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)
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                                                         20. Security Class (This Page)
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           21. No. of Pages
                50
                                                                                  22. Price
(See ANSI-Z39.18)
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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

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                                                                                       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.

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                                   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.

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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.

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                                      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

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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.

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     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.

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     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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