£EPA
Unittd States
Environmental Protection
Agency
Office of
Emergency and
Remedial Recponee
EPA/ROD/R09-85/009
September 1985
Superfund
Record of
Celtor Chemical, CA
(Second Remedial Action, 09/30/85}
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TECHNICAL REPORT DATA
(Please read Instructions on the revtne before completing)
1. REPORT NO.
EPA/ROD/R09-85/009
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
SUPERFUND RECORD OF DECISION
Celtor Chemical, CA
(Second Remedial Action)
5. REPORT DATE
_Sep.
i. PERI
6. PERFORMING ORGANIZATION CODE
I
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
1.1. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13,'TYPE OF REPORT AND PERIOD COVERED
Final ROD Report .
14. SPONSORING AGENCY CODE
800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Celtor Chemical Works site consists of approximately 2.5 acres, and is located
in the northern end of the Hoopa Valley in Humboldt County, CA. The Hoopa Valley India
Tribe is the owner of the Celtor site. The Tribe leased the land in 1958 to the Celtor
Chemical Corporation which processed sulfide ore for copper, zinc, and precious metal
extraction. In June 1962, the company was delinquent in its royalty payments to the
Hoopa Valley Indian Tribe and as a result, abandoned the site. Mine tailings generated
from the milling operations were left onsite. These tailings, along with nonspecific
releases of processed ore,» are believed to be the cause of the acidic surface water
runoff and elevated metals concentrations in the soils throughout the site. In additio:
the tailings may have caused the numerous fish kills for which the California Depart-
ment of Fish and Game cited the Celtor Chemical Corporation.
Initial remedial actions were implemented at the site in October 1983, and included
excavation and offsite disposal of all visibly contaminated material. This material
included all tailings, non-concrete structures, and a portion of the pasture adjacent
to the site. The selected alternative for the second remedial action includes exca-
vation and offsite disposal'of all soils contaminated above site-specific action levels
at a RCRA-approved hazardous waste disposal facility. Action levels for contaminants
in soil were based primarily on the acceptable range of contaminant levels in soil
(see separate sheet)
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c. COSATi Field/Group
Record of Decision
Celtor Chemical, CA
(Second Remedial Action)
Contaminated Media: soil, sw
Key contaminants: cadmium, heavy metals,
arsenic
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54
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SUPERFUND RECORD OF DECISION . .
Celtor Chemical, CA
(Second Remedial Action)
Abstract - continued
as derived from the EPA National Ambient Water Quality Criteria. These site-
specific action levels are: arsenic 100 mgAg; cadmium 25 mgAg/ copper 2,500 mg/
kg; lead 500 mgAg; and zinc 5,000 mgAg. Total capital cost is estimated to
be $3,065,338 and O&M costs are estimated to be $7,000 for an initial one year
period of grounds maintenance.
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. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
DATE September 30, 1985
^SUBJECT
FROM
Record of Decision for Remedial Action at
the Celtor Chemical Works Superfund Site
£eraydarian
Director, Toxics and Waste Management Division
TO Judith E. Ayres
Regional Administrator
A Record of Decision to select a remedial action for the
Celtor Chemical Works site is attached for your signature. Also
attached are the briefing documents describing the selection
process and the basis for our determination that excavation and
off-site disposal is the most cost-effective remedial action for
the site.
As you know, EPA Headquarters has been delegating the
authority to sign certain Records of Decision for remedial actions
from the Assistant Administrator for Solid Waste and Emergency
Response to the Regional Administrator. The authority to sign
this Record of Decision was delegated to you on June 17, 1985 in
the third Remedy Delegation Report.
The Record of Decision for the Celtor Chemical Works site
is a fourth quarter, FY-85, SPNS commitment for Region 9.
However, due to the current Superfund slowdown initiated by
Headquarters in August, 1985, funding for the remedial design has
been withdrawn pending CERCLA reauthorization.
Upon your signature, and pending available funding, the
U.S. Army Corps of Engineers will be given authorization to begin
design of the selected remedy. Provided we obtain funding in
October, 1985, we expect construction to begin in April, 1986
and to be completed by July, 1986, at which time the site will
be eligible for delisting from the National Priorities List.
Based on the Remedial Investigation Report, the Feasibility
Study Report, and the attached briefing documents, I request that
you sign the Record of Decision selecting excavation and off-site
disposal as the cost-effective remedial action for the Celtor
Chemical Works site. We have coordinated this Record of Decision
package with EPA Headquarters and the State of California and we
have received concurrence from Region 9's Office of Regional
Counsel, Water Management Division, and Air Management Division.
I am available to discuss this matter in more detail if you have
any questions concerning the attached Record of Decision package.
Attachment
13204 {«•». 3-76)
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RECORD OF DECISION
Remedial Alternative Selection
SITE; .Celtor Chemical Works, Hoopa, California
DOCUMENTS REVIEWED
My decision is primarily based on the following documents
that describe the cost-effectiveness of remedial alternatives for
the Celtor Chemical Works:
- Celtor Chemical Works Remedial Investigation
' - Celtor Chemical Works Feasibility Study
- Summary of Remedial Alternative Selection
-Community Relations Responsiveness Summary
DESCRIPTION OF SELECTED REMEDY
- Excavation and off-site disposal of all soils
contaminated above site-specific action levels
at a RCRA-approved hazardous waste disposal
facility.
DECLARATIONS
Consistent with the Comprehensive Environmental Response
Compensation, and Liability Act of 1980 (CERCLA), and the National
Oil and Hazardous Substances Contingency Plan (40 C.F.R. Part 300),
I have determined that excavation and off-site disposal of all
soils contaminated above site-specific action levels at the
Celtor Chemical Works is a cost-effective remedy which provides
adequate protection of public health, welfare, and the environment*
The State of California agrees with the selected alternative.
The remedial action I have chosen will require future
operation and maintenance to ensure its continued effectiveness.
These operations and maintenance activities are part of the
approved action and are eligible for Trust Fund monies for a
period of one year.
I have also determined that the remedial action selected is
appropriate when balanced against the availability of Trust Fund
monies for use at other sites. Finally, the off-site transport
and secure disposition of the hazardous substances is more cost-
effective than other remedial actions and is necessary to protect
public health, welfare and the environment.
DATE ^/ r _ JUDITH E. AYRES
Regional Administrator
EPA Region 9
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
CELTOR CHEMICAL WORKS
HOOPA, CALIFORNIA
* September 30, 1985
• Prepared by Nicholas Morgan
Federal Response Section, Superfund Programs Branch
Toxics and Waste Management Division
United States Environmental Protection Agency
215 Fremont Street
San Francisco, California 94105
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TABLE of CONTENTS
I. Site Location and Description 1
II. Site History 4
III. Current Site Status 7
IV. Enforcement Analysis 9
V. Alternatives Evaluation 9
V.A. Remedial Action Definition 10
V.B. Site-Specific Action Level Development 10
V. C. Technology Development 1 3
V.Di Initial Alternative Screening 13
V.E. Detailed Analysis of Alternatives.. 17
V.E.1. Technical Evalualtion 17
V.E.I.a. Performance 17
V.E.i.b. Reliability ...18
V.E.I.e. Implementability 19
V.E.I.d. Safety . 20
V.E.2. Institutional Evaluation .20
V.E.2.a. Agency Coordination 20
V.E.3. Public Health Evaluation 21
V.E.4. Environmental Evaluation 21
V.E.5. Cost Evaluation 22
VI. Community Relations 22
VII. Consistency with Other Environmental Laws 23
VILA. RCRA .. ...23
VII.B. E.O. 11988 24
VII.C. CWA 24
VII.D. OSHA 25
VII.E. DOT 25
VII. F. GWPS .25
VII.G. Other 25
VIII. Recommended Alternative .26
IX. Operation and Maintenance 26
X. Schedule .28
XI. Future Actions .....28
Glossary •••• .29
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
CELTOR CHEMICAL WORKS
HOOPA, CALIFORNIA
I. SITE LOCATION AND DESCRIPTION
The Celtor Chemical Works site is located in the northern
end of the Hoopa Valley in Humboldt County, California, (see
Figure 1). The 2.5 acre site is on reservation land of the Hoopa
Valley Indian Tribe, about 2 miles north of the town of Hoopa.
The main features of the site are the plantsite, a privately
owned pasture used for livestock grazing to the west of the
plantsite, and a shallow gully that runs northward from the
plantsite to the Trinity River (see Figure 2). Sulfide ores were
hauled to the Celtor Mill from the nearby Copper Bluff mine for
copper, zinc, and precious metal extraction. The plantsite
currently contains a number of concrete walls and slab floors
as remnants of the former ore processing operations.
Surrounding the mill are bare to partially vegetated slopes
that consist of native soil contaminated by ore and tailings.
Dirt roads cross the site, and a gravel fishing-access road
passes through the lower (western) part of the plantsite area
separating the plantsite from the pasture. The grass covered
pasture, located below and west of the fishing-access road and
the plantsite, is used to graze cattle. The 500 foot long gully,
which runs to the north of the plantsite, is heavily wooded and
contains thick brush. This gully discharges into the Trinity
River, which, in this area, is classified as a scenic river
area under the National Wild and Scenic River System. The Trinity
is also considered an important fish resource, including salmon
and trout spawning grounds.
In December,. 1964 the maximum historic flood for this area
was recorded. United States Geological Survey (USGS) and the
United States Army Corps of Engineers (USACE) records classify
the 1964 flood as greater than a 100-year event. Aerial
photographs, discussions with local residents, and a high water
mark indicate that in the site area the flood reached a height
of 321 feet above mean sea level. The lowest elevation of the
plantsite is 330 feet. Thus, all areas lower than the plantsite,
such as the pasture, at elevation 320 feet, and all of the gully,
may be impacted by a 100-year flood.
The predominant water bearing aquifer beneath the site is
a three to five foot thick bed of sandy gravel which rests atop
relatively impermeable unweathered phyllite bedrock. This highly
permeable and transmissive aquifer is located between 20 feet (at
the plantsite) and 60 feet (in the middle of the gully) below
the ground surface. A substantial amount of water, perhaps
greater than 10 cubic feet per second, flows in this aquifer in
a northerly direction into the Trinity River.
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Figure 1
7-1
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Figure 2
Figure 2
AERIAL PHOTOGRAPHY
OF
PROJECT VICINITY
CELTOR CHEMICAL WORKS
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The structure nearest to the site is a home situated
approximately 500 feet to the south. One thousand two hundred
twenty (1,220) feet south of the site are approximately one
hundred homes which are part of the Morton Field Development.
Altogether, approximately 900 residences are within three miles
of the site. Until as recently as 1985, residents of the Norton
Field Development, and other nearby homes, drank water from a
community well which tapped into the same ground water which
flows beneath the site. The well, which is located upgradient
(south) of the site was sampled by the United States Indian
Health Service (IBS), and was found to be free of inorganic
contamination, except for iron, which is believed to be a local
phenomenon. All residents in the vicinity of the site now drink
water supplied from an upstream surface water source, except for a
cluster of six to ten homes which draw from private wells located
further upgradient of the site than the Morton Field community
well.
II. SITE HISTORY
The Hoopa Valley Indian Tribe is the owner of the Celtor
site. The Tribe's land is held in trust by the United states.
The Tribe leased the land in 1958 to the Celtor Chemical
Corporation which processed sulfide ore taken from the nearby
Copper Bluff Mine. A responsible party search conducted for EPA
in November, 1984 indicated that ore processing may have occurred
at the site prior to 1958, but there is no reliable documentation
to support this contention.
The plant, known as the Celtor Chemical Works Mill, is
believed to have used dissolved air flotation to extract copper,
zinc, and precious metals from the ore. The ore concentrates
were then trucked off-site for further processing, some mine
tailings were stockpiled in the plantsite area. However, most
were presumably sluiced down the gully to the Trinity River.
The tailings may have been the cause of the numerous fish kills
for which the California Department of Fish and Game cited the
Celtor Chemical Corporation.
Beginning in 1960, the company became delinquent in its
royalty payments to the Hoopa Valley Indian Tribe. By 1962,
Celtor's indebtedness to the Tribe had increased to $23,592.87.
According to records from the United States Bureau of Indian
Affairs (BIA), mining and milling operations actually ceased
on June 2, 1962 and June 5, 1962, respectively. Finally, in
March of 1963, the BIA, as the trustee for the Hoopa Valley
Indian Tribe, cancelled the leases of both the Copper Bluff
Mine and the Celtor Chemical Works Mill.
After milling operations ceased, a very large pile of
tailings was reported to have been left standing on a sand and
gravel bar between the gully and the Trinity River, along with
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the tailings that are known to have been left at the plantsite
area. The aforementioned flood of 1964 removed all traces of
any tailings that may have been on the sand and gravel bar.
The remaining tailings in the plant area, along with non-
specific releases of ore or tailings throughout the plantsite
area, are believed to be the cause of the acidic surface water
runoff and very elevated metals concentrations in the soils
throughout the plantsite area. These conditions were identified
by sampling performed by the State of California Department of
Health Services (DOBS) in July, 1981. The sampling occurred in
the same month that DOHS first discovered the site through an
ongoing California statewide abandoned industrial waste facility
survey. In August of that same year, the IBS submitted to the
United States Environmental Protection Agency (EPA) a Notification
of Hazardous Waste Site under the Comprehensive Environmental
Response,•Compensation and Liability Act of 1980 (CERCLA). In
February, 1982 the EPA Field Investigation Team performed
additional sampling at the site.
In April, 1982 the site was placed on the California State
Priority List, and on December 30, 1982, the site was proposed
for inclusion on the National Priorities List (NPL).
On August 29, 1983, EPA wrote to the BIA, stating our intent
to perform an Initial Remedial Measure (IRM) at the site and
requesting BIA to either perform or sponsor the action. This
letter explained that EPA considered BIA a potential responsible
party at the site due to its role as trustee for the Hoopa Valley
Indian Tribe. The mill lease stated that the site was to be left
in a condition that would not be hazardous to public health or
safety, a condition that Celtor had not complied with. The BIA
response stated that the matter should be elevated to a higher
level for resolution. Due to the impending winter rains, which
would have caused continued acidic surface runoff and health
threats, EPA performed the IRM action in December, 1983, prior to
the resolution of the responsible party issue.
*
During the IRM, all visibly contaminated material was removed
from the site. This material included all tailings, non-concrete
structures, and a portion of the adjacent pasture (see Figure 3).
In all, approximately 1,400 cubic yards of contaminated material
were taken to the IT Corporation Class I hazardous landfill in
Benicia, California. The total cost of this action was approxi-
mately $337,000. After the contaminated soil was removed, the
fishing-access road was regraded and covered with fresh gravel.
Finally, a drainage culvert was installed at the north end of the
site, and the site was fenced. All IRM activities were completed
on December 18, 1983. Plans were made to return to the site
during the next rainy season to perform the sampling necessary to
determine if run-off or soils from the site or adjacent areas
still posed a health threat.
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PA «• TtSX-£.
n> rxw/rr
CltUJe-
DRAIUIU6
n/e.
Figure 3
SITE FACILITIES AND
I R M REMOVAL AREA
CELTOR CHEMICAL WORKS
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III. CURRENT SITE STATUS
On October 10, 1984, the Final Remedial Investigation/
Feasibility Study Work Plan received EPA approval. Remedial
investigation field work was completed on February 9, 1985,
and the final Remedial Investigation Report was released on
April 29, 1985. The results of the 177 surface and subsurface
soil samples, 32 surface water and ground water samples, and 16
air samples are discussed below.
In order to have a basis on which to evaluate the results of
the Remedial Investigation, criteria for evaluating the hazards
at the site had to be determined. Because no Federal action
levels exist for defining hazardous concentrations of metals in
soil, the State of California, California Assessment Manual (CAM)
Total Threshold Limit Concentrations (TTLC) criteria for defining
hazardous materials were used. Hater quality was evaluated on
the basis of the EPA One Hour National Ambient Water Quality
Criteria for Protection of Freshwater Aquatic Life, 45 Federal
Register 79318 et seq;, November 28, 1980 and 50 Federal Register
30784 et seq., July 29, 1985 (WQCAL), as promulgated under the
Clean Water Act as amended in 1977 (CWA) and the EPA Maximum
Contaminant Levels (MCLs) or Primary and Secondary Drinking
Water Regulations, 40 C.F.R. Part 141 and 49 Federal Register
24330 et seq., June 12, 1984 (DWRs), as promulgated under the
Safe Drinking Water Act as amended in 1977 (SDWA).
The soil samples taken from the main plantsite to a depth of
20 feet contained cadmium, copper, lead and zinc in concentrations
greater than the CAM TTLC criteria to depths of 2.5 feet. Elevated
concentrations of arsenic, copper, and zinc were also found to
depths of 11.5 feet. These deeper concentrations were above
background levels, but were not necessarily greater than the CAM
TTLC criteria. The most significant elevated metals concentrations
in the plantsite were 124,000 milligrams per kilogram (mg/kg),
or parts per million (ppm), copper at the surface, 23,330 mg/kg
zinc on the fishing access road surface, and 1,040 mg/kg lead,
also on the surface.
The gully was also found to be contaminated. The remedial
investigation field personnel observed a vein of tailings which
was approximately four feet wide and five feet deep. Again,
arsenic, cadmium, copper, lead, and zinc were found at
concentrations exceeding the CAM TTLC criteria. Although
concentrations above background were found at depths up to 4.5
feet, maximum concentrations were only found between the surface
and 2.5 feet. These maximum concentrations were 600 mg/kg for
arsenic, 310 mg/kg for cadmium, 25,500 mg/kg for copper, 1,680
mg/kg for lead, and 62,100 mg/kg for zinc.
A thin lens of contaminated material was found beneath the
clean fill that had been placed in the adjacent pasture after the
IRM. In this lens, 1.25 feet below the surface, arsenic, cadmium,
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, -8-
copper, lead, and zinc were found in elevated concentrations,
however, only lead, at 2,650 mg/kg, and zinc, at 11,200 rag/kg,
were above the CAM TTLC criteria.
During the winter months, water from many springs and seeps
travel through or beneath the plantsite. These springs either
emerge somewhere in the plantsite area and eventually collect
in the gully, or continue to travel beneath the plantsite for
eventual discharge into the trinity River.
Sampling showed that these waters become contaminated as
they pass through or on top of the site, water leaving the site
and in the gully was contaminated with cadmium, copper, lead,
iron, and zinc above the MCLs, as well as, in some cases, the
more stringent WQCAL. No WQCAL for lead has been established.
Maximum concentrations found on the plantsite or in the gully
were 241 micrograms per liter (ug/L), or parts per billion (ppb),
of cadmium, 9,920 ug/L of copper, 16,600 ug/L of iron, 7 ug/L of
lead, and 48,300 ug/L of zinc. The pH of the water was as low
as 3.6. That value, however, is not lower than the CAM TTLC and
the Resource Conservation and Recovery Act as amended in 1984
(RCRA) criteria for definition of a hazardous material, which is
pH equal to or less than 2.
Sampling upstream and downstream of the gully's discharge
point into the Trinity River showed that the river was not
detectably impacted by water discharges from the gully. A worst
case analysis of the potential impact was conducted in the Remedial
Investigation Report. Assuming a first flush of contaminants from
the site entered the river during low flow, this analysis showed
that river impact would be unlikely because the projected dilution
of 1:500 (normal dilution is between 1:1000 and 1:5000) would
prevent the water quality in the Trinity River from rising above
the WQCAL for more t'han a few hours.
Sampling during the remedial investigation showed that ground
water beneath, and in the vicinity of the site was not contaminated.
There were, however, elevated levels of iron in some of the samples,
but discussions with the Environmental Director of the Hoopa
Valley Business Council (HVBC), the representatives of the Hoopa
Valley Indian Tribe, and the IBS, indicated that this is due to
naturally elevated levels of iron in the local soils. In summation,
there does not appear to be a ground water contamination problem
associated with the site.
On June 18 and 19, 1985, in response to community concerns
about noxious odors in the vicinty of the site, the EPA Technical
Assistance Team performed air sampling at the site. No detectable
concentrations of air pollutants relating to the reported sulfur
odor could be found. However, there is a noticeable sulfur odor
in the area at times. If the odors are caused by the contaminants^
at the site, implementation of the recommended alternative should
eliminate this odor nuisance.
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-9-
i •• ~ • * t>
In summation, the Remedial Investigation found that the site
poses a threat to human health and the environment from high
levels of arsenic, cadmium, copper, lead, and zinc in the soil.
Direct -contact, especially ingestion of greater than 2 liters per
day, with contaminated water in the plantsite, roadway, or gully
areas also poses a human health and environmental threat.
IV. ENFORCEMENT ANALYSIS
A potential responsible party search completed for the EPA
in November, 1984 concluded that the Celtor Chemical Corporation
was a defunct company with no remaining assets or interests that
could be pursued for cost recovery. The BIA, as trustee for the
Hoopa Valley Indian Tribe and the United States Department of the
Interior (DOI), the parent agency of the BIA, are the only other
potential responsible parties.
On August 29, 1983, prior to the IRM, EPA sent to BIA a
3007/104 Notice Letter which identified the BIA as a potential
responsible party and requested BIA to fund or perform the IRM.
On October 24, 1983, BIA responded and suggested that the matter
be elevated to BIA Headquarters. After EPA conducted the IRM,
a second Notice Letter was sent to the DOI in August, 1985
specifying our intent to take remedial action and requesting DOI
to fund or perform the remedial action. A meeting was held in
Washington, D.C. on September 19, 1985 to disucss the DOI's
status as a potential responsible party. At the meeting, the
DOI refused to contribute to or conduct the remedial action.
However, DOI agreed to discuss the matter further with EPA after
the cleanup was completed during cost recovery negotiations.
Results of ongoing discussions at the Headquarters level .
regarding DOI's liability for sites on Indian lands that are
held in trust by DOI will be a key element in the resolution of
DOI's status at this site. .
V. ALTERNATIVES EVALUATION
The following section summarizes the alternatives evaluation
and recommended alternative selection process as documented in
the Feasibility Study. All procedures are consistent with the
National Oil and Hazardous Substances Contingency Plan, 47 Federal
Register '31180 et seq., July 16, 1982 (NCP) and the Guidance on
Feasibility Studies Conducted Under CERCLA, EPA, June, 1985.
This section begins with the definitions of the remedial actions
that were evaluated then describes the site-specific action
levels that were selected for the site. An alternative, consistent
with all relevant guidance, is then chosen. The steps in this
evaluation are technology development, initial alternative screening,
and detailed analysis of alternatives. Finally, the results of
alternatives evaluation is documented.
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V.A. Remedial Action Definition
The NCP, Section 300.68(e)(2) states that source control
remedial actions are appropriate when a substantial concentration
of hazardous substances remain at or near the areas where they
were originally located. Because all of the contamination in the
plantsite and gully are presumed to be left from operations of
the Celtor Chemical works, and not from off-site migration, the
measures under consideration for the plantsite and gully are
considered source.control. Because contaminants in the field are
presumed to have migrated from the plantsite, the remedial action
in the pasture area, according to the NCP Section 300.68(e)(3),
is considered an off-site, or management of migration, remedial
action.
V.B. Site-Specific Action Level Development
In the June 28, 1985 public comment draft Feasibility Study
Report, site-specific objectives for remedial action were
developed. According to the Public Health Assessment prepared
for the report, under the worst case scenario of no response
action and unrestricted residential site use, the primary health
threats are:
" Direct contact with soils contaminated with
arsenic, cadmium, copper and lead.
" Consumption of surface water running off the site
or in the gully. This water sometimes exceeds the
NCLs for copper, iron, lead, and zinc. The elevated
concentrations of iron are believed to be a natural .
condition.
As described in the NCP, Section 300.68(j), the objective of
every remedial action is to "...mitigate(s) and minimize damage
to and provide(s) adequate protection of public health, welfare,
or the environment....11 For the Celtor site, the general remedial
goals are to prevent human exposure to soil and water that is
contaminated at concentrations that may pose a public health or
environmental threat. To implement these goals, site-specific
action levels were developed as shown in Table 1.
The action levels for water were established as discussed
below. Water flows in the gully are intermittent and are
insufficient to support most aquatic life. Accordingly, water
quality criteria for the gully, for surface water running into
the gully, and for ground water, which is a known drinking water
resource, are based on action levels necessary to protect human
health. Therefore, the surface water and ground water site-
specific action levels selected for the site are the MCLs, or
DWRs. These actions levels fully protect public health in all
scenarios.
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TABLE 1
SITE-SPECIFIC ACTION LEVELS FOR THE CELTOR CHEMICAL WORKS SITE
SURFACE
&' - •
GROUND Trinity
METAL SOILS WATER1 RIVER2
ARSENIC 100 mg/kg 50 ug/L 50 ug/L
CADMIUM 25 10 2.8
COPPER 2,500 1,000 2.6
LEAD 500 50 50
ZINC 5,000 5,000 47
1. Site-specific action levels for on-site surface water and
local ground water are MCLs or DWRs, as promulgated under
the SDWA.
2. Site-specific action levels for the Trinity River at the
gully discharge point are the WQCAL, as promulgated under
the CWA and as based on a hardness of 75 mg/L as CaCo3,
except for arsencic and lead, where the more stringent MCL
was used. • '.
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Action levels for the Trinity River were based on the most
stringent Federal standards for protection of aquatic life.
These are the WQCAL, as based on a hardness of 75 mg/L as €3003.
For arsenic and lead/ however/ the more stringent MCL of 50 ug/L
was used instead of the WQCAL of 440 ug/L and 57.4 ug/L,
respectively. These action levels for the Trinity River fully
protect human health and most aquatic organisms.
In addition to the concerns regarding metals contamination/
low pH surface water may also pose a health hazard. Therefore/
an additional action level for surface water or soil of pH = 2 or
lower was developed. This is based on the RCRA corrosivity
requirements found in 40 C.F.R. 261.22, which is the definition
for a hazardous waste under RCRA.
Action levels for contaminants in soil were based primarily
on the acceptable range of contaminant levels in soil as derived
from the EPA National Ambient Water Quality Criteria for Protection
of Human Health/ 45 Federal Register 79318 et seq./ November 28,
1980 (WQCHH), as promulgated under the CWA/ and the MCLs, or DWRs,
as promulgated under the SDWA. First/ an acceptable daily dose
was computed by multiplying the WQCHH or MCL for a given
contaminant by two liters/ which is the maximum daily ingestion
rate for the WQCHH or MCL to protect human health. This computed
daily dose is then divided by 10 grams or 0.1 grams/ which is the
United States Centers for Disease Control (CDC) maximum estimated,
ingestion rate of soil for a child or an adult/ respectively.
The result is a range of contaminant concentrations in soil
which will fully protect human health. These acceptable
contaminant concentrations are: arsenic 10-1/000 mg/kg, cadmium
2-200 mg/kg; copper 200-20/000 mg/kg; lead 10-1/000 mg/kg; and
zinc 1,000-100/000 mg/kg.
Other considerations were also evaluated in setting the
action levels. The action level for arsenic of 100 mg/kg is
based on an advisory from the CDC for another CERCLA site. This
level is much stricter than the CAM TTLC of 500 mg/kg. The
action level for'cadmium of 25 mg/kg is consistent with the
action level set for the Capri Pumping Service site (a State of
California Superfund site)/ and is based on cleanup for
unrestricted residential use. It is one-quarter of the CAM TTLC
of 100 mg/kg. The action level for lead of 500 mg/kg is also
consistent with the Capri site, is one-half the CAM TTLC of
1/000 mg/kg/ and is also consistent with other CERCLA sites.
Action levels at these other Superfund sites ranged from 300
mg/kg to 1/000 mg/kg. The action levels for copper and zinc
were established at the CAM TTLC levels of 2/500 mg/kg and 5/000
mg/kg/ respectively/ because these levels are sufficient to
protect human health. Toxic effects from these metals are not
found except for materials with very high concentrations (20/000
to 100/000 mg/kg range) as these metals are primarily regulated
for taste and odor considerations. The copper and zinc action
levels are also consistent with the levels set for the Capri
site/ and provide a wide margin of safety even in worst case
scenarios.
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V.C. Technology Development
In order to meet these action levels, several general response
actions were developed. The general response actions, and some of
the associated technologies that were considered in the Feasibility
Study were:
" Containment: Capping, ground water containment
barrier walls, bulkheads, and gas
barriers.
* On-Site Disposal: Encapsulation and land application.
" Off-Site Disposal: Excavation and off-site disposal.
" On-Site Treatment: Incineration, solidification,
biological treatment, chemical
treatment, in-situ soil flushing
and soil flushing.
* Off-Site Treatment: Same as on-site treatment,
except for in-situ soil
flushing.
* No Action: No remedial action.
According to the Guidance on Feasibility Studies Under CERCLA,
the second step in the development of remedial alternatives is to
define and screen technologies that are applicable to the general
response actions listed above. Inapplicable, infeasible, or
unreliable technologies are assembled and screened primarily
through the use of engineering judgement and qualitative
comparisons. .
After developing an extensive list of technologies, based
on the general response actions listed above, and screening,
based on such factors as site conditions, waste characteristics,
and technology effectiveness, the technologies presented in
Table 2 remained.
V.D. Initial Alternative Screening
Once the technologies identified above have been screened,
more definite alternatives can be developed. At least one
alternative for each of the five following catagories must be
evaluated per the feasibility study guidance. These five
catagories, and the corresponding alternatives, are presented
below:
1. Alternatives specifying off-site storage, destruction,
treatment, or secure disposal of hazardous substances at
a facility approved under RCRA. Such a facility must also
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. . Table 2
TECHNOLOGIES REMAINING AFTER SCREENING
Response Action
Containment
Technologies
Onsite Disposal
Offsite Disposal
Treatment
Capping of Hazardous Soils and Nonhazardous
Concrete Structures
Native Soil (Silt)
Imported Clay
Multilayer Systems
Synthetic Cover and Soil
Loam over Synthetic Cover over Clay
Native Soil over Imported Clay
Drainage Systems (these technologies apply
to all response actions except no-action)
Interceptor Trenches
Permeable Geotextile Fabric
Drainage Pipes
Gravel Layers
Soil Excavation
Onsite Encapsulation of Hazardous Soil
Clay, Native Soil, and Synthetic Liner
Combination
Drainage Systems (see above list)
Onsite Burial of Nonhazardous Materials
(e.g., concrete)
Structure Demolition
Burial with Native Soil
Removal of Hazardous Soil
Soil Excavation
Trucking to Class 1 RCRA-approved Landfill
Disposal at Class 1 RCRA-approved Landfill
Removal, of Nonhazardous Soil and Concrete
Soil Excavation
Structure Demolition
Trucking to Class II or Class III Landfill
Onsite Treatment
Chemical
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be in compliance with all other applicable EPA standards
(e.g., Clean Water Act, Clean Air Act, Toxic Substances
Control Act). Removal and treatment are in this category.
2. Alternatives that attain all applicable or relevant Federal
public health or environmental standards, guidance, or
advisories. Removal, encapsulation, and treatment all
fall into this category.
3. Alternatives that exceed all applicable or relevant Federal
public health and environmental standards, guidance, and
advisories. No alternatives are in compliance with this
category because it was not feasible to develop an alternative
that would exceed all applicable environmental standards.
4. Alternatives that meet the CERCLA goals of preventing or
minimizing present or future migration of hazardous sub-
stances and protect human health and the environment, but do
not attain the applicable or relevant standards. This
category may include an alternative that closely approaches
the level of protection provided by the applicable or relevant
standards. Capping falls into this category.
5. A no-action alternative must be included.
A more detailed description of the alternatives mentioned
above is provided below:
1. No-Action
2. Capping - Partially demolish concrete structures (to
facilitate capping).
Excavate soils contaminated above action levels
from the pasture and gully, deposit in plantsite
area, and backfill pasture and gully with clean
soil.
- Regrade all areas.
- Install surface and subsurface drainage systems.
- Install multilayer system of clay, synthetic
cover, and native soil over contaminated material
in plant area.
- Vegetate site.
Install security fencing to protect cap and new
vegetation.
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3. Removal - Demolish and remove structures.
- Excavate soils contaminated above action levels
from all site areas.
- Remove all soils to a RCRA-approved Class I
landfill.
- Import clean fill as necessary.
- Regrade and vegetate site.
- Install security fencing to protect new
vegetation.
4. Encapsulation
- Demolish concrete structures and bury on-site.
- Excavate soils contaminated above action levels
from all site areas.
- Backfill pasture and gully with clean soil.
- Encapsulate contaminated soils on-site.
- Install surface and subsurface drainage systems.
- Import clean fill as necessary.
- Regrade and vegetate site.
Install security fence to protect new vegetation,
5. Treatment .
- Demolish and bury structures on-site.
- Prepare the site for a treatment facility.
- Excavate soils contaminated above action levels.
- Process soils contaminated above action levels
through the EPA Mobile Soils Flushing Unit.
- Return clean material to excavated areas.
- Add clean fill as necessary.
- Remove contaminated sludges/waste to a RCRA-
approved Class I landfill.
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- Remove treatment facility.
- Regrade and vegetate site.
- Install security fence to protect new vegetation.
An initial screening of alternatives is performed according
to the NCP, Section 300.68. Public health, environmental, and
cost factors, including potential adverse environmental impacts
and engineering feasibility are figured into the screening process.
No-Action was eliminated at this time because it would not
protect human health or the environment. However, No-Action
was carried through the detailed analysis for the purpose of
comparison with other alternatives. The results of a bench scale
soils flushing treatability study, Metals Extraction Study for
the Celtor Chemical Works, EPA, October, 1985, indicated that
treatment would not be effective. None of the flushing solutions
tested was able to extract sufficient contaminants to attain the
action levels. While treatment was carried through the detailed
alternatives analysis in the draft Feasibility Study Report, it
is now being dropped from further consideration on the basis of
the test data.
V.E. Detailed Analysis of Alternatives
A detailed analysis of the remaining alternatives was
performed according to the NCP, Section 300.68. Five factors
are evaluated in this analysis: technical, institutional, public
health, environmental, and cost. Chapters 3, 4, 5, 6, and 7
of the Guidance on Feasibility Studies Conducted Under CERCLA
provide an in-depth discussion of the components of each factor
requiring further evaluation.
V.E.1. Technical Evaluation
There are four primary factors in the technical evaluation:
performance (including effectiveness and useful life), reliability
(including operations and maintenance (O6M) requirements and
demonstrated performance), implementability (including on- and
off-site conditions, time to implement, and time to achieve
beneficial results), and safety.
V.E.I.a. Performance: Effectiveness: The Removal Alternative
would provide the highest level of protection to human health
and the environment because it would permanently remove all
contaminants from the site. Encapsulation and Capping may provide
an acceptable level of protection, if all of their components
(the liners, cap, and drainage facilities) were properly maintained.
However, the effectiveness of the encapsulation cell, and especially
the cap, may be seriously compromised by the natural springs in
the area. There is no assurance that the interceptor trenches
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and subsurface drains could effectively prevent ground water
(especially the springs) from coining into contact with the
contaminated soil. The certainty with which this objective
could be achieved is greater for encapsulation than for capping.
No-Action is completely ineffective in preventing direct contact
with contaminated soils or the formation of contaminated runoff.
Useful Life: Removal would have an infinite useful life.
The useful life of Encapsulation and Capping is estimated to be
thirty years, based on the life of the materials. At that time,
the entire encapsulation cell or cap might have to be replaced.
The concept of useful life does not apply to the No-Action
Alternative.
V.E.I.b. Reliability: Operation and Maintenance: Except for
No-Action, each of the alternatives will require grounds maintenance
for an initial period of one year. This would include caring
for surface vegetation, doing preventative work on any surface
water drainage systems, and taking care of erosion problems in
order to assure that revegetated areas become properly established.
After the first year, vegetation or surface drainage maintenance
would not be required for the Removal Alternative. Capping and
Encapsulation both require long term (thirty years and greater)
maintenance of vegetation and surface drainage features to ensure
the effectiveness of the technology.
A fence will be required the first year for all alternatives.
Thereafter, Capping, Encapsulation, and No-Action will all require
a fence. This is not a legal requirement. However, good engineer-
ing judgement indicates that maintaining a fence around the site
for those alternatives which leave hazardous materials at the
site is a sound method to ensure that the vegetation, the remedial
technology, and the contaminants are not disturbed.
Demonstrated Performance: All of the component technologies
utilized in the Removal, Capping, and Encapsulation Alternatives
have been widely used and proven in similar applications. Because
all contaminants will be removed from the site with the Removal
Alternative, there is no chance of failure of this technology.
At this site, Encapsulation is less likely to be effective than
Removal because there are many springs and seeps in the area.
Furthermore, it is impossible to predict the location of all
surface water in the area. It is unlikely, therefore, that
interceptor trenches and subsurface drains could prevent all the
subsurface water from coming into contact with the encapsulation
cell. In time, this water could damage the encapsulation cell
and compromise the effectiveness of this alternative. The Capping
Alternative, which has no bottom or side liner, has a greater
probability of failure than the Encapsulation Alternative also
because the interceptor trenches and subsurface drains may not
divert all water which may contact the contaminated material
beneath the cap.
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The Encapsulation and Capping Alternatives may also fail
because of degradation of their surface features. If vegetation
is not properly maintained, if erosion is not prevented, or if
any heavy objects fall or are placed on the surface, the integrity
of the top cap Will be compromised. Careful maintenance can
help prevent such a failure.
V.E.1.C. Implementability; Constructability: None of the
alternatives present exceptional problems for construction,
given a reasonable schedule, favorable weather, and good ground
conditions. Because several springs are present on the site,
construction of any of the alternatives would be unadvisable
during the wet winter months. For the Encapsulation and Capping
Alternatives, there must be controlled moisture conditions for
the placement of the clay layers. NO other on-site conditions
should be significant to the construction of any alternative.
There are many qualified contractors with extensive experience
in performing removal work. Currently no restrictions exist on
the off-site transportation or disposal of hazardous wastes that
would prevent the implementation of the Removal Alternative (see
the CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS section).
There are fewer qualified contractors who could perform the
encapsulation or capping work. Of the two alternatives, capping
is much simpler to perform and has had wider field use. Encap-
sulation is a complex technology with many components which would
require careful construction. Sealing the seams between the
sections of fabric is the most critical aspect of the construction,
but there are many portions of construction which must be properly
performed in order for this alternative to perform adequately.
Time to Implement and Time to Achieve Beneficial Results:
All of the alternatives have relatively short construction
schedules and could be implemented over one dry season, for
example, from April through October. The following construction
times do not include the design or bid and award period.
" Removal and Disposal......3 Months
* Capping 2 Months
" Encapsulation.... 4 Months
* Treatment .6 Months
* No-Action. .0 Months
The differences between construction times for the alternatives
(except for No-Action) are minor. Once constructed, each
alternative would immediately begin providing the benefits
associated with the component technologies.
V.E.I.d. Safety; Exposure to hazardous materials during
construction would be most likely to occur through inhalation of
airborne dust since all alternatives (except No-Action) involve
earthwork operations. Without strict dust control measures,
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this exposure could affect the public as well as construction
workers. Direct contact and ingestion by workers is also a
possibility.
The Removal Alternative presents the additional possibility
of exposure during off-site transportation* Depending on the
truck capacity and the total volume of contaminated soil hauled,
this may involve up to 600 truckloads, possibly including up to
20 trips per day. Health and safety considerations during
construction are not applicable to the No-Action Alternative.
The Capping Alternative requires the least amount of
earthwork, has the shortest construction period, and does not
involve any off-site transport of contaminated materials. There-
fore, it is the most favorable in terms of potential exposure
during construction. The Encapsulation, Removal, and Treatment
Alternatives all require about the same amount of excavation
of contaminated material, although Encapsulation may invlove
more handling because of the stockpiling of contaminated soils
required during the construction of the cell liner. The Removal
Alternative involves off-site transportation of hazardous materials,
while Encapsulation does not. Therefore, the overall potential
for exposure to contaminated material is approximately equal for
the alternatives, although somewhat different in types.
To help prevent potential health risks, stringent health and
safety requirements will be implemented during on-site work and
when contaminants are being hauled off-site.
V.E.2. Institutional Evaluation
There are three primary factors in the institutional evaluation:
compliance with applicable or relevant Federal environmental and
public health standards, agency coordination, and community rela-
tions. The first factor is discussed in detail in the CONSISTENCY
WITH OTHER ENVIRONMENTAL LAWS section, community relations is
dissussed in the accompanying Community Relations Responsiveness
Summary, and agency coordination is summarized below.
V.E.2.a. Agency Coordination: The following agencies have been
kept informed or have been coordinated with in the past, and we
will continue to so for all furture site activities:
Hoopa Valley Indian Tribe
BIA
DOI
DOHS
RWQCB
U.S. Army Corps of, Engineers
California Department of Fish and Game
U.S. Fish and Wildlife Service
The Hoopa Valley Indian Tribe, the BIA, the DOI, and the DOHS^
have all expressed a strong preference for the removal alternative.
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V.E.3. Public Health Evaluation
An (extensive Public Health Assessment was conducted for the
Feasibility Study. The CURRENT SITE STATUS section of this
document describes the results of the assessment while the
evaluation and selection of site-specific action levels
necessary to protect human health and the environment are
described previously in this section.
V.E.4. Environmental Evaluation
A detailed evaluation of the short and long-term adverse and
beneficial effects of the response on the resources people use
(air, water, land, etc.) and on the biological environment were
conducted in the Feasibility Study, it was determined that all
of the alternatives, except No-Action, would have similar short-
term impacts related to construction activities. These impacts
would be limited to the construction time and would include
elimination of wildlife habitats or passage ways, and extremely
limited use of the fishing-access road.
Surface water leaving the site is not currently used by
people or aquatic life and is likely to remain unused due to low
and intermittent flow. Removal will improve surface water quality
the greatest, since no contaminants will remain at the site.
The improvement in surface water quality will be permanent and
without regard to site or maintenance conditions. Encapsulation,
given proper construction and maintenance, should provide for
the next greatest improvement in surface water quality, since
contaminants should remain completely isolated from subsurface
water which could carry contaminants up to the surface. Capping
may improve surface water quality to the same degree as
Encapsulation, but it is unlikely, due to the increased
possiblility of subsurface water mixing with the contaminants.
No-Action will not improve surface water quality and, unlike the
other alternatives, will continue to allow off-site migration of
water containing concentrations of contaminants which are
hazardous to public health. ,
Removal provides for the most beneficial long-term use of
the land, as there would be no deed restrictions and the land
could be used for any future uses. Encapsulation and Capping
would both require permanent deed restrictions on the site, but
would allow for such limited uses as a park or wildlife area.
No-Action would require a permanent deed restriction, preventing
almost all future activities.
If the noxious odor described in CURRENT SITE STATUS is
coming from the site, Removal would be the most effective in
eliminating the problem. Encapsulation and Capping might be
effective in reducing the odor, and No-Action would have no
effect on the odor.
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Ground water and the Trinity River currently do not appear
to be impacted by the site, and none of the alternatives are
likely to have any long-term effects on either resource.
V.E.5. Cost Evaluation
The costs developed for this evaluation are order-of-magnitude
estimates with an accuracy of +50 and -30 percent. These estimates
reflect January 1985 price levels and include thirty years of
operation and maintenance. The costs are shown in present worth
utilizing a 10 percent discount rate as outlined in the Office
of Management and Budget Circular No. A-94.
Total
Alternative Cost Capital 0 & M
No-Action$ 0 $ 0 $ 0
Capping $ 921,705 $ 889,702 $ 32,000
Removal $ 3,072,338 $ 3,065,338 $ 7,000
Encapsulation $ 1,201,837 $ 1,169,837 $ 32,000
VI. COMMUNITY RELATIONS
The primary interested parties in this site are the Hoopa
Valley Indian Tribe, the BIA, and the DOI. Both the HVBC and
the BIA submitted written comments on the draft Feasibility Study
during the official comment period which ran from June 28, 1985
to July 19, 1985. Both commentors stated a strong preference for
removal, which is consistent with what both agencies have been
requesting since EPA first became involved in the site in 1981.
During the public meeting to discuss the Feasibility Study, which
was held on July 11,t1985, at the Hoopa Valley Business Council
chambers, some of the commentors expressed objections with the
Treatment Alternative and some expressed a preference for the
Removal Alternative. All of the comments and concerns are
discussed in the attached Community Relations Responsiveness
Summary.
The public comment period was extended until August 16, 1985,
for the DOI. They received the extension because of their status
as a potential responsible party and because they did not receive
a copy of the draft Feasibility Study until July 23, 1985. DOI
has not submitted written comments as of the date of this document,
but when solicited over the phone, DOI also preferred the Removal
Alternative.
The only other comment received on the remedial action
alternatives was on a proposed alternative that was not developed.
The HVBC suggested that EPA consider partial treatment combined
with removal. Because treatment was shown to be ineffective during
bench scale studies, the HVBC's proposed alternative would be a
more expensive variation of the removal alternative with no ^
additional benefits, such as reduced amounts of hazardous material
requiring off-site disposal.
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A full discussion of all community relations activities,
community concerns, comments, and the EPA response to the comments
is included in the attached Community Relations Responsiveness
Summary.
VII. CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
It is EPA policy to give primary consideration to remedial
actions that attain or exceed applicable or relevant federal
environmental or public health standards. State and local
standards should also be considered; however, State standards
that are more stringent than Federal standards may form the basis
for the remedy only if the result is consistent with the cost-
effective remedy based on federal standards. The State may also
pay the additional cost necessary to attain the State standard(s).
The environmental or public health laws which are relevant or
applicable to the Celtor site are:
" Resource Conservation and Recovery Act (RCRA)
* Floodplain Management Executive Order 11988 (E.0.11988}
' Clean Water Act (CWA)
* Occupational Safety and Health Administration (OSHA)
Requirements
* Department of Transportation (DOT) Hazardous Materials
Transport Rules
" Ground Water Protection Strategy (GWPS)
VILA. RCRA
RCRA Subtitle C, 40 C.F.R. Parts 264 and 265 contain
closure requirements for landfills and surface impoundments that
are relevant to this site. This law requires that all contaminants
be prevented from migrating off-site, and if off-site migration
has occurred, it must be cleaned up. Consolidation of all wastes
into the plantsite area and subsequent capping or encapsulation of
the wastes with long term surface and groundwater monitoring may
meet these requirements. However, significant uncertainty exists
regarding the ability of the interceptor trenches and subsurface
drains to divert all subsurface water from entering the waste
management area. Also, a high likelihood exists for off-site
migration of contaminants in the Capping scenario if subsurface
water enters the waste management area. Given the significant,
yet unpredictable amount of subsurface water flows in the area,
the integrity of the encapsulation cell may, over time, be
compromised. Off-site migration of wastes would then be just as
probable as with the Capping Alternative. Therefore, while
Capping and Encapsulation may, at the time of construction, meet
the requirements of RCRA, they are unlikely to remain in compliance,
Removal ensures that all RCRA requirements will be met.
On June 19, 1985 the Acting Assistant Administrator, the Office
of Solid Waste and Emergency Response and the Office of General
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Counsel agreed to a new interpretation of the Landfill and Surface^
Impoundment Closure Requirements described in 40 C.F.R. Part
264.111. "Clean closure" (i.e. no need for long-term monitoring)
no longer requires removal of all contaminants to background
levels. Clean closure may now be achieved by removing all
contaminants which may pose a threat to human health or the
environment or which may migrate off-site. The site-specific
action levels for this site will protect human health and the
environment and assure that Removal will be in full compliance
with this requirement, hence, full compliance with RCRA.
Since the No-Action Alternative would allow contaminants to
continue to migrate off-site in concentrations that pose a hazard
to human health and the environment, No-Action is not RCRA
compliant.
VII.B. E.O. 11988
Because portions of the site, the pasture and the gully are
presumed to lie within the 100-year floodplain, E.O. 11988 requires
that a floodplain assessment be conducted. The assessment requires
consideration of all environmental effects, community welfare,
costs, and all possible alternatives. The assessment concluded
that the best course of action to ensure protection of the
environment, the prevention of off-site contaminant migration,
and stabilization and preservation of the floodplain, would be to
remove all contaminants from the floodplain then regrade and
revegetate the affected areas to natural conditions. This will
ensure that areas in the floodplain (the gully) will be as resistant
to the damaging effects of floods, without the added possibility
of contaminants migrating off-site, as if no construction in the
floodplain had ever occurred. Therefore, Capping, Encapsulation,
and Removal all meet the substantive requirements of E.O. 11988.
Since No-Action does.not protect against the release of contaminants
into the environment during a 100-year flood it does not meet the
substantive requirements of E.O. 11988.
VII.C. CWA
Under the CWA, discharges from a facility which enter into
a water body of the United States must meet California Water
Quality Standards, based on the designated uses of the receiving
water. However, because this site is on Indian reservation land,
State environmental laws or regulations apply as State law. They
are, however, incorporated into the Federal law, the CWA, and
thus apply.
Disharges from the gully enter the south fork of the Trinity
River within the Klamath River Basin 1-A. The State of California
has not designated any specific discharge limits for inorganic
contaminants for this river basin. However, there does exist,
under California Water Quality Standards, a non-degradation
policy for all high quality waters in the State. While in theory
this means that the RWQCB requires zero discharge of contaminants
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from any site or facility, in practice the RWQCB recognizes that
zero discharge may be inpractical or unfeasible. Discussions
with the RWQCB have confirmed that should up and downstream
sampling confirm that discharges from the gully do not impact the
Trinity, an action level meeting the DWRs for water quality in
the gully would be acceptable.
Capping, Encapsulation, and Removal, would all ensure that
water quality in the gully is at least equal to DWRs and would
all comply with the CWA and California Water Quality Standards.
Because discharges from the site are not currently impacting the
Trinity, No-Action may also comply with these requirements.
VII.D. OSHA
Any applicable OSHA requirements will be addressed during
the detailed design phase of the selected alternative. OSHA
requirements address such concerns as on-site worker safety and
health. All alternatives can be designed to be in full compliance
with all OSHA requirements.
VII.E. DOT
DOT Hazardous Material Transport Rules apply only to the
off-site transportation of hazardous materials. The Removal
Alternative can be designed to be fully compliant with all DOT
rules and regulations.
VII.F. GWPS
The GWPS is not a relevant or applicable standard at this
time, but is to be considered during remedial alternative
selection. The ground water beneath the site is designated as
a Class II ground water under the GWPS since it has been used in
the past and could be used in the future as a drinking water
source. For these waters, the GWPS states that the goal of
CERCLA cleanups will be drinking water quality or RCRA approved
Alternative Concentration Limits. Currently, the site is not
impacting ground water, and implementation of any alternative is
not expected to cause an impact on ground water. All alternatives
would be in full compliance with the GWPS.
VII.G Other
As mentioned above, State laws and regulations do not apply
to this site as it is located entirely on Indian reservation
land. There are no other known applicable or relevant Federal
laws or regulations which apply to this site.
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-26-
VIII. RECOMMENDED ALTERNATIVE
Section 300.68(j) of the NCP states that "The appropriate
extent of remedy shall be determined by the lead agency's
selection of the remedial alternative which the agency determines
is cost-effective (i.e. the lowest cost alternative that is tech-
nologically feasible and reliable and which effectively mitigates
and minimizes damage to and provides adequate protection of public
health, welfare, or the environment)". Based upon the Remedial
Investigation and Feasibility study, EPA Region 9, the State of
California, the Hoopa Valley Indian Tribe, the Bureau of Indian
Affairs, and the Department of the Interior agree that excavation
and off-site removal of all soil contaminated above site-specific
action levels is the most cost-effective long-term remedial action
necessary to protect human health and the environment. This
alternative fully complies with all relevant or applicable laws
and regulations.
No-Action was eliminated as a potential alternative because
it would not protect human health and the environment, based on
the Public Health Assessment conducted for the Feasibility Study.
Capping was eliminated beause of the high probability of subsurface
water migration through the contaminated soil and off-site migra-
tion of contaminants. These contaminants could be carried to the
surface via the many springs in the area where they would pose a
human health threat. Encapsulation was also eliminated because
of probability that, over time, the many springs in the area
could damage the integrity of the encapsulation cell, thereby
permitting contaminants to migrate to the surface and off-site.
Capping and Encapsulation have the added disadvantage of
requiring a permanent deed restriction on the property, since the
inorganic contaminants present at the site do not degrade with
time. In addition, the entire cap or encapsulation cell may
require complete replacement every 30 years, the projected life
of the technology. For these reasons, Removal is selected as
the only remedial-action which is cost-effective and will assure
long-term protection of human health and the environment. Table 3
summarizes the information presented in this document regarding
the various alternatives.
IX. OPERATION AND MAINTENANCE
Projected O&M for removal, as for all of the alternatives,
is an initial one year period of grounds maintenance. This
would include caring for surface vegetation, doing preventative
work on any surface water drainage systems, and taking care of
erosion problems to assure that revegetated areas become properly
established. A fence will also be utilized for the first year
after remedial alternative implementation. The fence will help
to ensure that the vegetation is not disturbed while becoming
established. The total present worth of these O&M activities
is $7,000.
-------
Table 3
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tktrt il i Mllikilitr iliir ll llltilt •ifriliM
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-------
-28-
X. SCHEDULE
" Approve Remedial Action (ROD) September 1985
* Start Remedial Design November 1985
Complete Remedial Design March 1986
" Enter State Superfund Contract March 1986
Start Remedial Construction April 1986
" Complete Remedial Construction July 1986
" Start Delisting Process July 1986
' Delist Site from NPL December 1986
XI. FUTURE ACTIONS
Once a remedial action is selected and sufficient funding
is available, EPA will enter into Interagency Agreements with the
USAGE for design and construction of the selected alternative.
Remedial design should take approximately four months and should
be completed in March, 1986. Construction of the selected
alternative will take approximately three months and should be
completed in July, 1986. When construction of the selected
alternative is completed, the delisting process will be commenced.
Delisting of the site from the NPL is anticipated to occur in
December, 1986.
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-29-
GLOSSARY
BIA - United States Bureau of Indian Affairs
CAM - California Assessment Manual
CDC - United States Centers for Disease Control
CERCLA - Comprehensive Environmental Response Conservation
and Liability Act of 1980 ("The Superfund")
C.F.R. - Code of Federal Regulations
CWA - Clean Hater Act, as amended in 1977
DOI - United states Department of Interior
DOHS - State of California Department of Health Services
DOT - United States Department of Transportation
DWRs - Primary or Secondary Drinking Water Regulations
(or MCLs) of the SDWA
GWPS - EPA Ground Water Protection Strategy
HVBC - Hoopa Valley Business Council
IBS - United States Indian Health Service
IRM - Initial Remedial Measure
MCLs - Maximum Contaminant Levels (or DWRs) of the SDWA
mg/kg - Milligrams per kilogram (or ppm)
* . ' •
NCP - National Oil and Hazardous Substances
Contingency Plan
NPL - National Priorities List
O&M - Operations and maintenance
OSHA - United States Occupational Safety and Health
Administration
ppb - Parts per billion (or ug/L)
ppm - Parts per million (or mg/kg)
RCRA - Resource Conservation and Recovery Act,
as amended in 1984
-------
-30-
ROD - Record of Decision
RWQCB . - State of California Regional Water Quality
Control Board
SDWA - Safe Drinking Water Act, as amended in 1977
TTLC - CAM Total Threshold Limit Concentration
ug/L - Micrograms per liter (or ppb)
USAGE - United States Army Corps of Engineers
WQCAL - EPA One Hour National Ambient Water Quality
Criteria for Protection of Freshwater Aquatic Life,
as promulgated under the CWA
WQCBH - EPA National Ambient Water Quality Criteria for
Protection of Human Health, as promulgated under
the CWA
-------
COMMUNITY RELATIONS
RESPONSIVENESS SUMMARY
CELTOR CHEMICAL WORKS SITE
HOOPA, CALIFORNIA
September 1985
INTRODUCTION
The purpose of this Responsiveness Summary is to document
the following items for the public record: (1) the concerns
and issues raised by private citizens and governmental agen-
cies during the remedial planning process, (2) comments and
questions raised during the public comment period on the
Feasibility Study, and (3) the response of EPA to these com-
ments and concerns.
COMMUNITY RELATIONS ACTIVITIES
The community relations activities that were undertaken to
inform interested parties and solicit their comments
throughout the Remedial Investigation (RI) and Feasibility
Study (FS) are summarized below.
The primary interested party has been the Hoopa Valley Busi-
ness Council/ which represents the Roopa Valley Indian
Tribe. The Council has had ongoing communications with the
involved government agencies since the site was first iden-
tified in 1981. These agencies include the Indian Health
Service (IHS), Humboldt-Del Norte County Health Department,
California Department of Health Services (DOHS), and EPA.
In addition to the. meetings listed below, the Hoopa Valley
Business Council has been in contact with DOHS/ EPA, and
EPA's contractor by telephone and letter.
• April 1, 1982: DOHS notified Hoopa Valley Busi-
ness Council that the Celtor site was a candidate
state Superfund site.
• July 6, 1982: EPA met with Hoopa Valley Business
Council staff to discuss the status of several
hazardous waste disposal sites on the Indian res-
ervation.
• April-September 1982: Numerous meetings were held
among Hoopa Valley Business Council staff, DOHS,
and EPA to discuss applicability of the federal
Superfund to Indian lands.
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-2-
September 1982: DOHS notified Hoopa Valley Busi-
ness Council that the site was being considered
for the federal Superfund list.
November 3, 1982: DOHS and EPA met with the Hoopa
Valley Business Council to propose a joint federal
and state enforcement approach to get a voluntary
responsible party cleanup at the site. IBS and
the North Coast Regional Water Quality Control
Board also attended the meeting. !
April 28, 1983: EPA, DOHS, IBS, and Humbbldt-Del
Norte County;Health Department attended a meeting
with the Hoopa Valley Business Council to discuss
possible site response alternatives.
June 1983: A meeting was held among EPA, DOHS,
and the Hoopa Valley Business Council to discuss
the Initial Remedial Measure (IRM) Feasibility
Study.
June 1983: Interviews were conducted with in-
volved agencies and representatives of the Hoopa
Valley Business Council. The purpose of the in-
terviews was to identify concerns and information
needs for use in designing the Community Relations
Plan.
August 1983: EPA held a public meeting to discuss
the IRM Feasibility Study; issued a press release;
sent a summary of the IRM Feasibility Study and a
meeting notification to the project mailing list;
and established information repositories where the
IRM Feasibility Study Report and future documents
could be reviewed. Approximately 17 people at-
tended the public meeting.
November 1983: EPA issued a press release an-
nouncing approval of the IRM.
December 1983: Tribal representatives reviewed
the completed onsite IRM work.
September 1984: EPA met with Hoopa Valley Busi-
ness Council staff to discuss the proposed RI/FS
workplan and community relations activities. Rep-
resentatives from the Bureau of Indian Affairs (in
Hoopa) and the Humboldt-Del Norte County Health
Department also attended the meeting.
November 1984: EPA sent a fact sheet to the proj-
ect mailing list to present the content and
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-3-
schedule of the RI/FS. The RI/FS work plan was
made available for review at the information re-
positories.
• November 1984: Community relations staff conduct-
ed followup interviews for use in updating the
Community Relations Plan. Boopa Valley Business
Council staff reviewed the draft plan before it
was made final. • ' - :
• May 1985: EPA met with the Hoopa Valley Business
Council chairperson and staff to discuss the Reme-
dial Investigation Report (April 1985) and discuss
preliminary alternatives to be considered in the
Feasibility Study.
• June 1985: EPA sent a fact sheet to the project
mailing list to summarize the findings of the RI,
present the final alternatives included in the FS,
and announce the FS public comment period and pub-
lic meeting. A notice of the FS comment period
and meeting was placed in the Eureka Times and the
Klamath Courier.
• June 28-July 19, 1985: The public comment period
for the Feasibility Study was held. A public
meeting to discuss the FS was held on July 11,
1985.
CONCERNS RAISED PRIOR TO THE FEASIBILITY STUDY COMMENT PERIOD
A number of common issues and concerns were raised prior to
the Feasibility Study comment period by the Hoopa Valley
Business Council, the IBS, and the Humboldt-Del Norte County
Health Department.- These are summarized below, followed by
the EPA response.
1. Health Effects from Direct Human Exposure to Contami-
nants ;Concern was raised about open access to the
site. Children and motor bikers were using the site,
•and some people were using it as a waste dump. In ad-
dition, the access road was commonly used to reach a
fishing spot on the Trinity River.
Response: Direct exposure to contaminated soil in the
road and pasture area was reduced by implementation of
the Initial Remedial Measure (IRM). The main plant
area has been fenced and posted to limit access to re-
maining contaminated soils. Implementation of the re-
medial action will further reduce possible exposure to
contamination.
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-4-
2. Impact on Nearby Areas; Concerns about possible im-
pacts of the site on nearby areas have included:
• Contaminated dust blowing from the site and the
access road onto an adjacent HUD housing develop-
ment known as Norton Field.
Response: See Response No. 7 under Concerns
Raised During the Feasibility Study Comment
Period.
• Impacts on grazing cattle in an adjacent field
from contaminated soil, possible offsite migration
of contaminated surface water, and ingestion of
potentially contaminated grasses.
Response? See Response No. 12 under Concerns
Raised During the Feasibility Study Comment
. Period.
• Use of contaminated soil from the Celtor site as
fill on HUD housing developments.
Response; See Response No. 8 under Concerns
Raised During the Feasibility Study Comment
Period.
3. Impacts on Drinking Water; Concern was expressed that
contaminants from the site might be entering area
groundwater and contaminating local wells.
Response t The Hoopa public water system is upgradient
of the site. No private wells are located downgradi-
ent. Furthermore, based on the findings of the Re-
medial Investigation, local groundwater is not contami-
nated.
4. Impacts on the Trinity River; There was concern that
contaminated surface water runoff or groundwater could
reach the Trinity River. This was of particular con-
cern to the Hoopa Tribe because the river is the
tribe's only fish resource.
Response; The primary groundwater resource in the area
is a gravel aquifer that lies between 20 and 60 feet
below the ground surface of the site. Testing during
the Remedial Investigation showed that the gravel aqui-
fer is free from contamination. Thus, contamination
does not appear to be entering the Trinity River via
groundwater.
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-5-
Results of the Remedial Investigation indicate that
contaminated surface water is leaving the site and en-
tering the Trinity River. However, the dilution factor
is so high—anywhere from a ratio of 500:1 (parts river
water: part gully water) to a ratio of 5,000:1—that
contaminants are diluted below detectable concentra-
tions and appear to have no impact on the river's water
quality. Even in a "worst case" scenario (where river
dilution was at its lowest extreme and a "first flush"
of the gully by a localized storm caused a concentrated
contaminant discharge into the river), river water qua-
lity would be unlikely to exceed EPA 24-hour National
Ambient Water Quality Criteria for Protection of Fresh-
water Aquatic Life.
5. Location of the Site in the Floodplain: Concern was
expressed that the site is located in the floodplain of
'the Trinity River. If flooding occurred during the
rainy season, contaminants could be carried into the
river and downstream areas.
Responset It was determined during the Feasibility
Study that the main plant site area is above the 100-
year floodplain. A minor portion of the site (the pas-
ture and lower gully area) is located within the 100-
year floodplain. The remedial action for the site will
address this concern by reducing all sources of contam-
ination within the 100-year floodplain. For further
discussion of this issue, see the section titled "Sum-
mary of Remedial Alternative Selection: Consistency
with Other Environmental Laws" in the Record of Deci-
sion (September 1985).
6. Onsite versus Offsite Remedial Actions: During the IRM
Feasibility Study, Hoopa Valley Business Council rep-
resentatives indicated a general tribal preference for
offsite disposal rather than encapsulation or disposal
on reservation lands. The Hoopa Valley Business Coun-
cil also stated its preference for offsite disposal as
the permanent remedial action.
Response: Excavation and offsite disposal of contam-
inated soils was implemented as the IRM, and is also
the recommended final remedial action.
7. Additional Sampling and Testing; The Hoopa Valley
Business Council requested in February 1984 that EPA
include specified sampling locations in the post-IRM
site testing. The Council has also requested that test-
ing be performed to identify the white precipitate that
has formed in some locations following the IRM and to
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-6-
determine the composition of odors that are sometimes
present at the site.
Response! In response to the February 1984 request,
additional sampling locations were included in the Re-
medial Investigation.
Testing has been conducted to determine the composition
of the precipitate and of site odors. (See Response
Numbers 5 and 6 under Concerns Raised During the Fea-
sibility Study Comment Period.)
Employment Opportunities for Tribal Members; The Hoopa
Valley Business Council was concerned that employment
opportunities be provided for tribal members where pos-
sible during onsite work. If employment restrictions
exist/ the reasons should be provided.
Response: Because of Superfund program requirements,
only subcontractors who have completed an extensive
health and safety training program can work onsite
where contamination is present. For this reason, jobs
such as drilling cannot be subcontracted to the Tribe.
However, the security work during the onsite Remedial
Investigation work was subcontracted to the Tribe, and
will also be subcontracted to the Tribe during imple-
mentation of the remedial action.
An explanation of employment restrictions because of
health and safety requirements was included in the No-
vember 1984 fact sheet distributed to the project mail-
ing list.
CONCERNS RAISED .DURING THE FEASIBILITY STUDY COMMENT PERIOD
The public comment period on the draft Feasibility Study
Report began June 28, 1985, and ended July 19, 1985. A pub-
lic meeting was held on July 11, 1985, and was attended by
ten persons. Nine individuals or agencies submitted com-
ments or questions at the public meeting or in writing. A
list of those who commented is attached.
The comments and questions are summarized below by subject
and are followed by the response from EPA.
Comments Concerning the Cleanup Criteria
1. Comment/Question; The Hoopa Valley Business Council
submitted the following comments concerning the cleanup
criteria for the site:
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-7-
"The cleanup criteria established for cadmium and arse-
nic soil concentrations are based on information from
the Centers for Disease Control and other Superfund
sites. The effects of long-term, low-level exposure on
humans of such carcinogens have not been sufficiently
determined. To insure adequate protection, cleanup
levels for these substances should be set at background
levels.
"The Feasibility Study Report indicates that adequate
protection of the environment will be achieved in part
by insuring that surface water discharges do not exceed
the Federal Drinking Water Standards. The drainage
leaving the plant area may support amphibians and other
freshwater life if restored to its original condition.
Water Quality Criteria for Aquatic Life should there-
fore be used as a standard when stricter than the
drinking water standard."
Response; The cleanup criterion for in-soil arsenic
(100 ppm) is based on studies conducted by the Centers
for Disease Control evaluating the long-term effects of
arsenic exposure in a residential area, and on the EPA
Primary Drinking Water Regulations. The criterion for
in-soil cadmium (25 ppm) was extrapolated from the EPA
Primary Drinking Water Regulations and was based on
cleanup levels at other Superfund sites. These crite-
ria are conservative, based on an ingestion rate of up
to 10 grams of soil per day for children and up to 0.1
gram per day for adults over a period of 70 years. The
cleanup criteria for all contaminants found at the site
are equivalent to or stricter than the California As-
sessment Manual (CAM) standards, and are consistent
with cleanup levels used at other Superfund sites. EPA
considers cleanup of the Celtor site to these criteria
to be sufficient for the protection of public health
and the environment.
Water flow in the drainage channel leaving the site is
sporadic and probably cannot support fish or other
aquatic life. There are no existing guidelines speci-
fying the allowable metal intake levels for other
animals that may drink the water. Removal of the con-
taminated soil will reduce the source of metals to es-
tablished cleanup levels, and the runoff water quality
will be substantially improved, probably approaching
the pre-mining water quality.
2. Comment/Question; One person asked if the site could
be used for recreational or other activities after
cleanup to the action levels.
-------
-8-
Response; With treatment or removal to the action
levels, the site would be safe for all uses, including
residential. With encapsulation, future uses of the
land would be restricted. For example, it would not be
possible to build structures that require foundation
work or any other subsurface disturbance. However, the
site would be covered with clean soil and regrassed,
and recreational uses would be possible.
Comments Concerning the Remedial Alternatives
3. Comment/Question: Three comments concerned the pre-
ferred remedial action.
A Hoopa resident expressed concern that the treatment
alternative has not been sufficiently tested. The site
area provides the only access to the river and has the
potential for high recreational use. He believes that
people will have doubts about the area's safety if
treated soil is redisposed onsite; this psychological
factor is important to consider.
The Bureau of Indian Affairs, Sacramento Area Office,
submitted a written comment supporting the removal al-
ternative .
The Hoopa Valley Business Council submitted the follow-
ing comments, including a proposed alternative that was
not included in the Feasibility Study Report:
•While the treatment alternative will reduce the threat
to human health and the environment and reduce the vol-
ume of material sent to a Class I landfill, the experi-
mental nature of the process and the presence of resid-
ual contaminants in treated soil make the alternative
less desirable than removal. This process has been
utilized at .only two other sites and Celtor is not con-
sidered an appropriate location for further development
of the method. In addition, as with any such process,
some contaminants and extraction material residues will
remain in the treated soil that would be returned to
the site.
"The removal alternative will involve replacement of
contaminated material with clean soil containing only
background levels of heavy metals and no by-products of
the treatment process. There are no uncertainties in-
volved with the removal alternative such as unforeseen
problems which could occur with the still experimental
treatment method. Compared to treatment, removal would
-------
-9-
minimize the threat to human health and the environ-
ment, take less time to implement and be less costly.
Our preferred alternative is, therefore, removal and
replacement.
"Although not considered in the Feasibility Report, an
alternative that removes the contaminated soil and re-
places it with clean fill could be combined with limited
treatment. Once removed from the Celtor area, contam-
inated soils could be subjected to a limited treatment
to bring heavy metal concentrations below hazardous
levels. All treated soils could then be hauled to a
Class II landfill with hazardous waste or sludge re-
moved to a Class I site as in the treatment alterna-
tive. This approach would address concerns regarding
the experimental nature of the process and residual
soil contaminants as well as reduce the volume of mate-
rial to be sent to a Class I landfill."
Response; Further laboratory and field testing has
been conducted to determine the feasibility and cost of
implementing the treatment alternative at the Celtor
site. Results of the testing showed that treatment
would not be adequately effective at this site. There-
fore, excavation and offsite disposal is the recommend-
ed remedial alternative.
Treatment, which has been shown to be ineffective, com-
bined with removal would be more costly than removal
alone. This combined alternative could therefore not
become the cost-effective remedial action.
4. Comment/Question; The Hoopa Valley Business Council
also submitted the following comment concerning site
cleanup: '
"Since neither the concrete pads nor the soils beneath
the concrete have been tested, concentration of contam-
inants should be determined for each prior to final
action in these areas. Material not meeting the crite-
ria identified above [see Comment No. 1] should be re-
moved with other hazardous soils."
Response; Both the concrete and the underlying soils
.will be tested to ensure that all contaminated material
above the site-specific action levels is removed.
Comments Concerning Site Conditions
5. Comment/Question; One commenter expressed concern
about the formation of a white crystalline substance in
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-10-
the field next to the plant site area. It appears that
this substance appeared only after the soil excavation
performed during the Initial Remedial Measure (IRM).
What is this substance; will it be tested ? Is it pre-
venting vegetation from growing in the field? If not
all the contamination is removed from the site during
the remedial action, won't this substance continue to
form and recontaminate the clean soil?
Response: The white precipitate seen in the field was
not present when onsite sampling was performed during
the Remedial Investigation. At the time of the public
meeting, its composition was unknown. Tests had been
taken of a similar white precipitate that had formed
on the road. This was found to contain high levels of
copper, zinc, cadmium, arsenic, and iron, similar to
the levels found in soil samples from the site.
EPA has since sampled and tested the precipitate in the
field to determine its composition. Test results are
not yet available.
When contaminated soil was excavated and replaced with
clean soil during the IRM, provision was made for the
property owner to reseed the field. However, reseeding
has not yet been done. The absence of grass does not
necessarily mean that the field is incapable of sup-
porting vegetation; it may be because the field has not
been reseeded. Also, the portion of the field that is
denuded is in a low-lying area that is often flooded
during the winter months. This flooding may also be
preventing vegetation from growing.
Further formation of the white precipitate should be
controlled by the cleanup action. If it should occur
after the cleanup action is implemented, EPA will de-
termine if further response is needed.
6. Comment/Question; Two commenters were concerned about
theodors that periodically occur at the site. Al-
though EPA1s air sampling detected nothing, it was con-
ducted when odor was at a very low level. One of the
commenters asked if the odor is toxic.
Response: EPA conducted extensive onsite air sampling
over a 2-day period during conditions when odors are
normally present. Nothing was detected during this
period. Because of resource limitations, it was not
possible to wait at the site until odors returned. If
the odors are coming from contaminants at the site,
they should be significantly reduced after site clean-
up.
-------
-li-
lt is not possible to tell at this time if the odor is
toxic. Normally, sulfur odors are not hazardous unless
they are very strong and exposure is long-term.
Comments Concerning Exposure to Contaminants
7. Comment/Question; One commenter asked if people have
been exposed to contaminated dust raised by traffic
along the road. Are people living near the site still
being exposed to contaminated dust from the site or the
road, or to contamination that has been carried to the
housing areas by drainage from the site? Is this pos-
sible exposure a health threat?
Response; Before the IRM was implemented, it is possi-
ble that people were exposed to contaminated dust
raised by traffic along the road. However, limited
exposure to the levels and types of contaminants found
on the road is not likely to have presented a health
hazard. The placement of gravel on the road during the
IRM has reduced this source of exposure.
Soil sampling and testing has indicated that contami-
nants are not present further up the road. Drainage
patterns carry runoff from the site away from the hous-
ing areas. It is unlikely that contamination originat-
ing on the site migrates into these areas. During im-
plementation of the cleanup alternative, testing will
continue to ensure that all contaminated soils above
the site-specific action levels are identified and re-
moved.
It is unlikely that people living near the site are
currently being exposed to levels of contaminated dust
that would pr'esent a health hazard. Predominant wind
patterns are*to the north, away from the housing area.
In addition, the large number of trees between the site
and the housing area would act as a screen to limit
dust exposure.
8. Comment/Question; One commenter asked if contaminated
soil from the site area was used as fill on some of the
housing developments.
Response! In response to this concern, the Indian
Health Service conducted soil investigations in April
1984 at HUD housing developments, both on the reserva-
tion and in the Hoopa Valley. No contaminated soils
were discovered.
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9. Comment/Question; One commenter asked who is responsi-
ble if people become ill from exposure to contamina-
tion.
Response: Under the Superfund legislation, the federal
government is not liable for health impacts caused by
exposure to hazardous wastes at a Superfund site. .It
is also very difficult to determine if health problems
result from exposure to hazardous materials at a site,
or from other causes or exposures. The purpose of the
Superfund program is to respond to potentially hazard-
ous situations that have been discovered and to prevent
any further possible exposure to hazardous levels.
This is being achieved at the Celtor site by the IRM
and the permanent cleanup action.
EPA has identified a potentially responsible party at
the Celtor site and is conducting negotiations to de-
termine the full extent of this party's liability.
Once the negotiations are concluded, the responsible
party would appear to be the only source of economic
redress for illness caused by exposure to site con-
tamination.
10. Comment/Questioni One commenter asked about possible
health effects to her and her children from picking
berries in contaminated areas over the period of two
summers.
Response; It is unlikely that this amount of exposure,
either from eating berries or from contact with dust,
would result in any long-term health impacts. Any ex-
posure to acid runoff that may have occurred would have
been apparent at the time because it would have burned
the skin upon contact or soon after contact.
11. Comment/Questiont One commenter asked if the road and
the drainage areas leaving the site should be posted to
prevent people from using these areas.
Response; The only area that continues to present a
potential health hazard is the main plant site, which
has been fenced and posted. Dust emissions from the
road have been reduced by the gravel laid down during
the IRM. The pasture area has been covered with ap-
proximately 1-1/2 feet of clean soil. Contaminated
soil in the gully is practically inaccessible because
of the vegetation.
The water leaving the site in the ditches by the pas-
ture and in the gully does contain contamination levels
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above EPA Primary and Secondary Drinking Water Regu-
lations. However, this would be a health threat only
if people were to drink large quantities of water (2
liters per day) over a long period of time. Because
this is very unlikely, EPA does not consider it neces-
sary to post these areas.
12. Comment/Question; One commenter asked if cattle become
contaminated from grazing or drinking in the field;
does this affect their meat and present a human health
threat?
Response; Before the IRM, cattle may have been eating
contaminated grass in the field or drinking contaminat-
ed water. EPA asked the property owner if they could
examine the liver of any cattle that died, since the
liver would show the highest concentrations of contami-
nants. The only specimen they received was a stillborn
calf, whose liver showed no contamination. It is not
possible to tell if any cattle were affected in the
past.
Since the field was excavated during the IRM and new
soil was deposited, no grass has been growing; there-
fore, cattle are no longer grazing in contaminated ar-
eas of the pasture.
Other Comments
13. Comment/Question; One commenter asked if EPA will
attempt to recover funding for the cleanup action from
the responsible party.
Response; EPA has identified a potentially responsible
party at the Celtor site and is conducting negotiations
to determine the financial obligations of this party.
14. Comment/Question; One commenter felt that people had
not been sufficiently informed about hazardous condi-
tions at the site and their possible exposure to con-
tamination. .
Response; EPA has attempted to inform all interested
parties of its activities at the site. This has been
done through public meetings, newspaper ads, fact
sheets, information repositories, and contact with rep-
resentatives from the Hoopa Valley Business Council.
EPA regrets any lack of communication that may have
occurred, and encourages people to contact either the
Hoopa Valley Business Council representative or EPA if
they have any questions about the site or wish to be
added to the mailing list to receive future informa-
tion.
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15. Coament/Question; The Hoopa Valley Business Council
commented that the Tribal Employment Rights Ordinance
(T.E.R.O.) requires utilization of the local Native
American labor force within the Hoopa Square to the
maximum extent possible. The T.E.R.O. officer should
be contacted before finalization of any subcontract
provisions.
Responset See Response Mo. 8 under Concerns Raised
Prior to the Feasibility Study Comment Period.
The T.E.R.O. officer will be contacted to discuss sub-
contracting provisions.
REMAINING CONCERNS
Two concerns remain that will require EPA attention during
implementation of the remedial action:
Identification and control of the white precipi-
tate that has formed in some site areas if it is
determined to be hazardous (see Response No. 5
•under Concerns Raised During the Feasibility Study
Comment Period)
Hiring of local Native American labor force where
possible (see Response No. 8 under Concerns Raised
prior to the Feasibility Study Comment Period)
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LIST OF COMMENTERS
Commented at Public Meeting July 11, 1985
Dale LeMieux, Tribal Environmental Department
George Kalisik, Tribal Environmental Department
Pale Riesling, Community Member
Arden McCovey, Community Member
Deserrie McCovey, Community Member
Dan Jordan, Community Member
Del Robinson, Bureau of Indian Affairs, Hoopa
Submitted Written Comments
Bureau of Indian Affairs, Sacramento Office
Hoopa Valley Business Council
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nfi-*5ft
tl
^
P.O. So* W* • Hoept, C»llfoml» H54t • (918)82*4211
V HOOPA VALLEY TRll
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'£3 JUL22 PI2:'
July 18, 1985
Mick Morgan
Toxics and Waste Management Division
U.S. EPA (T-4-3)
215 Fremont Street
San Francisco, CA 9*1105
Dear Mr. Morgant
This letter is being sent in response to the June 28, 1985
Feasibility Study Report for the Celtor Chemical Works
"Superfund" site. The comments presented below are concerned
primarily with alternative actions,and cleanup objectives.
ALTERNATIVES
As indicated in our July 10, 1985 letter, we agree with the EPA's
decision not to support the encapsulation alternative.
Hydrologic and geologic conditions, restrictions on future land
use, monitoring and maintenance requirements, and the finite,
unproven life of the lining material make this alternative
unacceptable.
As you stated at the recent community meeting in Hoopa, of the
three final alternatives (encapsulation, removal, and treatment)
your agency has chosen treatment as the preferred action. While
the treatment alternative will reduce the threat to human health
and the environment and reduce the volume of material sent to a
Class I landfill the experimental nature of the process and the
presence of residual contaminants in treated soil make the
alternative less desireable than removal. This process has been
utilized at only two other sites and Celtor is not considered an
appropriate location for further development of the method. In
addition, as with any such process, some contaminants and
extraction material residues will remain in the treated soil that
would be returned to the site.
removal alternative will involve replacement of contaminated
material with clean soil containing only backgound levels of
heavy metals and no by-products of the treatment process. There
are no uncertainties Involved with the removal alternative such
as unforseen problems which could occur with the still
experimental treatment method. Compared to treatment, removal
would minimize the threat to human health and the environment,
take less time to implement and be less costly. Our preferred
alternative is, therefore, removal and replacement.
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Page two
Nick Morgan
July 18, 1985
Although not considered in the Feasibility Report, an alternative
that removes the contaminated soil and replaces it with clean
fill could be combined with limited treatment. Once removed from
the Celtor area, contaminated soils could be subjected to a
limited treatment to bring heavy metal concentrations below
hazardous levels. All treated soils could then be hauled to a
Class II landfill with hazardous waste or sludge removed to a
Class I site as in the treatment alternative. This approach
would address concerns regarding the experimental nature of the
process and residual soil contaminants as well as reduce the
volume of material to be sent to a Class I landfill.
CLEANUP CRITERIA
Page seven of the Feasibility Study Report indicates that
adequate protection of the environment will be achieved in part
by insuring that surface water dishoharges do not exceed the
Federal Drinking Water Standards. The drainage leaving the plant
area may support amphibians and other freshwater life if
restored to its original condition. Water Quality Criteria for
Aquatic Life should therefore be used as a standard when stricter
than the drinking water standard.
The cleanup criteria established for cadmium and arsenic soil
concentrations are based on information from the Centers for
Disease Control and other Superfund sites. The effects of long-
term, low-level exposure on humans of such carcinogens has not
been sufficiently determined. To Insure adequate protection,
cleanup levels for these substances should be set at background
levels.
*
OTHER CONCERNS
Since neither the concrete pads nor the soils beneath the
concrete have been tested, concentration of contaminants should
be determined for each prior to final action in these areas.
Material not meeting the criteria identified above should be
removed with other hazardous soils.
Finally, the Tribal Employment Rights Ordinance (T.E.R.O.)
requires utilization of the local Native American labor force
within the Hoopa Square to the maximum extent possible. James
Colegrove, T.E.R.O Officer, should be contacted at 916-625-4211
prior to finalization of any subcontract provisions.
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Page Three
Nick Morgan
July 18, 1985
II hope these comments will be useful. Thank you once again for
your continued cooperation.
• ' - - . .';••' •
Sincerely,
WilfredrK. Colegrove, Chairman
Hoopa Valley Business Council
oc: Del Robinson, BIA
Noel Palmer, I.H.S.
Bill Strickland, Humboldt County Public Health
Don Knapp, BIA
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I TO
land Operations
UNITED STATES
DEPARTMENT OF THE INTERIOR
•URCAU OF INDIAN AFFAIRS
SftcYMtato ATM Offle«
2100 Cott*t« W«y
Stcraanto, CalifonU
of
P1ease sH- sincerely,
oiieotor
JUL23 1985
Mr. Morgan: for the Draft study
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