United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R07-88/010
December 1987
Superfund
Record of Decision
Cherokee County/Galena, KS
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50272-101
REPORT DOCUMENTATION i »• REPORT NO.
PAGE
EPA/ROD/R07-88/010
4. Title and Subtitle
UPERFUND RECORD OF DECISION
iherokee County/Galena, KS
First Remedial Action
7. Author(s)
3. Recipient's Accession No.
5. R<
8. Performing Organization Rept. No.
9. Performing Organization Name and Address
10. Project/Task/Work Unit No.
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
11. Contract(C) or Grant(G) No.
(C)
(G)
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Notes
16. Abstract (Limit: 200 words)
The Cherokee County site, the Kansas portion of the Tri-State Mining District, is
located in the extreme southeastern corner of Kansas. The Galena subsite, one of six -
subsites identified within the Cherokee County site, encompasses 18 m^. The Galena
subsite is characterized by surface mining waste features that impact the quality of the
shallow ground water aquifer. This aquifer is a primary source of drinking water for
.approximately 1,050 people. Remains from past mining activity at the subsite include:
'large areas covered by mine and mill wastes, water-filled subsidence craters, and open
mine shafts. EPA investigations of the Galena subsite conducted in 1986 and 1987
demonstrated that the shallow ground water aquifer and surface water are contaminated
with elevated concentrations of metals. Due to the concern for the health of persons
drinking this water, EPA Region VII conducted a removal action and installed water
treatment units on these wells. This removal action was considered a temporary
protective measure. The primary contaminants of concern observed in the private wells
include: cadmium, lead, selenium, and zinc.
The selected remedial action for this site provides for collection of water from the
aquifer through existing wells owned by the City of.Galena with subsequent distribution
of that water through a pipeline network to 418 houses, businesses, and farms outside of
(See Attached Sheet)
17. Document Analysis a. Descriptors
Record of Decision
Cherokee County/Galena, KS
First Remedial Action
Contaminated Media: gw
(cadmium, lead, selenium, zinc)
c. COSATI Field/Group
i.3. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
50
22. Price
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;PA/ROD/R07-88/010
Cherokee County/Galena, KS
First Remedial Action
16. ABSTRACT (continued)
the Galena municipal water system but within the subsite. Additional capacity for the
expanded system will be rehabilitated to provide additional capacity for the expanded
system. If rehabilition becomes infeasible due to unforeseen onsite technicalities, a
new deep aquifer well may be drilled to provide additional waters. The remedy includes
acquiring the construction and equipment necessary to setup a water supply to this
area. The estimated present worth cost for this remedy is $5,300,000 with annual O&M of
$100,000.
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RECORD OF DECISION
OPERABLE UNIT REMEDIAL ALTERNATIVE SELECTION
SITE NAME
Cnerokee County Site - Galena Subsite
Cherokee County, Kansas
STATEMENT OF PURPOSE
This decision document represents the selected remedial action for the
alternative water supply operable unit developed in accordance with the
Comprehensive Environmental Response, Compensation and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act of
1986 (SARA), and to the extent practicable, the National Contingency Plan (NCP).
The State of Kansas has concurred on the selected remedy.
STATEMENT OF BASIS
This decision is based upon the administrative record. The attached
index identifies the items which comprise the administrative record.
DESCRIPTION OF THE SELECTED REMEDY
The Galena subsite is one of six subsites within the Cherokee County site.
It has been divided into two operable units, alternative water supply and j
ground water/surface remediation. This decision document addresses the
alternative water supply. The second decision document is expected to be
completed in the second quarter of FY-88.
The selected remedy provides for collection of water from the Roubidoux
aquifer through existing wells owned by the City of Galena and the distribution
of that water through a pipeline network to the houses, businesses and farms
within the subsite, but outside of the Galena municipal water system. The two
wells will need to be rehabilitated in order to provide the necessary water.
A new well will need to be drilled if the existing wells cannot be rehabilitated.
The remedy includes the construction and equipment necessary to set-up a water
supply to this area.
DECLARATIONS
Consistent with the Comprehensive Environmental Response, Compensation
and Liability Act of 1980, as amended, I have determined that the
provision of an alternative water supply to the residents of the Galena subsite
of the Cherokee County site, whose primary source of drinking water is the
contaminated shallow aquifer, is a cost-effective remedy, consistent with
permanent remedial action for the site and provides adequate protection of public
health, welfare and the environment. The remedy selection procedure and the
selected remedial action comply with the provisions of the Superfund Amendments
and Reauthorization Act of 1986. The selected remedy is not inconsistent with
the National Contingency Plan, 40 CFR §300, and is a component of a total remedial
action for the site. The State of Kansas has been consulted and concurs with
the selected remedy.
Date RegionTJ/Administratop-^y
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ROD DECISION SUMMARY
CHEROKEE COUNTY SITE
CONTENTS PAGE
Introduction 1
Site Location and Description 1
Site History 2
Enforcement 4
Community Relations History 6
Development of Alternatives 6
Remediation goals 7
Initial screening 7
Uetailed analysis of alternatives 15
Selected Remedy 23
General description 23
Scope and function of operable unit 24
Performance Goals . 26
Rationale for preference 26
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LIST OF FIGURES
FIGURE PAGE
1. Galena Subsite Map 3
2. Selected Alternative Uiagram 25
LIST OF TABLES
TABLE PAGE
1. Concentrations of Total Metals Observed S
in Private Wells
2. Response Action and Technology List 8
and Screening
3. Preliminary Alternatives Screening 12
4. Detailed Evaluation of Alternatives 17
5. ARARs for Selected Alternative 27
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ROD DECISION SUMMARY
CHEROKEE COUNTY SITE - GALENA SUBSITE
CHEROKEE COUNTY, KANSAS
INTRODUCTION
The purpose of this document is to describe the remedy that the U.S.
Environmental Protection Agency (EPA) has selected to implement at the Galena
subsite of the Cherokee County site. This document also describes the
decision-making procedures that were followed in selecting this remedial
action, which provides an alternative water supply for residents living within
the subsite.
The remedial action has been selected to remedy an environmental problem
potentially affecting the health of residents living within the subsite.
This action is one part of an entire response action for remedying an uncontrolled
site containing hazardous substances. As it is only part of the whole action,
this is referred to as an "operable unit" remedial action. Operable units
must be consistent with the final remedy for a site and must be cost-effective
according to the Superfund Amendments and Reauthorization Act of 1986 (SARA).
This action is consistent and cost-effective with the site-wide remedy.
The decision-making processes regarding the Cherokee County site began
with preliminary investigations, which led to the inclusion of the site
on the National Priorities List (NPL) for cleanup of releases or threatened
releases of hazardous substances. The site was separated into six subsites
for further investigation and eventual cleanup.
A remedial investigation (RI) and an operable unit feasibility study
(OUFS) conducted at the Galena subsite led to the conclusion that the shallow
ground water aquifer contains levels of metals above primary maximum contaminant
levels (MCLs) established by the Safe Drinking Water Act. Approximately 1,050
people who live within the Galena subsite use this contaminated shallow aquifer
for their sole source of drinking water. The decision to provide these people
with an alternative drinking water supply is based on the known release of
hazardous substances into the shallow ground water aquifer, which is primarily
the result of prior mining activities conducted at the subsite and degradation
of the mining wastes over the past 100 years. The following discussions explain
procedures EPA used in making this Record of Decision (ROD).
SITE LOCATION AND DESCRIPTION
The Cherokee County site is the Kansas portion of the Tri-State Mining
District, which includes the lead and zinc mining area in Jasper County,
Missouri, Cherokee County, Kansas and Ottawa County, Oklahoma. Cherokee County
is located in the extreme southeastern corner of Kansas.
The Galena subsite is one of six subsites identified within the
Cherokee County site. The Galena subsite encompasses 18 square miles and
includes the communities of Galena, Lowell and surrounding homes, farms
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and businesses (Figure 1). Approximately 1,050 people live outside the
City of Galena. These residents obtain drinking water from private shallow
aquifer wells ranging from 2U to 200 feet in depth. People within the City
of Galena receive drinking water from the'Galena public water supply system,
which provides good quality water from a deep aquifer, approximately
i.OOU to 1.2UO feet in depth.
The Galena subsite is characterized by surface mine waste features that
impact the quality of the shallow ground water aquifer. The most significant
mine waste area is referred to as "Hell's Half Acre," which contains sparse
to no vegetation and is totally covered with surface mine wastes. The mined
areas contain over 350 open shafts and collapses which are direct conduits to
the shallow ground water. Short Creek flows through Hell's Half Acre. Other
creeks in the area are Shoal Creek and Owl Branch. Short and Shoal Creeks empty
into the Spring River, wnich also flows through the subsite.
SITE HISTORY
Ore was first discovered in the Tri-State Mining District in 1848. The
first economically significant mine in Kansas was in the City of Galena, where
ore was discovered in 1876. Sphalerite (zinc sulfide) and galena (lead
sulfide) were the important commercial ore minerals. Pyrite and marcasite
(both iron disulfide) were commonly found in association with the lead and j
zinc minerals. The district was an important source of cadmium, which was
produced as a by-product of the lead-zinc smelting process. A smelter was
built along Short Creek in the 1890's. The area near the original smelter
was used for various smelting facilities until around 1961, then the remaining
facility was converted to produce sulfuric acid.
Ore deposits in the Galena vicinity occur in veins and are typically
80 to 100 feet deep. This shallow depth allowed numerous small mining
operations to prosper. Exploration and mine development were accomplished
by excavating vertical shafts to locate the ore body. Mining progressed
outward from the vertical shafts using a modified room and pillar method to
follow the ore vein. The use of vertical-'shafts as a means of mineral
exploration and the subdivision of leases into small subleased mining plots
result in a high density of mine shafts in the subsite. Over 350 open shafts
are readily accessible in and around the City of Galena. Several mines have
collapsed, forming subsidences of varying sizes and shapes. Many circular
subsidences are less than 75 feet in diameter while others, from circular to
rectangular, measure several hundred feet along the longest dimension. A
ground level difference of 20 to 40 feet is common in the subsidences within
the subsite. Some subsidences are filled with water and may be deeper.
The most obvious remains of the intense mining activity at the subsite
are large areas covered by mine and mill wastes, water-filled subsidence
craters and open mine shafts. The localized term "chat" describes the waste
piles of gravel-sized rock, which resulted from the early ore milling process.
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KANSAS
SITE --'MISSOURI
(?) GALENA
^SUBSITE
AREA
CHEROKEE COUNTY
SITE BOUNDARY
IfAWflf
LAKE
BAXTER
SPRINGS
KANSAS
OKLAHOMA
LAKE OTHE
CMSaOKEES
y
SU8SITE LEGEND:
1. WACO AREA
2. LAWTON AREA
3. BADGER AREA
4. GALENA SUBSITE AREA
/y
5. BAXTER SPRINGS AREA
6. TREECEAREA
FIGURE
SITE LOCATION
CHEROKEE CO.. KANSAS
GALENA SU8SITE-OUFS
ALTERNATIVE WATER SUPP'.Y
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Large chunks of unmilled waste rock derived from the excavation of vertical
shafts have been termed "bullrock." Little to no vegetation is found on
chat-covered areas. Although a very large portion of the subsite is covered
by these chat and bullrock piles, it has been impractical to measure or
estimate the quantity of this material at the site.
The EPA began its investigation of the Galena subsite in 1985. A Phase
I remedial investigation was completed in 1986. This investigation examined
the impacts of the mining activities on the ground water, surface water,
ambient air, soils, stream sediments and fish. At the result of this work,
EPA determined additional information on the ground water and surface water
was necessary in order to evaluate potential remedial actions. These additional
investigations were conducted in 1986 and 1987.
The subsite investigations demonstrated that the shallow ground water
aquifer and the surface water are contaminated with.elevated concentrations of
metals. The private shallow aquifer wells that were found to be contaminated
have been of great concern. Many of these private wells are contaminated
with metals that exceed the primary and secondary maximum contaminant levels
established by the Safe Drinking Water Act. Due to the concern for the
health of persons drinking this contaminated water, EPA, Region VII conducted *
a removal action and installed water treatment units on these wells with
permission of the property owners. This removal action has been considered a
temporary protective measure.
Table 1 lists the average and maximum levels of metals observed in
private wells in the subsite and the drinking water standards. The metals of
most concern for human health are cadmium, lead, selenium and zinc. The kidney
is the critical target organ in humans chronically exposed to cadmium by
ingestion. Exposure to lead can cause severe neurotopic effects that include
irreversible brain damage. Selenium ingestion causes depression, gastrointestinal
disturbances and occasional dermatitis. Excessive levels of zinc can cause
stomach disorders. Exposure to cadmium can cause changes in the distribution
of zinc, with increases in the liver and kidneys.
ENFORCEMENT
General notice letters were issued to inform potentially responsible parties
(PRPs) of their potential liabilities for past activities at the Cherokee County
site. Nine mining or former mining companies were notified in 1985. Two
additional companies were notified of potential responsibility in 1986. The
original nine companies received notification prior to the removal action and
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TABLE 1
CONCENTRATIONS OF TOTAL METALS
OBSERVED IN PRIVATE WELLS
Average Observed Maximum Observed Standard or
Metals
Barium
Cadmium
Chromium (total)
Copper
Lead
Manganese
Me rcu ry
Nickel
Selenium
Silver
Zinc
Value (ug/l)a Value (ug/1)
79
7.8
95
23
28
100 3
0.059
23
28
7.3
980 15
390
180
95
940
230
,400
0.44
190
50
11
,000
Criteria (ug/1 )
l.OOOb
lOb
50b
l.OOOc
50bd
50c
2b
150e
lOb
50b
5,000c
d = Micrograms per liter
b * Primary MCL,
c = Secondary MCL
d - The proposed
Safe Drinking Water Act
, Safe Drinking Water Act
MCLG (Safe Drinking Water
e = Lifetime Health Advisory (EPA, Office
Act) is 20
of Drinking
ug/1
Water)
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prior to the remedial investigation. All eleven companies indicated
no desire to participate in the remedial investigation or any additional
investigations or the Operable Unit Feasibility Study. The EPA conducts
periodic meetings with these PRPs to facilitate information sharing.
Special notice letters to initiate formal negotiations with these
eleven companies regarding the Remedial Design/Remedial Action (RD/RA) for
the alternative water supply operable unit are scheduled for issuance in
early 1988. In addition, the special notices will initiate negotiation
regarding the RD/RA of the second operable unit for the subsite on ground
water and surface water cleanup.
COMMUNITY RELATIONS HISTORY
Community and Congressional interest regarding EPA's activities at the site
have been high. A public meeting was held in July 1985 prior to the beginning
of the RI/FS. Another public meeting was held in May 1986 at the conclusion
of the remedial investigation and prior to the removal action. At the
conclusion of the OUFS for the alternative water supply, another public
meeting was held in November 1987.
All public meetings were held in the Galena subsite. The latter public
meeting coincided with a 37-day public comment period. A responsiveness j
summary of public comments regarding the alternative water supply OUFS is
attached to this Record of Decision. Information regarding EPA's
activities at the site has been available at the Galena Public Library in the
form of the information repository and administrative record. All community
relations activities have been in conformance with the requirements of
Section 117, CERCLA, as amended by SARA, and the National Contingency Plan
(NCH) in 40 CFR §300.
A group of legislators formed a task force to help assist coordination
of activities at the Cherokee County site. The task force is made up of 22
people, including the Lieutenant Governor, four State Senators and Representatives,
a U.S. Representative and people representing the City of Galena, Cherokee County,
Kansas National Guard, Kansas Department of Health and Environment, Kansas
Mined Lands Conservation and Reclamation Board, Kansas Water Office, U.S.
Bureau of Mines, U.S. Office of Surface Mining, U.S. Soil Conservation
Service, EPA and citizens.
DEVELOPMENT OF ALTERNATIVES
The remedial alternatives for the Alternative Water Supply Operable Unit
were developed and evaluated in compliance with the Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA), 42 U.S.C. §9t>01 et seq.,
and the National Oil and Hazardous Substance Pollution Contingency "Plan, 40 CFR
Part 300 (NCP). Section 121(b) of CERCLA provides that a remedy shall
be selected that is protective of human health and the environment, that is
cost-effective and that utilizes permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent practicable.
The OUFS for the alternative water supply evaluated alternatives in light of the
requirements of Section 121 of CERCLA.
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Remediation Goals
The primary goal of the operable unit remediation is to provide suitable
drinking water to the population within the subsite. Suitable drinking water
is water that meets the primary maximum contaminant levels (MCLs), 40 CFR §141,
as set by the Safe Drinking Water Act, 42 USC §1412 at existing water taps.
In addition, Kansas Safe Drinking Water Standards, KAR 23-15-1 through -10
should be met to provide safe and suitable drinking water. A second indirect,
but equally important goal, is to protect the deep aquifer from contamination
that could occur as a direct or indirect result of implementing an alternative
water supply. These goals are compatible with overall site-wide and subsite
remeaiation goals.
Initial Screening
Several general response actions and technologies were evaluated for
collecting, treating and distributing an alternative water supply. All
alternatives were evaluated based on their ability to achieve remediation goals.
Screening of the response actions and technologies as required by 40 CFR
§3U0.68(g) was conducted to eliminate alternatives that: 1) Did not effectively
protect public health, welfare and the environment, 2) Were not feasible or
reliable for the site and 3) Did not provide substantially greater protection, *
but were of greater costs. Table 2 lists the response actions and
technologies that were reviewed and specifies reasons for the elimination
of various technologies. The OUFS may be reviewed for details on the screening
process.
Various technologies to implement a reliable, good quality water supply
for the population were reviewed. Sources of water considered included: 1)
Deep aquifer, 2) Shallow aquifer, 3) Surface water and 4) Imported water.
Imported water technologies included tank truck delivery and bottled water
delivery. Surface water and shallow aquifer sources required biological,
chemical and physical treatment technologies and a pipeline distribution system
for delivery. The deep aquifer source required only chlorination and a pipe-
line system for delivery.
Remedial alternatives were developed utilizing the available technologies
after the initial technology screening. These preliminary alternatives were screened
using the same methodology employed in the technology screening, eliminating
alternatives that: 1) Did not effectively protect public health, welfare and
the environment, 2) Were not feasible or reliable for the site and 3) Did not
provide substantially greater protection, but were of greater costs. Table 3
lists these preliminary remedial alternatives and specifies reasons for the
elimination of various alternatives. The OUFS may be reviewed for details
on the screening process.
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Table 2
RESPONSE ACTION AND TECHNOLOGY LIST AND SCREENING
General Reaponie Reaponae Action* Potential Technologic*. Technical Option*
I. Ho Action No Action Not Applicable
2. Treatment at Individual Well Treatment Biological
Chemical
Phyalcal
Byproduct DUpoaal Undflll
*
Und Application
Byproduct Rcuae
3. Import Potable Water Supply Alternate Supply Distribution Syate*
*. Develop and Dlatrlbute En! a ting Collection Deep Well*
or New Peep Aquifer Supply
(Roubldoux)
Treatment Biologic*!
Chemical
Phyalcal
niitrlbutlon Pipeline Syatem
Storage
--
Chlorlnatlon
Precipitation
Filtration
Reverae Oamoal*
Ion Exchange
Hanganeae Creenaand
Filtration
Carbon Adaorptlon
Water Softening
Distillation
Boiling
RCRA Type
Sollda Undflll
--
Coat Recovery
Bottled Water Delivery
Tank Truck Delivery
Connect to Galena ayatem
Connect to other water
dlatrlcta
Hew Syatem
• -
Chlorlnatlon
Other*
-•
Pimped praaaura ayatem
Elevated Tank*
Reaervolr*
Retained for
Comnenta Further Analyala
No action alternative.
Not applicable for treatment of ahallou ground-
water with metala contamination.
Dlalnfectlon not required for Individual ayatema.
Not practical for am*ll ayatema.
Poaalble pretreatment prior to RO.
Marginally tultable for private well*.
Effective for metal* removal.
Huy be required for Iron end manganeae removal.
Not aa effective ea other method* for metala
removal.
Suitable for realdencea but not well proven for
metal* removal.
Very expensive, but retain for waate volume
reduction.
Not practical for netal removal due to high coata
and energy requirement*.
Hay bo required for aoiae waate* from treatment
proceaa.
Hay be acceptable for aome wastes from treatment
process.
Hay be acceptable for tome waste* from treatment
proceaa.
Not economical for small quantltle*.
Provide* only drinking and food preparation water.
Provldea only In-houae water uae*.
Cloaeat exlatlng *ource.
Generally farther away and Inadequete capacity.
Feasible.
Not needed.
Uacd for disinfection.
Hot needed.
Hot needed.
Convention*! water distribution system.
--
--
Yes
No
No
No
Ye*
Ye*
Ye*
Ye*
No
Ye*
Yea
No
No
Yea
Yea
Yea
No
Yea
Yea
Yea
No
Yea
No
Yea
No
No
Yea
Yes
Yea
-------
General Re»pon«e
Beapona* Action* Potential Technologic«
5. Develop, Treat, and Distribute
Shallow Aquifer Supply
Collection
Treatment
Shallow Well!
Biological
Chemical
Ptiyilcal
Byproduct Dlapoaal Landfill
Distribution
l.*nd Application
Byproduct Reuse
Pipeline Syatem
Storneu
Table 2
(continued)
Technical Options
..
--
Qilorlnstlon
Precipitation
Neutralliatlon
Aeration/Oxidation
llydrolyala
Dechlorlnatlon
Ozonstlon
Ultraviolet Radiation
Fhotolyala
Ion Exchange
Lime Softening
Coagulatlon/Flocculatlon
Sedimentation
Filtration
Oil -Water Separation
Carbon Adaorptlon
Mn Greenland Filtration
Membrane proceaae*
Reverse Osmosla
Ultraflltratlon
Dialysis
Electrodlalyala
Air and Steam Stripping
Flotation
Distillation Froce****
RCRA Type
Solid* Landfill
..
Coat Recovery
Pumped preaaure system
Clevated Tanka
Reservoirs
Retslned for
Connents Further Analysis
Location selection Is Important to ensure adequate
supply.
Not applicable for treatment of water that does not
have high organic contamination.
Uaed for disinfection.
Effective for removing soluble hesvy metal*.
May be required to *d]uat pll.
Used for Iron removsl.
Not well suited for water treatment.
Not required.
High cost, eliminated In favor of chlorlnatlon
for disinfection.
Deleted In fsvor of chlorlnatlon for disinfection.
Not suited for water treatment.
Effective for metala removal.
Hay not reduce sietsla to required levels, but
retain for further analycl*. Consider using with
soda ash.
Hay be required aa a pretreatment.
An Important process In precipitation of heavy
•etala.
An Important process Is precipitation of heavy
metala.
Not required for groundwater treatment.
Not aa effective aa other aiethoda for metal
removal.
Hay be used for Fe and Mn removal.
Depends on pretreatment requirement*.
Not aa effective a* RO.
Feasible, but more expensive thsn RO.
Feasible, but Bore expensive thsn RO.
Used for VOC removal. Not suited for metal
removal.
Hot aulted for metala removal.
Very expensive compared to membrane proceaaea but
retain aa possible mesns of wsste volume reduction.
Hay be required for some waste* from water
treatment proceasea.
Hay be acceptable for aome waste* from wster
treatment proceise*.
May be acceptable for aome waatea from water
treatment proceaaea.
Not economically feaalble for small quantities.
Conventional water distribution system
--
. .
Yes
No
Yes
Yes
Yes
Yes
No
No
No
No
No
Yes
Yea
Yea
Yea
Yes
No
No
Yes
Yes
No
Ho
Ho
No
No
Yes
Yea
Yea
Yea
No
Yea
Yea
Ye*
-------
General Re*ponae
6. Develop, Treat, and Distribute
Exlitlng or Hew Surface Water
Supply
Response Action* Potential Technologies
Stress) Intake
Collection
Raw water atorage
Channelisation
Treatment Biological
Chealcal
Pliyalcal
Table 2
(continued)
Technical Optlona
Connect to City of Baxter
Springa
Spring River location
Shoal Creefc Location
Short Creek Location
Eaplre Lake Location
Reservoir
Chlorlnatlon
Precipitation
Hautralliatlon
Aeration Oxidation
llydrolyala
Dechlorlnafion
Oionattbn .
Ultraviolet Radiation
Photolysis
Ion Exchange
LlM Softening
Coagulatlon/Plocculatlon
Sedimentation
Filtration
Oil-Water Separation
Carbon Adsorption
Molecular Slevea
Hunganeae Creenaand
filtration
Membrane Processes
Reverae Osmosl*
Ultraflltretlon
Dlalyala
eiectrodtalyala
Air and Steam Stripping
Flotation
Distillation
nt§
Retained for
Further Analyst*
Require* enpanalon of water treatment plant. Yea
Reliable aource with aultabla quality. Ye*
Somewhat lesa reliable aource and quality. Yea
Insufficient flow and degraded quality. Ho
Degraded water quality due to Short Creek discharge* Ho
and Halted circulation.
Hoy be required for •••Her water aourcea. Ye*
Not neceaaary to collect water. Letter option la
to collect froa enisling atream or Impoundment*. No
Not required. No
Died for disinfection. Ye*
Effective for removing aoluble heavy netall. Ye*
Hot required. No
U«ed for Iron removal. Yea
Not well aulted for water treatment. Ho
Not required. Ho
High coat and complex, delete In favor of chlorl-
natlon for dlalnfcctlon. No
Delated In favor of Chlorlnatlon for disinfection. Ho
Not wall aulted for water treatment. No
Hay be required If netal level* are high. Ye*
May not reduce aetal* to required levela, but
retain for further evaluation. Consider using
with aoda ash. . Yea
Effective process for reducing surface water Yea
turbidity.
Effective process for reducing surface water Ye*
turbidity.
Effective process for reducing surface water Yea
turbidity. No
Not required for local water aource*. Yea
Hay be required to resutve TIIH'a If present. Yea
Better treatment processes are available.
Use only if Fe and Mil are problusia. Yea
Needed only If aiotal levela are high. Yea
Hcuded only if swtal levela are high. Yea
Heedeil only If aictal levela are high. Yea
Needed only If octal level* are high. Ye*
Hot required for aietala treatewnt. No
Hot required for Bctala treatment. No
Very expensive and not required for treatatent. No
10
-------
General Reanoni* Re*pon*a Action* Potential Technologic*
». Develop, Treat, end Distribute Byproduct Dlepoiel Landfill
Surface Water Supply (continued)
Land Application
Byproduct Reute
Distribution Pipeline Syatea
Storage
Table . 2
(continued)
Technical Option*
RCRA Type
Solid* Landfill
Coat recovery
Puaped Preeaur* Syateu
Elevated Tanke
Reiervolra
Content a
Hay be required for *OBC watte* fron water
treatment proceaaa*.
Hay ba acceptable for aone wattea frooi water
treetnent proceaaaa.
Hay be acceptable for (one waatea froa water
treataient proceaaea.
Not economically feaalbla for the mall
quantltlea.
Conventional water dlatrlbut Ion ayaten.
Retained for
Fiirther Analyali
Yea
Yea
Yea
No
Ye*
Ye*
Ye*
11
-------
Table 3
PIlBI.IHINARy ALTERNATIVE SCREENING
General
Response
I .allvlnary
Alternative
I. Ho Action
2.
3.
Treat at
Individual
Hell.
liipoct Water
Supply
Ho Action
Treat at Individual
wells
bottled water delivery
Tank truck delivery
4.
Deep Aquifer
Supply
S.
Shallow
AIJU Her
Supply
City of Galena,
deep wells
New rural water dls-
trlct. deep well
Shallow aquifer well
In "Hull* Half-Acre."
Ion ««cli*noual.
liipleetentablllty
Not applicable
Poor. Requlree Inetallatlon of
•any treatment units. Poor con-
trot of aialntenence and wast* by-
product disposal.
Good. Requires vendor or agency
to establish and operate bottle
distribution syeteai. Very
flenlble.
Good. Requires vendor or agency
to establish and opsrste tsnk .
truck delivery eysteat. Requires
placement of storage tsnk* on
•very water iissr* property.
Good. Rsqulres sisnsgsaMnt by
rural wat*r district oc City of
Galena snd cooperation with City
of Calsns for use of evicting
wells.
Good. Require* rural water
dlitrlct.
Good. Requlree rural water dle-
trlct And conpnrutlon with City
of Caluna In locating treatauiiit
plan), end distribution
Pralleilnary Cost Eetlaatre
AnnuaI
Initial Operation
Capital and Maintenance
*2,000,000
$100,000
100,000
300.00O
1,200,000
100,000
1.200,000
1,10O,OOO
4,600,OOO
100,000
100,000
150,000
Screening
Retain. No action alternative la
retained for detailed evaluation
to provide coaparlson.
Del'ete. Poor Maintenance
(effsctlvenrit) control.
Retain. Attains specific goals
st lowest Initial coat.
Delete. Attains same basic goals
as bottled water delivery, but Is
•inch (tore costly.
Betsln. Good Implcusntablllty It
Is feasible to enpsnd distribution
eyeteei and rehabilitate enlatlng
welle.
Retain. Slullar to above
alternative.
Delete. Capital coat la slightly
ttlqhrr than for luc.it Ing shallow
wello In the arcA west of Catena.
Poorer qullty aoiirco water.
Anitttal t:ostn lil^ltcr th^u tnv lime
•iifl en! ii'l I rculr.niil JHO to lo.juii-
rrato w.inlu illti|H>sal I rqul rcMiii •-
12
-------
Table 3
(contInuodl
Cenural
Response
S. (cont'dl
Preliminary
Alternative
Shallow-aquifer well
In "Hells Half-Aero,"
line softening traat-
•ont
Shallow aquifer well
west of Galena, Ion
exchange treatment
Shallow aquifer well
weit of Galena, !!••
eoftenlng treatment
Surface Water
Supply
Shoal Creek Intake)
Spring River Intake
Effectiveness
Poor groundwatar quality
•ay require eecondary
treatment to Beet ARAB'a.
Require* potentially
haiardoua waete product
disposal.
Poor groundwater quality
•ay require secondary
treatment to Beet AMD's.
Requires) potentially
haiardoua waete byproduct
disposal.
Poor groundwater quality
•ay require secondary
treatment to Met ARAR's.
Require* potentially
haxardoua waete byproduct
disposal.
Should nomally achieve goal
of providing eafe water.
SOM concern for potential
dlecherg* of poorly treated
eewaga effluents upatreaa
of Intake combined with
••all dilution capability
of Shoal Creek. Requlree
waete byproduct disposal.
Achlovea goal of providing
eafe water eupply. Requires
waste byproduct dlnpueal.
Implementablllty
Good. Requires rurel water dis-
trict and cooperation with City
of Galena in locating treatment
plant and distribution eyatea.
Good. Requlree ruret water dle-
trlct and cooperation with City
of Galena In locating treatment
plant.
Good. Requires rural water
district and cooperation with
City of Galena in locating
treatMnt plant.
Good. Requires rural water dis-
trict. Dlveralons during low
flow stay adversely lapact fish
or wildlife. fleets concern over
adequacy of wetor eupply.
Technology readily available and
fssslble.
Good. Requlree rural water dis-
trict. Technology readily
available and feaalble.
Preliminary Cost Estimates
Annusl
Initial Operation
Capital and Maintenance
$4,600.000
$2SO,000
4,400,000
150,000
4,400,000
250,000
4,900,000
250,000
S,IOO,OOO
2SO.OOO
Screening
Delete. Capital cost la slightly
higher than Cor locating wells In
the area wont of Galena. Poorer
quality water source.
Delete. Ion exchange waste
disposal more coatly than live
aoftenlng.
Retain. Slightly lower capital
coat than fur locating wells In
"llnll'e Half Acre.* Lower annual
coats than for Ion exchange
treatment. Petaln for evaluation
of ono ehallow aquifer alter-
natlvn. Bettor quality water
eource.
Delete. Creator problems with
water quality, water eupply and
Isipacte on biota than In using ,
Spring River.
Retain. Host reliable quantity
and quo Illy uf Hie surface ~ef
sources consldeied.
13
-------
Tal>le 3
(continued)
Preliminary Coat Eetl»atee
Annual
General Preliminary ' Initial Operation
Response Alternative Bffectlvenea* Inpleisentjblllty Capital anj Maintenance Screening
6. (cont'd) City of Baxter Sprln9i, Achieve* goal of providing fair. Requires rural water die- $5.500,000 ' $350.000 Delete because eource le rela-
Sprlng River and deep cafe water aupply. Soeie trlct and cooperation with City lively remote Cruai eervlce area
wulle concern for effect* of . of Banter Springe. Require* and because the City la currently
Short Creek octal* die- expansion of treatment plant having groundxalnr and surface
charge Into Spring River. (river water) or new well. water quality problems. More
Protection of deep aquifer Require* river croselng for costly than other surface
water quality requires fur- trsnealeelon pipeline. eources.
ther evaluation If deep
well reaource le used.
• Require* wait* byproduct
disposal.
-------
15
Detailed An_a 1 ysis_ of_A1te nn atj ves
The initial screening of preliminary alternatives and response technologies
provided the basis for selectiny alternatives for detailed analysis. The six
remaining alternatives have been fully discussed in the OUFS Report. A brief
explanation of eacn alternative follows:
0 Alternative 1: No Action
No action would be taken to improve the water supply to the residents.
It is assumed that the residents would continue to use the existing shallow
wells as the primary source of water and that no treatment would be provided.
Periodic monitoring was considered as a back-up to the no-action alternative.
0 Alternative 2: Bottled Water
This alternative would provide water only for drinking and food
preparation. Water for all other uses such bathing, washing clothes and
dishes, toilet flushing, cleaning and lawn and garden irrigation would be
provided by existing shallow wells.
0 Alternative 3: City of Galena, Deep Wells *
Water would be collected from the City of Galena deep aquifer wells,
chlorinated and distributed to the residents via a water pipeline network.
The water collection and treatment would be maintained by the City of Galena.
The distribution of the water past the city boundaries would be managed by
the City of Galena, an existing rural water district or a new rural water
district.
0 Alternative 4: Rural Water District Deep Well
The alternative water would be collected from a deep aquifer well to be
constructed west of the City of Galena. Tne water would be chlorinated
and distributed by a water pipeline network to the residents. The entire
system would be managed by an existing rural water district, a new rural
water district or the City of Galena.
0 Alternative 5: Shallow Aquifer Well
The alternative water would be collected from a shallow aquifer well to be
constructed within the City of Galena. The water would be treated to remove the
heavy metals in a newly constructed water treatment plant. After treatment,
the water would be distributed by a water pipeline network to the residents.
The system would be managed by the City of Galena, a new rural water district
or an existing rural water district.
-------
16
0 Alternative 6: Spring River
The alternative water would be collected from a surface water intake
on the Spring River to be constructed north of Short Creek. The water
would be treated in a newly constructed water treatment plant located near
the intake. After treatment, the water would be distributed by a water
pipeline network to the residents. The system would be managed by the City
of Galena, a new rural water district or an existing rural water district.
As required by 40 CFR §3U0.68(h), EPA conducted a detailed analysis of
each of the six remedial alternatives. The analysis included: 1) Refinement
of the feasibility of the alternative, 2) Detailed cost estimation, including
operation and maintenance costs and distribution of cost overtime, 3)
Evaluation in terms of engineering, implementation, reliability and construct-
ability, 4) An assessment of the extent to which the alternative effectively
prevents, mitigates or minimizes threats to and provides adequate protection
of public health and welfare and the environment, 5) An evaluation of the
extent to which the alternative attains or exceeds applicable or relevant
and appropriate federal public health and environmental requirements, and
6) An analyses of any adverse environmental impacts. Analyses of recycle/reuse
waste minimization, waste biodegradation, or destruction or other advanced,
innovative or alternative technologies were not reviewed. These later analyses
will be made in the ground water/surface water OUFS. For a detailed description)
of the analyses conducted, refer to the OUFS Report.
The six alternatives considered in the detailed evaluation were compared
to CERCLA criteria for selection of remedy as defined in Section 121 of CERCLA
and EPA OSWER Directives 9355.0-19 and 9355.0-20. These remedy selection
criteria include: 1) Compliance with applicable and relevant or appropriate
state and federal regulations (ARARs), 2) Reduction of mobility, toxicity
or volume of waste, 3) Short-term effectiveness, 4) Long-term effectiveness,
5) Permanence, 6) Implementability, 7) Cost and 8) Community and state
acceptance. The detailed analyses of each alternative are summarized in
the following sections and on Table 4. More detailed information is located
in the OUFS Report.
Compliance With ARARs
Section 121(d), Degree of Cleanup, CERCLA, as amended by SARA, requires
that remedial actions shall attain a degree of cleanup of hazardous substances
released into the environment and a degree of control over further release
that at a minimum assures protection of human health and the environment. This
section elaborates on cleanup standards to be employed with respect to any
hazardous substance or contaminant that will remain onsite. It requires that
any Federal or State criteria or standard which are legally applicable to the
hazardous substance or are relevant and appropriate under the circumstances
shall be the level or standard of control for such hazardous substance or
contaminant remaining at the site. Certain Federal or State standards have been
determined to be legally applicable or relevant and appropriate requirements (ARARs)
-------
TABLE 4 - DETAILED EVALUATION OF ALTERNATIVES
Alternative
Convl iance
With AKARs
Reduction of
Mobility. Toxicity
or Volume of Waste
Short-Term
Effectiveness
(Construction)
Long-Tern
Effectiveness
1. NO Action
2. Bottled
Water
3. City of
GaIena,
Deep Wells
Does not meet
AKARs for drinking
water supplies.
Can be designed
to meet AKARs.
Meets ARARs.
No reduction of
TO01 lity, toxicity
or volume.
No reduction of
mobility, toxicity
or volume.
No reduction of
nobility, toxicity
or volume.
Risks to public nealtn
and environment remain
at current levels.
No construction, there-
fore, no additional risk
to conminity, workers
or environment during
construction. No
design needed, there-
fore, Implementation
•tould be rapid.
Worker precautions
necessary during
construction of the
distribution system
through mining areas.
Potential exposure of
community due to
soil disturbance.
Increased stream
turbidity possible
during stream
crossing of pipeline.
One year or "ore
required for design
and construction.
Kisks to public healtn
remain at current levels.
Risks may decrease over
geologic time due to
natural degradation.
Lower level of water
service than the other
action alternatives.
Residents oust keep
existing water supply
systems in service for
nondrinking uses.
Less protective of public
health than the other
action alternatives.
Bottle delivery system
and the water quality
are expected to be
reliable.
Very effective, fully
protects public health,
and is very reliable.
Increased use of the
Roubldoux aquifer water is
not expected to Increase
the potential for shallow
ground water to migrate
Into the Roubldoux system.
Permanent safe drinking
water supplied to
residents.
4.
Rural Water
District,
Deep Well
Meets AKARs.
5. Shallow
Aquifer
Can be designed
to meet ARARs.
6. Spring River
Can be designed
to meet AKAKs.
No reduction of
mobility, toxicity
or volume.
May have
beneficial Impact
on reduction of
add nine drainage
Into Short and
Shoal Creeks.
May nave limited
reduction of
nobility, toxicity
or volume of
contaminants In
Spring River.
Worker precautions
necessary during
construction of dis-
tribution system
through mining areas.
Potential exposure to
community due to soil
disturbance. Increased
stream turbidity
possible during stream
crossing of pipeline.
One year or more
required for design
and construction.
Greater potential for
exposure to workers
and community relative
to Alternatives 3, 4
and 6. Increased
turbidity possible
during stream crossing
of pipeline. One year
or more required for
design and construction.
Worker precautions
necessary during
construction of dis-
tribution system
through mined areas.
Potential exposure to
community due to soil
disturbance. Increased
stream turbidity
possible during stream
crossing of pipeline
and construction of
Intake. One or more
years required for
design and construction.
Very effective, fully
protects public health
and is very reliable.
Increased use of the
deep aquifer water Is not
expected to Increase the
potential for shallow
ground water to migrate
into the Roubldoux system.
Very costly treatment
system required.
Potential for problems
with shallow ground water
quality and the capability
for reliable treatment.
Wastes from water
treatment would be
difficult and costly to
handle and dispose and
would be considered
hazardous. Handling
and disposal of water
treatment hazardous
wastes would cause
adverse environmental
impacts.
Very effective and fully
protects public nealtn.
water supply and water
treatment method are
reliable. Water treatment
lime sludge requires
disposal. Conventional
landfill disposal can be
accomplished w1tn minimal
envi ronoenta1 impact.
-------
TABLE 4 (t._.,cinued) - DETAILED EVALUATION OF ALTEKNATIVES
Alternative
I. NO Action
2. Bottle
Water
3. City of
(ialena.
Deep
Wells
4. Rural Water
Uistriet.
Deep
Hell
5. Snallow
Well
6. Spring River
Permanence
Not applicaole.
Not a permanent
solution to
protect puolic
health.
Permanent solution
for alternative
water supply.
Not a permanent
solution for final
site-wide actions.
Provides for a
permanent solution
for alternative
water supply.
Not * permanent
solution for
final site-wide
actions.
Provides for a
permanent solution
for alternative
water supply,
although residue
hazardous material
will need to oe
disposed of. Not
a permanent
solution for
site-wide final
action.
Imp lenient ability Cost
Not applicable
Total Present Worth
J23U.UUU
Annual O&H
JZi.UUU
Total Present Worth
S2.bUU.OUO
Annual OW
J230.000
Good technical
and administrative
feasibility. No
offsite needs or
effects. Existing
Institutional control
of bottled water
vending is adequate.
Host flexible action
alternative.
Good technical feasl- Total Present Worth
bility. Requires S5.300.UUO
the cooperation of Annual 04M
City of Galena and S100.0UU
may require establish*
merit of a RWD. No
offsite needs or
effects. Existing
institutional
controls on municipal
water supply systems
are adequate. Low
flexibility for modifying
systems after installation.
Good technical
feasibility.
Requires establish-
ment of a RWU and/
or cooperation of
City of Galena.
No offsite needs
or effects. Existing
Institutional controls
on public water
supply system are
adequate. Low
flexibility for
modifying system
after Installation.
Total Present Worth
JS,300.UUU
Annual OIM
WOO. QUO
Questionable
technical feasibility.
Treatment process will
require pilot testing.
Requires a RWD and/or
cooperation of City of
lialena. Offsite hazardous
waste disposal required.
Existing Institutional
controls on public
water supply and on waste
disposal are adequate.
Poor flexibility for
modifying system after
Installation. Shallow
well supply My conflict
with ground water/surface
water remedial measures.
Total Present Worth
J8.a80.000
Annual 0*H
$3ZO,OUU
Provides tor a
permanent solution
for the alternative
water supply. Not
a permanent solution
for final site-wide
actions.
(iood technical
feasibility.
Requires estab-
lishment of a
RWU and/or
cooperation of
City of (ialena.
Requires offsite
lime sludge
disposal. Existing
Institutional
controls on
public water
supply systems are
adequate. Low
flexibility for
modifying systems
after installation.
Total Present Worth
$7.SOU,000
Annual 04M
S2UU.OUO
Community and
State Acceptance
Community and state
desire remediation of
the water supply. NO
action is not consistent
with community and state
sentiment.
Effected community may
not be supportive because
inconvenient alternative
and expensive U&N. State
Is not supportive of
alternative.
Public acceptance 1s
supportive, but varies
depending on cost to
individuals. Alternative
is supported by the state.
Public acceptance Is
variable depending on
cost to Individuals.
Alternative probably
would be supported by
the state If Alternative
3 Is not available.
Coawnity and state
acceptance of using poor
quality water shallow
aquifer as a source nay
be poor. Community and
state acceptance of
water treatment wastes
management methods may
be poor.
Community acceptance
variable depending
on costs to Individuals.
State not supportive
due to high U4M costs.
-------
for cleanup standards for the implementation of the remedial action at the
Galena subsite. Since hazardous substances will remain at the subsite after
completion of this remedial action operable unit, it was essential to identify
ARARs prior to, and in conjunction with, evaluation of the alternatives.
All alternatives that were evaluated can attain all ARARs for the
alternative water supply operable unit, with exception of the no-action
alternative.
Reduction of Mobility, Toxicity or Volume of Waste
Section 121(b) of CERCLA, as amended, states that remedial actions involviny
treatment, which permanently and significantly reduce the volume, mobility or
toxicity of hazardous materials, are to be preferred over those not involving sucf
treatment. Tnis evaluation criterion relates to the ability of a remedial
alternative to control or eliminate risks caused by the mobility, toxicity
or volume of a hazardous waste.
Alternatives 1 through 4 would have no direct impact on the mobility,
toxicity or volume of hazardous materials on the Galena subsite. Alternative 5
involves the pumping and treatment of the shallow ground water and may have
a beneficial impact on acid mine drainage into Short Creek and Shoal Creek. k
Alternative 5 may reduce the contaminant levels in the ground water which may
be an overall benefit to the subsite. Alternative 6 involves treatment of
water from the Spring River. Although Alternative 6 may reduce the level of
metals in the Spring River slightly, it would have little overall effect
on the contaminant levels in the river and would have limited overall effect
on the contaminant concentration levels in the ground water.
Short-Term Effectiveness
Short-term effectiveness measures how well an alternative provides
protection of the environment, community and workers during construction and
the time required for implementation of the remedial action.
Short-term risk to the public health and the environment would remain
at current levels for Alternatives 1 and 2. During the construction of the
waterlines for the pipeline network, Alternatives 3, 4, 5 and 6, would present
greater potential risks to the workers and the community due to the soil
disturbance in the mined areas. Stream turbidity may increase in Shoal Creek
while constructing a pipeline across the creek in Alternatives 3, 4, 5 and 6.
Some disruption of flow and turbidity may be created in Spring River during
the construction of the water intake described in Alternative 6.
Alternative 2 may be implemented immediately, while Alternatives 3, 4, 5
and 6 may take a year or more to design and construct. Alternative 1, No Action,
has no implementation.
-------
2U
Long-Term Effectiveness
Long-term effectiveness addresses the long-term protection and reliability
that an alternative affords. This includes the risk to the community once
the remedy is in place, risk to workers during operation and maintenance (O&M),
environmental risk due to residual hazardous substances, long-term reliability,
O&M requirements, time required to achieve protection and the difficulty in
detecting and mitigating problems with the completed remedy.
Alternative 1 would not be effective in protecting public health. The public
would continue to use existing wells for their water supply. A few people
may, on their own initiative, convert to an alternative water supply. The
health of the people who have shallow wells with poor quality water would be
at risk. More wells may become contaminated in the future, exposing additional
people to contamination. Without continued water quality monitoring, newly
contaminated wells would not be readily identified. Alternative 1 would not
be effective in protecting the environment.
The quality of the bottled water provided in Alternative 2 would be expecte/d
to be good. The level of service would be much less than in the other action
alternatives. The existing private shallow aquifer wells would remain in service.
Therefore, when more convenient, the shallow ground water may be used for
drinking and food preparation. The bottled water delivery system should be
reliable; however, poor road conditions and unreliable vendor operations
could cause some delayed product deliveries. Long-term 04M would be the
responsibility of the property owners. Due to the relatively high monthly cost
and inconvenience of handling of the bottled water, property owners may stop
the delivery and return to using their private wells for drinking water.
Alternatives 3, 4 and 6 would provide effective protection of public
health as soon as the construction and house connections are complete and the
system is operational. The water supplied should be of good quality. These
alternatives require conventional and well-proven distribution and treatment
systems. During routine O&M, workers should not be exposed to the hazardous
substances at the subsite. Occasionally, repairs to the pipeline may be
needed in the mined areas causing increased potential exposure to workers and
the community during those repairs. Alternatives 3 and 4, which would draw
water from the deep aquifer, may increase the shallow aquifer-deep aquifer
head differential. This is not expected to increase the potential for shallow
ground water to migrate into the Roubidoux System.
Alternative 5 may result in greater public health risk than Alternatives
3, 4 and 6. Reliable treatment of the shallow ground water may be difficult.
Therefore, the supplied water quality may be of questionable quality. Alternative
5 may have beneficial effects in reducing the amount of mine shaft water and
-------
shallow ground water that discharges into Short Creek and Shoal Creek.
Alternative b.may produce a hazardous material requiring storage, transportation
and disposal. Increased environmental risks may be created in the handling
and disposal of this material.
Permanence
The criterion of permanence is similar to lony-term effectiveness, but with
an emphasis on the need for management of treated residuals and untreated wastes.
The long-term remediation and permanent remediation of the source material will
be addressed in the second operable unit. This operable unit only addresses the
alternative water supply.
Alternatives 3, 4 and 6 would provide for a permanent solution for the
alternative water supply although continued O&M would be required to provide
the water supply. The sludge from Alternative 5 may contain hazardous materials,
wnich would require regulated disposal as a RCRA waste. Therefore, Alternative
5 would have continued O&M of hazardous substances. Alternative 2 would not
be permanent because it would not provide full protection for the public health
and may be eliminated at any time by the property owner. Alternative 1, No Action,
provides no permanence. )
Implementability
The implementability criterion measures the technical difficulties,
operations, reliability and availability of each alternative. Implementability
also involves the administrative feasibility of each alternative.
The implementability criterion does not apply to the no-action alternative
since no measures would be taken to provide a water supply. Alternatives 2, 3,
4 and 6 all have good technical feasibility and reliability. The proposed
water collection, treatment and distribution methods are all well proven to
perform their-intended functions. The technical feasibility and reliability'
of Alternative 5 is questionable. Water treatment to reduce acid mine drainage
heavy metals to drinking water standards and disposal of the waste products have
not been widely performed and are not well proven processes. The availability
of equipment for Alternatives 2, 3, 4, 5 and 6 is not expected to cause any
delays.
Alternative 2 would require administration of the process of installing
bottled water dispensers in the service area for residences and businesses. The
property owners should be responsible for maintaining the communications with
the bottle water distributors in order to receive a continuous supply.
Alternatives 3, 4, 5 and 6 would require administrative actions for
implementation. These actions are feasible, but would require the cooperation
of the water users in all cases and to some some extent the cooperation of
the City of Galena.
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22
Alternative 3 would require cooperation with the City of Galena to
rehabilitate its wells and to deliver water to the city limits. The City may
sponsor and operate the complete new service area distribution systems. If
the City does not sponsor and operate the complete project, then the formation
or expansion of a rural water district may be required. In either case,
public support of the project would be necessary to expand the City of Galena's
service area or form a rural water district. Alternatives 4, 5 and 6 also
would require a rural water district or Galena to operate the system. As in
Alternative 3, public support would be necessary to establish the district
or to expand the City of Galena service area. These three alternatives also
would include having the City of (ialena supply water to the north and south
service areas adjacent to the City. If the City does not agree to supply
these areas, then the project facilities would have to be extended, at additional
cost, to serve these areas.
Only Alternatives b and 6 would require offsite disposal facilities.
Alternative 5 may require a landfill approved for handling EP toxic materials
generated by the treatment process. Such wastes should be shipped offsite to
an approved RCRA facility for disposal. Alternative 6 would require a conventional
offsite sanitary landfill for disposal of the lime sludge generated in treatment
of the surface water.
The State of Kansas would require the distribution of the water as described
in Alternatives 3, 4, 5 and 6 to operate under a state-issued permit for public
water supply systems. Any rural water district formed under Alternatives 3,4,
5 or 6 would have to meet the state rules and regulations for formation of such a
district.
Cost
The cost criterion compares the cost of the alternatives with the overall
effectiveness and implementability. The costs include development and construction
costs, equipment, land and site development, buildings and services, relocation,
disposal, engineerings, legal fees and contingency allowances. The cost
criterion also includes O&M costs, including operating labor, maintenance
materials and labor, energy requirements, administrative costs, contingency
expenses, and insurance, taxing and licensing costs.
The 30-year present worth costs and annual O&M cost of each alternative
is presented on Table 4. Alternative 1 costs and a portion of the Alternative 2
costs include operation and maintenance of existing wells. Long-term monitoring
of wells was considered for Alternative 1, although is not included in the cost
figures cited.
Community and State Acceptance
Tnis criterion reviews community and state acceptance of the alternatives.
Comparison and review of supporting and opposing ideas are made to evaluate
acceptance of the remedial action. Also, since federal law requires the
State of Kansas to provide assurance of the funding of 10 percent of the
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23
remedial action, the acceptance criterion requires a review of the state's
ability to provide the required funds.
The comments received indicate that the public would not accept the
no-action alternative. Many residents understand the potential health risks
associated with drinking contaminated water and also are concerned about the
metals presenting taste, odor and color problems.
It is anticipated that the citizens benefiting from the remedial action
will be responsible for the 10 percent funds and the long-term O&M of the action.
It was anticipated based on discussions with KDHE that any alternative with
high O&M costs would not be supported by the community. Alternative 2 has
the lowest capital costs other than the no-action alternative and also has
the highest O&M cost. Therefore, it is expected to be opposed by the public
as a long-term solution. Public acceptance of Alternatives 3, 4 and 6 was
expected to'be high because these alternatives provide a reliable supply of
good quality water.
It was expected that the public may be wary of accepting the treated
shallow ground water that would be provided in Alternative 5. Also, handling ;
and disposing of wastes from the shallow ground water treatment may be generally
unacceptable to the public, especially those located near transportation
routes and the disposal site.
SELECTED REMEDY
General Description
Alternative 3 is the selected remedial action for provision of an alternative
water supply for residents utilizing private water wells, which currently
supply water from the contaminated shallow ground water aquifer. Alternative.
3 utilizes the City of Galena's deep aquifer wells, which supply reliable
good quality water. Distribution of the water will be accomplished through a
pipeline network to be constructed that will reach all homes, farms and
businesses in the subsite.
The City of Galena's existing wells numbers one and two will be rehabilitated
to provide additional capacity for the expanded system. The rehabilitation
work includes: 1) Replacement of upper well casing, 2) Replacement of pumps
for higher pumping capacity, 3) Upgrading the wellhead facilities and 4) Addition
of chlorination facilities. If rehabilitation becomes infeasible due to
unforeseen onsite technicalities, a new deep aquifer well may be drilled to
provide additional water. Existing pipelines within the current municipal
distribution system may be repaired or upgraded to facilitate additional flow
capacity.
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24
A new pipeline network will be constructed to supply the additional
service areas, wnich include the West, Lowell, North and South service areas
as shown on Figure 2. Each of the estimated 418 houses, businesses and farms
in these areas will be connected to the water distribution system. Flow
valves will De installed for each residence and business and at the Galena
distribution area boundaries. A water storage tank will be installed in
the west service area. The existing wells will be disconnected from the
houses and businesses. If agreeable to the property owners, the wells will
be plugged.
The selected remedy includes the purchase and construction of all
equipment and facilities needed to operate and maintain the alternative
water system collection, treatment and distribution.
The wells, chlorination system and distribution within the City of
balena will be operated and maintained by the City of Galena. The water
distribution system outside of the City of Galena will be operated by an
entity to be selected by the citizens in the service areas outside of Galena.
Tnis entity may be the City of Galena, a newly formed rural water district
or an expanded existing rural water district.
Scope and Function of Operable Unit
The Alternative Water Supply Operable Unit in the Galena subsite is
the first of several operable units on the Cherokee County site. CERCLA
Section 118, as amended by SARA, requires the EPA to give high priority to
response actions involving the release of hazardous substances into the
environment that resulted in the closing of drinking water wells or has
contaminated a principal drinking water supply. Therefore, the alternative
water supply operable unit has been conducted prior to other operable units
for the Cherokee County site.
The purpose of this operable unit is to provide suitable drinking water
to the current population within the subsite. Suitable drinking water is
water that meets the primary MCLs. Residences and businesses within the City
of Galena obtain their water from the public water supply, which already
provides suitable water. The population outside of Galena obtain their
water supply from the shallow aquifer and are at risk of using water exceeding
the MCLs. A second goal of the remedial action is to protect the deep
aquifer from contamination that may occur as a result of implementing an
alternative water supply.
A second operable unit in the Galena subsite will address the remediation
of the contaminated ground water and surface water. The other subsites will
be addressed as separate operable units.
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LEGEND
sitnsnr noiuiiioiiT AIIII
oiiisioi umiriOAiiv «H
SIMVICC AlltA
ilVL. iiu'i ill 4 Ll "" " " B>l >'n>c-i Al"
llf WOISIIIIIHIIHMI
bVSII M I'll'l I III! S.
IHAM1IIII II I UK III S
WAIlll S«MlU U|
OMtlMMMIinSVSIIM
SCAU I
FIGURE 2
Al M HNATIVE 3
COMCEI'TUAL LAVOUf
CtUUilM t CO KAIlVAj
t,*i IIIA MIMV.II i
At HMIIAllVf WAI I II it II "I'I V
25
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26
Performance Goals
Since the selected remedial action will operate as a public water supply,
the water must meet the primary MCLs as established by the Safe Drinking
Water Act. The water will be obtained from the Roubidoux aquifer and will
need no treatment other than chlorination. The goals of the action will be
met as soon as the system is constructed and on-line, i.e., the action is
protective immediately upon implementation. All ARARs for the remedial action
will be obtainable. The ARARs are listed on Table 5.
Rationale for Preference
The selected remedial action is preferred over all other alternatives
because it is the lowest cost alternative that provides the greatest protection
to the public health. Water collected from the Roubidoux aquifer is of good
quality and meets the primary MCLs. Therefore, treatment is unnecessary,
which makes the selected alternative more effective and implementable than .
Alternatives 5 and 6. Alternative 2 may be a protective remedy, but due to
potential interrupted service, it is not be as effective or implementable as
the selected remedial action. Alternative 3, the selected remedial action,
is superior to Alternative 4, which may be just as protective and effective,
because of administrative considerations. The City of Galena is a well )
established entity and is very capable of maintaining a good supply of water.
The selected action utilizes the City's experience in supplying water, while
Alternative 4 does not take advantage of this experience.
The costs of the selected remedial action are lower than Alternatives 5
and 6 and are approximately the same as Alternative 4. Alternative 2
has a lower present worth, although the annual O&M is unacceptably higher.
All alternatives except no action meet ARARs, so this was not a determining
factor. Although Alternatives 5 and 6 may reduce the mobility, toxicity and
volume of the contaminants, such reductions were not a goal for this operable.
unit, but will be important in the second operable unit. The short-term
effectiveness of the selected remedial action and Alternatives 4, 5 and 6 is
comparable. Since there is no construction in Alternative 2, its short-term
effectiveness may be higher. The selected remedial action as well as Alternatives
4, 5 and 6 provide a permanent solution for an alternative water supply.
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TABLE 5 - ARARs FOR SELECTED ALTERNATIVE
Chemi cal/Locat1 on/Act1 on
Treatment of water for
public supplies.
Waters of the US
Ground water source for public
water supply.
Installation of public water
supply well.
Permit for public water
supplies.
Design and operation of public
water supply systems.
Establish rural water district
or rural water supply district.
Expansion or improvement of
public utilities by a city.
Requirement
Water distributed by a
public water supply must
meet the SDWA primary MCLs
at the tap.
Regulates discharge of dredge
and fill material into
navigable waters of US
Controls well location,
spacing, water use,
aquifer depletion and
appropriations.
Regulates construction,
reconstruction, treatment
and plugging of water well
Standards define treatment
requirements for public
water supply systems.
Standards define design
requirements and acceptable
operation practices for
public water supply systems.
Establishes procedures to
create a rural water
district or rural water
supply district.
Rules govern the expansion
of utilities by city
governments.
Applicable or
Relevant and
Ci_tat ij>n
40 CFR §141
KAR 28-15-13,-14,-19
33 CFR §323
4U CFR §230 and §231
§404 CWA
Kansas Ground Water
Management District
Act; Kansas Water
Appropriation Act.
Kansas Administrative
Regulation 28-30-1 to
28-30-10.
Kansas Administrative
Regulations 28-lb-16.
Kansas Administrative
Regulations 28-15-11
and 28-15-14 through
-20. Design policies
in Kansas Builetin
B-l-15 (1984).
Kansas Statutes
Annotated, 82a-601
through 645.
Kansas Statutes
Annotated, 12-861,
862 and 863; 12-820
and 821; and 12-674
and 693.
Applicable
Relevant and
appropriate for
pipeline stream
crossing.*
Relevant and
appropriate.*
Relevant and
appropriate if well
is drilled or i f
wells are plugged.*
Relevant and
appropriate.*
Applicable
Applicable if RWO
established.
Applicable if city
distributes water.
not required for CERCIA onsite projects, thera^vp not applicable.
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COMMUNITY RELATIONS RESPONSIVENESS SUMMARY
" CHEROKEE'CUU'NTY SITE - GALENA SUBSITE
CHEROKEE COUNTY, KANSAS
The U.S. Environmental Protection Agency (EPA) completed an operable
unit feasibility study (UUFS) to examine different methods for providing an
alternative water supply for the residents of the Galena subsite of the
Cherokee County Superfund site. The Cherokee County site has been listed
on the National Priorities List (NPL) for cleanup of Superfund sites.
The EPA and the Kansas Department of Health and Environment (KDHE) developed
a proposed plan for an alternative water supply based on the results of
the OUFS. A fact sheet and the "Proposed Plan" outlining the proposed
remedial action was sent to about 300 interested persons in October 1987.
On November 4, 1987, a public meeting was held in Galena, Kansas, to
present the results of the OUFS and the proposed remedial action. Approximately
100 people attended the meeting. Representatives of EPA, KDHE and the City
of Galena presented the proposed remedial action to the public. The OUFS
report and the Proposed Plan were distributed at the meeting. The EPA
also announced that a 30-day public comment period was open from November 4
to December 4, 1987. Following a request that the comment period be extended,
the 30-day period was extended by EPA an additional seven days to December 11,
1987. Significant oral comments from the meeting and written comments
received prior to and during the 37-day comment period have been considered )
and responded to herein this summary. Responses to the comments are provided in
the following summary. During the comment period, eleven comment letters were
received from the general public and one comment letter was received from
seven potentially responsible parties (PRPs). During the public meeting on
November 4, approximately ten people made verbal comments. At a meeting held
with the PRPs, approximately six commenters made verbal comments.
I. General Response to Significant Comments
In general, public comments have been favorable of and support implementation
of the proposed plan for an alternative water supply to the residents of the
subsite. One significant concern, raised by several commenters, deals with the
10 percent matching funds that the State of Kansas must provide assurance of for
the remedial action. According to federal law, EPA will provide 90 percent of
the funding for the remedial action provided the State agrees to pay or provides
assurance of payment for the remaining 10 percent. The KDHE has indicated that
the local residents, who benefit from the remedial action, should provide the
10 percent matching funds. Several commenters suggested that the local residents
may not be capable of providing these funds.
The EPA believes these comments were based on past efforts of these residents
to obtain funding for the establishment of a rural water supply district. Such
efforts failed because the residents needed to supply 100 percent of the capital
costs for the water supply district. The EPA believes that because the federal
government will fund 90 percent of the capital costs for the water supply
system, these residents will be capable of providing the remaining 10 percent.
The KDHE also believes that funding can be provided by these residents.
-------
In yeneral, comments from the PKPs have been in opposition of the proposed
remedial action. One of the most significant concerns raised by several PKPs
deals with the necessity for supplying all residents within the subsite, who
obtain their water from the shallow ground water, with an alternative water
supply. The commenters suggest that only about 10 percent of these residences
need an alternative water supply because EPA's investigations demonstrate that
about 10 percent of these residences have known contamination in their private
water wells.
Although EPA's investigations demonstrate that only about 10 percent
of these private wells are currently exceeding maximum contaminant levels (MCLs),
the investigations also show that the contamination migrates through
the shallow ground water within the subsite. This migration of the contaminants
threatens all the private wells in the shallow ground water aquifer. Investigations
at the subsite demonstrate that migration occurs depending on various factors,
e.g., well pumping rates, annual precipitation, surface water infiltration
rates, seasonal variations and fractures within the formations containing the
shallow ground water. In addition, investigations have shown that the water
quality of a given well varies in time, e.g., one sample exceeding primary MCLs
and the next sample taken a week later from the same well falling below MCLs.
The EPA believes that all private wells obtaining water from this contaminated
shallow aquifer are either currently contaminated with hazardous substances
substantially threatened with such contamination.
II. Specific Comments From General Public
Comment: Several commenters suggested the local residents would not be
able to provide the 10 percent matching funds. Some commenters noted that
several years ago, a group of Lowell residents tried to form a rural water
supply district for water supply and distribution, however, they were unable
to obtain necessary funding.
Response: The Comprehensive Environmental Response, Compensation and
Liability Act of 1980 (CEKCLA), as amended, requires the affected state to
provide assurance of the funding for 10 percent of the cost of a remedial
action funded through the federal Superfund. The KDHE has stated that the 10
percent cost share for the alternative water supply operable unit should come
from the people who would benefit from the remedial action. The capital cost
per household is approximately $1,000 provided all 418 households participate.
The monthly cost for water use is approximately $20 per household. Since EPA
provides 90 percent of the funding, it is likely that these residents will be
able to obtain the necessary 10 percent funds. In addition, loans may be
available from the Farmers Home Administrative (FHA) for assisting a community
organization with the 10 percent cost share. That community organization would
need to discuss this with FHA.
Comment: Several commenters suggested that the City of Galena would
benefit from the action, but may not be required to pay any portion of the
10 percent matching funds.
-------
Response: The EPA cannot specify how the responsibility for providing
the 10 percent matching funds should be distributed among those who benefit
from the remedial action. The State of Kansas has placed this responsibility
upon the local community. The City of Galena would indirectly benefit from
the remedial action because the City's wells may be rehabilitated and some
city water pipelines may be repaired or upyraded if necessary to accommodate
increased flow capacity.
Comment: Several commenters stated they thought the affected people
would prefer the formation of a rural water district, as in Alternative 4 of
the OUFS, as opposed to the City of Galena providing the water. A couple of
commenters stated that the water lines in Galena are old and could have
problems. They did not want to pay for the upkeep of an old system when a
totally new system could be constructed and would have lower costs for upkeep.
Another commenter was concerned about the City of Galena setting the rate
structure for the rural area.
Response: The EPA recognizes these concerns. The Agency selected this
action over Alternative 4 because the City of Galena is experienced in
maintaining a public water supply system. Also, the City has trained staff
for the operation and maintenance (04M) of the system. The EPA believes
using the existing deep wells in the City of Galena is the best use of
available resources for implementation of this remedial action.
Comment: A couple of commenters questioned why EPA did not examine
the food intake contaminant pathway in the OUFS.
Response: The additional exposure to the contaminants through intake
of foods (crops and fish) raised onsite is a minor pathway. Exposure by
ingestion of the contaminants through water is a much more substantial
pathway, therefore, EPA did not quantify the food source pathway. During
the remedial investigation, fish were collected and analyzed. The levels
of metals in the fish were similar to levels in fish found state-wide.
Comment: A couple of commenters recommended that bottled water be
provided to the homes in the affected area until the remedial action is
in place. One commenter provided literature on a water treatment system for
removing heavy metals.
Response: The EPA does provide interim remedies in cases where there
is an immediate threat to human health. The EPA has used this authority
to provide individual water treatment units for private wells within this
subsite where the human health threat has been immediate. The levels of
contaminants in most of the private wells in the subsite are at levels
which do not represent an immediate threat. The major health risk at the
subsite is due to long-term exposure to the contaminants, therefore, an
interim remedy would not be appropriate.
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Comment: One commenter stated that there are additional costs of
the no-action alternative that were not discussed in the OUFS. He suggested
EPA address the health costs associated with the detrimental health
implications of the no-action alternative.
Response: Although additional health-related costs may be incurred
if the no-action alternative was implemented, such costs are technically
impractical for EPA to estimate.
Comment: A commenter suggested EPA post signs around the subsite
warniny of the physical dangers associated with the chat piles and open mine
shafts.
Response: Such problems are beyond the jurisdictional powers of the
EPA. However, these problems have been addressed in part by the U.S. Bureau
of Mines. The Bureau conducted an investigation of safety hazards and conducted
followup activities to correct those areas presenting the greatest safety
hazards to the general public.
Comment: One commenter suggested that the EPA conduct long-term health :
screening on the residents of the subsite to determine if the remedial action '
actually improves the health of the local population.
Response: The EPA has limited funding to cleanup Superfund sites
across the United States. The Agency must carefully determine the best use of
these funds. As a result of the OUFS, EPA believes this remedial action
is appropriate for the protection of the public health at this subs a. The
alternative water supply should reduce the exposure of the public to the
contaminants, thereby reducing the public health risks at the subsite.
Federal, State or local health agencies are the appropriate government entities
to conduct followup health studies on the population of concern.
Comment: A couple of commenters thougnt the distribution lines should
be extended further. One suggested that the area west of Lowell and east of the
Spring River should be Included. Another suggested that Sections 1 and 2 above
the north service area should be included.
Response: The EPA intended to include all houses west of Lowell and east
of the Spring River in the distribution system. Sections 1 and 2 north of
the north service area were left out of the distribution service area because
they are thought to be outside of the area affected by mining activities. Those
areas and other areas could be included when the distribution system is
developed, although EPA cannot pay 90 percent of the costs. Another commenter
stated that his well, located outside of the subsite, was sampled. The EPA
sampled wells site-wide and only detected problem wells in the Galena subsite.
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ill. Specific Comments From PRPs
Comments were received from a group of companies that comprise the
majority of the identified PRPs of this subsite. The following discusses
various significant comments from this group and provides EPA's response.
Comment: The PRPs suggested that mining activities are not the sole
source of contamination and that natural mineralization contributes to the
problem.
Response: In 1983 the Cherokee County site was placed on the National
Priorities List because of a known release of hazardous substances
into the environment and because of the substantial threat of continuing
releases of hazardous substances. The EPA contends that the source of the
release is the abandoned mining facilities, which currently exist at the
site and consist of mine waste piles, open mine shafts, underground mining
caverns and smelting wastes among other wastes. Although the remaining
undisturbed ore body may contribute to the release of hazardous substances,
the abandoned mine workings and wastes provide the major portion, if not
all, of the hazardous substances released and threatened to be released into
the subsite environment. The mining activities altered the existing ore >
body, which caused the mine wastes and remaining in situ ore to be exposed
to oxygenated water and air, which in turn caused the direct release of
hazardous substances into the shallow ground water at the subsite. This
exposure causes the production of acid mine drainage, which in turn mobilizes
the heavy metals and causes the release of heavy metals into the ground water.
In addition, mining activities may have increased the fractures in the rock
formations that contain the shallow ground water. This allows an increased
mobility of the ground water, hence an increased migration of the acid mine
drainage and the spread of heavy metal contamination throughout the shallow
ground water aquifer. Under the authority of the Comprehensive Environmental
Response, Compensation and Liability Act of 198U, as amended, EPA has
the authority to respond to releases -or the threat of releases of hazardous
substances into the environment.
Comment: The PRP commenters suggested that the area impacted by the mining
activities is much smaller than the subsite boundaries as defined by EPA.
The commenters stated that the area actually mined was about 246 acres within
the 18 square mile area encompassed by the subsite boundaries. The PRPs
disagree with EPA's inclusion of the entire 18 square miles in the subsite
boundaries. The PRPs allege that areas outside of the immediate mined areas
are not affected by acid mine drainage. The PRPs support their contentions
by citing a U.S. Geological Survey (USGS) report. The report, by Timothy Spruill
of the USGS, stated that within the Galena subsite no conclusive evidence exists
that demonstrates the lateral migration of the shallow ground water.
Response: Tne EPA acknowledges that the abandoned mining facilities
cover only a small portion of the entire Galena subsite (approximately 20 to
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3U percent). Nevertheless, EPA believes that the entire subsite is affected
by the subsequent lateral migration of the contaminated ground water. The
EPA's investigations at the subsite support our contentions. Random sampling
of wells located outside of the immediate mined areas has shown several wells
"to contain metals exceeding the MCLs. These wells obtain their water from
the shallow aquifer contained in fractured limestone formations. These
limestone formations are the same formations where the underground mines
are located. The EPA believes that natural flow gradients and artificial
gradients, created by pumping of wells, has caused migration of the
contaminated ground water within the subsite boundaries. The acid mine
drainage flowing through natural and man-made fractures in the limestone
formation may expand the fractures by dissolving the limestone, thus
increasing the flow of contaminated ground water.
The residents of the subsite, who are not currently connected to the City
of Galena's public water supply system, are dependent on the shallow aquifer
for their drinking water. Since the residents use wells that are located
in the same formations as the mines, and the mines currently contain
ground water with the highest levels of heavy metals found at the subsite,
the EPA believes that all of these private wells are threatened by migration
of the contaminated ground water.
>
The EPA acknowledges that because of the complex hydrogeology of the
site, it is not possible with the current data to define 1n detail the ground
water flow paths. The EPA considered investigating the subsite further to define
the detailed pathways, but determined that because of the large cost of such
a project with no guarantee of a conclusive answer, the limited funds in the
Superfund would be better spent addressing the threat. The USGS report referenced
by the commenter was prepared before EPA sampled and analyzed water from an
additional 133 wells in the subsite. The author of the USGS report has informed
EPA that with the limited data utilized in his report, no conclusive statement
could be made regarding the lateral migration of the ground water. Even with
the additional data, EPA and the USGS could not conclusively state that the
acid mine drainage will migrate to each well in the subsite. However, the
current understanding of the hydrogeological conditions of the subsite indicates
that lateral migration is occuring and it is only a matter of time before each
well at the subsite may be contaminated from the acid mine drainage containing
the heavy metals.
Comment: Several PRPs commented on the adequacy of the sampling program
and resulting data. They stated that no data were available to reach some of
the conclusions EPA made in the OUFS report.
Response: The EPA does have adequate data to support all the conclusions
made in the OUFS report. The procedures used in the investigations provided
excellent information for the feasibility study. The actual data were not
contained in the OUFS report, but are available in the administrative record
located in Galena and in Kansas City. The EPA believes the commenters will be
satisfied if they review the administrative record.
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Tne administrative record includes results of various EPA investigations
of the subsite. During 1985-86, EPA conducted two phases of sampling of
private wells in the immediate area around the City of Galena. Twenty-five
percent at the wells were sampled in the first round. The second sampling
episode was conducted because several wells were found to contain metals
exceeding the MCLs. During the second round, the EPA attempted to locate
and sample the remaining 75 percent of the wells in the immediate area to
identify additional wells with concentrations of metals exceeding MCLs.
In 1987, the EPA expanded the area of investigation because locations
southwest of Galena were suspected to be affected by migration of the
contaminants. Tne 1987 investigation attempted to locate and sample 25
percent of the wells in that area to obtain an indication of whether or
not the problem extended into those areas.
Of the 72 wells sampled in the immediate City of Galena area, about 7
percent exceeded the primary MCLs, 18 percent exceeded maximum contaminant
level goals (MCLG) and 14 percent exceeded health-based criteria established
in the Clean Water Act (CWA). Of the 49 wells sampled in the second
area, 8 percent exceeded MCLs, 10 percent exceeded MCLGs and 18 percent
exceeded CWA criteria.
Duriny 1987, a few wells were sampled three times and were found to vary
in the water quality. This variability is most likely due to changes in *
pumping rates throughout the aquifer or precipitation variability. One commenter
suggested that the variable could be in the field or laboratory techniques
as opposed to variations within the aquifer. The EPA believes that field
and laboratory techniques utilized in this investigation were most accurate.
The EPA believes that the data indicate the water quality to be quite
variaole; therefore, the one-time sampling of many wells may not provide
representative results of the long-term quality of the water. More wells
may actually exceed MCLs than indicated in the results.
Comment: Several PRPs comments pertained to the selection of other
available alternatives as opposed to the selected alternative. The
commenters were under the impression that EPA believed that all the wells
in the subsite were currently contaminated and pointed out that only 10
percent exceeded the MCLs as opposed to 100 percent. The commenters
suggested that the selected remedial action should be confined to only
the currently contaminated wells with periodic monitoring of the remaining
wells. They pointed out that EPA has already provided individual water
treatment units on several of the contaminated private wells.
Response: The EPA is including the whole subsite in the remedial action.
Several wells are currently contaminated and all the others are at risk because
of the threat of the migration of the contaminants to all wells. The EPA
initially considered supplying bottled water to only those households with
contaminated water wells and monitoring the remaining wells, although this
consideration was not included in the OUFS. The cost estimates of the proposed
remedial action and the bottled water with monitoring alternative action were
the same, yet the proposed action is much more protective of human health.
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As the commenters pointed out, EPA has supplied individual water treatment
units to several wells, however they cannot be provided to all wells as a
long-term remedy, only the wells of immediate health risk require this type
of temporary response action. The individual water treatment units require
monthly maintenance in order for them to remove the contaminants and
periodic sampling to monitor their effectiveness. Residents on sodium-
restricted diets should not drink water treated by these units because they
add a large amount of sodium to the water. Because of these problems,
units are considered only to be temporary. The overall remedy requires a
permanent solution.
Hazardous V
Information I
Comment: The PRPs suggested that the alternative water supply could ™
provided by bottled water delivery as analyzed in Alternative 2 of tne Oil
report. .They stated that it is protective of public health, meets applicabTe
and relevant or appropriate requirements (ARARs), provides a reliable
supply of water and has good technical feasibility. They stated it was
superior to the selected remedy because it would have no potential indirect,
environmental effects, would require less institutional and administrative
activities to implement, would be more flexible and could be implemented
more quickly.
Response: The EPA acknowledges that the bottled water alternative has >
many good points, however Alternative 3 of the OUFS was selected for several
reasons that make it superior to Alternative 2. The public water distribution
system is much more protective of public health because all indoor water taps
will provide good quality water, not just the bottled water taps. Residents
would be dependent on indefinite delivery times for the bottled water alternative,
while the public supply will be constant.
Federal law requires EPA to consider long-term operation and maintenance
costs in selecting remedial actions. This is a very important consideration
for Alternative 2 because the O&M per household is expected to be $46 per month
as opposed to $20 per month for Alternative 3, the selected remedy. The
commenters stated that Alternative 3 could cause an Indirect environmental effect
on the deep aquifer due to increased pumping. A preliminary review of data
collected during the summer of 1987 indicates no negative effects from the
additional pumping of the deep aquifer. Although a review of the preliminary
determination will be conducted prior to implementation of the selected remedy.
The review is expected to confirm that no adverse affects will result from the
increased pumping.
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