United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/RODiR09-83,001
October 1983
Superfund
Record of Decision:
Celtor Chemical Works
Site, CA
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TECHNICAL REPORT DATA
(PletUt rttld Instructions on tht rtvtnt /Hlort compltting) ,
1. REPORT NO. 12. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/R09-83/001
.. TITLE AND SUBTITLE < 5. REPORT DATE
SUPERFUND RECORD OF DECISION 10/04/83
Celtor Chemical Works Site, CA e. PERFORMING ORGANIZATION CODE
7. AUTHORCSI 8. PERFORMING ORGANIZATION REPORT NO.
e. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM EL.EMENT NO.
1,. CONTRACT/GRANT tlo.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Fjna1 ROT) R~Dort
401 MStreet, S.W. 1.. SPONSORING AGENCY CODE '
Washington, D.C. 20460
800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Celtor Chemical Works site is approximately 2.5 acres located at the north
end of the Hoopa Valley Indian Reservation in Humboldt County, CA. The site was
operated as a sulfide ore processing plant fror:1. 1957 to 1962. The site was
abandoned in 1962 following California Department ofFish and Game citations for
pollution and fish kills in the nearby Trinity River. The most acute problems at
the site are the extremely acidic nature of the runoff and the high concentrations
of-heavy metals in the soil. The selected initial remedial action for the site
includes excavation, transport, and off-site disposal of hazardous substances.
Off-si te disposal is estimated to cost $340,000.
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17. KEY WORDS AND DOCUMENT ANALYSIS
I. DESCRI,PTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSA TI Field/Group
Record of Decision .
Celt'o,r Chemical Works Site, CA
Contaminated media, gw, SW" soil
Key contaminants: heavy metals, ore
mining wastes, acidic leachate
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Tille should indica.e dculy and brieny Ihe subje.:. .:overa~.: uf .he repor.. and b.,' disl'lay~'d "rumincnlly. S~'I sllhti.I~'. ifll~'~I. III ~",ali~'r
Iype or olherwi. subordinale it to main litle. When a rcpor. is prepared in mor~' than "n~' volumc. n'I"'atth~' primary ti'le. ad\! v"I:.III1~'
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Enter information not included elsewhere but useful. such as:
To be published in, Supersedes. Supplemenu, etc.
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18. ABSTRACT
Include a brief (200 woTds OT less/ fae.ual summary of .he most signi''kantlftformali"n "oll!Jln~'d III II,,' "'1''''1. II 111,. "'1",'1 'IOI'I;IIIIS a
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17. KEV WORDS AND DOCUMENT ANAL VSIS
(a) DESCRIPTORS. Select from the Thesaurus of tngineerir.~ alld Sciclltifk Tern" Ihe proper aUII1"rl/,'J "'"11\ Ihat I\!enlify th~' majm
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ended terms written in dcscr,iptor form for those subjects for which no descriptur c"ists.
(c) COSA 11 FII-:LD GROUP. Field and gJOl,lp assilnments are '0 be laken from the 1965 (,OSi\TI Suhi~'d ('al~'j:"ry Us,. Sinc~' the ma'
jority of documents are mullidisciplinary in nature. the Primary Held/Group as\lgnm\:J1Us, 110'111 bt: sp~'~III,'\!i" Iplinc. an'a "I' hUlUan
endeavor. or type of physical object. The application(s) will be: crus).ret'crcneed with sc~'unllary II.-IlI/(;ruu\, J"Ij:I1I11\:lIts thai \\'111 I"U..",
the primary postinl(5).
18. DISTRI8UTION STATEMENT
Denote releasabilit)' to the public or limitation for reasons uther thiln \ccurity fur exanl!,l\: "ReI\:asc !;n!llllllc,I," Cile allY a~:lil;lhiht)' I"
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Insert the price sea by the National fechnicallnformation Service ur th\: Government I'rin"ng Office, if knuwn,
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L. E1
P-ECORD OF DSCISICN
IDitial Raueeial Measure Alte~2tive Selection
Site:
Celto:- Che:nicc.l Works, HOO~, California
Do=~ents Reviewed:
! h~'le ~e"Tie~~:: t..~e :cllc"1\"in;; c:;:;~'=!1ts des:::-ijin? ~~e ~J2..1:::-::; is
0: c~s~~::ec~ive~ess of Initi~l R~.e~i~l ~eas~=e ~ltE~at:ves £~r ~~e
Celtor G~emic21 Works Site:
Stucy titled, "Initial Remedial Mee.sure Feasibility Stucy, Celtor
G~emical Works Site, HCOp3, California, Aug~st 15, 1983.
Staff summaries and recommendations, including the Record of
Decision Briefing Paper and the Initial Remedial Measure L~?lementation
Alternative Selection.
Reccmllendations by the California Department of Health S€r.,rices.
Public Participation Responsiveness Summa-~.
Declarations:
Consistent wit.h the Canprehensive Environmental Response, Cc::rnpensation
and Liability Act of 1980, and the National Oil and Hazardous Substances
Contingency Plan, I have determined that the transport and off-site disposal
of hazardous substances at an EPA approved landfill effectively mitigates
and minimizes damage to, and provides adequate protection of public health,
welfare and ~~e environment. I have also determined that ~'e action being
taken is appropriate when balanced against the need to use Trust Fundrroney
at other sites. In addition, I have detemined that the off-site transport
of haza..""re cost-€ffective than other remedial actions
and is necess~ to protect public health and welfare and the environment
fran a potential risk which may be created by fur-...her exposu-""e to the
continued presence of such substances and, therefore, consistent with
Section 101(24) of CERCIA. .
~~/
M7~ /1
Assistant Administrat6r
Solid Waste and Emergency
A
Office of
Response
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CSLTOR CESMICAL WORKS
Recore of Decision Briefing
Purpose of the IN::
~:,~ :::ec:H:L-:-~snd:d I:-~:~ic.l ~E!:lecic.l ~~€Z.~.:.;~s is o::s:te
tr~nsport ~~G Gispcs~l of ~~ili~gs piles ~nc seil ccn~~~in~ted
with heavy metals such as c~dmiumr copper and zinc. This
remedial a~tion is necessary to prevent public contact with
the contaminated material and to protect the aquatic environment
of the Trinity River.
Background:
*
The Celtor Chemical Works site consists of approximately
2.5 acres at the north end of the Hoopa Valley Indian
Reservation in Humboldt County, California. The Trinity
River is within several hundred feet of the site.
*
The Celtor site was operated as a sulfide ore processing plant
from 1957 to 1962. The site was abandoned in 1962 following
California Department of Fish and Game citations for
pollution and fishkills in the Trinity River.
*
Cont~minated material from the site has washed onto the
heavily traveled access road to the Trinity River and
it is likely that the contamination runs off into the river
during the winter rainy season. The river is an important
fishing resource for the Hoopa reservation.
*
In July 1981 the site was identified in a California state-
wide abandoned industrial waste facility survey. Ce1tor
was included on the proposed (now final) National Priorities
List in December 1982. .
Remedial Planning Activities to Date:
*
In May 1983, a Focused Feasibility Study (FFS) of the site
was recommended by EPA Region 9 and the California Department
of Health Services (DOBS). This FFS was initiated in June.
*
During the FFS, CH2M-Hill reviewed
data on the site and evaluated the
to remedy the site. An assessment
potential public health impacts of
the existing monitoring
potential alternatives
which weighed the
the »no action" alternative
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w~s provided by the
August 11, 1983.
DOgS in mernorand~
d~ted
~l~rc~
10 and
* There are three areas of the site, containing an estimated
total of 1350 cubic yards of material, which need to be
addressed by the IR~:
The onsite t~i1ings piles, ore bins ~nd vats cont~in
approximately 865 cubic ya~ds of highly cont~min~ted
~~terial (u~ to 50~ he~vv ilie~~ls).
'T."" .<:. "10. ~ : "-: 1 V. - t -:::: .7 e ' ~" ..,.. ,.. ~e C' <: "..,.. - ,..:. :::: 0" ..; ;:: ,.. e n .;.. t '"' co;" Q
-.;..11;0. J..__v_- .-, _c~ c:...-...... -- -~c....... ';.. 1_""" \".. -.j --1.---
sc~aped to-a depth of 6 ihches along the edges of the
site, this road will yield an estimated 100 cubic yards of
material. The action will address the road to protect
the health of individuals using it.
The ditch and field adjacent to the site. These areas
have been defoliated due to years of runoff from the
site. Assuming that 6 inches of soil is scraped from
these areas, another 385 cubic yards of material must
be handled.
If
* The last category of material is somewhat different from
the onsite material and the adjacent road in that there is
not enough data available on the ditch and the field to
establish the transport of pollutants from these areas to
the Trinity river or to confirm a imminent threat to the
p~blic health or the environment. The few data points we
do have suggest that it is reasonable to assume such a
transport, however. The costs of the remedial investigation
to confirm the threat to the environment, together with
the additional costs to the Superfund to handle the ditch
and field under a separate remedial action construction
contract next year, far exceed the estimated $60,000 to $70,000
cost to include the ditch and field in this I~~. Therefore,
it i~ judged to be more cost effective to include those
areas in this action.
* Five
alternatives are evaluated in detail in
- Offsite transport and disposal
- Encapsulation
- Encapsulation
- Encapsulation
- Encapsulation
the FFS:
with Neutralization
with Solidification
with a Concrete Vault
* The Cost Effectiveness Evaluation of these options is presented
in Table 1. Although the offsite removal option is not the
least expensive option, it is the lowest cost alternative which
is technically feasible and reliable and which effectively
mitigates and minimizes damage to and provides adequate protection
for the public health, welfare and the environment. The
recommended cost-effective remedy to limit exposure or
threat of exposure to a significant health or environmental
hazard is offsite transport and dispo~al of the tailings
piles and contaminated material.
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::==e:::~vene.ss
~~2.s'U.!"es
Level 0: C:'e.L.nt.-;:
:~:. !i.~~.1i:"t.:1
Y'.i:1i::.i:E. C==.-..:::i:j'
~--...-
--,~c;,,-...
Heal:~, Safery, anQ
Envi:"onmen~al lm?ac:s
During C~nst~~c:~on
!e~~nology S~a~.1s
Ac::e?tAcili:j' 0: L4nd~Use
?~st-Const~:ion
Ris~ of Fa.ilure
C==?l:.t:.~le wic Fu~e
Rem~~al Act:.vi:~es
Total Ioieighted
::ffec:iver.ess ~ting
Design and CO~s~.1c:ion
Cosu
OC:M COS::3
Total weighted Cost
S~or~ (Rat~g/Cost)
RDS1/04J
....-.....
. )
:able ~
c:s: -~C::V!1\~SS EV ;~~AI:CN
~N~i~ ::.::;
F2.C::~!'
1.0
1.0
0.6
0.7
0.6
0.4
1.1
0.9
1.0
1.2
Of::si:e
R.~~\'~l
4.5
30.6
o .340
0.340
90.0
Li::er
~
5
5
~.S
5
~
5
5
3.5
oS
21.3
0.230
o
0.02
0.:~4
83.9
4-13
.-
On~:~= ~~~~~s~!a:::~
~=E.r ~.
N~'.!':':"c:.l::"=~
I..
4.
4.5
..
-
4
4.
4.
4.
2
2
.
..
2.
2
21.9
0.255
0.02
0.289
75.3
!.!n':.:- ;;
So Ed::':"1'
:..
'-.:
4.
4.
2
4.
21.9
0.296
0.02
.
0.320
68.4
C"'nc:"e~e
T!C:~!. :
4.5
4.
2
3
4.
4.
3
. -
...-,
2
::
25.0
0..320
0.02
0.344
72.7
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Public Review of FFS:
*
the FFS was released for
review
public
On August 19, 1983,
and com.:"'nent.
-I:
On ~~~~~t 29, lS83, ~cgicn 9 helc ~ ~u~l:c ~se~:~~
Eocp~ V~lley Business Co~~cil Cha~je~s to ;res~~~
na t i ves. and rece i ve publ ic comment.
2': :::e
t~E ~lte::--
*
The public comment period ended on September 6, 1983, after
two and one half weeks.
*
No adverse comments were received from the public.
Policy Affecting this Site:
*
Mining Wastes Policy The contamination on the site is
the result of processing ore to extract metals. The
materials to be removed consist primarily of tailings piles
and soil cont~.inated ~y runoff from the tailings piles.
It is current EPA policy to address min:ng wastes as hazardou~
-- substances if they or their components are specifically
included as hazardous substances in ~lOl(14) under statutes
other than RCRA. This site meets this definition.
*
Native American policy - The Celtor site is located entirely
on the Hoopa Valley Indian Reservation. Current EPA
policy is that sites located on Native American lands are
eligible foe remedial funding if the State or the Native
Americans provide the assurances required under CERCLA.
The State of California has indicated a willingness to
enter into a State Superfund Contract to provide those
assurances.
Enforcement:
*
A notice letter was sent by EPA Region 9 to the Bureau of Indian
Affairs as the "owner" of the reservation on August 29, 1983.
There has been no response to this notice letter.
*
The Celtor Chemical Corporation is a defunct corporation and
is unable to contribute to the clean up.
*
The Office of Waste Programs Enforcement has recommefi6ed
implementation of this IRM.
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Schedule:
*
7he site is loc~ted in ~n &rea ~hich receives 57 inc~es of
rainfall per ye~r, primarily during the winter ~onths.
Because runoff from the site is a serious threat to the
public he~lth end the environment, implementation of the
reme~y is sche~uled before the end o~ November.
t:
The schedule for work calls for the i~plementz~ion of
construction by October 17, 1983. If weather permits~
the construction will by complete by November 14, 1983.
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INITI.?.L R£Y~:;L!l.L y,vSl'rS IY~~2~\T.;;::rION
~.LTl:.:;:~..TIVE SELECTICN
CELIDR C?-D~IG.L WORKS SIT=:
EO::>P.~, C.~.LIFOR~L;;
1.
~::..-t.._--~ ~-,.:
.::;x:;.-.,'-.."""- ..,.4
On August 18, 1983, the San Francisc~ Regional Office of ~A released
the "Initial Re:nedial Measure Feasibility Study for the CELIDR Che.Trlical
Works Site, Hccpa, California" prepared by the consulting firm of CH2M-
Hill. Copies of the report. were distributed by C'2M-Hill to t.~e Hcopa
Valley Business Council, California Depa~ent of Healt.~ Services and other
Federal and State Agencies. Copies were also placed in the Bureau of .
Indian .;£:airs EOO?a, California of:ice, and in ~'e neigrboring to~n of
Willow Creek. In addition, a copy of t.~e study was delivered to the abut-
ting property crwner.
Press releases and notices were placed in the local newspapers announc-
ing the availability of t.,e study and ~-~uncir.g that a public meeting would
be held on ~~gust 29, 1983. The purpose of the meeting ~~ to present the
findings of t.~e study and todis~JSs the remedial c~tions which had been
c9nsidered. The meeting was also to receive input iran t.~e affected caTmU-
nity on the recammended alternative ~~d on the selection of .the remedial
action. A certified shorthand reporter was present and a transcript of
the meetir4 is available through the Regional Office for review.
Feasibility Study Alternatives
The purpose of the IRM is to remove the direct exposure to a potential
health and envirolroental hazard, remove highly contaminated soils at or
near the surface, and prevent the migration of hazardous ~2terials resulting
fran the exceptionally heavy winter rains. Once the IRM has been completed,
a remedial investigation will be undertaken to determine if the ground water
or soil remain a source of contaminatin at t.~e site. The objectives for
the IRM are as follows:
II.
A.
Remove Potential for Direct Contact -
The site contains eX};X)Sed concentrated ore piles, open ore bins, .
contaminated soils and partially filled extraction vats. The State of
California in a March 10, 1983, rnerrorandum (prepared by OOPS' Environmental
!'oxics Epidemiology Unit, Epidemiological Study Section), found that the
abandoned wastes remaining on site pose a potential health threat to people
using the adjacent road (a prime fishing access road for the Tribe), and
people accessing the site (children have been. frequently observed playing
at the site). Exposure can occur by direct skin or eye contact, inhalation
of dust during the dry season, and fran ingestion. It is ~~e intent of ~'e
IRM to remove these materials fran direct access to the public.
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B.
~ever:t Mi~r~tic~ to L~e Trinity River ~nd ~~j~~e~t Fields -
In ~=dition to ~~e ore piles, 0?E~ ore bins, c~n~~ina~ej seils, and
particlly filled ey.~ra~tion \i2::.5, t.i-}'3 rec-~Ld,ended :R-l will a==ress t.~e field
and the adiacent ditch. Cont~~inat:on in these areas is eviden~ bv t.~e
laej~ of ve~etadon and observed tailings that have migrated frcm t..;e piles
to t.~e ditch and field. These areas b~ve collected sur:ace ru~8f= directly
£~~ ~~e prG=ess pl~it ~rec d~ing ~~6 ~~iny se~sc~ end a=e co~sidsred to
be a contir.uin~ source of cont~:ina~ion to the river and t.~e adjacent f~.
T~is s~_~~ce r~~~=f ~~~s i~ ~~e ::eld ~~~ ~~~ c:t=~ ~rio~ t~ its
dis~'arge to tte Trinity River during periods of extended rainfall. This
standing w~ter is accessible to grazing an~Tals in the adjacent pasture.
These anbnals could ingest contaminated flora or drink contaminated water
~~d thus acc~~late toxic ID2tals in t.,eir tissues. Hul3n ex;osure could
occur fram ingestion of the cont~~inated an~~l products.
The s~-face runoff associated with the ditch could transport on-site
wastes to the Trinity River where they IT~y present a t.~eat to t.~e aquatic
environment of t..,e river and bioaccumulate in t.,e sport fish in t.~e area.
H~~ exposure would occur as a result of ingestion of t.,e contaminated
fish.
C.
Provide Controls w~ich will be Consistant with Future Remedial Actions -
At this time, our knowl~dge concerning the extent of the contamination
in the soil ~"1d ground w-ater is l:iInited. The reccmnended IRH will not preclude
additional sampling of the site nor will it l:iInit ~'e EPA's options for pe~ent
remedy at the site. Equally tmportant, it will not require additional remedial
action if the ~ainder of the site does not warrent additional acition. The
recommended IRM is the silnplest, cleanest method of addressing the bnnediate
runoff problem at the site in a manner which does not limit options for future
action at the site.
III. EXISTING S;'JA.?LING DATA
DTIDediately after beginning the study, existing data and information
contained in the files of t.~e California State Department of Health Services,
EP.r&.. R~ion 9, Indian Health Service, and Tribal records on the Hcopa Valley
Indian Reservation were obtained. These data were reviewed to deter.mine
t.i-}e nature and extent of contamination on the site and to help recommend
an IRM to m~tthe objectives stated above.
The most extensive sampling on the site was done by the DOHS in January
1983. Samples were taken fran the tailings piles and two ore bins located
in the process ing plant area. Several samples were also taken fran areas
west of the process plant area where there was evidence indicating migration
of the contaminants. These areas included the access road, ditch, and low
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area of L~e adjace~~ :leld.
area of the field.
'" =c.r.,.
.", --'"
S2:T;;;leS W2re 2;.lso taken
"~:est
0: t.;~e 10",,-'
P~lLainar}' s~191ing was d~ne on July 23, 1981, ~~d Fetruarj 2, 1982.
The 1981 s~.~lir~ was con. durin~ :n inveDtorj of potential hazardous
v,"zste sites. RepL-e~,e:itaL:es fr=::" D::-:5, HL..'"111:clc5.t Coun':y Eea1th ::epart.."T2!lt,
an~ ~~e Indi~, E~al~~ Ssrv:ce were ;resent during ~~e s~,~lin2. ~~ations
of t.."'lese sa:::;;les ere cesc::-i:::>?c1 z.s: vat, lC\.' p:Jir:t 0: s:r..=.ll t:2~.:::, citch,
e.nd o=-e lo.=.c.z~. The reS'l.llt~ c..re i:1::lt::e::: ~n a re;;crt titlE::: I; 'tie!.c I!1\:'esti-
;=.~ic:"':s c'= [;:1=::.:-:-:=:..l':'sj :-:=:'=~::::'''':£ ~,~~:.s::: S::'-:~::, :::' ?:"::~.-=.::~, S2..~,;:'~ir.;
D:::=..r:1=!1ta..~ic~;. Re;:::- ~, r:~::"?=. val~=~' S :..:e2 r E~~.p=.., Cz.lifoJ:7:iz., II =0.==:- ~::-1.
2-3, 1983, by Ecology and Enviro~l=nt.
The Februa-ry 2, 1982, s~~ling done as part of ~~e report mentioned
above was intendeJ primarily to previae sufficient infor.rztion to apply
E?A's Hazard ~~king Syste~ to ~~e site. These s?~les were taken in one
of the ore. bins, one of ~~e vats, and in the ditch.
In addition to ~"'le s~{~ling data of Janauary 23, 1983, a representa-
tive of ~~e Indian Health Services was present and took direct pH readin~s
of leachate ponded on the access r~d adjacent to the field. T~e lowest
reading was fram the tailings pile. A pH value of less then 0.4 was obtained
fram a sample taken along ~~e road both ncr--h and sou~~ of ~~e location of
the lowest reading. Values of pH increased as readings were taken in bo~~
dlrections.
TV . RATI~.LE FOR CT....EA..NUP
The most acute problem found at the site is the extremely acidic nature
of the runoff fran the tailings piles. The leachate v,t'dch is p:>nding on the
surface of the site, road and ditch has a reported pH of 0.4 to 2.2. The pH
is depressed by the sulfuric acid coming fram the piles. Solutions with a
pH below 2.0 are corrosive to the skin and eye tissues and, the~efore, hazardous
to the public. Solutions with a pH less than 1.0 will cause per.manentdamage
if splashed onto human skin or into eyes.
Because the leachate from the piles is pending on a
it is not p:>ssible to prevent public access by fencing.
assume that the local reside~ts and children may ccme in
ate and be burned as a result of that contact.
heavily traveled road,
It is reasonable to
contact with ~~e leach-
The tailings piles and road also contain high concentrations of heavy .
metals (cadmium, copper and zinc), posing a significant threat to the public
health, if the material is ingested, and to the enviro!l.TTIent, if it runs off into
the Trinity River. .
In addition to the tailings pile and the road, DaHS and Region 9
recommend ~~ving surface soils in the low area of L~e field and along
the ditch to prevent additional runoff of material contaminated by ~~e piles
to ~~e Trinity River. The cost t~ remove this material is significantly
less than ~'e cost to investigate the environmental damage caused by leaving
it in place and conduct a second remedial action next year.
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v. v0LU~1S 0: CCY.'IT..::'.!':!~L::T~ :>'c.:.l.=--."ID.l.S
Volumes of cont~in~te= IT~te~i~ls we~e estimated fc= each cf G~e follo~~
ing areas:
o TF.ILIN:?S PILE
p.:<=,Q~ 1"'...,
----- _L..
fisld C:'-:'22
C:':'-"~--'""'I<;
---'---."- r
~~e t~i~i~~s pile
--"",,\::-~....c::
--~.._-- '--
~: 5:;,0
c:.:.;jic
~~:.~s
:;f iZ~£=:.:..l.
:::-=. ;: i.les v.~~=e
~.s~'-::..2::' t.::. ;:'2
s::.. :.:.::-~;- '::-1
i.-=\:"f::~
;::-:::":~l: .
o ORE BINS
Based on the dL~=rsions of the bins and estimated ave~age dep~~ cf
material in each bin, the two ore birs are estimated to hold 260
~~ic yards of material.
o VA'IS
DOP£ and Regio~ 9 estimated G~at G~e G~ee vats hold a tot~l of-75
cubic yards of material.
o .;CCESS roAD
It is est~~ted that 100 ~~ic yards of material will ne;~ to be removed
fran the access road. This is based 0:1 sc::-aping 6 inches off the road
. beginning near its intersection with the ore haul road and ending near the
north end of the contaminated area of the field.
o DITCH
Fifty cubic yards will be removed from ~~e ditch by scraping 6 inches of
material off the bottom and sides. This would extend along ~~e ditch,
adjacent to the cont~~inated portion of ~~e field.
o FIELD
Acssurning that six inches of material will be rerroved frcm t.~e contaminated
area of the field an estimated 335 cubic yards of material would be
removed. This would include the area of the field where there is no
vegetation growing.
o TOTAL VOLUME
Based on presently available information, the selected IRM will remove
a total estimated volume of 1,350 cubic yards of contaminated material.
VI.
DEV"ELOFMENI' OF rorD'iTIAL ALTERNATIVES
During the development of potential alternatives, mining companies in
California, Nevada, and .~izona were contacted to dete~ine their interest
in the material remaining on the Celtor site. This research did not identify
any cattpany interested in the "mine tailings," which have the highest
concentrations of zinc and copper of the material remaining on the site.
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Th2~e ~as also SCIT:e conside~aticn given to trjir.g to locate a mine
tailings cisp:::sal area that ;.'as "cont=olled It (mG had capac i ty a\TailabJ.e
for dis~sal of tr,e material fran t..'1e Cel to:: sits. ~is ty;,= or c.n =.1 ter-
nat~v~ w~uld be attr~=~ive. f~ ~ ~~st-:=fe=ti~eness_s~~dpoin~ if.~2
facll:ty were locc.te~ 1n t..~e vlcln~ty cr w~e Slt€. hc~s,e=, tr4E ffilnlng
c~~y conta=ted had its o~.~ waste discharge pro~l~$ and was net rEceptive
to the idea 0: taking on more ,,-'c...ste. This type of altern::.tiv€ \'::::u1d a15:::-
present le;~ prcble=£ if ~~e site of dis~~cl W2re to b=c~,e a futu:~
:::::'::-ce cf c=:-:';.:.~~iZ'"l=-t:..c~. ~:2 z.2. :'E:-:1ati",7e v;~s the::-e:orc:. ~.:::;.~=.= ~-'_U
.. .. . .. .'
:u=-:.er C=~Sl=;~~~lC~.
The fir~t step in developing potential IK~ alternatives Wa5 to identify
potential reme1ial technologies for dealing with contaminated soils. The
following remedial technologies were considered:
o
Incineration
Wet air oxidation
SOlution mining
r-!icrobiological degradation
Encapsulation
Neuu-alization
Solidification
Excavation and disposal
o
o
o
o
o
o
o
Several factors used in screening the alternatives were:
o
Technical Feasibility
Cost effectiveness
Environmental effectiveness
L~l~entation timeframe
Compatibility with future actions
o
o
o
o
VII. INITLn.L SCREENING
The first step in screening alternatives was to lL~it t..'1e above general
technologies to t..'1ose appropriate for soils contaminated with heavy metals.
'!his eliminated incineration, microbiolcgical degradation, and '....et air
oxidation as potential te~~ologies for use in IBM alte~atives. These
alternatives are not applicable to inorganics such as heavy metals.
The second step eliminated in situ treatment such as neutralization,
solidification, and solution mining. Neutralization and solidification
alternatives ~uld not ensure isolation of contaminated soils unless the soils
were encapsJlated. Therefore, these are considered with the encapsulation
alternatives discussed in following sections. Solution mining also
cannot t:e considered without geologic and groundwater data which is not
available. Therefore, solution mining was dropped fram further consideration.
NO-AcrION ALTERNATIVE
Under the no action alternative, all hazardous wastes would t:e left
onsite in their present state. The significant heal~, ~~eats existing on
the site would re~~n under the no action alternative. These include the
health effects associated with ingesting material with high concentrations
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of ca~,ium, and direct ocr-tact with acid 581utions leaching
that ~~in on the site.
f:--~ ~~e
tailings
Because of ~~e potential heal~~ trIEat resultin~ fr~, ~~e no-action
alternative, it was drop;ed fr~, fUrL~er consideration.
Evaluation 0: Screenej ~~ternatives
Tne reIT~inin; vi~le alternative consisted of two ;eneral cate;ories,
on-site enca?sula~ion ~~j ~~"oval to off-site disposal.
Four on-site encz;sulation alternatives were considered. :TIee consistej
of a landfill t:fPe of encapsulation; two of these w~ee incluced technologies
that treat the contaminated soil before isolating ~~em wi ~~in the liner.
Such trea~~nt would add to the reli~ility of ~~e landfill er.caps~lation
alternative. The fou~~ encapsulation alternative consisted of constructing
a concrete vault for isolating the con~~inated soils.
The off-site alternative consisted of hauling ~~e cont~~inated soils
to the nearest Cldss 1 landfill in ~~e San Francisco Bay Area.
VIII.
ry:'-..sCR!PTIO~ OF TdE ALTERNA.TIVES
Each of ~~e five IRK alternatives~as developed in enough detail to define
major issues and concerns related to ea~~ alternative. A descri?tion of
assumptions used in developing each alternative is provided in ~~e following
sec:tions.
Each of the following alternatives includes either isolating or
the total volLrTIe of contaminated material as described abo-",e in this
All of ~~e alternatives also include replacing the conta~inated soil
the field with suitable imported topsoil and seeding.
reITOving
re:;::ort .
iran
Landfill EncaDsulation
The three landfill encapsulation alternatives are based on the same
assumptions and differ only in that two of them involve incorporating
additives into the contaminated material (lime for neutralization and
cement for solidification). Each landfill encapsulation alternative consists
of a double liner surrounding ~~e contaminated material, isolating it fram
uncontaminated soils, and a leachate collection system. It was assumed
that the top would consist of a PVC liner and an 18-inch-thick layer of
clay or silt mixed with bentonite. Six inches of topsoil covering the top
liner \oA:>uld be seeded to produce vegetation. The oottan liners would be.
seperated by 12 inches of gravel and slotted PVC pipe which would lead to
a leachate collection system. The leachate collection system would be
periodically rnonicored to dete~ine if the first liner is leaking.
It was assume~Lthat ~~e ore haul road and approximately 1-1/2 feet of
soil (assumed unoontaminated) \oA:>uld be excavated benea~~ the tailing pile.
The contaminated material would be encapsulated up against the remaining
slope where the ore haul road '.vas excavated. A portion of ~'1e material
excavated fraTI ~~e ore haul road was asst.=ned to be suitable for backfilling
the river access road. It was assumed that the excess material \oA:>uld be
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disposed of in ~'e ravine to ~'e S8U~~ and ~~at L~e scil sxc=vated
L~e field w8uld be replaced wi~, suitable topsoil.
iran
Concrete Vault ~~~~sulation
, The ccnc=ete vault alternative consists of a cylindric~l sh=ped vault
20 feet high and 50 feet in di~~eter. A cc~c=ete sl~ would be set on ~I
c.rs=. exc=.vate-:: c?p=oxi..,.~tely 5 feet 02-2;'>. The sl:.b y,'8'.lld b= set C:1 c. .
12-inch-t!:ic~: gr:=,vE;l drc.in ~;i~~ l=-~:-=o:-2..tej FJ7JC ~,i;>2s .=.n~ F",;;: li.r~er ::>21c:,,'
ta c::llec-:. l€~=:-.z:":.e in :.~e e't~~e!1t c~: f~ilu~. Tl~€. v2.ult. ~"1~~:...:lc z..ls0 be li~.:.':'
wi~~ a FvC liner.
The vault w~uld be placed where the tailings pile is presently located.
The existing ccncrete structures would be left onsite.
For t.i1e vault alternative, it was ass1.zrp-j that imported fill would be
req~ired to replace contaminated soils below the ground sur=ace to ensure
prcper site drainage.
All onsite encapsulation alternatives included fencing the enca9sula-
tion area and hydroseeding areas (other than roads)'where =ill material
....-c..s,LT.p0rted. These alternatives also incluc.ed a leachate collection
system wr.ich could be monitored.
R~~val to a Class I Landfill
The alternative for excavating the contaminated soils and disposing
of them at a Class I landfill was developed for ~'e same material as for
the onsite alternatives. However, in computing the total volume to be
hauled, a ~well factor of approxtmately 15 percent was used for same of
the contaminated soils. This was to account for the increase in volume of
excavated material relative to this same volume of material when it is
compacted in place. No swell factor was used for the mine tailings and
soils on the site that are not ccmpacted. This resulted in a volume of
1,420 cubic yards to be removed.
For the rem::val alternative, we assumed L,e contaminated material
would be removed and hauled to a Class I landfill approximately 360 miles
fran the site. This is t.~e closest approved landfill that could accept:
the waste fran the site. It was assumed that iro;;orted fill material would
replace the material excavated fram the field, ditch, and access road.
The area where contaminated material is removed will be seeded.
IX. COSTS
The following cost estimates are intended for the comparison of ,the alter~
natives. The final cost of t.~e' selected IRM alternative will depend on
actal labor and material costs, competitive market conditions, project scope,
ilnplementation schedule, and other variable factors.
It was assumed t.,at the health and safety plan for the site requires a
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protec~ive ge~r no~~lly rejuces e£ficien~y of C8ns~~~ct:on ~c~iv:ties. This
re::ucticr1 in ef£icienC"! ~~j its eff€cts 00 co~st:-~=cicr1 cos\:s ~~-2.::'"e es-:.ir~t€d
and acco~~tej fo~ in these cos~ est~~tes.
~~l costs are a~ July 1983 price levels. Inte~est duri~; cc~struction
an~ price escalation are not included in this analysis. Thre2 it~5 we~e
est~Tzte~ b==e8 C~ pzrcent of direct ccr.5t~~ction ccsts. These include heal~~
an"" S-';::;:....... re"""""'~"-"::~.':)"-s -t'" ~~"'-on-l- m-'~1'1;z::>t;0r1 ~~,~ ...t::"'~-'-'---y r-;::cili";es
"". c:."'-'-l' ~""--7"-"-. c:. ~ :;-........... '-, "..,,:-, -- - -, ..... '-~'':-'~-c.... - - '--
~t 10 ~~cen~, ~~~ b=~~s ~~= lr~ur~~ce a~ 2 per=en~.
Contingencies we~e added to each alte~ative ccs~ est~~~e to provide
for many minor iter.s net addressed prior to final design and for ~~foreseen
circumstances. A value of 10 to 30 percent of ~~e direct C8Sts is typical
depending on how ccnfident the estLT~tor is of the design criteria and
information u~n which ~~e estimate is based. A 30-pe~ce!1t c8ntingency was
used for all costs for each alternative except for the hauling ~~d disposal
costs fo the re:n:)val alternative. A lS-percent contingency was used for
thetwo direct costs because ~~ey were ~sej on telephone quctes from experienced
hazardous waste haulers in Norb~ern California.
Ass~ing b~e selec~ed IR~ will be L~lQ~ented this year, the earliest
construction could begi~ is in early October, and it W:)uld extens into the rnonL~
of Nov~be~, ~~e b&gir~ing of L~e rainy season in Hoopa. Therefore, effects of
rain 00 construction costs 'Here considered for all alternatives.
Cperation and maintenence (O&M) costs include an ~~nual allowcnce in
c8nStant 1983 dollars for encapsulation alternatives to account for maintaining
the fence, cap (landfill alternative only), warning sigrs, ditches and culverts
for diverting surface runoff. These costs are based on assuming the encapsulation
would be a pe~aent remedy. The tot~ annual O&M C8Sts fer onsite alternatives
are estimated to be 52,000, assuming a period of 50 years. It was assumed
that there would be no O&M costs for b~e removal alternative.
The following table is a summary of the design ~,d c8nstruction, annual
operation and maintenance costs for each alternative.
Alternative
Design and
Construction
Present Worb~ Operation
and Maintenance
1.
Off-site Removal
5340,000
2.
. Encapsulation
a. Liner only
b. Liner and Neutralize
c. Liner and Solidify
$254,000
$265,000
$296,000
$20,000
$20,000
$20,000
3.
Concrete Vault
$320,000
$20,000
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ca~'~:.;;:nTY I!\,\7QL 'lEy-nIT
At ~ public m~~tir.; held C~ Auq~st 2~, 1983, ~~e I?~~ Feas:bility St~cy
~~s prese~~e~ to p~lic ~~ t~e P.C8p~ V~lley 3~sin=ss Cc~,cil cf=ices fc~
t.i-.!eir revis',' ~'id C,_,..dl-2nt. T~le o'''e:-Y,TI=l:;~in; cc~csr...sus rran ~~e ~ublic ..'C,S
~2~ ~~ey s~pp~~~ ~~e rec~~~n~~G~tic~ of cf:-site rE~~v~l 0: t:le c~~~~~in~~ej
IT6te~i~ls ~t ~~e Celt~~ C~~.ical vicrks site to the ne~rEst Cl~ss I dis~cs~l
f~cility. .
,,-"';'"
.~.
:~;C:t'~.=2'2!)
":...f~!C:\:
Section 300.65(j) of ~~e N~tion~l Co~tingency Plan (~CP) [~7 F.K 31180,
July 16, 1983] states tr+at the appropriate extent of ~dy shall be
determined by the lead agency's selection of the remedi~l alternative ",'hich
the agency cete~ines is cost-effective (i.e., t.~e lowzst cost ~lternative
t.~t is technologically feasible and reliable) and which effectively
mitigates and minbnizes damage to and provides adequ~te protection of public
health, welfare, or the environment. Based on our evaluation of the cost-
effectiveness of ea~~ of the proposed alternatives, t.~e comme~ts received
fram the public, and information received fram the State, we rec8rnmend the
excavation, tr~port and off-site disposal of hazarcous substances as the
Initial rem~ial action. .
o~ anal~~is revealed t.~at off-site rc~val was t.~e lowest cost
alternative that eff~ctively mitigated the p~lic healt.~, welf~re ~~
enviro~8ntal i~~s ~,d satisfied Region 9's objectives for site cleanup
for the reasor.5 that follow:
o Level of Cleanup
Removal was rated t.~e highest because t.~e contaminated materi~l is to
be completely ~~ved fram the site. On-site encapsulation only isolates
the material and is less favorable.
o Implementation Tirneframe
Based on estimated construction schedules for each alternative, t.~e
removal alternative was rated the highest because it had the shortest
construction ceriod, and therefore less chance of a delav because of the
historic heavY winter rainfall at Hoopa. -
o Enviro~ental Effectiveness
!he removal alternative was rated the highest because after remova the
land is acceptable for any use. The removal alternative also elbninates
the community's concern by removing the contaminated material.
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\ )-,
..
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, .
I ;_h,
I
(
,
."
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o
Tec~£ic~l FE~sibili~y
ExC2vz.ticn hauling of con.tar;1in2.tej rra.te:-ials e.re VE::'} s:.rr.;>le and
proven constructic:1 act.ivities and ~~er6fcrc were rate::' ~he hi~:--,est cf the
alt.ernatives. ~c~psul~tion alternatives are m~re t.echnelogic~lly ~~lex
and requite m::re care duriD~ c;:).-tSL."Ucticn, especia:'ly in installing t.'1e
plastic liners to e~~ure that t.~e liners e.re n8t d~T~2e2 curing ccns~~Jcticn
ThEr"e is also. no risJ: of failu.:-e after w~te rc.;.;.:)',7al, '~.TIere~s leaks in P"vC
liners are net ~~~.:)n.
o
Ccrr.p::.twil: ~7i
v; i t!'.. E"1.:'":.:.l::=:
;.:::~iCllS
Encapsulation cCQpatable with future rem~jial act.iens because t.~e
encapsulated area would need to be undone to perform additional s~~ling
or any other remedial activity at the site.
o
Public Ccrn:nent
The public received in support of off-site disposal fur+~~er justifies
the expenditure of funds for removal of 1340 cubic yards of ccntamina~ed
In3.~erial. !-~sc, t."le acdi ticnal e~-p=nditure proviCes a much !':'Dre reliable
cleanup and elL~inates the potential to f~~e= contaminzte the area aro~~d
the site.
XI 1. ST..;TE INPiJI'
After givir~ consideration to the cost-effectiveness of each alternative
and evaluation o£ the public comments, the California State Department Of
Health Services recommends excavation, transport and off-site disposal of
hazarcous substances. A letter confiDTIing ~~e State's con~~-rence with
this recommendation is attached.
XIII. PROPOSED ACTION
We request your a?proval of ~~e off-site disposal Initial Remedial
Measure. OUr schedule ca.lls for construction to prcceed by O::tober 17,
1983, and completion of the IRM by November 14, 1983.
",
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