPA placed a quarter-page public notice in the RocKy
Mountain News with the same announcement. The notices also announced the October 9,
1991 public meeting, and informed the public of the availability of all pertinent information at the
two information repositories:
Adams County Public Ubrary
Commerce City Branch
7185 Monaco Street
Commerce City, CO 80022
(303) 287-0063
Mon, Th: 1 :00 pm to 8:00 pm
Tu, W, F, Sat: 10:00 am to 5:00 pm
The public meeting to discuss the OU 2 Proposed Plan was held on October 9, 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 25 community members, only two oral comments were received.
EPA Superfund Record Center
999 1 8th Street
Denver, CO 80202
(303) 293-1 807
Hours: Mon - Fri: 8:30 am to 4:30 pm
Between September 23, 1991 and November 22, 1991, EPA met with concerned citizens,
representatives of several community groups, and local officials to identify any questions they
might have about the OU 2 Proposed Plan. Additionally, on November 12, 1991, EPA held a
briefing for state and local officials and Congressional staff members to describe the Proposed
Plans for the Broderick Superfund site, together with those for three other Superfund Sites in
northern Denver and southern Adams County.
During the public comment period for the OU 2 Proposed Plan (which was extended to
November 22, 1991), EPA received written comments from attorneys for BIC, attorneys for
Brannan Sand and Gravel Co., the Fisher Ditch/United Water Co., and the U.S. Fish and Wildlife
Service. Responses to official public comments, both verbal and written, are presented in the
Responsiveness Summary attached to this ROD.
IV. SCOPE AND ROLE OF OPERABLE UNIT
The problems at the Broderick site are complex. As a result, EPA has organized the work into
the following two operable units (OUs):
. au 1: interim actions, and
. OU 2: final remedy.
The June 1988 ROD for Operable Unit 1 (OU 1) and its subsequent Amendment issued on
September 24, 1991, selected specific interim actions to be taken as part of the initial cleanup.
The interim actions were selected to meet the objectives 01 addressing the principal threats to
human health and the environment. These threats were associated with the ease of site
access and the potential for direct contact with the impoundment wastes. These wastes,
consisting of sludges remaining from disposal of wood-treating chemicals into the
impoundments, were the major source of contamination at the site. These sludges therefore
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posed the principal threat due to the potential for inhalation and dermal contact with chemical
wastes from the creosote and pentachlorophenol wood treating processes. By placing these
sludges in lined and covered storage cells, this threat has been temporarily isolated from the
soils and ground water. Removing and treating the sludge will eliminate this primary source.
Remedial design for the removal and transport of the sludge is proceeding.
Site access has been restricted through construction of a fence around the entire BWP site.
The June 1988 ROD deferred decision on a remedy for the buildings and vessels, and surface
soils to this final action.
OU 2, authorized by this ROD, addresses the remaining areas of the site. The Phase III RifFS
was initiated to fill data gaps from previous site investigations that prevented selection of a final
site remedy. Specifically, EPA identified additional work that was necessary to remediate the
site, particularly with regard to ground water and the principal threats of soils/sediments,
NAPLs and the structures and their contents. Site hazards addressed as part of OU 2 include:
. Contaminated soils
- organics-contaminated soils
- metals-contaminated soils
. Organics-contaminated Fisher Ditch sediments
. Contaminated ground water
- surficial/weathered Denver aquifer
- Denver aquifer
- Arapahoe aquifer
. Buildings, vessels, and drums.
The Phase III RI/FS effort included sampling of existing ground water wells on the site and on
the property north of the site, as well as soil sampling and bench scale bioremediation studies
of the soils. The Phase III RI report was completed on December 20, 1990 and the FS report
was completed on June 28, 1991 and subsequently revised.
V. SITE CHARACTERISTICS
Site Geology and Hydrology
The BWP site is situated on an elevated Quaternary alluvial terrace about one-half mile south of
Clear Creek. The site is located above the Clear Creek 1 CO-year floodplain. The surface of the
site is relatively flat but dips gently to the northeast Surface elevations range from 5,206 feet in
the northeastern corner of the site to 5,227 feet in the southern corner (EPA, 1988);
There is little surface run-on or run-off at the site because of existing topographic restraints and
man-made barriers, such as ditches or railroad cuts or embankments along site boundaries.
Fisher Ditch runs west to east along the northern boundary of the BWP site. The Fisher Ditch
Extension, a buried water pipeline, crosses the eastern portion of the property diagonally from
northwest to southeast. The United Water Company's Rocky Mountain Ditch, also a buried
culvert, crosses the extreme southern tip of the property. . .
Ground water is present in a series of three water-bearing geologic units beneath the site.
These three partially-saturated or saturated geologic units underlying the site are shown in
Figure 3. In descending order they are:
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1. Alluvial deposits and weathered Denver Formation bedrock (surficial aquifer);
2. The unweathered Denver Formation bedrock (Denver aquifer); and
3. The upper Arapahoe Formation (Arapahoe aquifer).
Surficial/Weathered Denver Aauifer. Ground water investigations revealed that the
surficial/weathered Denver formations act as a single unconfined aquifer (referred to hereafter
as the "surficial aquifer"). The surficial aquifer is a shallow, unconfined system composed of
Pleistocene eolian sands and silts, sands and gravels of the Slocum terrace alluvium, and
weathered Denver Formation claystone. The contact between the weathered and unweathered
bedrock lies at depths ranging from 15 to 30 feet across the site. Flow in the surficial aquifer is
to the north-northeast. The aquifer is recharged by surface infiltration, upgradient ground
water, and Fisher Ditch. A number of shallow domestic and irrigation wells are located in this
aquifer in the vicinity of the site. From recent well user surveys, the current use of these wells is
apparently limited to non-domestic purposes.
Denver Aauifer. The underlying unweathered Denver Formation aquifer is confined and also
has a north-northeast flow direction. The upper seven fo 15 feet of the Denver Formation are
weathered bedrock with vertical fracturing, which decreases with depth. The unweathered
Denver Formation bedrock constitutes the confined Denver aquifer and is made up of
claystone, shale and sandstone lenses. The unweathered bedrock is consolidated and only
locally fractured. The weathered portion and the unweathered portion of the Denver Formation
are treated as two separate hydrologic units with the upper, weathered portion considered as
part of the surficial aquifer (described above). The Denver aquifer under the Broderick property
appears to contain lenses of permeable sandstone interbedded in less permeable claystone
(see Figure 3). These lenses of sandstone generally do not have large areal extents, thereby
providing only limited water supplies and confining contaminants to relatively small areas.
Aecharge occurs primarily by downward migration of water from the overlying surficial aquifer
through vertical fractures. Some residences north of the site use Denver aquifer ground water
wells for commercial and/or irrigation purposes. .
Arapahoe Aauifer. The upper Arapahoe aquifer is also a confined system that is composed
predominantly of loosely consolidated sands with some interbedded claystone and shale. This
formation forms the major bedrock aquifer in the Denver Basin and lies at a depth of
approximately 200 feet below the surface. The regional dip of bedrock is gently toward the
north-northeast. The ground water flow in the Arapahoe aquifer is generally to the north. The
Arapahoe aquifer is confined by the overlying Denver aquifer. Recharge of the Arapahoe
occurs at the outcrop areas around the edges of the Denver basin, approximately 15 to 20
miles south and west of the site. Several private wells in the immediate area tap the Arapahoe
aquifer.
Nature and Extent of Contamination
The scope of the AI was directed at studies for all media that may have been contaminated.
Soils, Fisher Ditch surface water and sediments, ground water, buildings, and vessel contents
were investigated as potential pathways at the site. Some of these media were apparently
affected by the migration of contaminants from former industrial activities at the impoundment
area, process and drip track area, and the former railroad engine house/shop area (see Figure
2). Soils at the BWP site were found to have been affected by wood-treating chemicals (PCP I
creosote), heavy metals (arsenic, lead, cadmium, zinc), and other wastes (fuel oil and grease).
Fisher Ditch sediments were impacted by creosote-type polynuclear aromatic hydrocarbons
(PAHs). Ground water was found to have been affected by wood-treating chemicals
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(pentachlorophenol, creosote, isopropyl ether) and volatile organic compounds (primarily fuel
oil). This contamination is summarized below.
The estimated volumes of contaminated materials are given in the June 28, 1991 FS. These
contaminated volumes above the NCP-required goal of 10-6 include: .160,100 cubic yards of
soils; 119 cubic yards of Fisher Ditch sediments; 600 cubic yards of metals-contaminated soils;
528 million gallons of ground water; and 42,000 gallons of contents from buildings, vessels,
and drums on the Broderick property.
The primary contaminants of interest at the site are polynuclear aromatic hydrocarbons (PAHs),
acid extractable compounds (principally PCP and other chlorinated phenolic compounds),
dioxins and furans, volatile organic compounds (VOCs) (principally benzene, ethylbenzene,
toluene and xylene), and some toxic metals (principally arsenic, cadmium, lead, and zinc).
Soil Contamination. Soil contamination at the site is found primarily in the impoundment and
process areas to a depth of approximately 4 feet and consists primarily of PAHs and PCP.
Metals contamination of surficial soils was noted in the former railroad shop area. Some PCP
contamination was also identified along the eastern site boundary near the adjacent Koppers
wood treating facility.
Some PAHs were detected at concentrations as high as 14,000 ppm in the surface soils in the
impoundment area (see Table 1 A). Concentrations of PCP were observed as high as 8,600
ppm in the surface soils in the impoundment area and as high as 3,300 ppm in the surface
soils in the process area. Benzene was detected at a maximum of 0.33 ppm in the soil, while
other VOCs were found at maximum concentrations of 21.4 ppm for xylenes, 4.7 ppm for
toluene, and 4.3 ppm for ethylbenzene. The greatest concentrations of dioxins/furans were
found in surface soils in the impoundment area, with TCDD equivalency values as high as 56
ppb. TCDD-equivalency means that the concentrations of the less potent isomers were
multiplied by certain equivalency factors to express their relative strength compared to 2,3,7,8
TCDD, the most toxic form of dioxin (see Table A-1 in Exhibit A). .
Ground Water Contamination. Wood treating chemicals (creosote and PCP) have been
detected in the surficial and Denver aquifers (see Table 1B). Ught non-aqueous phase liquid
(LNAPL), often referred to as "floating product" or "fIoatersA, is present as a sheen in most of the
wells in. the process and impoundment areas but is not believed to be off the Broderick
property. Dense non-aqueous phase liquid (DNAPL), often referred to as usinking product" or
"sinkers", was detected in three wells on the Broderick property during the Phase II
investigation.
The PCP-contaminant plume from the impoundment area has migrated off the Broderick
property as far as the BFI-12 well. This well is approximately five hundred feet north of the BWP
site, along Huron Street.
PCP and isopropyl ether (IPE) contamination have been found in the ground. water along the
eastern site boundary. This contamination is attributed to a plume migrating onto the BWP site
from an adjacent wood-treating facility. This conclusion is supported by 1) the lack of use of
IPE at BWP, 2) IPE was an important part of process operations at the adjacent facility, and 3)
PCP has not been detected in any BWP wells between the eastern boundary and the process
area.
Surface Water and Sediment Contamination. Surface water investigations revealed that
contaminants do not leave the site through surface water pathways. This is because the
permeable nature of the surface soil allows most of the surface water to infiltrate, and wood
treating compounds tend to adhere to surface and subsurface soil particles during infiltration.
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TABLE 1A
BRODERICK WOOD PRODUCTS SITE
CHEMICALS OF INTEREST - SOilS
Surface Soils Subsurface Soils
Minimum Maximum Mean ARAR* Minimum Maximum Mean ARAR.
Chemical-of-Interest (mg/Kg) (mgIKg) (mgIKg) (mg/Kg) (mg/Kg) (mg/Kg)
carbazole 0.05 21.4 2.93 -- 0.0500 77.3000 9.6Q -- I
naphthalene 0.0555 11000 367.37 1.5 (1) 0.0510 2500.0000 141.74 1.5 (1 )
acenaphthylene 0.05 500 34.70 -- 0.0500 208.0000 13.77 --
acenaphthene 0.04 4100 211.23 -- 0.0510 290.0000 30.79 --
lIuorene 0.01 4300 174.01 -- 0.0100 230.0000 27.97 --
phenanthrene 0.025 14000 553.59 1.5 (1) 0.0250 680.0000 74.68 1.5 (1)
anthracene 0.025 2500 128.12 -- 0.0250 150.0000 16.02 --
lIuoranthene 0.01 11000 458.27 8.2 (1) 0.0100 400.0000 41.58 8.2 (1)
pyrene 0.0113 7800 355.59 1.5 (1) 0.0102 306.0000 27.81 1.5 (1)
benzo (a) anthracene 0.00113 1200 61.13 -- 0.0010 72.0000 6.98 --
chrysene 0.0085 2200 1 04.33 8.2 (1) 0.0077 99.5000 10.83 8.2 (1)
benzo (b) fluoranthene 0.00113 200 27.55 -- 0.0010 11.1000 2.17 --
benzo (k) fluoranthene 0.00113 500 35.37 -- 0.0010 100.0000 4.39 --
benzo (a) pyrene 0.00113 500 35.90 8.2 (1) 0.0010 100.0000 4.52 8.2 (1)
dibenzo (a.h) anthracene 0.001695 500 41.84 8.2 (1) 0.0015 100.0000 6.48 8.2 (1)
benzo (g.h.i) perylene 0.002825 500 39.38 -- 0.0025 100.0000 5.63 --
indeno (1,2.3-cd) pyrena 0.002825 500 25.29 -- 0.0025 100.0000 4.54 --
benzene 0.0005 0.33 0.04 36 (1) 0.0005 0.6250 0.04 36 (1)
toluene 0.0005 4.7 0.60 28 (1) 0.0005 25.0000 1.20 28 (1)
ethylbenzene 0.0005 4.28 0.59 -- 0.0005 28.0000 1.33 --
xylenes 0.0015 21.4 2.65 28 (1) 0.0015 160.0000 7.51 28 (1)
methylene chloride 0.015 1.6 0.43 -- 0.0095 0.9500 0.13 --
trichloroethylene 0.0025 0.3125 0.17 -- 0.0025 0.1250 0.02 --
tetrachloroethylene 0.0025 0.3125 0.17 -- 0.0025 0.1 250 0.02 --
phenol 0.08 500 35.57 -- 0.0800 100.0000 4.19 --
2-chlorophenol 0.08 500 35.57 -- 0.0800 100.0000 4.19 --
2-methytphenol 0.08 500 35.57 -- 0.0800 100.0000 4.19 --
4-methylphenol 0.08 500 35.57 -- 0.0800 100.0000 4.19 --
2.4-dimethylphenol 0.08 500 35.57 -- 0.0800 100.0000 4.16 --
2.4-dichlorophenol 0.08 500 35.57 -- 0.0800 100.0000 4.19 --
2.4.6-trichlorophenol 0.08 1500 68.90 -- 0.0800 100.0000 4.56 --
2.4.5-trichlorophenOI 0.08 2400 165.88 -- 0.0800 95.0000 8.55 --
pentachlorophenol 0.11 8600 653.25 7.4 (1) 0.0540 380.0000 28.34 7.4 (1)
2,3.7 ,8-tetrachlorodibanzo-p-d ioxin 0.00004 0.00155 0.0003 -- 0.0000 0.0007 0.0002 --
pentachlorOdibenzo-p-d ioxin 0.00001 0.0079 0.0016 -- 0.0000 0.0010 0.0003 --
hexachlorOdibenzo-p-dioxin 0.00015 0.31 0.0635 -- 0.0002 0.0269 0.0074 --
heptachlorOdibenzo-p-d loxin 0.000015 5.65 1.3209 -- 0.0047 0.9596 0.2540 --
octachlorOdibenzo-p-dioxin 0.00057 42.7 8.1094 -- 0.0637 3.0066 0.8366 --
tetrachlorOd ibenzofu ran 0.000005 0.0012 0.0005 -- 0.0000 0.0009 0.0004 --
pentachlorOdibenzofuran 0.00001 0.0623 0.0063 -- 0.0000 0.0009 0.0004 --
hexachlorOdibenzofuran 0.00001 0.83 0.1242 -- 0.0001 0.0018 0.0008 --
heptachlorOdibenzofuran 0.00003 1.4 0.3118 -- 0.0006 0.0532 0.0169 --
octachlorodibenzofuran 0.000015 2.5 0.5323 -- 0.0015 0.1380 0.0405 --
arsenic 0.7 187 29.68 5 (2) 0.9200 11.4000 3.76 5 (2) .
cadmium 0.075 193 24.69 1 (2) 0.0750 2.4000 0.23 1 (2)
lead 9.5 7140 838.19 5 (2) 4.1000 208.0000 26.71 5 (2)
zinc 43 10400 2083.74 -- 17.2000 1250.0000 130.52 --
Note:
. Land disposal restriction standard; placement ot wastes triggers standard.
(1) Non-ater total composition (mg/Kg)
!) Non-ater TClP (mg/l)
ARCS\BRODEAICK\T ABLES\ 1 a
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TABLE 1B
BRODERICK WOOD PRODUCTS SITE
CHEMICALS OF INTEREST - GROUND WATER
Surficial Aquifer Denver Aquifer
Minimum Maximum Mean AAAA Minimum Maximum Mean ARAR
Chemlcal-ol-Interest (pg/l) (pg/l) (pg/l) (mg/l) Chemical-of-Interest (pgIL) (pgIL) (pgIL) (mglL)
carbozole 1.00 951.00 92.0113 -- carbazole 1.00 19700.00 1915.7727 --
naphthalene 1.00 24900.00 1653.7483 -- naphthalene 1.00 233000.00 9500.2679 --
acenaphthylene 1.00 3930.00 280.7690 -- acenaphthylene 1.00 41800.00 1639.1843 --
acenaphthene 1.00 7600.00 372.7000 -- acenaphthene 1.00 102000.00 3713.4464 --
fluorene 0.10 8180.00 544.7378 -- fluorene 0.10 54100.00 2042.7250 --
phenanthrene 0.25 17500.00 1229.9015 -- phenanthrene 0.25 125000.00 4759.5446 --
anthracene 0.25 4160.00 248.8940 -- anthracene 0.25 24000.00 923.2304 --
fluoranlhene 0.10 7580.00 460.4488 -- fluoranthene 0.10 34500.00 1312.4536 --
pyrene 0.10 10800.00 643.6596 -- pyrene 0.10 . 99600.00 3726.6250 --
benlo (g,h,i) perylene 0.03 917.00 64.3343 -- benzo (g,h,i) perylene 0.03 4310.00 177 .4555 --
methylene chloride 2.50 25.00 7.0862 -- methylene chloride 1.00 25.00 5.2679 --
trichloroethylene 0.50 66.00 6.6207 0.005 (1,2) phenol 2.50. 20000.00 1051.9613 --
tetrachloroethylene 0.50 5.00 1.7586 0.005 (2) 2-chlorophenol 2.00 500.00 24.2679 --
phenol 2.50 2500.00 219.0862 -- 2-methylphenol 2.50 9700.00 784.5370 --
2-chlorophenol 2.50 2500.00 162.1552 -- 4-methylphenol 2.50 19000.00 1470.0000 --
2-methylphenol 2.50 2500.00 307.2321 -- 2,4-dlmethylphenol 2.00 4400.00 378.1607 --
4-methylphenol 1.00 2600.00 286.6897 -- 2,4-dichlorophenol 2.50 500.00 31.3393 0.21 (1)
2.4-dimethylphenol 2.00 4300.00 527.7069 -- 2,4,5-trlchlorophenol 2.50 2500.00 122.9464 --
2,4-dlchlorophenol 2.00 2500.00 162.9138 0.21 (1) pentachlorophenol 25.00 13000.00 1125.5900 0.001 (3)
2.4.5-trichlorophenol 2.00 2500.00 171.2069 -- 2,3,7,8 TCDD -- -- -- 1.0x1 0-8 pg/L (4
pentachlorophenol 8.00 48000.00 7862.0000 0.001 (3) pentachorodlbenlo-p-dloxln 0.00 0.00 0.0000 --
2.3,7,8 TCDD -- -- -- 1.0x10-8 pg/l (4 hexachlorodibenzo-p-dloxin 0.00 0.00 0.0000 --
pentachlorodlbenzo-p-dloxln 0.00 0.51 0.2551 -- heptachlorodibnezo-p-dioxin 0.00 0.00 0.0000 --
hexachlorodibenzo-p-dioxln 0.00 0.17 0.0840 -- oclachlorodibenlo-p-dioxin 0.00 0.00 0.0000 --
heptachlorodlbenzo-p-dloxln 0.11 0.19 0.1460 -- tetrachlorodlbenzoluran 0.00 0.00 0.0000 --
octachlorodlbenzo-p-dioxin 0.65 0.86 0.7550 -- pentachlorodibenzofuran 0.00 0.00 0.0000 --
tetrachlorodlbenzofuran 0.52 0.52 0.5200 -- hexachlorodlbenzoluran 0.00 0.00 0.0000 --
pentachlorodlbenzoluran 0.00 0.29 0.1451 -- heptachlorodibenzofuran 0.00 0.00 0.0000 --
hexachlorodlbenzofuran 0.01 0.29 0.1460 -- octachlorodlbenzofuran 0.00 0.00 0.0000 --
heptachlorodlbenzofuran 0.57 0.57 0.5650 --
octachlorodlbenzoluran 0.31 0.31 0.3050 --
Note:
(1) Colorado Basic Standards lor Ground Water
(2) SDWA Maximum ContamInant level (MCL)
(3) Proposed MCL
(4) Proposed MCl: see Exhibit A for explanation of equivalency
AACS\~RODERICK\T ABLES\ 1 B
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Inv~stigations of surface water in Fisher Ditch (which is used primarily for industrial and
agncultural purposes) showed that the water flow in Fisher Ditch recharges the surficial aquifer
along most of the northern boundary of the BWP property. Therefore, Fisher Ditch is not being
impacted by contaminated ground water from the BWP site.
With the exception of one sample, contaminants were not detected in Fisher Ditch water. In
this one sample, located at the eastern edge of the BWP site (sample # 89-45W), PAHs were
detected at a concentration of 6.65 ppb (parts per billion).
Elevated concentrations of PAHs and oil and grease were noted in the Fisher Ditch berm and
sediments. The source for the PAHs is uncertain since these PAH contaminants were also
detected in samples slightly upstream of the BWP site.
Surface water in the seeps due north of the impoundments and immediately north of Fisher
Ditch "(see Rgure 2) were contaminated with very low levels of PCP. The source may be the
contaminant plume in the surficial aquifer, which has moved off the BWP property and extends
slightly north of Fisher Ditch. Ught-phase PAHs were also detected in this surface water, in the
ditch berm, and in some of the sediments in the bottom of the ditch.
RI Conclusions
The final Phase III RI Report was completed on December 20, 1990. The report concluded that
the highest concentrations of soils contaminated with wood-treating chemicals (creosote and
PCP) and their by-products (dioxins and furans) occur in the impoundment and process areas
and that only the Fisher Ditch sediment contamination has been found off the BWP site. A
small amount of soil in the eastern portion of the BWP site is contaminated with heavy metals,
apparently from industrial use of the site prior to its use for wood treating. Ground water in the
surficial and Denver aquifers beneath the BWP site is contaminated with wood-treating
chemicals and their by-products. The contaminated surficial ground water has moved at least
500 feet north of Fisher Ditch, which runs along" the northern boundary of the BWP site. In
addition, at several locations, non-aqueous phase liquids (NAPL) were found floating on the
water table 01 the surficial aquifer or sinking into portions of the Denver aquifer. RI
investigations detected very small amounts of P AH and PCP in one of the four wells in the
Arapahoe aquifer. Approximately 42,000 gallons of wood-treating chemicals, fuel oil,
contaminated water, and Freon were found to exist in tanks, drums, and buildings. Asbestos-
containing building materials were also found in some of the buildings and drums.
VI. SUMMARY OF RISKS
As part of the Phase III RifFS, a committee, comprised of the EPA Broderick team and BIC,
prepared an Endangerment Assessment (EA) for the BWP site in January 1991. This EA was
carried out to characterize, in the absence of remedial action (i.e., the uno-actionu alternative),
the current and potential Mure threats to human health and the environment. Figure 4
provides a glossary of the key risk terms from the EA that are used in this section.
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Figure 4
Key Risk Terms
Cancer Potency Factor (CPF): Also known as cancer slope factors (CSFs) , have been developed by EPA's
Carcinogenic Assessment Group. Slope factors estimate excess lifetime cancer risks associated with exposure to
potentially carcinogenic chemicals. Slope factors are derived from the results of human epidemiological studies
or chronic animal bioassays to which animal-to-human extrapolation and uncertainty factors have been applied.
The slope factor for a given compound is multiplied by the estimated dose to obtain the carcinogenic risk
estimate. The individual risks 1rom each compound in a particular exposure pathway are then summed to obtain
an estimate of the overall carcinogenic risk posed.
Carcinogen: Any substance that can cause or contribute to the production of cancer.
Chronic Exposure: A persistent, recurring, or long-term exposure. Chronic exposure may result in health effects
(such as cancer) that are delayed in onset, occurring long after exposure ceased.
Chronic Hazard Index: The EPA-pre1erred method used to assess the potential human health risk of exposure to
contaminants exhibiting non-carcinogenic effects. The ratio of the actual intake or dose to the RfD (defined below)
1s calculated. If the ratio is less than 1.0, then the exposure represented by the intake or dose is judged unlikely to
produce harmful effects. A cumulative chronic hazard index can also be calculated to evaluate the risks posed by
exposure to more than one chemical by summing the ratios for all the chemicals of Interest that exert a similar
effect on a particular organ of the body, such as the liver. This approach assumes that several exposures less
than the threshold value (RfD) could combine to result in a harmful effect on a particular organ. If the cumulative
chronic hazard Index is greater than 1.0, then there may be concem 10r public health risk.
Exposure: Direct contact with a chemical or environmental medium (such as soil or ground water) containing a
chemical
Exposure Assessment: An assessment of the amounts of chemicals to which individuals are, or could potentially
be, exposed.
Reference Doses (RfDs): Reference doses have been developed by EPA. RfDs indicate the potential for
adverse health effects caused by exposure to contaminants exhibiting noncarcinogenic effects. RfDs are derived
from human epidemiological studies or animal studies to which uncertainty factors have been applied. These
uncertainty factors help ensure that the RIDs will not underestimate adverse noncarcinogenic effects. The RfD for
a given compound is divided into the estimated dose to obtain the hazard quotient (HO). The HOs for each
compound in a particular exposure pathway are then summed to obtain a hazard index (HI), which is the estimate
01 the overall non-carcinogenic risk.
Risk: The nature and probability of occurrence 01 a potentially harmful effect on human health or on the
environment.
Risk Assessment: A study characterizing the potential harmful effects on human health or on the environment
According to the National Research Council's Committee on the institutional Means 10r Assessment of Health Risk,
human health risk assessment includes: description 01 the potential adverse health e1fer.ts based on an evaluation
01 results of epidemiologic, clinical, toxicologic, and environmental research; extrapolation from those results to
predict the types and estimate the extent of health effects in humans under given conditions or exposure;
judgements as to the number and characteristics of persons exposed at various intensities and durations;
summary judgements on the existence and overall magnitude 01 the methods of the public-health program; and
characterization of the uncertainties inherent in the process of estimating risk.
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Contaminants of Interest
The EA began by compiling a list of contaminants from the results of the various sampling
activities that were measured to be above detection limits or above natural background levels.
The quality 01 the data was then evaluated. Chemicals of interest were identified for the
impoundment area, process area, and former railroad shop area. These chemicals were
selected based on concentrations; toxicity; physicaVchemical properties that affect
transport/movement. in air, soil, and water; and prevalence/persistence in these media. The
identified chemicals included the potential contaminants 01 concern for human health and
environmental risks at the site.
Exposure Assessment
Potential migration of contaminants at the Broderick site occurs from both the liquid and solid
phases. Soils comprise the solid component and surface and ground water comprise the
liquid component. The migration pathways for the contaminants from the impoundment area,
process area, and former railroad shop area include:
.
direct contact with contaminants remaining in the soil;
.
leaching from subsurface soils into ground water;
.
migration in ground water or surface water;
.
release to the air through volatilization and fugitive dust emissions; and
.
bioaccumulating in the food chain at the site.
Human intake 01 contaminants in soil and water at the site could occur through three routes of
exposure: ingestion (Le., swallowing), inhalation (i.e., breathing), and direct contact (i.e.,
touching). The EA considered inhalation of on-site air, including volatiles or fugitive dust, as
one exposure pathway. The EA also evaluated the risk associated with ingestion 01, or direct
contact with, contaminants in the surface and subsurface soil and ground water. Potential
human receptors considered in the EA for the three exposure pathways include the following:
Current Land Use Conditions
.
On-site Visitors
Off-site Industrial Workers *
Off-site Residents (Adults, Children and Young Children)
Off-site Workers Maintaining Fisher Ditch
Off-site Users of Fisher Ditch Water
.
.
.
.
Future Land Use Conditions
.
On-site Construction Workers
On-site Industrial Workers *
On-site Residents (Adults, Children and Young Children)
On-site Day Care Children
Off-site Industrial Workers *
Off-site Residents (Adults, Children and Young Children)
Off-site Workers Maintaining Fisher Ditch
Off-site Users of Fisher Ditch Water
.
.
.
.
.
.
. .
16
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*
Children aged 3-15 years, Young Children aged 1-6 years (ages from EPA guidance)
Estimates of current exposures to contaminants in soil and ground water are used to estimate
whether adverse health effects could occur due to existing exposure conditions at the site.
Estimates of Mure exposures are used to evaluate the potential that future adverse health
effects may occur and include a qualitative estimate of the likelihood that such exposure would
actually occur. The contaminant intake equations used for the EA and values chosen for
various intake parameters are in accordance' with the EP A Risk Assessment Guidance for
Superfund (EPN540/1-89/002, 1989). Exposure point concentrations in contaminated media
(air, soil, and water) were estimated using site investigation data in conjunction with
mathematical models. Details of the intake equations, parameters such as length of exposure,
and mathematical models are provided in the EA. Intake assumptions were then combined
with the exposure point concentrations to estimate intakes for each receptor scenario.
As can be seen in the list above, the EA considered both residential and industrial use of the
site as viable potential future uses. In addition, for either of these Mure uses, a construdion
worker scenario was considered.
Toxicity Assessment
The purpose of the toxicity assessment was to weigh available evidence regarding the potential
for chemicals of interest to cause adverse health effects in exposed individuals and to provide,
where possible, an estimate of the relationship between the extent of exposure to a chemical
and the increased likelihood or severity of the adverse effect. The toxicity assessment
considered:
.' types of adverse health effects associated with exposures to chemicals of interest;
. related uncertainties such as the weight of evidence of a particular chemical's
carcinogenicity in humans; and
. the relationship between the magnitude of exposure and the adverse effects.
The toxicity assessment for the BWP site was accomplished in two steps: hazard identification
and dose-response assessment. The first step, hazard identification, is the process of
determining whether exposure to an agent can cause an increase in the incidence of an
adverse health effect. Hazard identification also involves charaderizing the nature and strength
of the evidence of causation. The second step, dose-response evaluation, is the process of
quantitatively evaluating the toxicity information and characterizing the relationship between the
dose of the contaminant administered or received and the incidence of adverse health effects
in the exposed population. From this quantitative dose-response relationship, toxicity values
were derived and used to estimate the incidence of adverse effects that may occur in humans
at different exposure levels.
Qualitative weight-of-evidence classifications illustrate the varying degrees of confidence in the
weight of evidence for carcinogenicity of a given chemical. EPA's weight of evidence
classification provides information which indicates the qualitative level of confidence or
uncertainty in the carcinogenicity data obtained from studies in humans or experimental
animals. The carcinogenic potential of a chemical is classified into one of the following groups,
according to the weight-of-evidence from epidemiological and animal studies:
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Group
Description
A
B
Human Carcinogen.
Probable Human Carcinogen:.
B1
B2
limited evidence of carcinogenicity in humans;
sufficient evidence of carcinogenicity in animals with inadequate or lack
of evidence in humans.
C
Possible Human Carcinogen - limited evidence of carcinogenicity in animals or
lack of human data.
D
Not Classifiable as to Human Carcinogenicity.
Evidence of Noncarcinogenicity for Humans.
E
The summation of the risks associated with all potential carcinogens, which is done for each
evaluated exposure pathway in the EA, may overestimate risk by including probable human
carcinogens (Group B) with known human carcinogens (Class A). This conservative estimate
of the potential carcinogenic risks prevents any potential underestimation. Chemicals in
categories C and D are not considered as carcinogens in the EA.
Contaminants present in the affected media include P AHs, phenolics, dioxins/fUrans, volatile
organics, and metals. These contaminant groups and some individual chemicals are described
briefly in the following paragraphs. For more detailed toxicology information concerning these
chemicals, see Exhibit A or the toxicology profiles for these contaminants presented in the EA.
Polvnuclear Aromatic Hvdrocarbons. Polynuclear aromatic hydrocarbons (PAHs) were
detected in contaminated soils, sediments, and ground water at the site. PAHs are degraded
by photodecomposition or biodegradation in surface soils, surface water, and the atmosphere.
Generally, PAHs are readily metabolized by most plants and animals, and do not tend to
bioaccumulate. In water, PAHs may either evaporate, disperse into the water column, become
incorporated into bottom sediment, become assimilated by aquatic biota, or experience
chemical oxidation and biodegradation.
The EA divided the PAHs into two categories:
. potentially carcinogenic and
.. noncarcinogenic PAHs.
If there was any evidence of potential carcinogenicity in animals, the compound was classified
as a potential carcinogen. The other compounds were classified as noncarcinogens. PAH
absorption following oral and inhalation exposure is inferred from the demonstrated toxicity of
PAHs following these routes of administration. PAHs are also absorbed following dermal
exposure. Acute effects from direct contact with PAHs and related materials are limited
primarily to phototoxicity; the primary effect is dermatitis. PAHs have also been shown to
cause cytotoxicity in rapidly proliferating cells throughout the body, particularly in the
hematopoietic system, lymphoid system, and testes.
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Non-neoplastic lesions are seen in animals exposed to the more potent carcinogenic PAHs but
only after exposure. levels exceed those required to elicit a carcinogenic response.
Carcinogenic PAHs are believed to induce tumors both at the site of application and
systemically. The chemicals of interest at the Broderick site include the following PAHs rated
by EPA as B2 - Probable Human Carcinogens: carbazole, chrysene, benzo(a)anthracene,
benzo(a)pyrene, benzo(b)f1uoranthene, benzo(k)fluoranthene, dibenzo(a,h) anthracene,
indeno(1,2,3-cda)pyrene. The following PAHs are classified as Class D (inadequate evidence
of carcinogenicity) or are not classified by EPA: naphthalene, acenaphthylene, acenaphthene,
anthracene, benzo(g,h,i)perylene, fluoranthene, fluorene, phenanthrene, and pyrene.
Acid Extractable Oraanics. The acid extractable family of phenol compounds have been found
in the soils and ground water in the impoundment and process areas. The primary phenol
present on the site is pentachlorophenol, also known as penta or PCP. PCP is moderately
soluble in water and readily degrades by microbial, chemical and photochemical processes.
PCP has also been shown to bioaccumulate in fish and other organisms. PCP and 2,4,6-
trichlorophenol are classified as B2 - Probable Human Carcinogens. O-cresol (2-methylphenol)
is classified as a C - Possible Human Carcinogen. Class D - Inadequate Evidence of
Carcinogenicity - includes 4-methylphenol and phenol. Other acid extractables are found at the
site that are not rated by EPA, including 2-chlorophenol, 2,4-dichlorophenol, and 2,4,5-
trichlorophenol.
Dioxins and Furans. Isomers of dioxins/furans have been detected in the soil and ground
water at the Broderick site. However, only the heavier isomers of the dioxins/furans, such as
penta, hexa, hepta and octa, were detected. These compounds degrade very slowly by
dechlorination, biodegradation, and photodegradation. The most potent isomer, 2,3,7,8
tetrachloro dibenzodioxin (2.3,7,8 rCDD), has never been found in creosote or PCP
manufactured in the U.S. (EPA, 1991) and was not detected in any medium at the BWP site.
rCDD has be.en classified by EPA as a B2 - Probable Human Carcinogen. Concentrations of
the less potent isomers must be multiplied by certain toxicity equivalency factors to express
their relative risk compared to 2,3,7,8 rCDD. These equivalency factors are found in Exhibit A.
Volatile Oroanic Compounds. Benzene, xylenes, toluene, and ethyl benzene were found in
small quantities in several areas of the site. These compounds, components of most petroleum
hydrocarbon fuels, are less mobile in the ground water than in soil. Migration may be inhibited
by preferential adsorption to the soil matrix as well as by biological degradation of adsorbed
and dissolved residues. Benzene is classified as a Class A carcinogen - Human Carcinogen -
which is readily absorbed through both oral and inhalation routes. The toxic effects of benzene
in humans and other animals include central nervous system effects, hematological effects, and
immune system depression. EPA has classified methylene chloride, trichloroethene (TCE), and
trichloroethylene as B2 - Probable Human Carcinogens. EPA has classified tetrachloroethylene
as a Group C - Possible Human Carcinogen. Toluene, ethylbenzene and xylene are
categorized as Class D.
Metals. Potentially toxic metals have been detected in the soils near the long-demolished
engine house area. Concentrations of these metals are relatively low and these metals are not
generally very mobile in the type 01 environment found at the BWP site. The metals 01 concern
at the site include arsenic, cadmium, lead, and zinc. Arsenic is classified by EPA as an A -
Human Carcinogen, based on sufficient evidence that arsenic compounds are skin and lung
carcinogens in humans. Cadmium is classified as a 81 - Probable Human Carcinogen, based
on evidence of lung cancer in smelter workers. Lead and most lead compounds are classified
as 82 - Probable Human Carcinogens, resulting from sufficient evidence 01 carcinogenicity in
animals and inadequate evidence of carcinogenicity in humans. Zinc is categorized as Class
D.
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Quantitative Indices of Toxicity
For carcinogens, the dose response relationship is expressed by cancer slope factors (CSF).
These CSFs reflect a linear relationship between dose and cancer risk. These CSFs also
assume that any exposure to a potential carcinogen poses a measurable risk above zero.
Uncertainties in estimating cancer slope factors are compensated for by using the upper 95%
confidence limit on the slope of the line relating dose to risk, which is estimated using
mathematical models which extrapolate from high experimental doses on laboratory animals to
the loW levels of exposure anticipated for humans. The slope factor is characterized as an
upper-bound estimate for a specific chemical, while the dose-response assumptions used in
the EA provide a rough but plausible estimate of the upper limit of the risk of cancer to humans
at the Broderick site.
For both carcinogens and non-carcinogens, a chronic reference dose (RfD) is an estimate of
the daily exposure to the human population (including sensitive subgroups) that is likely to
occur without an appreciable risk of harmful non-carcinogenic effects during a person's
lifetime. Uncertainty factors are used in calculating the RfD, which reflect scientific judgement
regarding the various types of data used to estimate the RfD.
The oral and inhalation quantitative indices of toxicity for the contaminants 01 interest are
summarized in Table 2. The table summarizes the RfD and CSFs, where available, for each
contaminant. Several compounds, including acenaphthylene, phenanthrene, and lead do not
have quantitative toxicity indices available. In accordance with the Risk Assessment Guidance
(EPA, 1989), these compounds were evaluated on a qualitative basis. The EPA interim
guidance on establishing soil cleanup levels for lead was used in the EA.
Risk Characterization
The EA evaluated the potential noncarcinogenic and carcinogenic risks posed by the
contaminants in the various environmental media (Le., soil, ground water, etc.) at the Broderick
site. Carcinogenic risk is presented as a probability value (Le., the excess chance of
contracting cancer over a lifetime).
Carcinoaenic Risk. Carcinogenic risk was estimated by multiplying the calculated intake 01 a
contaminant by its CSF. A summary of the carcinogenic effects for the most impacted Mure
use scenarios is provided in Table 4. (The EA presents a complete, detailed analysis for all
future use scenarios and potential receptors at the site.) Based on this summary, the total
carcinogenic risk for the various scenarios ranges from 10-2 to 1 f1J for ground water, ~ to
10-12 for surface soils, and 1 fP to t~ for subsurface soils. The carcinogenic risk for many
of the scenarios exceeds the 1 et4 to 1 0-6 risk range specified in the NCP. Risk values
calculated for ingestion and direct contact exposure pathways for the on-site surficial ground
water are higher than risk values that were calculated for any other affected environmental
medium. . Therefore, using these values from the EA, the FS recommended the remediation of
organics- and metals-contaminated surface and subsurface soils on the Broderick property and
surficial aquifer ground water on and off the Broderick property.
Non-Carcinoaenic Risk. The ratio of estimated intake. to the chronic RID was computed for
each contaminant and the sum of the resulting ratios (referred to as hazard quotients) of each
chemical of interest give the chronic (or noncarcinogenic) hazard index for each pathway.
Chronic hazard indices were calculated for each exposure pathway of concern in each
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TABLE 2
BRODERICK WOOD PRODUCTS SITE
TOXICITY DATA FOR CHEMICALS OF INTEREST
REFERENCE DOSES CANCER SLOPE FACTORS
MGlKGJDAY (MGlKGJDAY)-1
COMPOUND CHRONIC
ORAL INHALATON ORAL INHALATON
POLYNUCLEAR AROMATIC
HYDROCARBONS
Carbazole 0.02
Naphthalene 0.004 NO
Acenaphlhylene
Acenaphlhene 0.08 NO
Fluorene 0.04 NO
Phenanthrene
Anthracene 0.3 NO
Auoranthene 0.04 NO
Pyrene 0.03 NO
Benzo(a)anthracene 0.1541 0.08174
Chrysene 0.0138 0.00732
8enzo (b) nuoranthene 0.92 0.48
Benzo (k) nuoranthene 0.0508 0.02684
Benzo (a) pyrene 11.5 e.1
Oibenzo (a.h) anthracene 7.935 4.209
Benzo (g.h.i) perytene
Indeno(1.2.2-cd) pyrene 0.19685 0.10431
VOLATILE ORGANICS
Benzene 0.029 0.029
Toluene 0.3 0.57
Ethyl Benzene 0.1 NO
Xylenea 2 0.085
Methytene chloride 0.08 NO 0.0075 0.014
Trichloroethene 0.011 0.017
Tetrachloroethene 0.01 NO 0.051 0.0033
ACID EXTRACT ABLES
Phenol o.e NO
2-Chlorophenol 0.005 NO
2-Methytphenol 0.05 NO
4-Methytphenol 0.05 NO
2.4-Dimethytphenol 0.02 NO
2.4-Dichlorophenol 0.003 NO
2.4.8- TrichlorophenoJ 0.011 0.011
2.4.5- Trichlorophenol 0.1 NO
Pentachlorophenol 0.03 NO 0.12
OIOXlNSIFURANS
2.3.7.8-TCOD 150000 150000
H8xachlorodiben~ioxin 75000 75000
Pentachlorodibenz~ioxin 15000 15000
Hepthachlorodibenzo-p-dioxin 1500 1500
Octachlorodibenzo-p-dioxin 150 150
Tetrachlorodibenzofuran 15000 15000
Henchlorodibenzofuran 75000 75000
Pentachlorodibenzofuran 15000 15000
Heptachlorodibenzofuran 1500 1500
Octacnlorodibenzofuran 150 150
METAlS
Arsenic 0.001 NO 1.75 50
Cadmium 0.00051 0.001. NO 8.1
Lead
Zinc 0.2 ND
Not.:
. Verified RIDI for wat., (0.0005) and food (0.0011
NO - Nol Determined
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TABLE 3
BRODERICK WOOD PRODUCTS SITE
SUMMARY OF FOCUSED ASSESSMENT RISKS
ON-SITE RESIDENT ON-SITE INDUSTRIAL
ON-SITE SURFACE SOIL YOUNG CHILDREN WORKERS
Impoundment Soils 2.49E-02 1.I4E-02
Process &. Drip Track 6.02E-03 2.8 I E-03
EAgine House 3.55E-04 2.66E-04
Storage Area 1.73E-04 8.4 I E-05
Low Use Area 2.14E-05 4.06E-06
ON-SITE
ON-SITE SUBSURFACE SOIL CONSTRUCTION WORKER
Impoundment Soils 5. 16E-06
Process &. Drip Track 4.25E-05
Engine House I. 87E-07
Storage Area 1.24E-06
Low Use Area 4.14E-08
ON-SITE ON-SITE
ON-SITE GROUNDWATER RESIDENT ADULT INDUSTRIAL WORKER
Surficial Aquifer
Impoundment Area 2.03E-o I 1.43E-01
Process &. Drip Track 7.79E-02 5.54E-02
Eastern Boundary 5.24E-03 3.73E-03
Background 5.15E-05 3.54E-05
Denver Aquifer
Impoundment Area 2.45E-01 I. 74E-() I
Process &. Drip Track 2.11£-02 I.5SE-02
Arapahoe Aquifer
Impoundment Area 1.17E-04 8.34E-05
OFF-SITE
OFF-SITE GROUNDWATER RESIDENT ADULTS
Surficial Aquifer
Impoundment Area 2.08E-02
Process &. Drip Track 2.07E-02
Daaver Aquifer
Impoundrnaat Area 4.59E-03
Process and Drip Track 7.51£-04
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TABLE 4
BRODERICK WOOD PRODUCTS SITE
SUMMARY OF CARCINOGENIC EFFECTS
SOIL
ON SITE RESIDENT YOUNG CHILDREN ON-SITE INDUSTRIAL WORKERS
INCIDENTAL DERMAL INHALATION INCIDENTAL DERMAL INHALATION
INGESTION OF CONTACT WITH OF AIR FROM INGESTION OF CONTACT WITH OF AIR FROM
CHEMICAL-Of-INTEREST SURFACE SOILS SURFACE SOILS SURFACE SOILS SURFACE SOILS SURFACE SOILS SURFACE SOILS
carbazole 7.0SE-08 4.4SE-09 O.OOE+OO 1.13E-08 1.2SE-08 O.OOE+OO
benzo(a)anthracene S.64E-06 3.S6E-07 3.04E-09 4.74E-07 S.22E-07 3.S8E-10
chrysene 1.S9E-06 1.00E-07 8.74E-10 1.76E-07 1.94E-07 1.36E-10
benso(b)lIuoranthene 1.74E-OS 1.10E-06 2.30E-07 1.S8E-06 1.74E-06 2.93E-08
benso(k)lIuoranthene 2.04E-06 1.29E-07 9.9SE-10 2.72E-07 2.99E-07 1.86E-10
benzo(a)pyrene 2.S0E-04 1.58E-05 1.20E-07 2.14E-OS 2.36E-OS 1.44E-08
dlbenzo(a,h)anthracene S.S7E-04 1.62E-OS 1.SSE-07 2.S1E-OS 2.76E-OS 2.12E-08
Indeno(1,2,3-cd)pyrene S.48E-06 3.46E-07 2.39E-09 S.30E-07 5.83E-07 3.23E-10
benzene 9.20E-11 5.80E-12 2.43E-09 7.32E-12 8.0SE-12 2.71E-10
pentachlorophenol 3.S7E-OS 2.25E-06 O.OOE-OO 2.93E-06 3.22E-06 O.OOE+OO
pentachlorodibenzo-p-dloxlon 1.62E-04 1.02E-05 2.38E-06 4.24E-OS 4.67E-05 8.71E-07
hextachlorodlbenzo-p-dloxln 1.18E-03 7.42E-05 1.73E-OS 3.07E-Q4 3.38E-Q4 6.31E-06
heptachlorodlbenzo-p-dloxln 2.44E-03 1.S4E-04 3.58E-05 6.36E-Q4 7.00E-Q4 1.31 E-OS
otachlorodlbenzo-p-dloxln 1.48E-03 9.33E-OS 2.17E-OS 3.86E-Q4 4.2SE-Q4 7.93E-06
tetrachlorodlbenzofuran 8.4SE-06 5.33E-07 1.24E-07 2.21 E-06 2.43E-06 4.S3E-08
pentachlorodlbenzofuran 7.77E-04 4.90E-OS 1,14E-05 2.03E-04 2.23E-04 4.17E-06
hexachlorodlbenzofuran 2.69E-03 1.69E-04 3.94E-05 7.02E-04 7. 72E-04 1.44E-OS
hepachlorodlbenzofuran S.82E-04 3.69E-05 8.S5E-06 1.S2E-04 1.67E-04 3.12E-06
octachlorodlbenzofuran 1.01 E-04 6.40E-06 1.49E-06 2.65E-OS 2.91 E-OS 5.44E-07
arsenic 7.56E-OS 4.77E-06 1.77E-06 3.61E-OS 3.97E-OS 1,18E-06
cadmium O.OOE+OO O.OOE+OO 1.98E-07 O.OOE+OO O.OOE+OO 1.33E-07
23-0ec-91 ARCSIBRODERICKIT ABlES\4
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TABLE 4 (continued)
BRODERICK WOOD PRODUCTS SITE
SUMMARY OF CARCINOGENIC EFFECTS
SOIL
ON-SITE CONSTRUCTION WORKERS
INCIDENTAL INCIDENTAL DERMAL DERMAL INHALATION INHALATION
CHEMICAL-Of-INTEREST INGESTION OF INGESTION OF CONTACT WITH CONTACT WITH OF AIR FROM OF AIR FROM
SURFACE SOILS SUBSURFACE SOILS SURFACE SOILS SUBSURFACE SOILS SURFACE SOilS SUBSURFACE SOilS
carbazole 2.16E-09 2.0SE-09 2.37E-09 2.26E-09 O.OOE..OO O.OOE+OO
benzo(a)anthracene 2.62E-07 9.99E-09 2.89E-07 1.1OE-OB 3.57E-10 1.31E-11
chrysene 5.59E-08 1.35E-09 6.15E-08 1.48E-09 7.71E-11 1.77E-12
benso(b)lIuoranthene 7.13E-07 1.84E-OB 7.85E-07 2.02E-08 1.36E-08 3.61E-11
. benso(k)lIuoranthene 6.62E-OS 2.69E-09 7.2SE-08 2.96E-09 8.55E-11 3.53E-12
benzo(a)pyrene 1.12E-05 6.16E-07 1.23E-05 6.77E-07 1.43E-08 8.09E-10
dibenzo(a.h)anthracene 9.84E-06 5.27E-07 1.08E-05 5.80E-07 1.43E-08 6.93E-10
Indeno(1,2,3-cd)pyrene 2.12E-07 1.06E-08 2.33E-07 1.16E-08 2.58E-10 1.39E-11
benzene 5.89E-12 1.45E-11 6.44E-12 1.60E-11 2.17E-10 1.04E-10
trichloroethylene O.OOE+OO 2.67E-12 O.OOE+OO 2.94E-12 O.OOE+OO 2.96E-11
tetrachloroethylene O.OOE+OO 1.49E-11 O.OOE+OO 1.64E-11 O.OOE+OO 6.93E-12
pentachlorophenol 1.76E-06 3.52E-OB 1.93E-06 a.87E-OB O.OOE+OO O.OOE-OO
pentachlorodlbenzo-p-dloxlon 4.50E-06 O.OOE+OO 4.95E-06 O.OOE+OO 9.76E-08 O.OOE+OO
hextachlorodlbenzo-p-dioxin 3.26E-OS 1.98E-06 3.S8E-OS 2.1SE-06 7.07E-07 1.07E-08
heptachlorodlbenzo-p-dloxln 6.7SE-05 7.05E-06 7.42E-OS 7.7SE-06 1.46E-06 a.80E-08
otachlorodlbenzo-p-dioxln 4.09E-OS 2.22E-06 4.S0E-OS 2.44E-06 8.89E-07 1.19E-08
tetrachlorodlbenzofuran 2.34E-07 O.OOE+OO 2.S7E-07 O.OOE+OO 5.0SE-09 O.OOE+OO
pentachlorodlbenzofuran 2.15E-OS 3.55E-07 2.37E-05 3.90E-07 4.67E-07 1.91 E-09
hexachlorodlbenzoluran 7.44E-OS 1.45E-07 8.18E-OS 1.60E-07 1.61 E-06 7.82E-10
hepachlorodibenzoluran 1.61 E-OS 3:98E-07 1.77E-05 4.38E-07 3.50E-07 2.15E-09
octachlorodlbenzoluran 2.81 E-06 1.02E-07 3.09E-06 1.12E-07 6.10E-08 5.51E-10
arsenic 1.92E-06 5.41E-08 2.12E-06 5.95E-08 1.26E-07 3.83E-09
cadmium O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 1.41E-08 4.45E-011
23-Doo-81 ARCSIBRODERlCI<\TABLES\4.
-------
TABLE 4 (continued)
SUMMARY OF CARCINOGENIC EFFECTS
BRODERICK WOOD PRODUCTS SITE
GROUNDWATER
CHEMICAl-QF-INTEREST
ON-SITE RESIDENT ADULTS
DERMAL INCIDENTAL INHALATION
CONTACT WITH INGESTION OF . OF AIR FROM
GROUNDWATER GROUNDWATER SHOWERS
I
ON-SITE INDUSTRIAL WORKERS
INCIDENTAL
INGESTION OF
GROUNDWATER
benzo(a)anthracene
carbazole
pentachlorophenol
hextachlorodlbenzo-p-dloxln
heptachlorodlbenzo-p-dioxin
octachlorodibenzo-p-dloxin
hexachlorodlbenzofuran
7AOE-07 4.78E-04 1.74E-10 3.41 E-04
6.21E-08 4.01E-OS O.OOE+OO 2.86E-OS
2.49E-OS 1.61E-02 O.OOE+OO 1.1SE.02
4.69E-OS 3.03E-02 7.45E-04 2.16E-02
5.26E-06 3.40E-02 8.35E-OS 2.42E-03
2.44E-06 1.58E-03 3.BBE-OS 1.13E-03
8.10E-OS 5.23E-02 1.29E-03 3.73E-02
-------
scenario. Chronic Hazard Indices are shown in Table 5 for the two most impacted populations.
Results indicated that some chronic hazard indices do exceed unity; therefore, EPA believes
that there is a noncarcinogenic public health threat associated with soils and ground water on
the Broderick property, based on the scenarios used in the EA.
Environmental Risks
The NCP requires that the EA evaluate potential threats to both human health and the
environment. In the environmental risk analysis prepared as part of the EA, no endangered or
economically important species and no critical habitats were identified at or near the Broderick
site. The ecosystem types that were identified as potentially exposed in the EA are freshwater
aquatic and terrestrial organisms. The EA evaluated direct contact such as dermal contact and
ingestion of contaminated media, and indirect exposure by ingestion of contaminated
organisms and bioaccumulation of contaminants up the food chain as the primary
environmental exposure pathways.
The areas along Fisher Ditch and the Terrace area were identified in the EA as potential
ecological receptors. Leaching to ground water and the subsequent ground water migration
and discharge to seeps off the Broderick property is the probable migration pathway for the
PAH contaminants found in these areas.
The impoundments, which contained PAHs and PCP, were determined to have been a primary
contaminant source area. However, the removal and storage of the impoundment sludges as
part of the OU 1 interim action has reduced the primary environmental risk from the
impoundments. The removal 01 the sludges for off-site recycling during the OU 1 RA should
completely eliminate this environmental risk. Migration of contaminants from media already
affected by the impoundments continues to be a minor concern, although risks are in the
acceptable range for all contaminants except some PAH contamination in Fisher Ditch
sediments (for further discussion and maps showing the locations of these sediments, see the
June 28, 1991 Feasibility Study). For this reason, some Fisher Ditch sediments will need to be
excavated and treated to mitigate this environmental risk.
Conclusions from the Endangerment Assessment
Actual or threatened releases of hazardous wastes 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.
As discussed in the sections on Risk Characterization, there are several environmental media
for which the risk to primary impacted populations exceeds the 10-4 to 10-6 risk range. These
include inhalation and ingestion of soils and ingestion of ground water by on-site resident
young children, industrial workers, and construction workers. The chemicals of probable
concern for the impoundment and process areas include PAHs, PCP, dioxins and furans, and,
in the engine house area, toxic heavy metals, such as arsenic, cadmium, lead, and zinc. For
this reason, the Feasibility Study (FS), which followed the Endangerment Assessment,
evaluated the location and quantities of contaminated materials on the Broderick site.
As stated in the Environmental Risks section, some PAH contamination also exists in Fisher
Ditch sediments. For this reason, some Fisher Ditch sediments will also need to be excavated
and treated to mitigate this environmental risk. This treatment was also evaluated in the FS.
\brodrick\Ou2rod7\O 11592
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TABLE S
SUMMARY OF CHRONIC HEALTH EFFECTS
BRODERICK WOOD PRODUCTS SITE
SOIL
ON SITE RESIDENT YOUNG CHILDREN ON-SITE INDUSTRIAL WORKERS
INCIDENTAL DERMAL INCIDENTAL DERMAL
CHEMICAL-Of-INTEREST INGESTION OF CONTACT WITH INGESTION OF CONTACT WITH
SURFACE SOILS SURFACE SOILS SURFACE SOILS SURFACE SOILS
naphthalene 0.14 0.01 0.00 0.00
fluorene 0.01 0.00 0.00 0.00
fluoranthene 0.11 0.01 0.00 0.00
pyrene 0.24 0.01 0.01 0.01
pentachlorophenol 0.14 0.01 0.00 0.00
arsenic 0.60 0.04 0.05 0.05
zinc 0.22 0.01 0.02 0.02
ON-SITE CONSTRUCTION WORKERS
INCIDENTAL INCIDENTAL DERMAL DERMAL
CHEMICAL-Of-INTEREST INGESTION OF INGESTION OF CONTACT WITH CONTACT WITH
SURFACE SOILS SUBSURFACE SOILS SURFACE SOILS SUBSURFACE SOILS
naphthalene 0.02 0.01 0.02 0.02
fluoranthene 0.01 0.00 0.01 0.00
pyrena 0.02 0.00 0.02 0.00
pentachlorophenol 0.02 0.00 0.02 0.00
arsenic 0.04 0.00 0.04 0.00
zinc 0.01 0.00 0.02 0.00
26-Dec-91 ARGSIBRODERICKIT ABLESICI
-------
TABLE 5 (continued)
SUMMARY OF CHRONIC HEALTH EFFECTS
BRODERICK WOOD PRODUCTS SITE
GROUNDWATER
ON-SITE RESIDENT ADULTS ON-SITE INDUSTRIAL WORKERS
DERMAL INCIDENTAL INCIDENTAL
CHEMICAL-Of-INTEREST CONTACT WITH INGESTION OF INGESTION OF
GROUNDWATER GROUNDWATER GROUNDWATER
naphthalene 0.06 75.45 15.97
acenaphthene 0.00 1.31 0.28
fluorene 0.00 2.76 0.58 .
anthracene 0.00 0.17 0.04
fluoranthene 0.00 2.38 0.50
pyrena 0.00 4.49 0.95
phenol 0.00 0.06 0.01
2-melhylphenol 0.00 0.98 0.21
4-malhylphenol 0.00 0.96 0.20
2.4-dlmethylphenol 0.00 4.30 0.91
2.4-dlchlorophenol 0.01 10.04 2.12
2.4.5-trlchlorophanol 0.00 0.31 0.07
pentachlorophenol 0.02 10.44 7.43
2O-Dtc-8\ ARCSIBRODERlCKITABlESI8B
-------
As one step in the evaluation of potential carcinogenic health effects, a ''focused risk
assessment" was included in the EA. The focused risk assessment estimated risks for the
highest risk populations associated with potential exposure to "hot spots". These hot spots
represent discrete areas of high contamination in each of the five areas of the site shown on
Figure 2 for soils and each of the three aquifers shown on Figure 3 for ground water. The
migration pathways included on-site surface soil, on-site subsurface soil, on-site ground water,
and off-site ground water. This focused assessment represents the highest exposure possible
from the contamination within the Broderick site. Results of the focused assessment
specifically for media in the impoundment area, process and drip track area, railroad shop,
storage area, and low-use area are provided in Table 3.
VII. DESCRIPTION OF ALTERNATIVES
A feasibility study was conducted to develop and evaluate remedial alternatives for OU 2 at the
BWP site. The final Phase III feasibility study (FS) for au 2 was completed on June 28, 1 991,
and an Addendum to this FS was completed on July 11, 1991.
Remedial alternatives for each contaminated media we,(e assembled from applicable remedial
process technology options and were screened for effectiveness, implementability, and cost.
The FS identified three remedial alternatives for soils/sediments contaminated with organics,
three remedial alternatives for the contaminated surficial ground water, and one remedial
alternative each for metals-contaminated soil, Denver aquifer ground water, Arapahoe aquifer
ground water, and buildings, vessels and their contents which passed this initial screening.
The alternatives passing the initial screening were then evaluated in detail based on the nine
criteria required by the NCP. For purposes of the detailed analysis, the FS combined the
remedial alternatives for each media into combinations of detailed alternatives so that all
contaminated media were addressed by each detailed alternative. This resulted in nine
detailed alternatives, that is, three soil/sediments remedial alternatives times three surficial
ground water remedial alternatives plus "common elements". The "common elements- were
made up of the remedial alternatives for the media which had a single remedial alternative at
the conclusion of the screening stage of the FS. In addition, the FS considered a no-action
alternative in the detailed analysis. The NCP requires that a no-action alternative be included
to provide a baseline for comparison of the other alternatives. Therefore, 10 detailed
alternatives were analyzed in the FS. This same breakdown of alternatives was used in the
Proposed Plan.
In order to simplify the analysis for this ROD, EPA has decided to alter the approach used in
the FS and Proposed Plan. Instead of combining the remedial alternatives for each major
media into detailed alternatives, the remedial alternatives for each media will be presented and
analyzed separately. The three major media groups are soils and sediments, ground water,
and buildings, vessels, and their contents. The discussions will present remedial alternatives
for each media as well as the common elements for that media. The chosen remedial
alternatives for each media will then be combined in Section IX, below, to provide the final site
remedy. Table 6 has been included to provide a link between the discussion below and the
discussion of detailed alternatives in the FS and the Proposed Plan.
The remedial alternatives for soils and sediments are described first, ground water remedial
alternatives are described second, and remedial alternatives for building, vessels, and their
contents are described third.
\brodrick\0u2rod7\011592
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TABLE 6
BRODERICK WOOD PRODUCTS SITE
SUMMARY OF 10 ALTERNATIVES IN FS
Component Detailed Alternatives In FS
Media Descriptor Remediation Alternative 1 2 3 4 5 6 7 8 9 10
Organic
SA1 No Action - all soils . 0 0 0 0 0 0 0 0 0
SA2 Thermal Desorption 0 0 0 . 0 0 . 0 ' 0 .
Solis & SA3 In-Situ Bloremedlation 0 . 0 0 . 0 0 . 0 0
Sediments SM Ex-Situ Bloremediation 0 0 . 0 0 . 0 0 . 0
Common Elements:
Metals Chemicallixation/iandfilling 0 " " " ' "
Sediments Excavate/lreat with organics solis 0 " " " ' "
Impoundments RCRA closure: wastes In place 0 " " " ' "
Residual Access/deed restrictions 0, . . . . . . . . .
Surficial GW:
GA1 No Action -' ground water . 0 0 0 0 0 0 0 0 0
GA2 Institutional Controls 0 . . . 0 0 0 0 0 0
Ground GA3 Ex-Situ Dioremedlatlon 0 0 0 0 . . . 0 0 0
Waler GM Ex/In-Situ Bloremedlatlon 0 0 0 0 0 0 0 . . .
Common Elements:
Denver Monltorlngllnstltullonal Controls 0 " " " " ,
Arapahoe Monitoring/Further Investigation 0 " " " " ,
Surficial Monltorlngllnstltutional Controls 0 " . . . , . " .
BVD1: No Acllon - buildings. vessels . 0 0 0 0 0 0 0 0 0
Buildings. BVD2:
Vessels & Buildings Demollshltemporarlly store debris 0 " " " ' "
Drums Buildings Transporllreclalm melal oil-site 0 " " " ' "
Tanks Transporllreclalm conlents oll-slle 0 " " " ' "
Water Transporlilandlill 0llsll8 0 . . . . . . . . .
Misc. Debris Transporl/landlill oll-slle O . . . . . . . . .
Footnote: Filled symbol Included In alternative
-------
Remedial Alternatives for Soils and Sediments
Two distinct groups of contaminated soils were discovered at the site. The first group is the
organics-contaminated soils and sediments. Organics-contaminated soils and sediments
make up the vast majority of the contaminated soils at the site. The second group is the heavy
metals-contaminated soils. The screening and detailed analysis of remedial alternatives in the
FS resulted in the identification of three remedial alternatives for the organics-contaminated
soils and sediments. Two of the four remedial alternatives below, Alternative 2, Thermal
Desorption, and Alternative 4, Ex-Situ Bioremediation, were analyzed in detail under two
different action levels, Le., 10-4 and 10-5. No alternatives were analyzed in detail for the 10-6
action level. Technologies that could reach the 10-6 action level were determined not to be
cost effective during the FS screening. Under the 10-4 action level, contaminated soils would
be excavated such that residual cancer risks in the unexcavated soils would be at or below the
1 0-4 level. Under the 1 0-5 action level contaminated soils would be excavated such that
residual cancer risks in the unexcavated soils would be at or below the 10-5 level. Thus, the
volume of soils excavated under 10-5 would be greater than under 10-4. To simplify the
description and comparison of alternatives, alternatives are presented only in this and the
following section assuming a 10-5 action level. For a detailed analysis and comparison of the
two action levels, please refer to Section XI below.
EPA has determined, for the following reasons, that an action level for soils based on an
industrial use scenario is appropriate for this site. The industrial use scenario is appropriate
because the present land uses in the vicinity of the site are predominantly industrial and
commercial. Industrial and commercial land uses have dominated the area around the site for
the last 40 to 50 years. It is reasonable to assume that such uses will continue into the
foreseeable future.
Table 7 lists the remedial alternatives considered for the organics-contaminated soils and
sediments.
Screening in the FS left only one remedial alternative for the heavy metals-contaminated soils.
This single remedial alternative is included as a common element of each of the soil/sediment
alternatives described below (except no-action). Table 7 also presents a summary of the
volume of contaminated material to be treated by each alternative, the present value costs, and
period of treatment for each soils and sediments remedial alternative. Each alternative below
contains a brief analysis of ARARs. All ARARs analyzed for the site can be found in the FS.
Soils and Sediments Alternative #1 - No-Action. In this alternative, an analysis 01 which is
required by the NCP, no action would be taken to contain or treat the contamin"ated soils and
sediments at the site. However, the completion 01 the au 1 interim action would not be
impacted by this alternative. The site was fenced and the impoundment sludges have been
isolated in lined storage cells under the OU 1 ROD Amendment. These sludges would still be
transported from the site to an oft-site recycling facility under OU 1.
Because contaminated soils would remain in place and would contribute to ground water
contamination, a no-action alternative would present long-term health risks both on and off the
property. Short and long-term health risks would be present in exposure scenarios involving
land development and/or industrial and construction activity. Leaching of contaminants into
the underlying ground water would continue to present an environmental threat. Costs
required to implement and maintain this alternative are assumed to be zero.
\brodrick\Ou2rod7\011592
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TABLE 7
BRODERICK WOOD PRODUCTS SITE
SOIL ALTERNATIVES
Present
Treated Value Remedial
Volume Cost" Time
Alternative (cu. yds.) ($1,000) (Years)
Soil Alternative 1 :
No Action 0 0 0
Soil Alternative 2: Thermal Desorption
Organics - soils 59,225 *31,780 6.6
Organics - sediment 120 7.4
Metals - soils 800 317.2
Impoundment closure - 283.4
Access/deed restrictions/institutional controls 101,000 ***
Soil Altemative 3: In-situ Bioremediation
. Organic - soils 48,189 2,431 7
Organics - sediment 120 7.4
Metals - soils 800 317.2
Impoundment closure - 283.4
Access/deed restrictions/institutional controls 150,000 ***
Soil Alternative 4: Ex-situ Bioremediation
Organics - soils 59,225 3,885 7
Organics - sediment 120 7.4
Metals - soils 800 317.2
Impoundment closure - 283.4
Access/deed restrictions/institutional controls 101,000 ***
. Cost shown only for on-site landfilling.
.. Present value cost - Capital cost + 0 & M costs.
. . . Costs not yet calculated
broderick\t-7
-------
Soils and Sediments Alternative #2 . Thermal Desorption. In this alternative organics-
contaminated soils and sediments would be excavated. oversized materials removed. and the
soils moved to an on-site thermal desorption unit. The thermal desorption process would
involve batch process heating of the contaminated soil to a temperature between 3000 and
8000 F. in order to drive the PAHs, PCP and Dioxins/Furans out of the soil. The vapors would
either be condensed and recycled or sent into an afterburner unit that destroys the
contaminants.
Approximately 120 cubic yards of organics-contaminated sediments from Fisher Ditch would be
excavated and treated to remove water. After removal of water these sediments would be
moved to the thermal desorption unit for treatment, along with the soils.
If the condenser were used. recovered PAHs and PCP would be transported to an off-site
reclamation facility. Production and transportation of these hazardous wastes would be carried
out in compliance with RCRA regulations.
Afterburner gases would be released into the atmosphere. These air emissions would be
controlled to comply with any Federal or State air quality regulations identified as ARARs.
During excavation of the soil before treatment, appropriate measures would be taken to control
fugitive dust and to assure compliance with provisions of the Colorado Air Quality Control Act
identified as ARARs. .
A wide variety 01 organic constituents are amenable to treatment by thermal desorption.
. Desorption efficiencies for specific constituents may vary as a function of constituent vapor
pressure I residence time. and treatment temperature. Removal efficiencies of 25 to 98 percent
have been observed for PAHs and removals of 99.9 percent have been observed for volatile
organic constituents such as benzene, toluene, and xylenes. For Dioxins/Furans, removal
efficiencies greater than 90% have been observed. Field demonstration tests and full scale
operational data indicate that well-operated thermal desorption systems can exceed the RCRA .
standards for hazardous waste incinerators and the treated waste can be sufficiently detoxified
to enable it to be delisted.
After each batch of soil and sediment is heated, the treated soils/sediments would be removed
from the unit and either placed in an on-site landfill constructed to meet all ARARs or
transported to an off-site. permitted RCRA landfill. Landfilling of contaminated soils after
treatment in the desorption unit would trigger the RCRA LDR standards for K001 wastes. The
LDR requirements would be met through a Soil and Debris Treatability Variance. The
Treatability Variance treatment level ranges or percent reduction ranges that thermal desorption
would achieve for the constituents are:
KOO1 Constituents
Treatment Levels
Naphthalene
Pentachlorophenol
Phenanthrene
Pyrene
Toluene
Xylenes (Total)
Lead
95-99% Reduction
90-99% Reduction
95-99% Reduction
95-99% Reduction
.5-10 ppm
.5-10 ppm
99-99.9% Reduction
Community acceptability may be a significant issue with regard to thermal desorption of soil
containing hazardous waste. Some opposition to incineration was expressed during the public
comment period for Operable Unit 1 (removal/treatmenVdisposition of the impoundment
\brodrick\Ou2rod7\011592
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sludges). It would be expected that similar opposition would be expressed for an on-site
thermal desorption unit.
Design and construction of the thermal desorption unit would require one year. Following
construction, the organics contaminated soil and sediment would be treated and landfilled over
a seven-year period. Soil volumes for this option would be 59,000 cubic yards. The costs for
this option would range from $31.8 million for on-site landfilling to $44.0 million for off-site
landfilling. The cost for the excavation and dewatering of the Fisher Ditch sediments is
estimated at $7,400. .
This alternative would not be protective for residential uses of the property. Therefore,
exposure and access to organics-contaminated .soils remaining after treatment and to the
treated soil landfilled on the property would be controlled by the use of deed restrictions or
other institutional controls to prohibit non-industrial uses of the site. The cost to apply these
restrictions is not currently known.
In addition to the organics contaminated soil and sediment, approximately 800 cubic yards of
soils contaminated with heavy metals above RCRA Toxicity Characteristic levels would be
treated. This soil would undergo chemical fixation using such stabilization compounds as
cement or fly ash to form a chemically and mechanically stable material. Treatability studies
would be conducted to determine the best stabilization compound for the wastes at the site.
The metals-contaminated soils would be excavated and then mixed with water and the fixation
agents. The resultant product would be poured into forms. Once the material was solidified,
the solid blocks would be removed from the forms and allowed to cure. After the blocks had
cured, they would be transported to an off-site, RCRA Subtitle D-permitted landfill for disposal.
LDR standards would apply to this action. The potential heavy metals found at the BWP site
which have LOR treatment standards are arsenic (0004), cadmium (0006) and lead (0008). To
meet the LOR standards, it would have to be shown that the stabilized soil was below Toxicity
Characteristic levels for these metals. The cost for stabilization and transportation is
approximately $317,200.
The former sludge impoundments are RCRA interim status units. As such these impoundments
must be closed in compliance with RCRA interim status regulations found in 40 CFR 265. The
cost for this closure is estimated to be $283,400 (see Table 7). The total present worth cost,
including capital and O&M costs, would be approximately $32,388,000. This alternative would
be monitored continuously during operation. Because hazardous substances would be left on
site above levels which would allow unlimited use and unrestricted exposure, the
protectiveness of the remedy would be reviewed at least every five years as required by
CERCLA.
Soils and Sediments Alternative 3.- In-Situ Bioremediation. This soil remediation technology
would involve removing the oversized rocks from the natural, in-place soils. Then the soil
would be periodically plowed and/or disced, fertilized, and irrigated using common farm
implements. This process, commonly called "land farming", is done in order to maintain the
moisture, nutrients, and aeration required to promote rapid growth of soil bacteria. These
microscopic bacteria occur naturally in the soil at the site and grow using hydrocarbon
contaminants as a ''food'' source. The ultimate goal of this process would be to break
contaminants down into simpler, less toxic materials, such as simpler, non-chlorinated
hydrocarbon compounds, then to organic carbon and water. The remedy would be designed,
operated, and closed in compliance with RCRA land treatment requirements.
Approximately 120 cubic yards 01 organics-contaminated sediments from Fisher Ditch would be
excavated and treated to remove water. After removal 01 water, these sediments would. be
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spread within the area to be land farmed for treatment. No LDRs apply to placement of these
sediments because the level of contamination is already below LOR standards.
Depending on the permeability of the subsoils. the leachate from the "farming" process may
drive the contamination downward toward the water table through infiltration and percolation
prior to complete biodegradation. RCRA land treatment regulations. identified as ARARs for
this alternative, would require a monitoring program to detect migration of contaminants. This
monitoring system may include Iysimeters at the base of the treatment zone, or "zone of
incorporation" to collect soil pore liquid, which together with soil cores taken at random
locations, would be periodically collected and analyzed to determine removal efficiency and
contaminant level. In addition, monitoring wells located upgradient and downgradient of the
land farming area would be sampled periodically to determine the potential for migration of
leachate.
Biodegradation of organic wood-treating wastes in a soils matrix has proven effective at
hazardous waste locations throughout the country. Although fewer data are available for In-
Situ Bioremediation at wood-treating sites than for Ex-SituBioremediation, the treatment
processes are similar and In-Situ Bioremediatton has been successfully applied to remediation
of fuel spills and other volatile organic compounds. At the Brainerd site in Minnesota, removal
rates for total PAH have ranged. from 70% to 90%. The major limiting factor is that In-Situ
Bioremediation would not be feasible for treatment of subsurface soils since the maximum
treatment depth is 12 to 24 inches with an optimal depth 01 12 inches or less.
LOR standards do not apply to In-situ Bioremediation (in-place land farming) of the organics-
contaminated soils and sediments because placement does not occur. It is expected that
some K001 contaminated soils in the impoundment area would be moved in preparing the area
for land farming. However, this would not trigger LDRs. The impoundment area is considered
by EPA to be an area of contamination (AOC). Movement 01 wastes within the AOC to prepare
for land treatment is, by definition, not placement.
The land farming process would extend over a seven-year period (see Table 7). This
alternative would be monitored continuously during operation. Because hazardous substances
would be left on site above levels which would allow unlimited use and unrestricted exposure,
the protectiveness of the remedy would be reviewed at least every five years as required by
CERCLA. The volume to be treated is expected to be approximately 48,000 cubic yards. The
costs for this option are estimated at $2.4 million.
The remedy proposed in this alternative would not be protective for residential uses of the
property. Therefore, exposure and access to organics-contaminated soils, both treated and
untreated, would be controlled by the use of deed restrictions or other institutional controls to
prohibit Mure non-industrial uses of the property. The cost to apply these restrictions is not
currently known.
Metals-contaminated soils would be remediated as provided above in Alternative 2. The costs
for treating these soils are shown in Table 7.
The former sludge impoundments are RCRA interim status units. Since In-Situ Bioremediation
would only treat contaminants in the top 12 to 24 inches, it is certain that waste residuals would
be left in place. Therefore, RCRA interim status requirements for closure with wastes in place
are ARARs for this alternative. As such, these impoundments must be closed. in compliance
with RCRA interim status regulations found in 40 CFR 265. The cost for this closure is
estimated at $283,400 (see Table 7). The total present value cost for this remedial alternative,
including capital and O&M costs, would be approximately $3,039,000.
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Soils and Sediments Alternative #4 - Ex-Situ Bioremediation. This is EPA's preferred alternative
for treatment of soils and sediments. This soil remediation technology would involve
excavation and on-site biological treatment of organics-contaminated soils and sediments in a
"land-treatment unit" (LTU). This LTU would be constructed by building earthen berms around
the unit, then placing a synthetic liner and leachate collection and recovery system and a
compacted filter material over the liner. The remediation process would include excavating the
soil, separating the oversized rocks, and moving the soil to the LTU. Once placed into the LTU;
the soils would be land farmed as in Alternative #3, above. The RCRA land treatment
requirements, Subpart M, 40 CFR ~264.270 to 264.283 are applicable to this alternative. The
LTU would be designed, operated, and closed in compliance with these regulations. EPA is
including, as extra protective measures, the liner and leachate collection system as well as
closure with a multi-layered cap. .
Approximately 120 cubic yards of organics-contaminated sediments from Fisher Ditch would be
excavated and treated to remove water. After removal of water, these sediments would be
placed in the L TU to be land farmed for treatment. No LDRs apply to placement of these
sediments because the level of contamination is already below LOR standards.
Unlike Alternative #3, In-Situ Bioremediation, the leachate from this. process would be isolated
from the site subsoils by the liner and collected, treated, and reused in the treatment process.
As in Alternative 3, Iysimeters may be used below the liner to collect soil pore liquid, which
together with soil cores taken at random locations within the land treatment unit soils, would be
periodically collected and analyzed to determine removal efficiency and contaminant levels.
Monitoring would be conducted in accordance with the requirements of the land treatment
regulations and the general RCRA monitoring requirements 0140 CFR 264, Subpart F. 'This
process would be capable of treating contaminated subsoils, as well as the upper 12 inches 01
surface soil.
Bench-scale tests conducted for the Broderick site (RI, 1990) have indicated that
bioremediation is a viable approach, especially for reducing PAH concentrations. Removal
efficiencies of 98% for PAHs, 70% for PCP, and 100% for volatile organic compounds were
demonstrated for the Broderick soils. Recent studies by the USDA Wood Products Laboratory
in Wisconsin have shown degradation of greater than 90% for PCP. Successful land treatment
was demonstrated at the Koppers Feather River site in California, with removal of some of the
heavy dioxin/furan compounds to levels exceeding 90% (FS, 1991, Appendix C). In addition, at
a site in Ubby, Montana, which is very similar to the Broderick site, a full-scale L TU has been
pilot tested and is currently operational. Finally, pilot studies of the land treatment unit will be
conducted at the Broderick site at the initial stages of the RA phase to better define removal
rates and efficiencies and to optimize the addition of nutrients and water.
Excavation and placement of the contaminated soils into the L TU would trigger the RCRA LOR
standards for the KOO1 wastes from the impoundments. These LDR treatment standards would
not be met at the time Qf placement in the LTU. Therefore, EPA would invoke a temporary
waiver of the LOR treatment standards through an interim action waiver. At the completion 01
the remedial action, the LOR requirements would be met through the Soil and Debris
Treatability Variance.
The Treatability Variance treatment level ranges and percent reduction ranges that Ex-situ
Bioremediation would attain for the constituents are:
KOO1 Constituents
Treatment Levels
Naphthalene
Pentachlorophenol
95-99% Reduction
90-99% Reduction
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Phenanthrene
Pyrene
Toluene
Xylenes (Total)
lead
95-99% Reduction
95-99% Reduction
0.5-10 ppm
0.5-10 ppm
99-99.9% Reduction
The treated soil would remain in the l TU following treatment and the LTU would be closed in
accordance with the RCRA land treatment requirements and general RCRA closure
requirements.
The remedy proposed in this alternative would not be protective for residential uses of the
property. Therefore, exposure and access to "organics-contaminated soils, both treated and
untreated, would be controlled by the use of deed restrictions or other institutional controls to
prohibit non-industrial uses of the site. The cost to apply these restrictions is not currently
known.
The treatment process would extend over a seven-year period. This alternative would be
monitored continuously during operation. Because hazardous substances above health-based
levels would be left on the property, the protectiveness of the remedy would be reviewed at
least every five years as required by CERClA The volume to be treated is expected to be
approximately 59,000 cubic yards. The estimated costs for this option are $3.9 million (see
Table 7).
Metals-contaminated soils would be remediated as provided in Alternative # 2 and #3, above.
The costs for this remediation are shown in Table 7.
The former sludge impoundments are RCRA interim status units. Although with Ex-Situ
Bioremediation contaminants in the subsurface soils would be excavated and treated, it is ,still
expected that waste residuals would be left in place in the impoundment area after treatment.
Therefore, RCRA interim status requirements for closure with wastes in place are ARARs for this
alternative. As such, these impoundments must be closed in compliance with RCRA interim
status regulations found in 40 CFR 265.228 and Subpart G of 40 CFR 265. The cost for this
closure is estimated at $283,400 {see Table 7). The total present value cost for this remedial
alternative, including capital and O&M costs, would be approximately $4,493,000.
Remedial Altematives for the Ground Water
Three distinct aquifers were identified under the site. These are the surficial aquifer, the Denver
aquifer, and the Arapahoe aquifer. Only the surficial and Denver aquifers were found to have
contaminants above levels of concern. The screening of remedial alternatives in the FS
resulted in the identification of three alternatives for the surficial aquifer and one alternative for
the Denver aquifer. Table 8 lists the ground water alternatives for the surficial aquifer. The
single alternative for the Denver aquifer is included as a common element 01 each of the
surficial aquifer alternatives described below. Table 8 also presents a summary of the present
worth costs for each of the remedial alternatives. Each alternative below presents a brief
analysis of ARARs. A list of all ARARs analyzed for the site can be found in the FS.
Ground Water Alternative #1 - No-Action. .In this alternative, an analysis of which is required by
the NCP, no action would be taken to contain or treat the contaminated surficial ground water
at the site. However, the completion of the au 1 interim action would not be impacted by this
alternative. The site was fenced and the impoundment sludges have been isolated in lined
storage cells under the OU 1 ROD Amendment. These sludges would still be transported from
the site to an off-site recycling facility under OU 1 .
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TABLE 8
BRODERICK WOOD PRODUCTS SITE
GROUND WATER ALTERNATIVES
Present
Treated Value Remedial
Volume Cost Time
Alternative (Gallons) ($1 ,000) (Years)
Ground water (GW) Alternative' :
No Action 0 0 0
GW Alternative 2: Institutional controls
Institutional controls ** . .
-
Monitor 3 aquifers - 685.8 30
Arapahoe testing - 126.2 0.3
GW Alternative 3: Ex-situ treatment
Ex-situ treatment 526M 8.468 10
Monitor 3 aquifers - 685.8 30
Arapahoe testing - 126.2 0.3
Institutional contrOls ** ..
-
GW Alternative 4: Ex/in-situ treatment
Ex/in-situ treatment 526M 9.648 10
Monitor 3 aquifers - 685.8 30
Arapahoe testing - 126.2 0.3
Institutional controls ** ..
-
Note:
M. million gallons
* * Includes controls on and off the BWP property. Costs are not currently known. Remedial time tOf controls may be perpetual.
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Because ground water contamination would remain untreated on the property and could
continue to migrate off the property, a no-action alternative would present long-term health
risks both on and off the property. Leaching of contaminants into the surficial ground water
and continued migration of surficial contamination both off the property and into the underlying
Denver aquifer would also continue to present an environmental threat. Chemical-specific
ARARs would not be met for either the surficial or Denver aquifers and any reduction in toxicity,
mobility, or volume of the contamination would occur only very slowly (hundreds to millions of
years) due to natural degradation. Costs required to implement and maintain this alternative
are assumed to be zero.
Ground Water Alternative #2 - Monitorina/lnstitutional Controls. In this alternative, ground
water monitoring would be-conducted periodically for a minimum of thirty years in all three
aquifers at wells on and off the property to assess ground water quality and migration of
contaminants. The specific details of this monitoring program would be developed during
remedial design. However, it has been assumed for estimating. costs that approximately 15
monitoring wells would be utilized for this purpose. Samples of water from these wells would
be collected at regular intervals. Laboratory measured contaminant concentrations from these
samples would be used to update the' prediction of migration patterns and impacts on well
owners north of the property. The chemical parameters to be monitored include total
carcinogenic PAHs, pentachlorophenol, and dioxins and furans.
EPA has determined that it is technically impracticable to actively remediate the Denver aquifer
due to its hydrogeologic characteristics. The Denver aquifer under the Broderick property is
made up of small lenses of permeable sandstones interbedded in near-impermeable claystone
which significantly limits the ability to pump and treat the contaminated ground water. Due to
the small areal extent of the permeable lenses, the contaminated ground water is believed to
be confined to within a few hundred feet of the impoundments. Consequently, institutional
controls and monitoring would be required for the Denver aquifer. Federal and state ground
water standards identified as ARARs would not be met for the Denver aquifer. These ARARs
would need to be waived for the Denver aquifer due to technical impracticability. If new
information indicates that it is not technically impracticable to treat the Denver aquifer under the
Broderick property, or if monitoring or other information shows that the remedy is not
protective, EPA will reconsider the remedy chosen for this aquifer.
In addition, the ground water in the Arapahoe aquifer would be monitored to determine the
level of contamination. This investigation would include the installation of new monitoring
wells, completion of a cO,nstant discharge aquifer test, sampling the new and existing Arapahoe
wells, and analyzing the samples in a laboratory. If contamination is found, the aquifer would
continue to be monitored and appropriate measures would be taken.
Institutional controls would be applied to the future use of the ground water. Institutional
controls might include deed restrictions, covenants, or acquisition of property rights. Deed
restrictions could be placed on future uses of ground water on the Broderick property by the
current owner to control access to the contaminated water in the surficial and Denver aquifers.
In fact, the owners 01 the Broderick site have indicated that they would cooperate with placing
deed restrictions or covenants on the property. However, placement of deed restrictions or
other institutional controls outside of the BWP property are uncertain because the cooperation
and assistance of off-property owners would be necessary. This is due to the fact that no
specific state or local government agency regulations are currently available to preclude the
use of ground water that is off the BWP property. Despite the placement 01 deed restrictions or
other institutional controls on the property and notifications to appropriate agencies and the
public, it is' conceivable that present or future property owners may develop and use
contaminated ground water. Therefore, the long-term effectiveness of institutional controls
alone would be questionable.
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The potential reduction in toxicity, mobility, and volume 01 contaminants in this alternative are
the same as those in the No-Action alternative. Short- and long-term health effects would also
be the same as in the No-Action alternative. Federal and state ground water standards
identified as ARARs would not be met under this alternative in the surficial aquifer. These
ARARs could not be waived 10r the surficial aqui1er since EPA has determined that there are
technologies available that would clean the aquifer to ARARs within a reasonable time.
The estimated cost 10r a periodic monitoring program over a 3D-year period is approximately
$685,000, as shown in Table 8. The cost for the Arapahoe aquifer testing would be
approximately $126,000. No costs have been currently calculated for'institutional controls, so
the purchase of wells or water rights outside the BWP property would constitute an additional
cost item. The total present value cost 10r this alternative, which includes capital and O&M
costs, would be approximately $812,000. Since contaminated ground water would remain on
the site, five-year reviews would be conducted as required by CERCLA.
Ground Water Alternative #3 - Ex-Situ Bioremediation. This alternative would involve collection
of 526 million gallons 01 ground water and light non-aqueous phase liquids (LNAPL) from the
surficial aquifer in a series of subsurface drain trenches on the BWP property and a recovery
well off the property. These trenches would be located in the areas 01 highest ground water
contamination and would extend to sufficient depth to intersect the unweathered Denver
Formation. This depth may range from approximately 20 to 35 feet, depending on the depth to
bedrock. Most 01 this ground water and LNAPL would come from the surficial aquifer, although
small amounts of dense non-aqueous phase'liquids (DNAPL) and ground water would also be
extracted from the Denver aquifer through existing monitoring wells and any new monitoring
wells which may encounterDNAPL.
An on-site water treatment plant would be constructed. This plant would be designed to first
remove LNAPL and DNAPL from the ground water in an oil/water separator. These NAPLs
would be reclaimed by placing them in tanks or drums, then shipping them to an off-site
recycling facility. The plant would then treat the water in a two-stage, fixed-film bioreactor,
similar to a common water treatment plant. The water would be batch processed in several
large tanks using nutrients, aeration, heat, and mixing to provide an environment conducive to
rapid bioremediation. Small quantities 01 the treated water would be used for the soil
remediation processes and the remaining treated water would be reinjected into the surticial
aquifer. This ground water treatment would substantially reduce organics in the ground water
before each reinjection in compliance with RCRA section 3020.
Recent EPA studies of the effectiveness of ground water extraction systems in achieving
chemical-specific goals found that ground water extraction is an effective remediation measure
for some organic contaminants and can achieve significant removal of other contaminants.
Since the water treatment plant technology has been used at refinery sites for many years, the
actual treatment technology 10r the recovered water is well established. A treatment plant
similar to the one proposed for the Broderick site is currently operating at the Ubby Superfund
site in Montana. Recent studies under the EPA Superfund Innovative Technology Evaluation
(SITE) program have removed over 99% of PCP in treated ground water
It is often difficult to predict the ultimate concentration to which contaminants in the aquifer may
be reduced. The ground water models in Appendix B 01 the FS indicate relative cleanup times
m'ay be as short as 1.6 years and as long as 600,000 years for specific contaminants using this
alternative. Thus, FederaJ and state ground water standards identified as ARARs would not be
met under this alternative in the surficial aquifer within, a reasonable time. A waiver is not
available 10r the surficial aquifer since EPA believes that the ex-situ/in-situ alternative discussed
below may clean the ground water to Federal and state standards within a reasonable time.
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This alternative would use institutional controls on the property as set out. in Alternative #2
during the implementation and operation of the remedy. Ground water in all three aquifers
would also be periodically monitored for thirty years both on and off the Broderick property to
assess ground water quality and migration of contaminants. The specific details of this
monitoring program would be developed during Remedial Design, but would be similar to
those described in Alternative 2 above. The cost for a periodic monitoring program over a 30-
year period is approximately $685,000.
The Denver and Arapahoe Aquifers would specifically be addressed as provided in Ground
water Alternative 2. Costs are shown in Table 8.
For cost purposes, the proposed treatment times for the volume of water discussed above
includes one year for constructing the water treatment unit and approximately 10 years of
operation. However, the system would actually be run until action levels are reached or until a
decision is made to cease operation. Since contaminated ground water would remain on the
site, five-year reviews would be conducted as required by CERCLA. The total present value
cost for this remedial alternative, including capital and O&M costs, would be approximately
$9,280,000.
Ground Water Alternative # 4 - Ex-Situ/ln-Situ Bioremediation. This alternative is EPA's
preferred alternative and would involve use of a two-phase (ex-situ and in-situ) biological water
treatment process. Ground water would be recovered and treated in an above-ground water
treatment plant as described in Alternative #3, above. After some of the treated water .is
diverted for soil treatment, the remaining treated water would be mixed with nutrients and an
oxygenating chemical, such as hydrogen peroxide. This nutrient-rich water would be reinjected
into the aquifer to stimulate bacterial growth in order to promote further breakdown of
contamination within the surficial aquifer. Experience with this treatment process has been.
found to reduce PAHs by 97% and PCP by 95%. Therefore, ground water treatment would
substantially reduce organics in the ground water before each reinjection in compliance with
RCRA section 3020.
Ground water in all three aquifers would be periodically monitored as described in Alternative
#3, above.
An in-situ treatment system similar to the one proposed for the Broderick site is currently
operating at the Ubby Superfund site in Montana. The advantage that this system has over the
pump-and-treat system in Alternative 3 is the ability to both treat contaminants in the aquifer
and to desorb contaminants from soil particles in the aquifer to allow their removal to the water
treatment plant. Although it is often difficult to predict the ultimate concentration to which
contaminants in the aquifer may be reduced, the ground water models in Appendix B of the FS
indicate relative cleanup times may be as short as 11 days to as long as 1 0 years for specific
chemical contaminants using this alternative. Even assuming that these values are based on
simplified model parameters, this two to five order of magnitude difference in relative treatment
times indicates this approach will achieve all ARARs in a reasonable period of time.
This alternative would use institutional controls on the property as set out in Ground Water
Alternative #2.
The Denver and Arapahoe Aquifers would be addressed as discussed in Ground Water
Alternative #2. Estimated costs are shown in Table 8. .
The proposed treatment times for the volume of water discussed above includes one year for
constructing the water treatment unit and approximately 10 years of operation for cost
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purposes. However, the system would actually be run until action levels are reached or until a
decision is made to cease operation. The total present value cost for this remedial alternative,
including capital and O&M costs, would be approximately $10,460,000. Since contaminated
ground water would remain on the site, five-year reviews would be conducted as required by
CERCLA.
Remedial Alternatives for the Buildings, Vessels and Drums and Their Contents
BVD Alternative #1 - No Action. In this alternative, an analysis of which is required by the NCP,
no action would be taken to address the buildings, vessels and drums (BVD) and their
contents. Uke the no action alternatives for the soils and sediments and ground water, the
completion 01 the au 1 interim action would not be impacted by this alternative.
Because the structures and their contents would be left in place, a no-action alternative would
present long-term health and environmental risks through direct contact and/or leaching.
Costs required to implement and maintain this alternative are assumed to be zero.
BVD Alternative #2 - Demolition and Reclamation. Under this alternative, the buildings would
be demolished and the building debris temporarily stockpiled on the Broderick property. The
process building contains asbestos contaminated materials. Demolition and disposal of these
materials would be done in compliance with Federal and state regulations identified as ARARs
including State Air Quality Regulation 8 and the National Emission Standard for Asbestos. An
estimated 225 tons of scrap metal would be transported for disposal at an off-site recycling
facility. An estimated 850 cubic yards of building debris and 205 cubic yards of asbestos-
containing materials would be disposed in appropriate oft-site, permitted landfills.
Significant quantities (an estimated 42,000 gallons) of organic liquids and sludges remain in the
drums and vessels at the Broderick site. The vessel contents would be pumped or excavated,
stored temporarily on the Broderick property in drums, and then transported to an off-site
reclamation facility, along with the contents already in drums. This storage and transportation
would require compliance with all RCRA hazardous waste generator and transporter
requirements.
Approximately 9,500 gallons of contaminated water remain in building sumps and basements
at the site. This includes some fire water contaminated with asbestos left from the process
building fire in 1985. This water would be pumped, stabilized, drummed and transported to a
RCRA-permitted landfill.
The time for demolition and removal of all building materials from the site is estimated at one
year. The estimated total present worth cost for this remedial alternative would be $1,230,000
(see Table 9).
VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
All of the remedial alternatives which passed the initial screening process were evaluated in
detail in accordance with Section 300.430 (e)(9) of the NCP. The detailed analysis was
conducted using the nine criteria identified in the NCP. The nine criteria are: 1) overall
protection of human health and the environment; 2) compliance with applicable or relevant and
appropriate requirements (ARARs); 3) reduction of toxicity, mobility, or volume through
treatment; 4) long-term effectiveness and permanence; 5) short-term effectiveness; 6)
implementability; 7) cost; 8) state acceptance, and 9) community acceptance.
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TABLE 9
BRODERICK WOOD PRODUCTS SITE
BUilDINGS. VESSELS, AND DRUMS (BVD)
ALTERNATIVES
Present
Value Remedial
Treated Cost Time
Alternative Volume ($1 ,000) (Years)
BVD Alternative 1 :
No Action 0 0 0
BVD Alternative 2:
Tank and drum contents 42.000 gal 444.1 1
Dispose water 9.500 gal 100.5
Demolish buildings 1 .050 cu yd 690.1
Recycle metal. 225 tons -
. Cost for recycling scrap metal assumed to be SO, since
return on scrap metal equals decontamination and transportation
costs.
.,
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Criteria 1 and 2 are threshold criteria which must be met by the selected remedial action.
Criteria 3, 4,5, 6 and 7 are balancing criteria. The final two criteria are modifying criteria used
to evaluate the alternatives based on State and local concerns.
A discussion of the comparative analysis of alternatives for the soils and sediments is provided
below followed by discussions of the comparative analysis of alternatives for groundwater of
the surficial aquifer and the buildings, vessels and drums and their contents.
Soils and Sediments
Overall Protection of Human Health and the Environment. Overall protection of human health
and the environment 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 of the alternatives, except no-action, would provide protection 01 human health and the
environment by eliminating, reducing, or controlling the risks identified for the contaminated
soils on the site. . Each of the soils/sediments alternatives would use treatment to eliminate or
reduce the initial risks and use institutional controls to eliminate or control the residual risks.
Alternative 4, Ex-Situ Bioremediation. and Alternative 2, thermal desorption, would provide
greater overall protection because surface and subsurface soils would be excavated and
isolated in engineered containment structures after treatment. Alternative 3, In-situ
Bioremediation, provides less protection, since it does not include an engineered containment
structure and does not feasibly treat the subsurface soils.
Alternative 1, no-action, would not provide protection of human health, since the contaminated
soils would remain in place and would continue to pose risks through ingestion, inhalation and
dermal contact. In addition, leaching 01 contaminants into the underlying ground water would
continue to present an environmental threat. Since this no-action alternative would not meet
this threshold criterion, it is not included further in the comparative analysis.
Comoliance with ARARs. Compliance with ARARs addresses whether a remedy will meet all
applicable or relevant and appropriate Federal and state environmental laws and/or provide a
basis for a waiver from any of these laws. ARARs are generally divided into chemical specific,
action specific, and location specific requirements.
All ARARs identified for these alternatives would be met or a waiver would be available.
Placement of the contaminated soil from the impoundment area into the L TU in Alternative 4.
Ex-Situ Bioremediation, would trigger LDRs. This ARAR would not be met at the time of
placement but would be met at the completion of the remedial action. Thus, this ARAR would
be waived under an interim action waiver. LDR requirements would be met at the end 01 the
remedial action through a soil and debris treatability variance.
Land farming in Alternatives 3 and 4 would be designed, operated and closed in compliance
with the RCRA land treatment regulations in 40 CFR, Subpart M. As an additional measure 01
protectiveness in Alternative 4, Ex-Situ Bioremediation, a liner would be placed under the L TU
to prevent leaching of contaminants from the L TU to the ground water.
Alternative 2, Thermal Desorption would be operated to comply with all federal and state air
quality regulations identified as ARARs. Disposal of the soils after treatment in the thermal
desorption unit would trigger LDRs. LDR requirements would be met for this alternative by use
of a soil and debris treatability variance.
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RCRA closure requirements for wastes left in place are ARARs for each alternative. Closure of
the impoundments would be performed pursuant to these closure requirements.
Reduction of Toxicitv. Mobilitv, or Volume ThrouQh Treatment. Reduction of toxicity, mobility,
or volume through treatment refers to the preference for a remedy that uses treatment to
reduce health hazards, contaminant migration, or the quantity of contaminants at the site.
All alternatives significantly reduce the toxicity, mobility and volume (TMV) of the soils and
sediments exceeding the action levels at the site. Studies for this and other wood treating sites
have demonstrated potential treatment efficiencies for the destruction of PAH, PCP and
dioxins/furans of 90% to 99% for Alternative 2, Thermal Desorption, and Alternative 4, Ex-Situ
Bioremediation. Alternatives 2 and 4 decrease the potential for contaminant mobility through
destruction and the use of engineered containment structures. Alternatives 2 and 4 would
significantly reduce the volume of contaminants; however, the volume of contaminated soils
would probably not be significantly reduced. Alternative 3 would not be expected to reduce
TMVas significantly, since it would not include an engineered containment structure and would
not feasibly treat the subsurface soils.
LonQ-term Effectiveness and Permanence. Long-term effectiveness and permanence refers to
the ability of a remedy to maintain reliable protection of human health and the environment over
time. This criterion includes the consideration of residual risk and the adequacy and reliability
of institutional controls.
Alternatives 2, Thermal Desorption, and Alternative 4, Ex-situ Bioremediation, would be
expected to provide the greatest long-term effectiveness and permanence. Each of these
alternatives would produce similar levels of contaminant reduction. The excavation and
treatment of surface and subsurface soils in Alternatives 2 and 4 would reduce residual risk to
the 1 0-5 risk level based on an industrial-use scenario. This residual risk would be further
controlled by institutional controls on soils not excavated and treated. Residual risks for
treated soils would be controlled through placement of the treated soils in engineered waste
management units and institutional controls. Alternative 3, In-Situ Bioremediation, would be
expected to provide a lesser degree of long-term effectiveness and permanence because
subsurface soils below 12 inches would not be effectively treated and control of the greater
residual risk would be more dependent on institutional controls. The effectiveness and
reliability of institutional controls is considered less than engineered controls.
Short-term Effectiveness. Short-term effectiveness refers to the period of time needed to
complete the remedy and any adverse impacts on human health and the environment that may
be posed during the construction and implementation of the remedy.
All the alternatives require disturbance of the contaminated soils. In-Situ Bioremediation would
require the least disturbance and therefore presents the least short-term risks. Alternative 2,
Thermal Desorption, presents the greatest short-term risks. This alternative would present the
greatest threat of air emissions. Short term risks can be controlled or eliminated through
proper construction techniques. All of the alternatives would require approximately the same
amount of time to implement, approximately, seven years.
Implementabilitv. Implementability refers to the technical and administrative feasibility of a
remedy, including the availability of materials and services needed to implement the chosen
solution. It includes coordination of Federal, State, and local governments to clean up the site.
All alternatives are expected to be technically implementable. In- and Ex-Situ Bioremediation
are relatively simple treatment technologies, are easy to construct and operate, and have been
successfully implemented at other sites. Of the two, In-Situ Bioremediation is more easily
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implementable, since it does not require the construction of an L TU and does not involve
subsurface soils. Thermal Desorption is a new and more complex technology and requires
specialized equipment and knowledge which makes it more difficult to procure, construct and
operate. In addition, air quality concerns in the Denver Metro Area may make it more difficult to
implement the Thermal Desorption alternative.
Institutional controls for each alternative would entail deed restrictions on use of and access to
the site. The implementation of such deed restrictions or other institutional controls would
require the cooperation and approval of the site owners. The owners of the site have indicated
they would cooperate in establishing any needed deed restrictions or institutional controls.
Cost. This cr~erion examines costs for each remedial alternative. For comparison, capital and
annual 0 & M costs are used to calculate a present worth cost for each alternative.
The total present worth costs for each soils/sediments alternative would be as follows:
Alternative 2 - Thermal Desorption
Alternative 3 - In-situ Bioremediation
Alternative 4 - Ex-situ Bioremediation
$32,388,000
$ 3,039,000
$ 4,493,000
State Acceptance. This criterion addresses the State of Colorado's response to the
alternatives described in the proposed plan.
The State of Colorado has concurred with EPA's preferred alternative: Alternative 4, Ex-5itu
Bioremediation.
Community Acceptance. This criterion addresses the public's general response to the
alternatives described in the proposed plan. .
The general public neither supported nor opposed EPA's preferred alternative: Alternative 4,
Ex-5itu Bioremediation. The Potentially Responsible Party (PRP), BIC, supported EPA's
selection of ex-5itu Bioremediation but opposed EPA's decision to excavate soils based on the
10-5 action level. Specific comments submitted by the public during the public comment period
and EPA responses to those comments are attached as part of the Responsiveness Summary.
Ground Water Treatment For The Surficial Aquifer
Overall Protection of Human Health and the Environment. The active remediation alternatives
would be expected to provide adequate protection of human health and the environment by
eliminating. reducing, or controlling the risks posed by contaminated ground water. ex-5itu
Bioremediation and Ex-situ/ln-Situ Bioremediation would eliminate or reduce the contaminant
levels in the ground water in order to provide protectiveness. Ex-5itu/ln-5itu Bioremediation
would provide the greatest overall protectiveness by eliminating or reducing contaminant levels
in a reasonable time. Ex-situ Bioremediation would eliminate or reduce contaminant levels, but
not in a reasonable period of time (see discussion on ARARs below). Stand-alone Institutional
controls may provide some protection to human health by limiting exposure, but they provide
no environmental protection and will not ensure protection of human health.
Alternative 1, no-action, would not provide protection of human health, since the untreated
ground water would pose risks through ingestion and dermal contact to people on and off the
property. Also, the surficial aquifer contamination would continue to migrate to the underlying
Denver aquifer and off the Broderick property. Since this no-action alternative would not meet
this threshold criterion, it is not included further in the comparative analysis.
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Compliance with ARARs. The Safe Drinking Water Act (SDWA) Maximum Contaminant Levels
(MCLs) were identified as ARARs for this site. For stand-alone institutional controls, MCLs
would be met only through natural attenuation. Ground water modeling for the surficial aquifer
was conducted to determine the time it would take to reach MCLs for the ground water
alternatives under ideal conditions. The model was used only to determine the relative
effectiveness of the three alternatives. It showed that under ideal conditions it would take
millions of years for the surficial aquifer to reach MCLs by natural attenuation. Thus,
institutional controls alone would not meet MCLs within a reasonable time.
For Alternative 3, Ex-Situ Bioremediation, the model also determined that it would take an
unreasonable number of years to reach MCLs (Le., 661,000 years). Therefore, this alternative
would not meet ARARs within a reasonable time. A waiver based on technical impracticability
is not available for these ARARs because there is presently a practicable technology for
remediating the surficial aquifer. Since Alternatives 2 and 3 do not meet this threshold criterion,
they are included in the analysis below for comparison purposes only. These alternatives were
not considered for selection purposes.
Only the combination of in-situ bioremediation and ex-situ bioremediation would be expected
to meet all MCLs for the surficial aquifer. The model predicts that under ideal conditions, MCLs
for the surficial aquifer may be met both on and off the Broderick property within 10 years.
MCLs are exceeded in the Denver aquifer under the site. Due to the hydrogeology of this
aquifer beneath the BWP property, it was determined that there is no practicable technology
currently available for remediating this aquifer. Thus, the MCLs as an ARAR for the Denver
aquifer have been waived due to technical impracticability (see Ground water Alternative 2 in
the Description of Alternatives section for more information).
Reduction of Toxicitv. Mobilitv. or Volume (TMV). The Ex-Situ/ln-Situ Bioremediation alternative
would be expected to substantially reduce toxicity, mobility and volume of contaminants in the
surficial aquifer, since bioremediation (Le., degradation) occurs both on the surface and within
the surficial aquifer. The Ex-Situ Bioremediation alternative would also reduce TMV but it would
require a much longer period of time since bioremediation occurs only on the surface. The
institutional controls alternative would not reduce TMV through treatment.
LonQ-term Effectiveness and Permanence. The Ex-Situ/ln-Situ Bioremediation' alternative
provides the greatest long-term effectiveness and permanence. This alternative is considered
effective and permanent in that it degrades and/or destroys contaminants to acceptable levels
within a reasonable timeframe. It is the only alternative expected to reduce residual risk to
acceptable levels. The Ex-Situ Bioremediation alternative would degrade/destroy the
contaminants, but not within a reasonable timeframe. Therefore, it is not adequately effective
or permanent. Institutional controls would not provide long-term protection of human health
and the environment.
Short-term Effectiveness. The Ex-Situ/ln-Situ Bioremediation alternative is the most effective
treatment alternative in the short-term. It is estimated that this response action could be
completed (Le., reach MCLs) in approximately 10 years under ideal conditions. The Ex-Situ
Bioremediation alternative would require thousands of years to be effective. Institutional
controls on the BWP property may provide an effective short-term remedy in that they may
reduce the potential for human exposure immediately; however, the ability to implement
institutional controls off the property is questionable. Construction of the extraction and
treatment systems for Ex-situ and Ex-situ/ln-situ Bioremediation would be identical except Ex-
situ/In-situ would add the nutrient oxygen component. . Therefore, these alternatives present
similar short term risks during construction. Any risks presented by construction could be
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controlled or eliminated by proper construction and health and safety techniques.
construction is required for institutional cOl}trols.
No
Imolementabilitv. The two active treatment alternatives are expected to be easily
implementable. Ex-situ/ln-situ Bioremediation has been successfully implemented at a number
of sites, one of which is very similar to the BWP site and can serve as a model (i.e., the Libby
Superfund site). Of the two active treatment alternatives, the Ex-Situ Bioremediation alternative
is slightly more implementable given that it does not require the construction of a nutrient
component unit. The implementability of stand-alone institutional controls outside of the BWP
property is questionable. This is due to uncertainties regarding the legal and/or administrative
mechanisms for implementing and enforcing the controls. More information on institutional
controls is provided in the Description of Alternatives section.
Cost. The total present worth costs for each ground water alternative are estimated as follows:
Alternative 2 - Institutional Controls
Alternative 3 - Ex-situ Bioremediation
Alternative 4 - In-situ/Ex-situ Bioremediation
$ 812,000
$ 9,280,000
$10,460,000
State Acceptance. The State of Colorado has concurred with the selection of Alternative 4, Ex-
Situ/In-Situ Bioremediation, for the ground water.
Community Acceotance. The general public neither supported nor opposed EPA's selected
remedy. The PRP, BIC, generally opposed the selected remedy and instead supported
containment of the LNAPL and institutional controls/monitoring for the dissolved contamination
in the ground water. Specific comments submitted by the public during the comment period.
and EPA responses to those comments, are included with this remedy selection as part 01 the
Responsiveness Summary.
Buildings, Vessels and Drums and Their Contents
Overall Protection of Human Health and the Environment. Alternative 1. no-action, would not
provide protection of human health, since the structures and their contents would be left in
place and would pose risks through direct contact. Leaching of the contaminants to the
ground water below would continue to present an environmental risk. Because this no-action
alternative would not meet this threshold criterion, it is not included further in the analysis.
Alternative 2 would be protective of human health and the environment by reclamation of any
useable components and disposal 01 the remaining components at a RCRA-permitted facility.
Since Alternative 2 is the only active remedial alternative identified for the structures and their
contents and would meet all ARARs, the comparative analysis is not continued further.
IX.
SELECTED REMEDY
After consideration of the statutory requirements of CERCLA, the detailed analysis of the
alternatives, and public comments, EPA has determined that the most appropriate remedy for
the site is as follows:
Soils/sediments
-Ex-Situ Bioremediation for the organics contaminated soils (Soils Cleanup
Alternative 4),
-Chemical fixation of the metals contaminated soils,
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-Institutional Controls for the organics-contam.inated soils remaining after
treatment.
-Closure of the former sludge impoundments
Ground water
-Ex-Situ/ln-Situ Bioremediation and institutional controls for the surficial aquifer
(Ground water Cleanup Alternative 4),
-Institutional controls for the Denver aquifer,
-Drilling of additional wells in the Arapahoe aquifer to further characterize the
aquifer and contamination, if any,
-Monitoring of the three aquifers.
Structures and Their Contents
-Demolition and Disposal of buildings, vessels and drums to a RCRA-permitted
landfill,
-Reclamation of scrap metal and contents,
-Disposal of basement and sump water to a RCRA-permitted landfill.
Remedy for Soils/Sediments
The remedial alternative selected by EPA to remediate the soils and sediments is Alternative 4,
Ex-situ Biorernediation. This soil remediation technology will involve excavation and on-site
biological treatment of organics-contaminated soils and sediments in a "land-treatment unit"
(LTU). This LTU will be constructed by building earthen berms around the unit, then placing a
synthetic liner and leachate collection and recovery system and a compacted filter material
over the liner. The remediation process will include excavating the soil, based on the action
levels set out below in Table 11, separating the oversized rocks, and moving the soil to the
LTU. Once placed into the LTU, the soils will be land farmed to meet the treatment levels set
out in Table 12. The RCRA land treatment requirements, Subpart M, 40 CFR ~264.270 to
264.283 are applicable to this alternative. The L TU will be designed, operated, and closed in
compliance with these regulations. EP A is including, as extra protective measures, the liner
and leachate collection system, as well as closure with a multi-layered cap.
Approximately 120 cubic yards of organics-contaminated sediments from Fisher Ditch will be
excavated and treated to remove water. After removal of water, these sediments will be placed
in the L TU for treatment. No LDRs apply to placement of these sediments because the level of
contamination is already below LDR standards.
The leachate from this process will be isolated from the site subsoils by the liner and collected,
treated, and reused in the treatment process. Lysimeters may be used below the liner to
collect soil p.ore liquid, which together with soil cores taken at random locations within the land
treatment unit soils, will be periodically collected and analyzed to determine removal efficiency
and contaminant levels. In addition, monitoring will be conducted in accordance with the
requirements of the land treatment regulations and the general RCRA monitoring requirements
0140 CFR 264 Subpart f. This process will be capable of treating contaminated sub-soils, as
well as the upper 12 inches of surface soil.
Pilot studies of the land treatment unit will be conducted at the Broderick site at the initial
stages of the RA phase to better define removal rates and efficiencies and to optimize the
addition of nutrients and water.
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Excavation and placement of the contaminated soils into the L TU will trigger the RCRA LOR
standards for the K001 wastes from the impoundments. These LDR treatment standards will
not be met at the time of placement in the L TU. Therefore, EPA will invoke a temporary waiver
of the LOR treatment standards through an interim action waiver. At the completion of the
remedial action, the LDR requirements will be met through a treatability variance for soil and
debris. The treatability variance treatment level ranges or percent reduction ranges that Ex-situ
Bioremediation will attain for the constituents are discussed later in this section and presented
in Table 12.
The treated soil will remain in the L TU following treatment and the L TU will be closed in
accordance with the RCRA land treatment requirements and general RCRA closure
requirements.
The selected remedy will not be protective for residential uses of the site. Therefore, exposure
and access to organics-contaminated soils, both treated and untreated, will be controlled by
the use of deed restrictions or other institutional controls to prohibit non-industrial uses of the
site. The cost of instituting these controls is not known at this time.
The treatment process in the L TU will extend over a seven-year period. This alternative will be
monitored continuously during operation. Because hazardous substances would be left on the
property, the protectiveness of the remedy would be reviewed at least every five years as
required by CERCLA. The volume to be treated is expected to be approximately 59,000 cubic
yards.
In addition to the organics contaminated soil and sediment, approximately 800 cubic yards of
soils contaminated with heavy metals above RCRA Toxicity Characteristic levels will be treated.
This soil will. undergo chemical fixation using such stabilization compounds as cement or fly
ash to form a chemically and mechanically stable material. Treatability studies will be
conducted to determine the best stabilization compound for the wastes at the site.
The metals-contaminated soils will be excavated and then mixed with water and the fixation
agents. The resultant product will be poured into forms. Once the material is solidified. the
solid blocks will be removed from the forms and allowed to cure. After the blocks have cured,
they will be transported to an off-site, RCRA Subtitle D-permitted landfill for disposal. LOR
standards will apply to this action. The heavy metals which have LOR standards are arsenic
(D004), cadmium (D006) and lead (D008). To meet the LOR standards, it will have to be
shown that the stabilized soil is below Toxicity Characteristic levels. The LDR standards for
these metals are presented in Table 12, below.
The former sludge impoundments are RCRA interim status units. Although with Ex-Situ
Bioremediation contaminants in the subsurface soils will be excavated and treated, it is still
expected that waste residuals will be left in place in the impoundment area after treatment.
Therefore, RCRA interim status requirements for closure with wastes in place are ARARs for this
alternative. As such, these impoundments must be closed in compliance with RCRA interim
status regulations found in 40 CFR 265.228 and Subpart G of 40 CFR 265.
Remedy For The Surficial Aquifer Ground Water
The ground water remedial alternative selected by EPA to remediate contaminated ground
water in the surficial aquifer is Alternative 4, Ex-situ/ln-situ Bioremediation. This alternative will
involve the collection of 526 million gallons of ground water and light non-aqueous phase
liquids (LNAPL) from the surficial aquifer in a series of subsurface drain trenches on the BWP
property and at least one recovery well off the property. These trenches will be located in the
areas of highest ground water contamination and will extend to sufficient depth to intersect the
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unweathered Denver Formation. This depth may range from approximately 20 to 35 feet,
depending on the depth to bedrock. Most of this ground water and LNAPL will come from the
surficial aquifer, although small amounts of dense non-aqueous phase liquids (DNAPL) and
ground water will also be extracted from the Denver aquifer through three existing monitoring
wells and any new monitoring wells which encounter DNAPL
An on-site water treatment plant will be constructed. This plant will be designed to first remove
LNAPL and DNAPL from the ground water in an oil/water separator. These NAPLs will be
reclaimed by placing them in tanks or drums, then shipping them to an off-site recycling facility.
The plant will then treat the water in a two-stage, fixed-film bioreactor, similar to a common
water treatment plant. The water will be batch processed in several large tanks using nutrients,
aeration, heat, and mixing to provide an environment conducive to rapid bioremediation. Small
quantities of the treated water will be used for the soil remediation processes and the
remaining treated water will be reinjected into the surficial aquifer. This ground water treatment
will substantially reduce organics in the ground water before each reinjection in compliance
with RCRA section 3020.
An in-situ treatment system similar to the one selected for the Broderick site is currently
operating at the Ubby Superfund site in Montana. The advantage that this system has over
common pump-and-treat systems is the ability to both treat contaminants In the aquifer and to
desorb contaminants from soil particles in the aquifer to allow their removal to the water
treatment plant. Although it is often difficult to predict the ultimate concentration to which
contaminants in the aquifer may be reduced, the ground water models in Appendix B of the FS
indicate relative cleanup times may be as short as 11 days to as long as 1 0 years for specific
chemical contaminants using this alternative. Even assuming that these values are based on
simplified model parameters, the modeling indicates this approach will achieve all ARARs in a
reasonable period of time. .
Institutional controls will be applied to the future use of the ground water. Institutional controls
might include deed restrictions, covenants, or acquisition of property rights. Deed restrictions
or other institutional controls could be placed on future uses of ground water on the Broderick
property by the current owner to control access to the contaminated water in the surficial and
Denver Aquifers. In fact, the owners of the Broderick site have indicated that they would
cooperate with placing deed restrictions or covenants on the property.
EPA has determined that it is technically impracticable to actively remedlate the Denver aquifer
due to its hydrogeologic characteristics. The Denver aquifer under the BWP property Is made
up of small lenses of permeable sandstones interbedded in near-impermeable claystone which
significantly limits the ability to pump and treat the contaminated ground water. Due to the
small areal extent of the permeable lenses, the contaminated ground water is confined to within
a few hundred feet 01 the impoundments. Consequently, institutional controls and monitoring
will be required for the Denver aquifer. Federal and state ground water standards identified as
ARARs will not be met under this remedial alternative. These ARARs are being waived due to
technical impracticability. If new information indicates that it is not technically impracticable to
treat the Denver aquifer under the Broderick property, or if monitoring or other Information
shows that the remedy is not protective, EPA will reconsider the remedy chosen for this aquifer.
In addition, the ground water in the Arapahoe aquifer will be tested to determine the level of
contamination. This investigation will include the installation of new monitoring wells,
completion of a constant discharge aquifer test, sampling the new and existing Arapahoe wells,
and analyzing the samples in a laboratory. If contamination is found, the aquifer will continue
to be monitored and appropriate measures will be taken.
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The selected remedy will include surficial ground water extraction and ex-situ/in-situ
bioremediation for an estimated period of ten years, during which time the' system's
performance will be monitored on a regular basis and adjusted as warranted by the
performance data collected during operation. Modifications may include any or all of the
following:
.
Discontinuing pumping in areas of the surficial aquifer where cleanup goals have been
attained;
.
Alternating pumping at locations to eliminate stagnation points;
Pulse pumping to allow surficial aquifer equilibration and encourage adsorbed
contaminants to partition into ground water;
.
.
Installing additional extraction trenches or wells to facilitate or accelerate cleanup of the
contaminant plumes.
The proposed treatment time for the volume of water discussed above includes one year for
constructing the water treatment unit and. approximately 10 years 01 operation for cost
purposes. Since contaminated ground water will remain on the site, five-year CERCLA reviews
will be conducted by EPA.
Remedy for the Buildings, Vessels and Drums and Their Contents
The remedial alternative selected by EP A to address the buildings entails demolishing and
temporarily stockpiling the debris on the site. Under this alternative, the buildings will be
demolished and the building debris temporarily stockpiled on the Broderick property. The
process building contains asbestos contaminated materials. Demolition and disposal of these
materials will be done in compliance with Federal and state regulations identified as ARARs
including State Air Quality Regulation 8 and the National Emission Standard for Asbestos. An
estimated 225 tons 01 scrap metal will be transported for disposal at an off-site recycling facility.
An estimated 850 cubic yards of building debris and 205 cubic yards of asbestos-containing
materials will be disposed in appropriate off-site, permitted landfills.
Significant quantities (an estimated 42,000 gallons) of organic liquids and sludges remain in the
drums and vessels at the Broderick, site. The vessel contents will be pumped or excavated,
stored temporarily on the Broderick property, and then transported to an off-site reclamation
facility, along with the contents already in drums. This storage and transportation will require
compliance with all RCRA hazardous waste generator and transporter requirements.
Approximately 9,500 gallons of contaminated water remain in building sumps and basements
at the site. This includes some fire water contaminated with asbestos left from the process
building fire in 1985. This water will be pumped, stabilized, drummed and transported to a
RCRA-permitted landfill. .
The time for demolition and removal of all building materials from the site is estimated at one
year.
Cost Of The Remedy
Table 10 shows the detailed cost summary for the selected remedy as a whole. The total cost
estimate for the remedy is $15.5 million. Some changes may be made to the remedy as a
result of the remedial design and construction processes. Such changes, in general, reflect
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TABLE 10
BRODERICK WOOD PRODUCTS SITE
SELECTED REMEDY
COST ESTIMATE SUMMARY
Total
Present Present
Capital Worth Worth
Description Cost O&M Cost Cost
A. Direct Cost Summary
Solis:
Site Preparation. Mobilization, establishment, and $162,150 $124,002 $286,152
continued operation of on-site support facilities
including offices and equipment, decontamination
facilities and utility hookupS (water, electric, etc.).
Other site preparation activities include construction of
support facilities for on-site surface biological
treatment, on-site chemical fixation, and materials
handling.
Construct ex-Situ Biological Treatment System - $383,527 $0 $383,527
The components of the ex-situ biological treatment
system will be constructed. The major components
include a perimeter dike, a lined treatment area, and
irrigation equipment.
Excavate 5011 Containing Organics above Action $702.050 $0 $702,050
. Levels - Soils containing organics above action levels
would be excavated and stockpiled near the ex-situ
biological treatment unit.
Treat 5011 Containing Organics above Action $0 $747,924 $747,924
Levels In the ex-Situ Biological Treatment Unit -
Soil containing organics above action levels would be
treated in the ex.situ biological treatment unit. The soil
would pass through size separation and mixing
operations prior to treatment, if necessary. Treated
soil would remain in the treatment area.
Excavate 5011 Containing Metals above Action $10.189 $0 $10,189
Levels - Soil containing metals above action levels
. would be excavated and stockpiled near the chemical
fixation area.
Chemically Fix 5011 Containing Metals above $242,503 $0 $242.503
Action Levels and Place Treated 5011 In a Solid
Waste landfill - Soil containing metals abOve action
levels would be chemically fixed at an on-site location.
The soil would pass through size separation and
mixing operations prior to treatment as necessary.
Treated soil would be placed in an off-site solid waste
landfill.
100')1, Rec:yc:ted
ibrodrick\lable - 1 O\010592\pg. 1
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TABLE 10
BRODERICK WOOD PRODUCTS SITE
SELECTED REMEDY
COST ESTIMATE SUMMARY
Description
Capital
Cost
Present
Worth
O&M Cost
Total
Present
Worth
Cost
Solis (cont'd):
Backfill Impoundments to Grade and Cap. Each
impoundment would be backfilled with fill material 10
achieve an acceptable grade.
Soli Remedy Direct Costs Subtotals:
Groundwater:
Conduct Further Investigation of Arapahoe Aquifer
. Further investigation ot the Arapahoe aquifer would
be initiated 10 confirm the absence ot any impacts
(see Remedial Investigation, p.6-88). This
investigation includes installation 'of new monitoring
wells, completion of an aquifer constant discharge
test, and monitoring of groundwater levels and
groundwater quality.
Construct, Operate, and Maintain Wastewater
Treatment System - A wastewater treatment system
would be constructed to treat recovered groundwater
and NAPL and water trom buildings and vessels. The
wastewater treatment system would be designed to
treat wastewater at a flow rate ot 100 gpm.
Install, Operate, and Maintain Groundwater
Recovery/Recharge System - A series of subsurface
trenches would be constructed for recovery of surficial
aquifer groundwater and LNAPL and for recharge of
treated wastewater. The groundwater
recovery/recharge system would also include all of the
necessary equipment tor addition ot oxygen and other
nutrients for in.situ subsurface biological treatment.
This step also includes installation of any new,
groundwater monitoring wells deemed necessary tor
monitoring system performance or for monitoring
potential migration of contaminants of interest.
'\brodrick\labI8_10\010592\pg.2
$217,983
$1,718,402
$97,089
$1,161,500
$1,486,950
$0
$871,926
$0
$779,376
$199,551 ,
$217,983
S2.590,328
$97,089
$1,940,876
$1,686,501
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TABLE 10
BRODERICK WOOD PRODUCTS SITE
SELECTED REMEDY
COST ESTIMATE SUMMARY
Total
Present Present
Capital Worth Worth
Description Cost O&M Cost Cost
Operate and Maintain Groundwater $11,500 $3,782,548 $3,794,048
Recovery/Recharge System - The groundwater
recovery and recharge system would begin operation
following construction of recovery and recharge
systems and the wastewater treatment plant. The
wastewater treatment plant would undergo start-up
operations and testing prior to full-scale operation.
Operation of the groundwater recovery and recharge
system would also include routine monitoring and
reporting of groundwater elevations and groundwater
quality in the surficial and Denver formations. Full-
scale operations would continue until response
objectives have been met.
Groundwater Remedy Direct Cost $2.757.039 $4.761.475 $7,518.514
Subtotal:
Buildings, Vessels, and Drums:
Remove Vessel and Drum Contents - The vessel $418,922 $0 $418,922
contents would be removed by pumping or
excavating as appropriate. Partial demolition of some
vessels may be required to access the contents and
completely remove all vessel contents. Vessel
contents would be temporarily stored on-site prior to
transport and off.site reclamation.
Remove Building Contents and Demolish $530,854 $0 $530,854
Buildings - Removal of building contents would be
conducted in conjunction with building demolition.
Building water would be pumped, stabilized,
drummed, and transported to a RCRA permitted
landfill. Building debris would be stockpiled, as
necessary, and then transported to an off-site
hazardous waste landfill.
Building, Vessels, and Drums Remedy $949.776 ~ $949.776
Direct Cost Subtotal:
TOTAL DIRECT COSTS $5.425.217 $5.633.401 $11.058.618
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TABLE 10
BRODERICK WOOD PRODUCTS SITE
SELECTED REMEDY
COST ESTIMATE SUMMARY
Total
Present Present
Capitat Worth Worth
Description Cost O&M Cost Cost
B. Indirect Cost Summary
Engineering Design - Developing finat designs and $815,085 $59,049 $874,134
bid specifications for site preparation, ex-situ
biologicat treatment equipment, on-site landfill,
wastewater treatment units and support facilities and
updating designs during treatment period.
Obtain Necessary Approvals - Approvals for off-site $29,581 $0 $29,581
landfilling of building debris and asbestos and off-site
reclamation of NAPL creosote/PCP materiat, and
scrap iron would be received before any associated
removal activities are initiated.
Engineering Administration (10% of Direct Capital $626,988 $569,245 $1.196,233
Costs)
Contingency (20% of Direct Capital Costs) $1.253.977 $1.138.490 $2.392.467
TOTAL INDIRECT COSTS $2.725.631 $1.766.784 $4.492.415
TOTAL COST OF SELECTED REMEDY*'
$8,150,848
$7,400,185
$15,551,033
* Does not include costs for institutional controls.
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modifications resulting from the engineering design process. For example, the amount of soils
and sediments to be treated will depend on verification sampling, and the extent of the ground
water extraction system for Ex-situ/ln-Situ Bioremediation will depend on ground water
sampling.
Remedial Action Objectives
The objectives of this remedial action are to: control present and future risks posed by direct
contact to and/or ingestion of and/or inhalation of contaminated soils, sediments and ground
water; to control the migration of contaminants from the soils to the aquifer systems; and, to
prevent significant future human exposure to residual contamination in the soils and sediments
and ground water. Other objectives are to remove and properly dispose of the buildings,
vessels and drums and their contents including asbestos. The objectives will be met by
attaining remedial action 'goals.
Remediation Goals and Action Levels for The Soils/Sediments
For soils and sediments the remedial goal is excavation and treatment so that the level of
contaminants remaining in these materials poses no unacceptable risk to human health and
the environment. Because the location, characteristics, and use of the site make its future use
for residences unlikely. action levels to be met by the remedial action for the soils and
sediments were established using an industrial use scenario. Determination of excavation and
treatment standards for soils and sediments has been conducted using two methods: 1)
Evaluation of the standards in various ARARs, such as BOAT concentrations in the Land
Disposal Restrictions; and, 2) use of a human health risk assessment to determine
contaminant concentrations which are protective of human health. Since the total Hazard
Index using an industrial use scenario is below 1 .00, non-carcinogenic health risks due to the
soils are not indicated. Therefore, excavation and treatment standards are not required for the
non-carcinogenic compounds in the soils and sediments. EPA has determined that the
following action levels and treatment levels for the carcinogenic compounds are protective of
human health and the environment and are in compliance with ARARs. The remediation
activities for soils and sediments will be required to meet these levels.
Excavation of Soils/Sediments. Contaminated soils from the impoundment, process and
surrounding areas will be excavated using a method that will ensure that a cumulative cancer
risk level of 10-5 is achieved in unexcavated soils. One such method applies health-based
cleanup levels presented in Table 11, and uses "cleanup level indices (CLI)" as calculated by a
formula described in Exhibit C for determining when excavation of soils is necessary. A CLI of
less than one for a particular location indicates that the total cancer risk associated with all
chemicals in the location is below the target risk level. If the CLI is one or greater in a particular
location, then excavation will be required. The decision on the specific method to be used will
be made when the sampling and analysis program is developed during remedial design.
Fisher Ditch sediments with concentrations of carbozole greater than the 23.2 mg/kg will be
excavated and treated. This action level is based on ecological risk factors.
Treatment Levels for Excavated Soils. Table 12 lists the treatment levels to be achieved in the
L TU for the soils from the impoundment, process and surrounding areas. . Benzo(a)pyrene and
dibenzo(a,h)anthracene together represent 96% of the risk from the carcinogenic PAHs.
Reducing the concentrations of these two PAH compounds to their treatment levels should
reduce the total risk from the PAHs to or below the 10-5 risk level for an industrial use scenario.
Therefore, these two compounds are used as indicators for total PAH reduction. The 2.3,7,8-
TeDD equivalent concentration incorporates all dioxins/furans found in the soils.
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TABLE 11
BRODERICK WOOD PRODUCTS SITE
HUMAN HEALTH BASED CLEANUP lEVELS (HBCl)
1 OE-05 CANCER RISK lEVEL
INDUSTRIAL WORKER
HBCl
Chemical of Interest (mg/kg)
Carbozole 2,222.22
Benzo(a)anthracene 1,250.00
Chrysene 5,988.02
Benzo(b)fluoranthene 146.41
Benzo(k)fluoranthene 117.51
Benzo( a)pyrene 15.02
Dibenzo(a,h)anthracene 13.91
Indo(1,2,3-cd)pyrene 578.03
Benzene 2,557.54
Pentachlorophenol 1,890.36
Pentachlorodibenzo-p-dioxin 0.000303
Hexachlorodibenzo-p-dioxin 0.001517
Heptachlorodibenzo-p-dioxin - 0.015175
Octachlorodibenzo-p-dioxin 0.151745
Arsenic 6.134969
'.
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TABLE 12
BRODERICK WOOD PRODUCTS SITE
TREATMENT LEVELS
FOR SOILS AND SEDIMENTS
Mean Conc. Treatment
Surf.1Sub. Level
Chemical (mglkg) (mgJkg)
ORGANICS:
Total PAHs
benzo(a)pyrene 35.9/4.5 15.2
dibenzo(a,h)anthracene 41.816.5 13.9
2,3,7.8- TODD equivalent .0006*
K001 Constituent. *
Naphthalene 3671142 95-990/0
Pentachlorphenol 6531380 90-99%
Phenanthrene 556n5 95-99%
Pyrene 356/28 95-99%
Toluene .6/1.2 .5-10
Xylene (Total) 2.7n.5 .5-10
Lead NA 99-99.9%
METALS:
Arsenic * .. 29.7/3.8 5.0
Cadmium *.. 24.7/.2 1.0
Lead*.. 838.2126.7 5.0
. Laboratory detection limitations may not allow measurement to this level.
In that case, the detection limit will be the treatment level. The currently
recognized detection level of 1 pglkg corresponds to a cancer risk level
close to 1 0(-5).
.. Remedy will comply with LDRs through a Treatability Variance.
Treatment levels or percent reduction ranges that Ex-situ Sio will attain
are presented.
... Action levels are based on non-wastewater TCLP (mgJl).
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Ex-Situ Bioremediation of the organics-contaminated soils will comply with the LORs through a
treatabifity variance. The treatability variance treatment level ranges or percent reduction
ranges (considered ARARs) that Ex-situ Bioremediation will attain for the K001 constituents are
listed in Table 12. These treatment levels fall within the 10-6 to 10-7 risk range for an industrial
use scenario.
tOA standards will apply to the metals-contaminated soils. To meet the LOA standards, it will
have to be shown that the stabilized soil is below Toxicity Characteristic levels. These
treatment levels are also listed in Table 12.
The treatment levels for the sediments will be the same as for the organics-contaminated soils.
The health risks of dioxins are presently being reassessed by the Office of Research and
Development (ORO). If EPA's policy on dioxins changes due to this reassessment before or
during the implementation of this remedy, the equivalency concentrations for dibenzo-p-dioxins
and dibenzofurans combined will be changed accordingly.
Remediation Goals and Treatment levels for the Surficial Ground Water
Remediation goals for the surficial ground water are: 1) restoring the contaminated ground
water to a quality consistent with its potential future uses; 2) protecting uncontaminated ground
water by minimizing the migration of contaminants within the ground water; and, 3) ensuring
that the level of contaminants remaining in ground water poses no unacceptable risk to human
health and the environment.
Ground water cleanup criteria to meet the remediation goals have been determined by
examination and consideration 01 pre-established AAARs such as the Sa1e Drinking Water Act
Maximum Contaminant Levels (MCLs) and the Colorado Basic Standards 10r Ground Water
and the use of a human health risk assessment to determine contaminant concentrations
which are protective 01 human health.
Table 13 lists the treatment levels for the surficial aquifer. EPA has determined that ground
water treatment levels for carcinogenic compounds will be the following for the surficial aquifer:
1) total 2,3,7,B-TCDD equivalency concentrations for dioxins/turans will be reduced to no
greater than 0.5 pg/L (picograms per liter); 2) trichloroethylene will be reduced to
concentrations no greater than 5 micrograms per liter (ug/L); 3) tetrachloroethylene will be
reduced to concentrations no greater than 1.6 ug/L; 4) carbozole will be reduced to
concentrations no greater than 4.1 ug/L; and, 5) other organics, i1 detected, which may be
present in the ground water will be reduced to the most stringent Federal or state standard
identified as an AAAR or TBC. The total TCOD equivalent is a proposed MCL. The treatment
level for trichloroethylene is a Colorado Basic Groundwater Standard. Although a Colorado
Basic Standard applies, the more stringent risk-based level was selected for
tetrachloroethylene. The treatment level for carbozole was determined by risk analysis and
corresponds to a 10-6 risk level.
EPA has also determined that groundwater treatment levels for non-carcinogenic compounds
will be as listed in Table 13. All of these treatment levels, except for PCP, were determined by
risk analysis and correspond to Hazard Quotients less than 1. The treatment level for PCP is a
Proposed MCL identified as a TBC.
One of the goals 01 the ground water component 01 this remedial action is to restore the
surficial ground water to a quality consistent with its. beneficial use which is for domestic use.
Based on information obtained during the remedial investigation, and the analysis of all
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TABLE 13
BRODERICK WOOD PRODUCTS SITE
TREATMENT LEVELS FOR GROUNDWATER
Mean Treatment
Concentration Level
Chemical (pgJl) (pgll)
Carcinogenic Chemicals:
2.3.7,8- TCDD equivalent 5 x 10(-5}
Trichloroethylene 6.6 5.0
Tetrachloroethylene 1.8 . 1.6
Carbozole 92.0 4.1
Non-carcinogenic Chemicals:
Naphthalene 1653.7 41.6
Acenaphthene 372.7 623.0
Fluorene 544.7 416.0
Anthracene 248.9 3120.0
Fluoranthene 460.5 416.0
Pyrene 643.7 312.0
Phenol 219 623.0
2-methyphenol 307 520.0
4-methyphenol 286.7 520.0
2,4-dichlorophenol 162.9 31.2
2,4,5-trichlorophenol 171.2 1040.0
Pentachlorophenol 7862.0 1.0
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remedial alternatives, EP A and the Colorado Department of Health believe that the selected
remedy will achieve this goal. However, ground water contamination may be especially
persistent in the immediate vicinity of the source of contamination, where concentrations are
relatively high. The ability to achieve cleanup levels at all points throughout the area of
attainment, or plume, cannot be determined until the extraction system has been implemented,
modified as necessary, and plume response monitored over time. If EPA determines that the
selected remedy cannot meet the specified remediation levels at any or all of the monitoring
points during implementation, modification of the remedy may be necessary.
Remediation Goals and Cleanup Criteria for the Buildings, Vessels and Drums and Their
Contents
For the buildings, vessels and drums and their contents, the remedial goals are based on
removal and/or recycling of the buildings, vessels and drums and their contents, so that they
will no longer pose an unacceptable risk to human health and the environment.
Demolition and disposal of the buildings, vessels and drums and their contents will be done in
compliance with Federal and State regulations identified as ARARs. Also, all asbestos ARARs
will be met. ..
X. STATUTORY DETERMINATIONS
EPA's primary responsibility under Superfund is to select remedial actions that are protective of
human health and the environment. CERCLA also requires that the selected remedial action
comply with applicable or relevant and appropriate environmental 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 the soils/sediments, ground water and structures and their contents meets
these requirements.
Protection of Human Health and The Environment
The remedy selected for the organics-contaminated soils/sediments at the Broderick Wood
Products site will protect human health and the environment by treating the soils/sediments
using Ex-Situ Bioremediation to degrade and/or destroy and isolate the organic contaminants.
The remedy will also chemically fix the metals-contaminated soils. Contaminant levels in the
un excavated organics-contaminated soils/sediments will be reduced to, or below the 10-5
cancer risk level based on the industrial use scenario. Contaminant level reductions in the L TU
will be within 10-4 to 10-5 risk range. The risks in both the unexcavated soils/sediments and the
L TU fall within the 10-4 to 10-6 risk range specified by the NCP. Following the remedial action,
the hazard index for non-carcinogens will be less than one. The liner and leachate collection
system for the L TU and closure of the L TU with a multi-layered cap are extra precautionary
measures and will minimize human exposure to any residual contaminants.
The remedy selected for ground water at the site will protect human health and the
environment by reducing the levels of contaminants found in the surficial aquifer to Federal and
state groundwater standards or risk-based levels found in Table 13. Restoration of the surficial
ground water to these standards will ensure that ground water at the site will comply with the
Safe Drinking Water Act and the Colorado Basic Standards for Groundwater, thereby providing
protectiveness in the case of ingestion 01 or contact with the water. Although the surficial
ground water is not currently believed to be used for drinking water purposes in the vicinity of
the site, it is a potential drinking water source. Institutional controls will be required and
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implemented to the extent allowed by law for the surficial and Denver Aquifers. Institutional
controls for the two aquifers will' assist in reducing the possibility of human exposure to
contaminated ground water. All three aquifers will be monitored for up to 30 years.
The remedy selected for the buildings, vessels and drums will protect human health and the
environment by reclamation of any useabJe components and disposal of the remaining
components at a RCRA-permitted facility.
Of the alternatives evaluated for cleaning up soils/sediments, ground water and structures and
their contents, the selected remedy provides the best protection of human health and the
environment. No unacceptable short-term risks or cross-media impacts will be caused by
implementing this remedy.
Attainment of ARARs
All ARARs will be met upon completion of the selected remedy or a waiver will be available.
Federal and State ARARs and to-be-considered (TBC) items for the selected remedy are
presented in Exhibit B.
Chemical Specific ARARs. The selected remedy will comply with chemical-specific ARARs
related to ground water and ambient air quality. The principal chemical-specific ARARs for the
selected remedy are primary drinking water standards (MCLs) established under the Safe
Drinking Water Act which are relevant and appropriate. MCLs have been designated for some
contaminants at the site. MCLs have been proposed for other contaminants. Proposed MCLs
are TBCs and will also be met. The Colorado Basic Standards for Ground Water are ARARs
and will be met. These ground water ARARs and TBCs will be met in the surficial aquifer
through implementation of the ground water extraction and treatment system. These ground
water ARARs and TBCs will not be met in the Denver aquifer beneath the BWP property due to
technical impracticability. Therefore, these ARARs are waived for the Denver aquifer by the
signing of this ROD. .
Action Specific ARARs. The selected remedy will comply with all action specific ARARs.
Certain RCRA requirements have been found to be ARARs for the selected remedy. RCRA land
disposal restrictions (LDRs) are applicable to portions of the selected remedy because soils
contaminated with K001 wastes will be placed in the LTU in a manner that falls within the RCRA
definition of "placement." Since LOR treatment standards for these K001 wastes will not be met
upon placement in the LTU, the treatment requirement is temporarily waived using an interim
measures waiver, granted through the signing of this ROD. The placement of these wastes will
be followed by treatment with biodegradation. This treatment will comply with the LDRs for
K001 waste through a soil and debris treatability variance also granted by the signing of this
ROD. The interim measures waiver will not cause additional migration of contaminants,
complicate the site response, present an immediate threat to public health or the environment,
or interfere with or delay the final remedy.
LDRs are also applicable to metals-contaminated soils. These soils will be solidified to meet
the LORs.
RCRA requirements for land treatment facilities are applicable to the LTU. These requirements
will be met in designing, operating and closing the L TU. Even though not required by the land
treatment regulations, the LTU will include, as an extra precautionary measure,an impermeable
bottom liner and multi-layer cap to prevent the migration of contaminants during and after
treatment.
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Closure of the RCRA interim status impoundments will occur during the CERCLA action. All
RCRA closure requirements and monitoring requirements will be met and it is intended that
formal RCRA closure will be accomplished simultaneously through coordination with RCRA
authorities.
This alternative will comply with Federal and State air quality regulations during construction
and implementation of the remedy.
RCRA section 3020 is applicable to the reinjection of treated ground water into the surficial
aquifer. As required by RCRA section 3020, treatment before reinjection will substantially
remove the contaminants from the water.
Location Soecific ARARs. No location specific ARARs were identified for this site.
To Be Considered (TBCs). While not ARARs, TBCs should be considered with regard to
designing, implementing, and operating the remedy. Proposed MCLs are TeCs for this action
and will be met. .
Cost Effectiveness
EPA believes the selected remedy is cost-effective in mitigating the principal risks posed by the
soils/sediments, contaminated ground water and the structures and their contents within a
reasonable period of time. Section 300.430(f)(ii)(D) of the NCP requires EPA to evaluate cost-
effectiveness by comparing all of the alternatives which meet the threshold criteria against three
additional balancing criteria: long-term effectiveness and permanence; reduction of toxicity,
mobility or volume through treatment; and, short-term effectiveness. The selected remedy
meets these criteria and provides for overall effectiveness in proportion to its cost. The
estimated cost for the selected remedy is $15,500,000.
The selected remedy for the soils provides the best overall effectiveness of all alternatives
considered proportional to its cost. The selected remedy will greatly reduce the toxicity,
mobility, and volume of soils exceeding the selected action levels. Also, the implementation of
this remedy will result in long-term effectiveness by reducing residual carcinogenic risks to 10-5,
based on continued industrial use of the site, through permanent treatment. Alternative 2,
Thermal Desorption, also provides high overall effectiveness, but Alternative 2 is much more
expensive than the selected remedy. Although Alternative 3, In-Situ Bioremediation, is less
expensive than the selected remedy, it does not provide as great a degree of long-term
effectiveness or reduction in TMV through treatment.
The selected remedy for ground water provides the best overall effectiveness of all alternatives
considered proportional to its cost. Alternatives 3, Ex-Situ Bioremediation, and 4, In-Situ/Ex-
Situ Bioremediation, will both reduce the TMV of affected ground water and will be permanent
solutions. However, Alternative 4 is the only alternative expected to reach MCLs within a
reasonable time. Alternative 4 will reduce TMV more rapidly and will require less material
handling and, therefore, has greater short-term effectiveness. Although the least expensive,
Alternative 2, Institutional Controls, will not reduce TMV and will not provide long-term
effectiveness and permanence.
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 the
Broderick site. Of those alternatives that are protective of human health and the environment
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and comply with ARARs, EPA has determined that the selected remedy provides the best
balance of trade-ofts in terms of long-term eftectivenessand permanence; reduction in TMV
achieved through 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. The following discussion of tradeoffs among remedial alternatives
is divided into sections for soils/sediments and ground water.
Soils/sediments. For the alternatives for remediating the soils/sediments, the more critical
evaluation criteria were: long-term effectiveness and permanence; reduction of toxicity,
mobility, or volume through treatment; and, cost. Alternative 1, No-Action, is not considered
since it would not meet the threshold criteria.
Alternatives 2, Thermal Desorption, and 4, Ex-situ Bioremediation, provide the greatest long-
term effectiveness and permanence. Each of these alternatives produce similar levels of
contaminant reduction. The excavation and treatment of surface and subsurface soils in
Alternatives 2 and 4 reduce residual risk to the 10-5 risk level based on an industrial-use
scenario. The residual risk from soils not excavated and treated is controlled by institutional
controls. Residual risks for treated soils are controlled through placement of the treated soils in
engineered waste management units and institutional 'controls. Alternative 3, In-Situ
Bioremediation, would provide a lesser degree of long-term effectiveness and permanence
because subsurface soils below 12 inches would not be effectively treated resulting in a greater
residual risk due to untreated soils and control of this greater residual risk would be more
dependent on institutional controls. The effectiveness and reliability of institutional controls is
considered to be less than for engineered controls.
Studies on this and other wood-treating sites have demonstrated potential treatment
efficiencies for the destruction of PAHs, PCP and dioxins/furans of 90% to 100% for the
treatment processes in Remedial Alternatives 2 and 4. These alternatives also decrease the
potential for contaminant mobility through engineering controls. Alternative 3 would be
expected to provide similar destruction efficiencies in the top 12 inches. Sub-surface soils
below 12 inches would not be treated, and therefore, the reduction of TMV would not be as
great. Also, Alternative 3 would not include engineering controls.
Alternative 2 would be the most costly alternative ($32.388 million). At $4.493 million,
Alternative 4 has the second highest cost. Despite a cost which is nearly an order of
magnitude less than that for Alternative 2, Alternative 4 will achieve a similar level of cleanup.
Alternative 3 would be the least costly ($3.039 million), but falls short with regard to long-term
effectiveness and permanence and reduction of TMV.
Ground Water. For the remedial alternatives for the surficial aquifer, the critical evaluation
criteria were ,the threshold criteria, overall protection 01 human health and the environment and
compliance with ARARs. Alternative 1, No-Action, is not considered since it would not be
protective 01 human health and the environment.
Ground water modeling for the surficial aquifer was conducted to determine the time it would
take to reach MCLs for the ground water under ideal conditions. The model was used only to
determine the relative effectiveness of the remedial alternatives. It predicted that, under ideal
conditions, it would take millions of years for institutional controls (Alternative 2), which rely on
natural attenuation, to reach MCLs. It also predicted that it would take thousands of years for
Alternative 3 (Ex-Situ Bioremediation) to reach MCLs. Thus, these alternatives would not
comply with ARARs, a threshold criterion, and Alternative 2 would not provide overall protection
of human health and the environment. Consequently, these alternativeS were eliminated from
further'selection consideration. Alternative 4, Ex-Situ/ln-Situ Bioremediation, is the only
alternative that meets the threshold criteria.
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The State of Colorado concurs with the selected remedy. The Proposed Plan for the site was
released for public comment on September 23, 1991. The Proposed Plan identified Ex-Situ
Bioremediation for the soils/sediments and Ex-Situ/ln-Situ Bioremediation for the surficial
aquifer. EPA reviewed all written and verbal comments submitted during the public comment
period which ended on November 22, 1991.
Preference for Treatment as a Principal Element
The selected remedial alternatives for remediation of the contaminated soils/sediments
(Alternative.4, Ex-Situ Bioremediation), ground water (Alternative 4, Ex-Situ/ln-Situ
Bioremediation). and buildings, vessels and drums and their contents satisfy the statutory
preference for remedies that employ treatment as a principal element. By treating
contaminated soils/sediments and ground water. the selected remedy incorporates the use of
treatment technologies. Two treatment technologies will be used for contaminants in the
soils/sediments: bioremediation for the organics-contaminated soils, and solidification for the
metals-contaminated soils. Contaminated ground water will be treated using Ex-situ/ln-situ
Bioremediation. Principal threats including the contents of the buildings, vessels and drum.s
and NAPLs will be removed and recycled, thus eliminating the need for treatment. Thus. the
selected remedy satisfies the statutory preference for remedies that employ treatment as a
principal element.
XI. EXPLANATION OF SIGNIFICANT CHANGES
The Proposed Plan for the Broderick site was released for public comment in September 1991.
The Proposed Plan identified Alternative 4, Ex-Situ Bioremediation, for the contaminated soils
and sediments, Alternative 4, Ex-Situ/ln-Situ Bioremediation, for the surficial groundwater and
Alternative 2 for the buildings, vessels, and drums as the preferred alternative. As noted above
in the Description of Alternatives section, the presentation of the alternatives in this ROD differs
from the presentation of the alternatives in the Proposed Plan. These presentation differences
are explained above and will not be repeated fully here.
The Proposed Plan presented a cost and excavation volume, based on the 10-4 action level, for
all soil remedial alternatives, but only presented a cost and excavation volume for the 10-5
action level for Ex-Situ Bioremediation. In the ROD, EPA has analyzed all soil remediation
alternatives at the 10-5 action level. This was done primarily to simplify the description and
comparison of alternatives. In order to maintain continuity between the Proposed Plan and the
ROD, the analysis and comparison of the soil remediation alternatives under the nine criteria for
the 10-4 and 1 eP action levels is presented below.
Overall Protection of Human Health and the Environment. Both the 10-4 and the 10-5
alternatives would provide overall protection of human health and the environment because
each alternative would reduce residual risk in the unexcavated soils to within the 10-4 to 10-6
risk range specified in the NCP. The 10-5 alternatives would provide a greater degree of
protection because of a greater degree of long term permanence and effectiveness and a
greater reduction of toxicity and mobility of contaminants through treatment.
Compliance with ARARs. All of the soil alternatives under either action level would comply with
all identified ARARs or would be waived.
Lona-Term Permanence and Effectiveness. The 10-5 alternatives would be expected to provide
a greater degree of long-term permanence and effectiveness because the residual risk in
unexcavated soils would be reduced to a lower level. The placement of the excavated soils in
engineered structures for the Thermal Desorption and Ex-Situ Bioremediation would also
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~
increase long-term effectiveness and permanence at the 10-5 level because there would be less
reliance on institutional controls to prevent exposure to residual risks. In addition, these two
alternatives would produce benefits for the overall remedy because containment and isolation
of the contaminated soils in engineered containment structures eliminates a potential source
for further contamination of the groundwater. The benefits of the engineered containment
structures are increased by use of the 10-5 action level because a greater volume of source
material would be removed and isolated.
The treatment endpoint for each of the three treatment technologies is expected to be about
the same. Therefore, reduction of residual risk through treatment would be expected to be
greater for the 1 0-5 alternatives because of the greater volume of soils which would be treated
to a reduced contaminant level.
Reduction of Toxicitv. Mobilitv. and Volume of Contaminants throuah Treatment. The 10-5
alternatives would provide a greater reduction of toxicity and mobility of contaminants since a
greater volume of soils would be treated.
Short-Term Effectiveness. The 10-4 alternatives present less short-term risk because less soil
would be excavated or treated. Less time would, therefore, be spent implementing the remedy.
Short-term risks for any of the alternatives under either action level can be controlled or
eliminated through proper construction and health and safety techniques.
Implementabilitv. Each of the alternatives under either of the action levels would be fully
implementable.
Cost.
10-4
10-5
In-Situ Bioremediation -
Ex-Situ Bioremediation -
Thermal Desorption -
$1.02 million
$1.81 million
$8.96 million
$ 2.43 million
$ 3.88 million
$31.78 million
Cost figures for In-Situ Bioremediation under the 10-5 action level were not calculated in the FS
and have been subsequently calculated by EPA.
State Acceptance. The State supports using the 10-5 action level but does not support the 10-4
action level.
Community Acceptance. BIC has stated its preference for use of the 10-4 action level. The
community has not indicated a preference for either action level.
EPA's determination to utilize the 10-5 action level was based on the results of the above
analysis and comparison as well as the stated preference in the preamble of the NCP for
remedies that reduce cancer risks as close to 10-6 as possible. EPA has determined that the
increased cost of implementing the 1 0-5 action level for excavation is justified by the increase in
long-term effectiveness and permanence both for soils and, as a result of greater source
reduction, for ground water. In addition, the 10-5 action level produces a greater reduction in
the toxicity and mobility of contaminants through treatment. The only criteria which favored the
10-4 action level were cost and short-term effectiveness. However, short-term effectiveness is
not a significant factor in this case because short-term risks can be easily addressed. The cost
difference between the two action levels under the selected remedy was not substantial. When
considered in terms of the selected. remedy for soils/sediments, the increase in cost of using
the 10-5 action level is accompanied by a proportional increase in overall effectiveness which
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results in the conclusion that use of the 10-5 action level for the selected remedy is cost-
effective.
Buildino Water
The selected remedy in the June 1988 ROD for OU1 provided that water in the building's
basement and sumps would be used as quench water for the on-site incineration of the
impoundment sludges. The incineration remedy was replaced by off-site reclamation 01 the
sludges. As a result, EPA reproposed, in the Proposed Plan for OU2, that the basement and
sump water be treated in the water treatment plant which was part of the preferred alternative.
The UIC regulation, identified as an ARAR for the ground water portion of the selected remedy,
prevents the basement and sump water from being treated and reinjected into the suriicial
aquifer. Instead, EPA will send this water off-site for disposal as a hazardous waste. This will
require that the water be stabilized as required by RCRA. The stabilized material will be
transported for disposal to a RCRA Subtitle C hazardous waste landfill. This change would be
necessary regardless of the ..remedial alternative chosen as the selected remedy, except no
action. This change will increase the cost by approximately $20,000.00.
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XII. REFERENCES
. EP A, 1988. Record of Decision, BWP Company. U.S. EP A - Region VIII, June 1988.
EP A. 1989. Risk Assessment Guidance for Superfund, Volume I Human Health Evaluation
Manual (Part A), Interim Final (EPN540/12-89/002). U.S. EPA, December 1989.
EPA, 1990a. EPA Response to BIC, Review of Design Documents for the BWP Site and
Request for Reconsideration of the ROD. U.S. EPA, April 3, 1990.
EPA, 1990b. 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.
EP A, 1991 a. On-site Treatment of Creosote and Pentachlorophenal Sludges and Contaminated
Soil. U.S. EPN600/2-91/019.
EPA, 1991b. Record of Decision Amendment, BWP Company. U.S. EPA - Region VIII,
September 1991. .
Holland & Hart, 1990. Petition for Re-Evaluation for 1988 ROD. Holland & Hart, May 1990.
ReTec, 199Oa. Removal and Storage of Main and Secondary Impoundment Sludge. ReTeC,
Inc., December 18,1990. .
ReTec, 199Oc. Phase 11/ Remedial Investigation Report. ReTec, Inc., December 1990.
ReTec, 1991 a. Endangerment Assessment Report. ReTec, Inc., January 1991.
ReTec, 1991 b. Phase 11/ Feasibility Study Report. ReTec, Inc., June 1991.
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EXHIBIT A
TOXICOLOGY PROFILES FOR
CONTAMINANTS OF CONCERN
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EXHIBIT A
TOXICOLOGY PROFILES FOR
CONTAMINANTS OF CONCERN
The following discussion comes from the toxicology profiles for these contaminants presented
in the Endangerment Assessment. The following summaries provide information regarding the
carcinogenicity, mutagenicity, reproductive effects, and acute toxicity, if available, for the
carcinogenic and non-carcinogenic PAHs, PCP, dioxins and furans, and toxic metals:
ORGANIC CONTAMINANTS:
Potentiallv CarcinoQenic PAHs
Carbazole. EPA has classified carbazole as a B2 - Probable Human Carcinogen based
on inadequate evidence in humans and' sufficient evidence of carcinogenicity from
animal studies. .
Chrvsene. EPA has classified chrysene as a B2 - Probable Human Carcinogen based
on inadequate evidence in humans and sufficient evidence of carcinogenicity from
animal studies. Carcinogenic effects were observed in mice following repeated dermal
application. Chrysene is considered to have weak carcinogenic activity compared to
benzo(a)pyrene and is reported to have mutagenic effects. No information concerning
teratogenicity or reproductive effects is available.
Benzo(a)anthracene. EPA has classified benzo(a)anthracene as a B2 - Probable
Human Carcinogen based on inadequate evidence in humans and sufficient evidence
of carcinogenicity from animal studies. Evidence from animal studies indicates that this
compound is carcinogenic in mice when administered orally and dermally. Neither
acute nor chronic exposures produced significant toxic effect. No data was found
regarding teratogenicity, mutagenicity, or reproductive effects.
Benzo(a)pvrene. EPA has classified benzo(a)pyrene as a B2 - Probable Human
Carcinogen based on limited evidence in humans and sufficient evidence of
carcinogenicity from animal studies. Mouse studies show this compound to be a local
and systemic carcinogen. Adequate data does not exist to assess the effects on
humans of acute or chronic exposure. No teratogenicity or other reproductive effects
have been observed in laboratory animals.
Benzo(b)fluoranthene. EPA has classified benzo(b) fluoranthene as a B2 - Probable
Human Carcinogen based on inadequate evidence in humans and sufficient evidence
of carcinogenicity from animal studies. Mouse skin painting studies show this
compound to be a complete carcinogen. Adequate data does not exist to assess the'
effects on humans of acute or chronic exposure. No data are available on
teratogenicity or other reproductive effects.
Benzo(k)fluoranthene. EPA has classified benzo(k) fluoranthene as a B2 - Probable
Human Carcinogen based on inadequate evidence in humans and sufficient evidence
of carcinogenicity from animal studies. No data are available regarding mutagenicity,
teratogenicity, or reproductive effects.
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Dibenzo(a,h)anthracene. EPA has classified dibenzo(a,h) anthracene as a 82 . .
Probable Human Carcinogen based on inadequate evidence in humans and as an
experimental carcinogen from animal studies. Neither acute nor chronic exposures
produced significant toxic effect. Data are available regarding mutagenicity effects.
Indeno(1.2,3-cda)pvrene. EPA has classified indeno(1 ,2,3-cd)pyrene as a 82 - Probable
Human Carcinogen based on inadequate evidence in humans and positive evidence of
carcinogenicity from animal studies. Mutagenicity data in laboratory animals are
available.
NoncarcinoQenic PAHs
Naphthalene. No data is available regarding the carcinogenicity of naphthalene to
humans. This compound is generally considered noncarcinogenic in experimental
animals. However, naphthalene is classified as a Class D Carcinogen - there is not
adequate evidence of carcinogenicity. Teratogenic and reproductive effects of inhaled
or ingested naphthalene are not well documented, however,. phototoxic effects in
humans and rabbits have resulted from ingestion. Oral administration of naphthalene in
rabbits and rats has resulted in cataract formation. Umited information is available
concerning acute and chronic toxicity effect to humans and experimental animals.
Acenaphthvlene. There are no data available regarding the carcinogenici1y,
teratogenicity, or reproductive effects in humans or experimental animals.
Acenaphthene. There is no evidence suggesting carcinogenicity and limited evidence
of mutagenicity. Slight morphological changes in the liver and kidney of rats have been
reported following oral exposure to acenaphthene. Acute and chronic effects of
acenaphthene exposure to humans are poorly understood.
Fluorene. Inadequate studies exist to evaluate the carcinogenicity of this compound.
Mixed results in mutagenicity testing exist. No data are available on the teratogenic or
reproductive effects or chronic and acute toxicity.
Phenanthrene. Insufficient studies have been performed to evaluate the carcinogenicity
of the compound, although it may be a weak initiator. The acute and chronic toxic
effects are unknown. There is limited evidence of mutagenicity and no evidence of
teratogenic or reproductive effects.
Anthracene. There is no evidence suggesting carcinogenicity in humans by the oral
route. Anthracene exhibits mixed results in mutagenicity testing. There are no reports
of teratogenic or reproductive effects due to exposure. Little information concerning
acute and chronic effects is available.
Fluoranthene. There is no information concerning carcinogenicity in humans, but
fluoranthene appears to posses potent carcinogenic activity in test animals. There is
limited evidence of mutagenicity and no information regarding teratogenicity or
reproductive effects. Sufficient data exists on chronic effects to allow the EPA to set a
human health water quality criteria.
Pyrene. No data is available to assess carcinogenicity to humans, but this compound
has not been found to be carcinogenic in animal studies. There is limited evidence of
mutagenicity. Information on teratogenic or reproductive effects is not available.
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Benzo(q,h.i)pervlene. EPA has classified benzo(g,h,i) perylene as a noncarcinogenic
PAH based on limited evidence of carcinogenicity from animal studies. Data are
available regarding mutagenicity effects.
Acid Extractables
Phenol. Phenol is classified by the EPA as a Class D agent which implies there is not
. adequate evidence of carcinogenicity. Phenol is readily absorbed through the gut, by
inhalation, and percutaneously. Data on mutagenicity are equivocal. Phenol does not
appear to be teratogenic. Due to its relatively low volatility at room temperature, phenol
generally does not constitute a serious respiratory hazard; upon direct contact, it is a
skin hazard.
2-Chlorophenol. The EPA has stated that 2-chlorophenol has not been evaluated for
evidence of human carcinogenic or chronic health effects.
2-Methvlphenol.. 2-Methylphenol (or a-cresol) is classified by the EPA in Class C -
Possible Human Carcinogen,' based on skin studies in laboratory animals.
Experimental evidence indicates that 2-methylphenol is absorbed following ingestion,
inhalation, and dermal exposure. Effects following acute exposure to 2-methylphenol
include injury to the eyes, skin, liver, kidney, and vascular system.
4-Methvlphenol. 4-Methylphenol is classified by the EPA in Class D agent which implies
there is not adequate evidence of carcinogenicity. Experimental evidence indicates that
4-methylphenol is absorbed following ingestion, inhalation and dermal exposure.
Effects following acute exposure to 4-methylphenol include muscular weakness,
gastroenteric disturbances, severe depression, edema of the lungs, injury to the eyes,
skin, liver, kidney, pancreas, spleen and vascular system, collapse and death.
2.4-Dichlorophenol. The EP A has stated that 2,4-dichlorophenol has not been
evaluated for evidence of human carcinogenic or chronic health effects. Based on
studies in laboratory animals, experimental evidence indicates that 2,4-dichlorophenol
causes teratogenic and reproductive effects following chronic exposure
2.4.5-Trichlorophenol. The EPA has stated that 2,4,5-trichlorophenol has not been
evaluated for evidence of carcinogenic health effects. 2,4,5-trichlorophenol is classified
by the EPA as a potential chronic health hazard based on evidence of oral effects from
studies in laboratory animals. No experimental evidence is available for inhalation
exposure.
2.4.6-Trichlorophenol. 2,4,6-trichlorophenol is classified by the EPA as a B2 - Probable
Human Carcinogen, based on no human data and sufficient evidence from studies in
laboratory animals. Experimental evidence indicates that is absorbed following
ingestion and inhalation exposure. The EPA has stated that 2,4,6-trichloropheno! has
not been evaluated for evidence 01 chronic health effects.
Pentachlorophenol. PCP is classified by the EPA as a Class 82 - Probable Human
Carcinogen. PCP is readily absorbed following oral and inhalation exposure; evidence
from occupational studies indicates it is also absorbed following dermal exposure (EP A,
1984d). Case reports in humans via occupational exposure indicate the following
effects of PCP; neurotoxicity, immune system effects, liver and kidney damage, and
hematological disorders. Phototoxic effects associated with skeletal ossification, as well
as maternal toxicity in rodents were observed.
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DioxinsfFurans
The isomer 2, 3, 7, 8 TCDD is used as the reference compound to evaluate the toxicities
of the polychlorinated dibenzo-p-dioxins and polychlorinated dibenzofurans. TCDD is
demonstrated animal carcinogen following dermal and oral administration. Various
investigations show a weak link between occupational and environmental exposures of
2, 3, 7, 8 TCDO and carcinogenicity in humans. The U.S. EPA classifies this compound
as a Class B2 - Probable Human Carcinogen. Teratogenic effects were observed in
rats. Evidence of teratogenicity to humans is weak. Both positive and negative results
were obtained in mutagenicity tests indicating that evidence is inadequate.
The following table shows equivalency factors for converting other dioxins to 2,3,7,8-
TCOO.
Table A-1
Equivalency Factors for DioxinsfFurans to 2,3,7,8-TCDD
Dioxin/Furan
Factor'
2,3,7,8-TCDD .
1.0
Pentachloro-dibenzo-p-dioxin
Hexachloro-dibenzo-p-dioxin
Heptachloro-dibenzo-p-dioxin
Octachloro-dibenzo-p-dioxin
0.5
0.1
0.01
0.001
Pentachloro-dibenzo-p-furan
Hexachloro-dibenzo-p-furan
Heptachloro-dibenzo-p-furan
Octachloro-dibenzo-p-furan
0.5
0.1
0.01
0.001
Volatile Organic Compounds VOCs
. .
Benzene. Benzene is classified as a Class A carcinogen - Human Carcinogen based on
adequate evidence of carcinogenicity from epidemiological studies. Benzene is readily
absorbed through both oral and inhalation routes. The toxic effects of the benzene in
humans and other animals include central nervous system effects, hematological
effects, and immune system depression. Chronic exposure to benzene vapors can
produce reduced leukocyte, platelet, and red blood cell counts.
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Toluene. Toluene is categorized as a Class 0 agent which implies there is inadequate
evidence of carcinogenicity. Toluene is absorbed in humans following both inhalation
and dermal exposure. In humans chronic exposure to toluene vapors at concentrations
of approximately 200 to 800 ppm (parts per million) has been associated with central
nervous system and peripheral nervous system effect, hepatomegaly, and hepatic and
renal function changes.
. .
Ethvlbenzene. Ethylbenzene is categorized as a Class 0 agent which implies there is
inadequate evidence of carcinogenicity. In humans, ethylbenzene is characterized by
its irritancy to skin and mucous membranes. No data are available on the teratogenic,
mutagenicity or reproductive activity of ethylbenzene.
Xvlenes. Xylene is categorized as a Class 0 agent which implies there is inadequate
evidence of carcinogenicity. The three xylene isomers, compounds having the same
chemical constituents in a different configuration, have similar toxicological properties
and are discussed together. When' inhaled at high concentrations, xylene causes
central nervous system depression; it can also cause reddening of the face, disturbed
vision and salivation. There is some evidence suggesting that xylene sensitizes the
myocardium to the endogenous neurohormone, epinephrine and can precipitate heart
failure and death. Workers chronically exposed to xylene display symptoms similar to
those seen in acutely exposed individuals. In addition, there have been reports that
disturbances in the blood can occur from xylene exposure. There are no studies to
indicate that xylene is carcinogenic or mutagenic.
Methvlene Chloride. EPA has classified methylene chloride as a 82 - Probable Human
Carcinogen. Methylene chloride is absorbed following oral and inhalation exposure.
Acute human exposure to methylene chloride may result in irritation to the eyes, skin
and respiratory tract; central nervous system depression, elevated carboxyhemoglobin
levels and circulatory disorders that may be fatal. Chronic exposure of animals can
produce renal and hepatic toxicity. Several inhalation studies conducted in animals
provide clear evidence of methylene chloride's carcinogenicity. There is only
suggestive evidence in experimental animals that hepatocellular carcinomas and
neoplastic nodules arise from oral exposure.
Trichloroethene. EPA has classified trichloroethene (TCE) as a 82 - Probable Human
Carcinogen based on inadequate evidence in humans and sufficient evidence of
carcinogenicity from animal studies. TCE is a central nervous system depressant
following acute and chronic exposure. High level exposure can result in death due to
respiratory. and cardiac failure. Hepatotoxicity has been reported in human and animal
studies following acute exposure to TCE.
Trichloroethvlene. EPA has classified trichloroethylene as a 82 - Probable Human
Carcinogen based on inadequate evidence in humans and sufficient evidence of
carcinogenicity from animal studies. Trichloroethylene may damage the liver and other
organs following chronic exposure. High level exposure can result in death due to
cardiac failure. .
Tetrachloroethvlene. EPA has classified tetrachloroethylene as a Group C - Possible
Human Carcinogen, based on conflicting evidence in humans, and as an experimental
carcinogen from animal studies. Inhalation' of vapors from tetrachloroethylene may
affect the liver and may be a depressant to the central nervous system.
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INORGANICS:
Metals
Arsenic. There is inadequate evidence for the carcinogenicity of arsenic compounds in
animals. There is sufficient evidence, however, that these compounds are skin and lung
carcinogens in humans. EPA classifies this compound as a Class A - Human
Carcinogen. Oral doses to experimental animals produced phototoxic symptoms
indicating arsenic to be teratogenic. Weak or negative results were obtained in most
bacterial tests for mutagenicity. Toxicity depends on the chemical form of arsenic,
arsenites (As +3) are more toxic than arsenates (As+S), along with the route and
duration of exposure. . .
Cadmium. The evidence for carcinogenicity in humans is limited and is based on a
study of lung cancer in cadmium smelter workers. Evidence for carcinogenicity in
animals was considered syfficient based upon subcutaneous and intramuscular
injection studies. The U.S. EPA, therefore, classifies cadmium as a 81 - Pr~bable
Human Carcinogen. Cadmium has been shown -to reduce fertility and cause
teratogenic effects in experimental animals following intravenous, intraperitoneal and
subcutaneous administration. Cadmium has also been shown to be weakly mutagenic.
Lead. Lead and most lead compounds are classified by the U.S. EPA as Class 82
Carcinogens - Probable Human Carcinogens, resulting from sufficient evidence of
carcinogenicity in animals and inadequate evidence of carcinogenicity in humans. Lead
is stored in the body in bone, kidney and liver (EPA, 1984e). The major adverse effects
in humans caused by lead exposure include alterations in the hematopoietic and
nervous systems. The toxic effects are generally related to the concentration of this
metal in blood. Mutagenicity cannot be determined from short term tests due to cellular
toxicity. Subchronic and chronic exposures of rats and mice to lead have resulted in
teratogenic and reproductive effects. Teratogenicity of inhaled lead has also been
observed in humans occupationally exposed to lead.
Zinc. Zinc is categorized as a Class D agent which implies there is inadequate
evidence of carcinogenicity. Zinc is an essential trace element that is necessary for
normal health and metabolism and therefore is nontoxic in trace quantities.
Overexposure to zinc has been associated with gastrointestinal disturbances,
dermatitis, and metal fume fever, a condition characterized by fever, chills, coughing,
dyspnea, and muscle pain (EPA, 1984). Chronic oral exposure of humans to zinc may
cause anemia and altered hematological parameters. There is no evidence of
teratogenic or carcinogenic effects.
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\brodrick\0u2tod~010792
EXHIBIT 8
ARARS IDENTIFIED FOR THE FINAL REMEDY
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'. ',' - ..,
. -,"
\Brcs\brodrick\Tbl.CSA\OI0592\pg. 1
TABLE B-1
BRODERICK WOOD PRODUCTS SITE
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
...... .-.- '.-. - .
. . - f
100% Rocyclod
STANDARD, REQUIREMENT,
CRITERIA OR LIMITATION
COMMENTS
DESCRIPTION
STATUS
Chemical-Specific ARARs
Safe Drinking Water Act
MCLs (40 C.F.R S141.11-.12;
6 C.C.A. 1007-3,6265, App.
III: Interim Primary Drinking
Water Standards; 56 F.R.
3528 (January 30, 1991»
Establishes health-based standards for
community water systems. MCLs for
chemicals of concern at this site are:
Relevant and
appropriate
Contaminant
Maximum
Concentralion (mQ/U.
arsenic
cadmium
lead
benzene
chromium
trichloroethylene
1,1,1 trichloroethane
tetrachloroethylene
toluene
ethylbenzene
total xylenes
0.05
0.005
0.05
0.005
0.100
0.005
0.200
0.005
1.000
0.700
10.000
MCLs are not applicable to surface or
ground water at the Broderick site
because the sources do not serve a
pubic water system. These standards
are relevant and appropriate for ground
water under the sile since this water Is a
potential drinking water source.
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ro.,~,'.. .'""'-,-"':~'.\'''''L,,,,,,,';',,,,~y.~....'~,,.~,,,''''.''r,",.", ;'".' ',..',
\arcs\brodrlck\Tbl.CSA\O1 0592\pg. 2
TABLE B-1
BRODERICK WOOD PRODUCTS SITE
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
100% Recycled
STANDARD, REQUIREMENT,
CRITERIA OR LIMITATION
COMMENTS
DESCRIPTION
STATUS
RCAA land Olsposal
Restrictions (KOO1 Waste)
(40 C.F.R. ~268.41. 268.43;
55 Fed. Reg. 22,520 (June 1,
1990»
RCAA Land Olsposal
Restrictions ('D" Waste) (40
C.F.R. 5S261.24, 268.41,
268.43; 55 Fed. Reg. 22,520
.(June1,1990»
lOAs prohibit "placement" ot hazardous
waste without treatment by a particular
technology or to a particular concentration.
lOA standards tor KOO1 wastes at this site
based on the soli and debris treatability
variance are:
Applicable
~
napthalene
PCP
phenanthrene
pyrene
toluene
xylenes
lead
Percent
Aeduction
95.99%
90.99%
95-99%
95-99%
N/A
N/A
99-99.9%
Treatment
AanQe
N/A
N/A
N/A
N/A
.5.10ppm
.5-10ppm
N/A
LDAs prohibit "placement" of hazardous
waste without treatment by a particular
technology or to 8 particular concentration.
lOR standards for "0" wastes 8t this site are:
Potentially
applicable
Contaminants
0004 Arsenic
0006 Cadmium
0008 lead
Concentrations In
Waste Extract
5.0 mgJl
1.0 mg/l
5.0 mgJl
These standards are ARAAs tor solis in
the Impoundment area contaminated
with KOO1 waste Insotar as the salls are
"placed.' Excavation and movement at
these salls to the lTU Is "placement."
KOO1 Is the only listed waste identified
at the site which has lOR standards.
The LOA requirements will be met
through the 5011 and debris treatability
variance.
These restrictions are applicable to
waste with the characteristic ot toxicity
under 40 C.F.R. ~261.24. 81te
Investigation has revealed only one
area where soli Is contaminated with
these metals at levels suggesting that
the solis could be a characteristic
waste; the former railroad roundhouse
area. Allhough no TClP test has been
performed, It a TClP test reveals that
these solis are characteristic wastes
subject to this regulation, the
restrictions are applicable it these
wastes are "placed."
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TABLE B-1
BRODERICK WOOD PRODUCTS SITE
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
. .
.-. ..'.
100% Recycled
STANDARD, REQUIREMENT,
CRITERIA OR LIMITATION
COMMENTS
DESCRIPTION
STATUS
Clean Water Act, Ambient
Water Quality Criteria
Safe Drinking Wafer Act,
Secondary Maximum
Contaminant Levels (40
. C.F.R. S143.3)
Section 121 of CERCLA provides that Clean
Water Act Criteria may be relevant and
appropriate depending upon the
circumstances of the release or threatened
release.
Establishes welfare standards for community
water systems. Standards for chemicals of
concern at this site are:
Contaminant
bID!m
zinc
5 mg/L
Relevant and
appropriate
. .
Relevant and
appropriate
The water and fish Ingestion criteria
may be relevant and appropriate for
ground water If no MCL exl5t5 and if
adjusted to remove the fish Ingestion
component. The only contaminant of
concern for which criteria have been
Issued which does not have a
corresponding MCL (promulgated or
proposed) Is Fluoroanthene. The
standard for Fluoroanthene (unadjusted
for fish Ingesllon) Is 2 X 10.02 1l9/L.
These levels are not applicable at the
Broderick site because neither Fisher
Ditch nor ground water In the area Is
part 01 a public water system. The
standards are relevant and appropriate
for Fisher Ditch water and the three
ground water-bearing formallons under
the slte'whlch have potential for use as
drinking water.
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., '....-
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TABLE B-1
BRODERICK WOOD PRODUCTS SITE
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
'" ....'..'
100% Recycled
STANDARD, REQUIREMENT,
CRITERIA OR LIMITATION DESCRIPTION STATUS
Colorado Waler Quality These standards are considered and applied Relevant and
Standards (Table Values) (5 by the Colorado Water Quality Control appropriate
C.C.R.1002.~3.1.16) Commission In establishing site-specific
numeric standards. Relevant standards
Include:
Contaminant ArQlcullure Domesllc
arsenic 100 1J9/L 50 IJg/L
(30 day) (1 day)
cadmium 10 1J9/L 10 1J9/L
(30 day) (1 day)
chromium III 100 1J9/L 50 IJg/L
(30 day) (1 day)
chromium VI 100 1J9/L 50 1J9/L
(30 day) (1 day)
copper 200 IJg/L 1000 IJg/L
(30 day) (30 day)
lead 100 1J9/L 50 1J9/L
(30 day) (1 day)
zinc 2000 JJ9/L 5000 JJg/L
(30 day) (30 day)
COMMENTS
These standards are not applicable to
the seeps north of the Broderick
property, although the agricultural and
domestic standards are relevant and
appropriate for the Fisher Ditch water
because water from the ditch Is
potenllally used as drinking water and
for Irrigallon.
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TABLE B-1
BRODERICK WOOD PRODUCTS SITE
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARa)
100% Recycled
STANDARD, REQUIREMENT,
CRITERIA OR LIMITATION
COMMENTS
DESCRIPTION
STATUS
Colorado Water Quality
Standards Clear Creek:
Segment 15 (5 C.C.A. 1002-
8, A3.8.6)
RCRA Maximum
Contaminant Levels (40
. C.F.R. 6264.94,6 C.C.R.
1007-31264.94
Standards considered and applied by the
Colorado Water Quality Control Commission.
Relevant standards Include:
Relevant and
appropriate
Contaminant
Level (mQ/L)
arsenic
cadmium
chromium (trl)
chromium (hex)
copper
lead
zinc
0.05
0.001
0.05
0.025
0.014
0.025
0.17
Establishes maximum concentrations of
specific constituents to protect ground water
under solid waste management units. The
relevant standards are:
Applicable
Contaminant
Level mQ/1
Arsenic
Cadmium
Lead
.05
.01
.05
These standards apply to Segment 15
of Clear Creek, the segment from which
the water Is withdrawn and the nearest
str.eam segment to the Broderick site.
These surface water standards apply
only to .state waters.. State waters do
not Include .water withdrawn for use
until use and treatment have been
completed.. C.A.S. A25-8-103(19),
therefore, these standards are not
applicable to Fisher Ditch waters.
However, the standards are relevant
and appropriate to Fisher Ditch water
because of the potential use of ditch
water as a drinking water supply.
These standards are applicable to the
L TU or RCAA land treatment unit, which
Is a solid waste management unit.
-------
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-oj".'...-. ,
\arcs\brodrlck\Tbl-CSA\010592\pg. 6
. ",," .-." "..,' -, ,..' ~. ,," .-. ."- " .. ..,... ..,
TABLE B-1
BRODERICK WOOD PRODUCTS SITE
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
.-,.",., ..,.-..- 9..,..
", ,," .. ,',.. .,'.',
100",(, Recycled
STANDARD. REQUIREMENT.
CRITERIA OR LIMITATION
COMMENTS
DESCRIPTION
STATUS
Colorado Basic Standards
for Ground water --
(5 C.C.A. 1002-8 & ~3.11.5.
Tables 1-3 Basic Ground
Water Standards)
Human
Health
Standards
Parameter (mQ/U
Secondary
Drinking
Water Agrlcu"ural
Standards Standards
(mQ/L) Jm9l!J
Relevant and
appropriate
arsenic 0.05 N/A 0.1
cadmium 0.01 N/A 0.01
chromium 0.05 N/A 0.1
copper N/A 1 0.2
lead 0.05 N/A 0.1
zinc N/A' 5.0 2.0
These standards are relevant and
appropriate, because the ground water
Is a potential drinking water and
agricultural water source. The lowest
number will be used as the ARAA.
-------
\arcs\brodrlck\Tbl.eSA\OI0S92\pg.7
100% Recycled
TABLE B-1
BRODERICK WOOD PRODUCTS SITE
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
STANDARD, REQUIREMENT,
CRITERIA OR LIMITATION
COMMENTS
Colorado Basic Standards
for Ground Water u Organic
(5 C.C.A. 1002-8 &
~3.11.5(c) Interim Organic
Pollutants Standards, Tables
A, B.)
OSHA Asbestos Regulations
29 C.F.A. S1926.58(b), (c)
DESCRIPTION
STATUS
Parameter
Standard
(J1Q/U
Detection
Level
-1lliJLU
These standards apply to all State
ground water. Note that whenever the
detection level Is greater than the
standard, the detection level "shall be
used as the performance standard In
regulating specific actlv"les," 5 C.C.A.
1002-8 S 3.11.5(c)(4).
Applicable
benzene 1
ethylbenzene 680
pentachlorophenol 200
toluene 1000
1,1,1 trichloroethane 200
2,4,6 trlchlorophenol 2
2,3,7,8 TCDD 2.2x10-7
2.4 Dlchlorophenol 21
1
1
50
1
5
50
50
All other organic
pollutants
Lowest
practical level
Parameter
Level
Applicable
This ARAR applies to all construction
work, Including demol"'on of structures
where asbestos Is present. The
requirement Is applicable to the
demolition of the bulldlng(s) at the she.
Asbestos
0.1 * fibers/cu~lc cm
0.2+ fibers/cubic em
."Actlon Level, . 8-hour time-weighted
average.
+ 'Permlsslble Exposure Level," 8-hour tlme-
weighted average.
-------
\arcs\brodrlck\ Tbl.CSA\O 1 0592\pg. 8
. ". .' ~ .' ~
100% Recycled
TABLE B-1. .
BRODERICK WOOD PRODUCTS SITE
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
STANDARD, REQUIREMENT,
CRITERIA OR LIMITATION
DESCRIPTION
STATUS
COMMENTS
Hazardous Air Pollutant
Regulations (5 C.C.A. 1001-
10, .Regulatlon 8, Part B,
~(III)(C)(7)(b»
Parameter
b!!Y!!!
Relevant and
appropriate
. This regulation Is applicable to any area
of public access. Because the BIC sile
Is fenced, this requirement Is only
applicable to air In areas off-sile. It Is
relevant and appropriate to air on-site
because of the extent and nature of
probable future human contact with
contaminated air.
Asbestos'
0.01 fibers/cubic cm*
Q! 70 structures/square mm +
* Measured by .PCM,. or .phase contrast
microscopy,. NIOSH 7400 method. .
+ Measured by "TEM,. or .Transmlsslon
electron microscopy,. 40 C.F.R. Part 763,
Appendix A.
(There Is a proposed revision to
Regulation 8 that would eliminate the
publc/nonpubllc distinction and so Is a
TBC. However, since the "public.
standards are relevant and appropriate
and thus already ARARs for the
nonpubllc areas at the Broderick site,
the proposed revision would have no
effect as a T8C.)
-------
\arC8~brodrlck\TbI'CSAX\010592\pg. 10
TABLE B-1
BRODERICK WOOD PRODUCTS SITE
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
".. ...."
100% Recycled
STANDARD, REQUIREMENT,
CRITERIA, OR LIMITATION
Action Specific
Clean Air Act 42 USC
~~7401-7642 40 CFR 50
National Ambient Air Ouallty
Standards (NMOS)
Solid Waste Disposal Act (42
USC ~~6901.6987, 40 CFR
Part 262)
Solid Waste Disposal Act (42
USC ~~6901-6987, 40 CFR
Part 263)
Solid Waste Disposal Act (42
USC U6901-6987)
Standards for Owners and
Operators of Hazardous
Waste Treatment, Storage,
and Disposal Facilities (40
CFA Part 264)
DESCRIPTION
STATUS
Applicable'
Establishes standards for generators of
hazardous waste.
Applicable
Establishes standards for transport of
hazardous waste.
Applicable
Establishes minimum standards that define
the acceptable management of hazardous
waste for owners and operators of facilities
which treat, store, or dispose of hazardous
waste.
Applicable
COMMENTS
NMOS would be applicable to the
extent that Implementation of the
remedy would Impact the ambient air
quality.
Applicable to actions to be taken In
remedlatlng the buildings, vessels, and
drums and to the recovery of NAPLs In
the water treatment systems.
Applicable to transport of Identified
hazardous waste In remedlatlng the
buildings, vessels, and drums and
recovery of NAPLs In the water
treatment system.
Certain of these requirements are
applicable to the construction,
operation, closure, and monitoring 0'
the LTU.
-------
. ~ . ..
~.. : '" :'::"..1'-' 0 ",:.
; ,~, '.. ~ ," \..,: " '. ...,. ..
.' ',...:: .'. :... :~..:.
. :"0 . ~ .: '., :, :;. "'"'., :..
, ..., "0'
. " . ': ,";'
100% Recycled
\arcs\brodrlc:k\TbI.CSAX\Ot0592\pg. t t
TABLE B-1
BRODERICK WOOD PRODUCTS SITE
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
STANDARD, REQUIREMENT,
CRITERIA, OR LIMITATION DESCRIPTION STATUS COMMENTS
Solid Waste Disposal Act (42 Releases from solid waste management Applicable Applicable to the L TU.
USC ~~6901-6987, 40 CFR units. Requirements for ground water
Part 264 Subpart F) monitoring In the upper-most aquifer and
corrective action If a release Is discovered.
Solid Waste Disposal Act (42 Requirements for closure and post-closure of Applicable Applicable to closure of the L TU.
USC ~~6901-6987, 40 CFR solid waste management units and treatment,
Part 264 Subpart G) storage, and disposal facilities.
Solid Waste Disposal Act (42 Requirements for storage or treatment of Applicable or Applicable to tanks used to store or
USC ~g6901-6987, 40 CFR hazardous waste In tanks. Relevant and treat contaminants recovered from the
Part 264 Subpart J) Appropriate water treatment plant and contents from
the buildings, vessels, or drums which
can be Identified as hazardous waste.
Certain of the contents In the buildings,
vessels, and drums have not been
Identified as hazardous waste.
However, these contents are hazardous
substances which are sufficiently
similar to hazardous waste that these
tank regulations would be relevant and
appropriate to storage or treatment of
these contents In tanks.
Solid Waste Disposal Act (42 Regulates management of "land treatment Applicable Applicable to the construction,
use ~g6901-6987, 40 CFR units. that treat or dispose of hazardous operation, and closure of the LTU.
Part 264 Subpart M) waste.
-------
\arC8~brodrtck\Tbl-CSAX\010592\pg. 12
TABLE B-1
BRODERICK WOOD PRODUCTS SITE
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
100% Recycled
STANDARD, REQUIREMENT,
CRITERIA, OR LIMITATION
Solid Waste Disposal Act (42
USC ~~6901-6987), Closure
with waste In place (40 CFR
~~265.228, 265.117(c),
265.310(b»
Solid Waste Disposal Act (42
USC ~~6901-6987, 40 CFR
Part 268)
DESCRIPTION
STATUS
Regulates post-closure care when closIng an
existing Interim status surface Impoundment
with waste In place.
Applicable
Establishes a tImetable for restriction of land
disposal of banned wastes, LDRs.
Applicable
COMMENTS
Applies to closure of the existing Interim
status surface Impoundments at the site
because It Is unlikely that all waste
residues can or will be removed.
Applicable to placement of solis from
the Impoundment area Into the LTU
because all such solis are considered
contaminated with KOO111sted
hazardous wastes. These wastes will
not be treated prior to placement. An
Interim measure waiver will be granted
to allow remedial action to proceed.
The lDR treatment standards will be
met at the conclusion of the remedial
action through a treatability variance for
solis and debris. These regulations
also are applicable to metal
contaminated 80lls which exceed
toxicity characteristic levels. LDRs for
these 80lls will be met by treatment, I.e.,
solidification.
-------
.'.'" ; "'..,. '. ~. .'.'. .,,~'..: .... .0."'. .'- '.....,.'- .. . '.
\8r~\brodrlck\TbI.CSAX\010592\pg. 13
'" ........,
.' '''.' .. ".. ..... . ... '. ...... ~ " ; '.'''. ". . . . ..~ ~ ;.. ...\o-.'~.. ,."""-~.'- "" ..40 .... '.' , .'....... . . .1.0 .'. . ,.. -. ... .'. --. .
TABLE B.1
BRODERICK WOOD PRODUCTS SITE
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
100% Rocyclod
STANDARD, REQUIREMENT,
CRITERIA, OR LIMITATION
COMMENTS
Solid Waste Disposal Act (42
USC U6939(b))
Safe Drinking Water Act,
Underground Injection
Control (42 USC ~300H: 40
CFR Part 144) .
DESCRIPTION
Provides exception to ban on disposal of
hazardous waste by underground Injection
for Injection of contaminated ground water
Into the aquifer from which It was withdrawn If
1) such reinjection Is part of a CERCLA
response action, 2) the contaminated ground
water Is treated to substantially reduce
hazardous constituents prior to reinjection,
and 3) such response action will, upon
completion, be sufficient to protect human
health and the environment.
Regulates underground Injection of waste
and treated ground water.
STATUS
Applicable
Applicable
The exception to the ban on disposal of
hazardous waste by underground
Injection Is applicable because 1) the
reinjection Into the same aquifer 15 part
of a CERCLA response action, 2) the
contaminated surficial aquifer ground
water 18 expected to be treated to MCLs
or below, thereby substantially reducing
hazardous constituents prior to
reinjection. and 3) the response action
for ground water, upon completion, Is
expected to reduce contaminant levels
In the surficial aquifer to levels
protective of human health and the
environment.
Applies to the reinjection of treated
water from the ground water treatment
plant. The Injection well In this case will
be a class IV well, I.e., water removed
from a contaminated aquifer and
treated under a CERCLA remedial
action will be reinjected Into the aquifer
from which It came.
-------
\arcs\brodrlck\TbI-CSAX\010592\pg. 14
TABLE B-1
BRODERICK WOOD PRODUCTS SITE
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
. r ".0 ".:. . . .
, .
100% Recycled
STANDARD, REQUIREMENT,
CRITERIA, OR LIMITATION
National Emission Standard
for Asbestos, 40 CFR
SSS1.140, 61.141, 61.145,
61.150
Occupational Safety &
Heahh Act (29 CFR
S1926.58)
Occupational Safety &
Heahh Act (29 USC SSS51-
655, 670)
Colorado Solld'Waste
Disposal Shes and Facilities
Act (CRS SS30.20-101
through 105, 109, 110, and
112; 6 CCR 1007-2, SS1
through 7)
DESCRIPTION
STATUS
Regulates emissions of particulate asbestos
material to the outside air.
Applicable
Specifies regulations concerning exposure to
airborne concentrations of asbestos.
Applicable
RequIres an occupational heahh and safety
program for workers.
Applicable
Regulates disposal of solid wastes on site.
Applicable
COMMENTS
Applies to clean-up of asbestos -
containing materials In the process
building.
Applicable to demolhlon and
remediation of the process buildings
which have been found to contain
asbestos.
OSHA heahh and safety requirements.
are applicable to all remedial actions
but are not ARARs which EPA enforces.
Applicable to disposal of solid wastes
on-she.
-------
\arca\brodrlck\Tb'.CSAX\010592\pg. 15
1 ()()'j(, Recycled
TABLE B-1
BRODERICK WOOD PRODUCTS SITE
ApPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARa)
STANDARD, REQUIREMENT,
CRITERIA, OR LIMITATION DESCRIPTION STATUS COMMENTS
Colorado Hazardous Waste . Operator must prepare final Inventory of Applicable Applicable to closure of the Interim
Siting Act (CRS fi25-15-209) wastes deposited at the site. status surface Impoundments and the
LTU.
Colorado Hazardous Waste Requires ground water monitoring In Applicable Applicable to Interim status surface
Regulation 6 CCR 1007-3 uppermost aquifer during the post-closure Impoundments.
fi265.90-265.93 care period.
Colorado Hazardous Waste General Impoundment closure requirements. Applicable Applicable to closure of Interim status
Regulation, 6 CCR 1007-3 Impoundments.
fi265. 1-11
Colorado Ground Water Requires permit prior to construction of a well Applicable Substantive provisions will be followed.
Management Act (CRS 6637- or Installation of a pumping system.
91-101 to 112; 2 CCR 402-2)
Colorado Water Quality Regulates discharge Into a publicly owned Applicable Would be applicable to any discharge
Control Act (CRS 5925-6- treatment works ("POTW'). to a POlW. No such discharge 15
202,25-8-205; 5 CCR 1002- expected.
20, 664.3.0-4.3.8, 4.3.11-
4.3.13)
Colorado Water Quality Requires any person discharging any Applicable Substantive provisions of NPDES will
Control Act (5 CCR 51002-2, pollutant Into waters of Colorado to obtain be applicable if there are any surface
5 CCR 1002-3) any NPDES permit. water discharges.
-------
. .... ..: ~., . 0
." .
.' .'0 :
. . -:.. 1" .'. ".'
. " ...
.,I-,.C),:,',
\81cs~rodrtck\1bI.CSAX\010592\pg" 16
100% Recycled
TABLE B-1
BRODERICK WOOD PRODUCTS SITE
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
STANDARD, REQUIREMENT,
CRITERIA, OR LIMITATION DESCRIPTION STATUS COMMENTS
Colorado Air Quality Control Allows suspension of abatement work Relevant and May be relevant and appropriate to
Act, Reg. 8, Part B (5 CCR practice requirements which might endanger Appropriate demolition and remediation of the
1001-10, ~111.C.2.q) personnel who remove asbestos. process buildings If the state or local
government orders the buildings to be
demolished.
Colorado Air Quality Control Requires that emissions not exceed 2()0,.(, Applicable Activities at the site will be conducted to
Act, Reg. 1 (5 CCR 1001-3, opacity. meet this requirement.
S111.D)
Colorado Air Quality Control RequIres an Air Pollutant EmissIon Notice Applicable Substantive provisions of APENs will be
Act, Reg. 3 (5 CCR 1001-5) (APEN) before an emission of air pollutants. met.
Colorado Air Quality Control Regulates "detectable odors" In excess of Applicable Operation of theLTU may cause odors.
Act, Reg. 2 (5 CCR 1001-4) listed limitations. No odors are expected, but If present,
will be controlled. .
Colorado Air Quality Control Requires use of Reasonably Available Relevant and May be relevant and appropriate to
Act, Reg. 7 (5 CCR 1001-9) Control Technology (RAC1) In disposal of Appropriate L TU. Determination will be made
volatile organic compounds by evaporation during remedial design.
or spillage.
Colorado Noise Act (CRS Establishes state-wide standards for noise Applicable Industrial limits are applicable to
SS25-12.101 to 12-104) level limits for various time periods and constructIon activities at the site.
areas.
Colorado Ground Water Well permits for nontrlbutary ground water. Applicable Substantive requirements will be
Management Act (CRS ~~ complied with.
37-90-102, 107, 137; 2 CCR
402.6)
-------
.. .
\arca\brodrlck\Tbl-CSAX\010592'1pg. 17
. .
.' .
100% Recycled
TABLE B-1
BRODERICK WOOD PRODUCTS SITE
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
STANDARD, REQUIREMENT.
CRITERIA. OR LIMITATION
10 Be Considered
Safe Drinking Water Act
Proposed MCls 54 Fed.
Reg. 22 062, 22 155-57 (May
22. 1969),55 Fed. Reg.
30370, 30445 (July 25. 1990)
and 56 Fed. Reg. 3600
(January 30,1991) (to be
codified at 40 C.F.R. gg
141.61).
Proposed Maximum Contaminant levels
(MCls) are unpromulgated versions of the
MCls discussed In the ARARs section. The
proposed standards relevant to this site are:
DESCRIPTION
STATUS
COMMENTS
To be Considered
(TBCs)
MCLs apply only to public water systems.
These proposed MCLs are TeCs for the
surficial aquifer.
0.001
0.0002
0.0001
0.0002
0.0002
0.0002
0.0003
0.0004
5.0 X 10-8
Note that, except for PAHs, pentachlorophenol,
and dioxin, the proposed MClGs for each of
these contaminants are the same as the
proposed MCLs. 54 Fed. Reg. at 22,155. For
PAHs, pentachlorophenol, and dioxins,
MClGs ar9 zero. 55 Fed. Reg. at 30444; 56
Fed. Reg. at 3613. However, If an MClG 19 set
to zero, only the MCl 19 relevant for cleanup.
Contaminant
Concentration (mQ/l)
Pentachlorophenol
P AHs--Benzo(a) pyrene
Benz(a)anthracene
Benzo(b)fluorantherie
Benzo(k)fluoranthene
Chrysene
Dlbenz(a,h)anthracene
Indeno(1,2,3-CD)pyrene
2,3,7,8-TCDD (dioxin)
-------
\brodric:k\Ou2r10691
EXHIBIT C
CALCULATION OF HBCLs FOR SOILS
100'1(, recyd8d
-------
EXHIBIT C
Action Levels for Excavation of
Organics-Contaminated Soils at the Broderick Site
This Exhibit describes a methodology for applying the health-based cleanup levels
(HBCl), as presented in Section 2~ 1 of the Feasibility Study for the BWP site and Table
11 of this ROD, for excavation of organics-contaminated soils at the site using cleanup
level indices. As discussed below, these cleanup level indices are similar in concept to
the hazard index used to evaluate noncarcinogenic effects. A cleanup level index
ensures that remediation meets the target risk level for site cleanup, when using the
health-based cleanup levels presented in Table 11. This approach is consistent with
risk assessment principles. The methodology is presented in two parts: first, a
description of the cleanup level index approach and its use for evaluating cumulative
health-effects for all compounds is presented; second, an example is provided to
demonstrate the application of the cleanup level index.
CLEANUP LEVEL INDEX
The procedure presented in section 2.1 of the FS for developing health-based cleanup
levels (HBCl) calculated a concentration for individual constituents in a particular
medium that is at an acceptable risk level (where risk level is defined as either a
specified individual lifetime cancer risk or a hazard index less than 1). In many cases,
one or two constituents are responsible for much of the potential cancer risk or non-
carcinogenic effect estimated for a site, so reducing concentrations of all constituents
below their HBCLs should reduce total risks below their target levels. To make sure this
is actually the case, the following methodology is proposed. .
First, compare the concentrations of individual constituents in a sample with the
individual HBCLs. If the concentrations are all below their individual HBCLs, then the
cleanup level index (CLI) may be less than 1, but this condition would need to be
verified by using the following computations. . (If the concentration of one or more
constituents are above their individual HBCLs, then it can be concluded that the CLI is
greater than 1 without completing any further computations.) Second, segregate
chemicals into those with HBCLs using carcinogenic effects as their endpoint and those
using non-carcinogenic effects as their endpoint. For chemicals using carcinogenic
effects as their endpoint, a cleanup level index is calculated.
Nc
CLic = ~ Cj / HBCLj
j = 1
(1)
where:
CLic
Cj
HBCLj
Nc
cleanup level index for carcinogenic effects,
concentration of chemical j in a particular medium,
health-based cleanup level.for chemical j, and
number of chemicals with HBCLs using carcinogenic effects as
their endpoint.
If CLic is I~ss than 1 then the sum of the risks associated with these chemicals is less
than the acceptable cancer risk level. To show that this is the case, recall that HBCLj is
defined as
=
=
=
=
BWP\ExhibC\010692
C-1
100% Recycled
-------
HBCLj = ARL I URFj
(2 )
where:
ARL
URFj
=
acceptable risk level, and
unit risk factor for chemical j.
=
Substituting Equation 2 into Equation 1 gives the following:
Nc
CLic = ~ Cj . URFj I ARL
j = 1
(3 )
If CLic is equal to or less than 1, then Equation 3 can be rearranged to give:
Nc
AR~~Cj . URFj
j = 1
(4 )
Since the quantity Cj . URFj gives the risk level associated with chemical j, then
Equation 4 indicates the sum of the individual chemical risks are below the acceptable
risk level. Thus, if CLis as given by Equation 1 is less than or equal to 1, then the
cumulative risk associated with all chemicals is less than the acceptable risk level.
EXAMPLE
To illustrate this application of the cleanup level index, consider a hypothetical site with
four locations being considered for remediation. There are 20 chemicals with potential
carcinogenic activity that are being evaluated at this site. These chemicals are named
A1 through A2.0. Health-based cleanup levels (HBCLs) have been developed for each
chemical based on these potential carcinogenic effects and the HBCL for each
chemical is presented in Table 1. Additionally, we have presented HBCLs divided by
the number of chemicals (20). Also presented in Table 1 are concentrations observed
in each location.
Remediation would be required in Locations 1 and 2 because the concentrations of
some chemicals (i.e., D, E, F, and G) exceed their HBCLs. At Locations 3 and 4, the
concentrations are below HBCL for each chemical. However, the total cleanup level
index (CLI) for Location 3 exceeds 2, indicating remediation will be required. The total
Cli at Location 4 is below 1, indicating the total cancer risk associated with all
chemicals is below the target risk level.
BWP\ExhibC\010692
C-2
100')(, Recycled
-------
TABLE C-1
EXAMPLE DATA IllUSTRATING THE
CLEANUP lEVEL INDEX CONCEPT
Health- Sample Concentrations
Based
Cleanup Location
Level 1 2 3 4
Chemical (mg/kg) (mglkg) (mg/kg) (mg/kg) (mg/kg)
A1 500 100 200 25 5
A2 500 100 250 30 5.5
A3 500 100 225 30 6
A4 50 50 70 15 2.5
AS 5 20 15 2.5 1.5
A6 10 10 9 4 2
A7 200 500 700 10 2.5
A20 500 200 100 25 2
Chemical Cleanup Level Index (CLI)
A1 0.2 0.4 0.05 0.01
A2 0.2 0.5 0.06 0.011
A3 0.2 0.45 0.06 0.012
A4 1 1.4 0.3 0.05
AS 4 3 0.5 0.3
A6 1 0.9 0.4 0.2
A7 2.5 3.5 0.05 0.0125
A20 0.4 0.2 0.05 0.004
Total CLI: 14.3 12.75 2.07 0.652
Note: Chemicals A8-A20 are assumed to be present at the same concentrations
in all locations and have the same HBCL.
broderick\tc-1
C-3
-------
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~-:i!::-.~-:~'~~~~~~:';~~-
. :;:::.~;:. ~::';''': .~;:.:..~-
..~~.:~.~- '-;.:,.F"
-
OOLORADO
,DEPARTMENT
OF"HEALTH
4210 East 11th Avenue
~enver, Colorado 80220-3716
Phone (303) 320-8333
Hazardous Materials and
Waste Management Division
Telerax Number: (303) 331-4401
Telefax Numbers:
Main BuildingIDenver
(303) 322-9076
Ptarmigan PlaceIDenver
(303) 320-1529
First National Bank BuildinglDenver
(303) 355..os59
Grand Junction Office
(303) 248-7198
1\,,&-1.
',-~ I) 1/
I',t) /
(:.i~vi ",. i
;;7 ~'J
ROY ROMER \), \
Governor
JOEL KOHN
Interim Executive Director
March 3, 1992
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Re: State of Colorado Concurrence with the Broderick Wood Products Op~able ~t
#2 Record of Decision ~ r;: -,
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The State of Colorado, through the Colorado Department of Health (the State), concurs
with the Proposed Plan and Record of Decision for Operable Unit #2 at the Broderick
Wood Products site at 5800 Galapago Street in unincorporated Adams County, Colorado.
This concurrence is based on currently available information indicating the nature and
extent of contamination from the historic wood treating activities at the site. We believe
the selected remedy will be protective of human health and the environment, complies with
federal and state requirements, and meets the relevant and appropriate criteria of
CERCLA.
Mr. Jack McGraw, Acting Regional Administrator
U.S. Environmental Protection Agency, Region vm
999 18th Street
Denver, CO 80202-2405
Dear Mr., McGraw:
The State and EP A have had discussions concerning the nature and extent of contamination
and the selected remedy at the site. The following items were found to be of concern at the
Broderick Wood Products site:
1) We concur with the waiver of ARARs for the remediation of the Denver aquifer under
the Broderick property because of the site-specific hydrogeologic characteristics and present
technical engineering'limitations. We agree that institutional controls and monitoring will
be required. The remedy must be reconsidered if new information indicates that it is
technically practicable to treat the Denver aquifer under the Broderick property or if
monitoring shows that institutional controls do not protect public health.
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~ 2rfN e concur with the development and implementation of the appropriate institutional
~ ccW.trols to prevent exposure to and use of residual contaminated soil and ground water at
~t.~' thi=Droderick site. Institutional controls must be required to ensure the necessary level of
~-1:i pecD1anence, and protection of human health and the environment as contemplated by the
'~@. Long term operation and maintenance of any institutional controls imposed at the
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~r. Jack ~c(Jravv
~arch 3, 1992
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site vvill require a careful determination that the selected mechanisms protect public health
and the environment. .
The Department of Health vvill actively participate in the Remedial Design and Remedial
Action phases of Operable Unit #2 at the Broderick Wood Products site.
Sincerely,
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Thomas P. Looby, D' c
Office of Environme
Colorado Department of Health
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