PB95-964206
                                  EPA/ROD/R06-95/098
                                  June 1996
EPA  Superfund
       Record of Decision:
       National Zinc Corporation,
       Bartlesville, OK
       12/13/1994

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    OKLAHOMA DEPARTMENT OF ENVIRONMENTAL
                              QUALITY
                     RECORD OF DECISION
                FOR OPERABLE UNIT ONE OF
                   THE NATIONAL ZINC SITE
SITE NAME AND LOCATION

National Zinc Site
Bartlesville, Oklahoma
and portions of Washington and Osage Counties, Oklahoma
STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected remedial action for the first operable unit
of the National Zinc Site, in Bartlesville, Oklahoma, developed in accordance with the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as
amended by the  Superfund Amendments and Reauthorization Act (SARA) and, to the
extent practicable, the National Oil and Hazardous Substances Pollution Contingency
Plan. This decision is based on the administrative record for the site.
ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from this site, if not addressed
by implementing the response action selected in this Record of Decision (ROD), may
present an imminent and substantial endangerment to public health, welfare, or the
environment.
DESCRIPTION OF THE REMEDY

This operable unit is the first of two that are planned for the site. The first operable unit
addresses the portions of the Site that are most likely to impact human health.  The
function of this operable unit is to reduce the risks to human health associated with
exposure to the contaminated materials.  While the Operable Unit One remedy does
address the principle threats at the Site, the second operable unit will involve continued
study and possible remediation of the portions of the Site that may pose undue risks to

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environmental receptors. The second operable unit will also address any issues involving
contamination of ground water since it poses a potential ecological threat. Ground water
in the vicinity of the Site is not used for public or private drinking water supply but does
discharge into surface water in certain areas.

The major components of the selected remedy include:

•    removal and disposal of contaminated soils followed by restoration of yards in
      residential areas;

•    implementation of a program to monitor blood lead levels throughout and after the
      remedial  action in the affected community; and

•    removal, tilling, capping, and/or treatment of contaminated soils in commercial and
      industrial areas.
STATUTORY DETERMINATIONS

The selected remedy is protective of human health and the environment, complies with
Federal and State requirements that are legally applicable or relevant and appropriate to
the remedial action, and is cost-effective.  This remedy utilizes permanent solutions and
alternative  treatment technologies  to the maximum extent practicable for this Site.
However, because treatment of the principal threats of the Site was not found to be
practicable, this remedy does not satisfy the statutory preference for treatment as a
principal  element of the remedy.   The initial studies  for treatment of the metals
contaminated soils have not proven conclusive and therefore, removal was selected for
residential areas.  Treatability studies will continue throughout the remedial design and
if proven effective, treatment options will be available for application in commercial and
industrial areas.

Because the remedy will result in hazardous substances remaining onsite above health
based levels, a review will be conducted five years after the commencement of remedial
action to ensure that the remedy continues to provide adequate protection of human
health and  the environment. Data gathered as part of a program to monitor blood lead
levels in the affected community will be considered in the five year review.
                                                              H /is/1 f-
Mark S. Coleman, Executive Director                          Date
Oklahoma Department of Environmental Quality
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 HIGHLIGHTS  OF THE SELECTED REMEDY
This Site is separated into operable units.  This Record of Decision is for
Operable Unit One which deals with human health concerns.
Separate remediation levels are being established (or two different land use
categories.  Category 1 goals apply to residential and recreational lands.
Category 2 goals apply to commercial and industrial lands.

                               Remediation Levels    fmq/Vg)
                               Category 1         Category 2
              Lead                 925             2.000
              Cadmium             100              200
              Arsenic                60              600
Removal of contaminated soils and capping of unpaved alleyways will be the
remedy for Category 1 lands. More detailed soil screening will be conducted
in Category 2 lands. A report summarizing the results of this screening and
identifying the most appropriate remedy for each parcel of land in Category 2
will be prepared and made available for public  comment.    The types of
remedial options that will Ikely be applied to Category 2 are removal, capping,
mixing, institutional controls, and phosphate amendment (if it proves feasible).
More detail of these options shall be provided in the upcoming Remedial
Design.
A Medical Monitoring program will be conducted to allow the opportunity for
blood lead testing annually throughout the Remedial Action. An interim study
will be conducted in the summer of 1995 and comprehensive blood lead
studies win be conducted two years and then at five years after the completion
of the Remedial Action in residential areas.
An Institutional Control Plan will be included in the Remedial Design. This
plan win identify institutional controls that are currently available and those that
need to be developed.  Coordination with the appropriate local governments
will be an essential part of the development of this plan.
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THE DECISION SUMMARY
SUE LOCATION AND DESCRIPTION

This Record of Decision (ROD) addresses the National Zinc Site (the Site) in Bartlesville,
Oklahoma, and portions of Washington and Osage Counties in Oklahoma. The National
Zinc facility was located on the western edge of the City of Bartlesville.  The location of
the former National Zinc facility coincides with the current location of the Zinc Corporation
of America (ZCA) facility (Rgure 1).  The Site consists of those  areas that have
concentrations of lead, cadmium, or arsenic in soil, which exceed the remediation levels
established in this ROD, within approximately a 3-mile radius of the ZCA facility. The
ZCA facility is not a subject of this ROD or of the subsequent remedial action; it is being
addressed under the authority of the Resource  Conservation and Recovery Act of 1976
(RCRA), as amended.  The term Site, as used in this ROD, only includes areas beyond
the boundary of the ZCA facility. The former Somex facility location is not considered part
of the ZCA facility and is, therefore, part of the Site.

The Site covers a large area and is composed of a mixture  of properties used for
residential, commercial, industrial, recreational, and agricultural purposes. There are also
some undeveloped lands which serve as wildlife habitat. The ZCA facility is now bounded
to the west, northwest, and south by industrial and commercial properties. Further to the
west and south land uses are primarily rural and  agricultural.  Residential properties
border the ZCA facility to the north, northeast, east, and southeast.  The central, eastern,
and northern portions of the Site are primarily urban. The main commercial district in the
area is in the center of Bartlesville, approximately 1.5 miles to the east of the ZCA facility.
The population of Bartlesville is approximately  35,000 persons.  The City is essentially
bisected from north to south by the Caney River.  Portions of the Site lie within the flood
plain of the Caney River.
HISTORY AND ENFORCEMENT ACTIVITIES

There has been a long and complex history of metal processing operations at the location
of the present ZCA facility. In approximately 1907, three horizontal retort zinc smelters
commenced operation at this location. Two of the smelters appear to have ceased opera-
tions in the 1920s.  In 1976, the remaining horizontal retort zinc smelter was converted
to an electrolytic zinc refinery, which is not currently operating.  During the time the
horizontal retorts were in operation, metals contained in the airborne emissions from the
smelter were deposited  over much of the area of Bartlesville that lies west of the Caney
River.
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The Site  has been  the  subject of various  prior  studies and  investigations.   These
investigations revealed elevated concentrations of metals in the soil and sediment,
including associated  surface waters, in portions of the area within approximately a three-
mile radius surrounding the ZCA facility. The metals include lead, cadmium, arsenic, and
zinc.  Soil sampling showed that elevated concentrations of these  metals were typically
found in the uppermost few inches of soil.

Historical sources of  metals at the National Zinc site included ore concentrates delivered
to the facility by railcar, dust from the transport and storage of ore concentrates and solid
waste materials at the facility, metals emissions from roasting and smelting processes,
airborne particulates from smelting and sintering processes, and various solid waste
materials (e.g., retort and sinter residues, slag, crushed retorts, and condenser sands).
Current potential sources of metals at the ZCA facility  are being addressed by EPA
pursuant to RCRA under a Consent Order with ZCA, the current owner and operator of
the facility.

In addition to the  metals found in environmental media, available data on the blood
concentrations of metals (especially lead) in humans (especially children) in Bartlesville
were also  evaluated as an indicator  of human  exposure to metals.  Investigations
conducted over the last 20 years have shown increased absorption of lead and to some
extent cadmium.   Although there  has been a decline in blood lead concentrations in
children living in west Bartlesville over this period, the most recent data indicate that the
average blood lead concentration in west Bartlesville children (approximately 5.6  ng/dL)
is above the 3.6 ng/dl average blood lead level observed in children ages one through
five  for the period 1988-1991  according to the third National Health and  Nutrition
Examination Survey (NHANESIII) level (4.2 to 5.2 ng/dL). The average blood lead con-
centration in east Bartlesville children (2.8 iig/dl_) is below the average observed in the
NHANESIII study baseline.

Approximately 13 percent of Bartlesville children living on or near the site had blood lead
levels greater than or equal to 10  (ig/dL, the concentration set by  the  U.S. Centers for
Disease Control, as  the indicator for potentially elevated blood lead levels. A control
group of children, from areas of Bartlesville which are not in the vicinity of the site, had
a 0 percent incidence of blood lead levels exceeding 10 ng/dL.

On May 10, 1993,  the  United States Environmental Protection Agency (EPA) proposed
the  Site  to the National Priorities List  (NPL).   Subsequently,  a memorandum of
understanding (MOU)  was signed between EPA  and the Oklahoma Department of
Environmental Quality (ODEQ) to conduct a national pilot project to complete a Compre-
hensive Environmental Response, Compensation, and Liability Act  (CERCLA) quality in-
vestigation and remediation of  the Site under state authority.  EPA agreed to not make
a final determination  to list the Site on the NPL as  long as the pilot project proceeds in
a timely manner and achieves  CERCLA quality results.

A remedial investigation and feasibility study (RI/FS) was conducted by PTI Environmental
Services (PTI) on  behalf of the potentially  responsible parties  (PRPs),  Cyprus Amax
Minerals Company, Salomon Inc, and the City of Bartlesville.  The RI/FS was conducted

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pursuant to a Consent Agreement and Final Order for Remedial Investigation, Feasibility
Study, and  Remedial Design (Case  No.  EH  94 106) issued by ODEQ.  OOEQ  is
responsible for the oversight of the RI/FS and remedy selection for the Site, under the
State Pilot Project being conducted in conjunction with the EPA.

In addition to the investigations conducted at the Site, removal actions have been and are
currently being conducted to address areas that have elevated concentrations of metals
in soil.  In 1992, EPA evaluated soils at 54  high access areas, and the decision  was
made to take action on soils at 25 of those  locations.  In 1993, soils in 22 residential
yards were evaluated by  EPA and the decision was made to remediate soils  at 10 of
those residences.  The high-access areas include places where children congregate such
as schools, day care and family care centers, and parks. In 1994, Mintech, Inc., acting
on behalf of Cyprus Amax Minerals Company, Salomon Inc, and the City of Bartlesville,
began a second round of  removal action for certain residential yards under a Unilateral
Administrative Order from  EPA. This second  round of removal action consists of remov-
ing  soil  from yards where at least one soil sample contains elevated concentrations of
metals (i.e., greater than 1,500 mg/kg lead or 90 mg/kg cadmium) and replacing it with
clean soil and sod.
COMMUNITY  PARTICIPATION

The involvement of local citizens in this project has been a major goal of both OOEQ and
EPA.  The scope and complexity of this project necessitated more intensive efforts to
involve the community than is typical of most projects.  In 1992, ODEQ established a
steering committee of local representatives which attempted to include all  potentially
affected stakeholders in the community of Bartlesville.  The steering committee serves
as a mechanism to voice local concerns directly to the regulatory agencies throughout the
project.  Public meetings are also held in the evening following steering committee meet-
ings and the general public has  been provided information on the project in smaller
portions and in a more timely manner than is typical of most projects. ODEQ and EPA
have jointly participated in numerous meetings with the public throughout the project.
Much of the information that is included in the remedial investigation and feasibility study
reports was released and discussed with the public several months before the completion
of the final documents.

The Remedial Investigation and Feasibility Study report was released in draft form to the
public for review and comment on July 1,1994. The proposed plan was released to the
public for review and comment on September 1, 1994.  The administrative record and
copies of these two documents are available at two  public  repositories in the City of
Bartlesville, the Bartlesville Public Library and the Bartlesville Chamber of Commerce.
These documents are also available for public review at the  ODEQ central office.  The
potentially responsible parties (PRPs) have also established a public information office
staffed by a local representative to assist citizens in obtaining  information and answering
questions regarding the site.  The notice of availability was published in the Bartlesville
Examiner-Enterprise on September 1, 1994.  A public comment period was  held from
September 1,1994 through October 31,1994. A public meeting, held on Septembers,

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1994, presented the proposed plan to the public and invited comment. Responses to
comments received are included as part of this ROD in the Responsiveness Summary.


SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY

Due to the complexity of the site and the desire to expedite cleanup in residential areas,
the Site has been divided into two operable units.  They are:

Operable Unit One - Residential, Commercial, and Industrial areas;
Operable Unit Two - Ecologically Sensitive areas

This ROD details the remedy selected for Operable Unit One.  Operable Unit Two will be
addressed following the completion of the Ecological Risk Assessment in  1995.  An
evaluation of the use of groundwater in the vicinity of the Site did not identify any active
public or private water wells.  No viable groundwater  resources have been identified
beneath the Site. Therefore, ground water issues will be evaluated and addressed as part
of Operable  Unit Two.   Qroundwater is not used as a water supply and only potentially
impacts environmental receptors when it discharges to surface waters. The response
action for Operable Unit One compliments the ongoing removal action in residential areas
being conducted by the PRPs under the direction of EPA.
SUMMARY OF SITE CHARACTERISTICS

The remedial investigation revealed that soil contamination by lead, cadmium, arsenic,
and zinc is  present, in  elevated concentrations,  over  a relatively  widespread area.
Airborne emissions from historical smelting operations and associated activities appear
to be the predominant mechanism of dispersal of the contaminants across the Site. In
addition, spillage and wind transport of ore  concentrates from rail cars may have also
contributed to elevated metals at the Site. It is also likely that solid waste materials from
the smelters were physically moved to areas within the Site boundaries for uses as fill or
for other purposes. Lead, cadmium, and arsenic may also have other non-smelter related
sources in a typical urban environment.  The concentrations of metals are not uniform
across the Site and some areas within the Site boundaries are not significantly impacted.

Of the environmental media evaluated in the remedial investigation (air, surface water,
sediments, groundwater, and soil), the medium of concern for the protection of human
health is soil. Metals concentrations measured in air have not exceeded regulatory limits.
Groundwater at the Site is not used for drinking  water because aquifers under the Site
yield only small amounts of poor quality water due to natural geologic conditions and
historical oil production activities.  Soil,  surface water, and sediments are considered
media of potential concern for the Ecological Risk Assessment for Operable Unit Two.
Shallow groundwater is also a medium of potential concern for Operable Unit Two be-
cause metals may be transported from the ZCA facility to the surface water south of the
facility.
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                          TABLE 1. REMEDIATION LEVELS
                        FOR PROTECTION OF HUMAN HEALTH
Residential
Arsenic
Cadmium
Lead
60
100
925
Industrial
600
200
2.000
Recreational4
60
100
925
                     Not*: Soil concentration measurements in mg/kg.
                     • For play areas located in residential  neighborhoods, soil
                     recreational remedaSon levels are the same as the residential
                     remediation levels.


Areas and volumes of potential concern were estimated for soil based on preliminary
remediation goals for the three different land use scenarios (Table 2). The purpose of
this estimation was only to develop cost estimates and to allow comparisons among
remedial alternatives. The actual areas to be remediated will be defined during the
remedial design phase based on data available at that time, including the screening data
from the current removal action.
SUMMARY OF SITE RISKS TO HUMAN HEALTH

The primary risk associated with the Site is related to ingestion of and/or direct contact
with contaminated soils. Children from the ages of six months to six years are the most
sensitive to metals contamination in the soil because they tend, through play and other
activities, to ingest soil. The concentrations of lead that have been detected in onsite
soils range from 0 up to 16,000 milligrams per kilogram (mg/kg).  It is anticipated that
exposure to lead in the concentration ranges found  on the National Zinc Site can be
associated with the increased risk of undue lead absorption which may be associated with
developmental problems in the six month to six year  age group. These developmental
problems are not life threatening but may contribute to conditions such as learning dis-
abilities,  attention deficit disorder, and hearing impairment.

Exposures to cadmium present concern because cadmium has a tendency to accumulate
in the body. As  it accumulates, there may be  damage to the kidneys and development
of hypertension.   There are also data which suggest  cadmium may be associated with
development of certain kinds of cancer.  The concentrations of cadmium that have been
detected in onsite soils range from  0 up to 34,000 milligrams per kilogram (mg/kg).

Arsenic is not considered to be a major contaminant at this Site.  Remedial action goals
for arsenic will be set at this Site to insure that if areas with unacceptable concentrations
of arsenic are found they will be addressed. Exceptions may be made for naturally occur-
ring arsenic in subsurface soils that are near the action levels.
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Zinc does not represent a threat to human health at this Site but is of potential concern
for ecologically sensitive areas, particularly for aquatic areas.  High levels of zinc can also
inhibit plant growth, which may have resulted in poor vegetation quality in the area. Zinc
contamination will, therefore, be addressed specifically in Operable Unit Two. At that time
action levels may be set to protect ecological receptors based on the  results of the
ecological risk assessment, which is currently underway.
DESCRIPTION OF ALTERNATIVES

In the Feasibility Study, several methods for remediation of the Site were described and
evaluated. A summary of the remedial action alternatives is presented here. A list of the
alternatives is shown in Table 3. The applicability of the alternatives will vary depending
on land use.  For example, different approaches would be needed to remediate play area
soils in a residential yard compared to bare soil areas within a commercial property. The
Feasibility Study report contains a more detailed description of the alternatives.
Alternative S-1:  No Action

The no-action alternative is required by EPA as a baseline to which all other alternatives
must be compared. No action consists of the baseline conditions at the Site prior to the
implementation of any removal actions that commenced in  1992.  It assumes that no
past, present, or future removal actions or remedial actions have been or will be con-
ducted at the Site.
Alternative S-2:  No Further Action

The no further action  alternative includes all removal actions conducted at the Site
through 1994.  This includes removal actions previously conducted by EPA and their
contractors, and the removal actions currently being conducted by the PRP's removal
contractor.
Alternative S-3:  Institutional Controls

Institutional controls consist of a variety of physical, legal, and administrative measures
that would have the potential for reducing human exposure to soil containing elevated
concentrations of the chemicals of potential concern at the Site. These types of controls
may be applied separately or in combination with other alternatives.

Security fences may be installed around commercial/industrial properties, as appropriate,
to limit access.  For example, a fence may  be installed at an industrial property that is
adjacent to a school.  Zoning and/or deed notices may be implemented for recreational
and commercial/industrial properties, as appropriate, to restrict property use. It might be
necessary to restrict the type of crops which may grown in the area. This wouid prevent

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uptake of metals into the plants and thus into human or animal diet.  In addition, re-
strictions may be implemented for dust control and soil management during construction
activities. These restrictions would likely be implemented through the construction permit
process.  Requirements for continued maintenance of areas addressed by capping may
be necessary.

Public education programs would also help reduce exposures.  Implementing additions
to existing programs such as public meetings, informational brochures, newspaper arti-
cles, radio programs, educational materials for schools, and similar activities would inform
and educate the public regarding practices to be followed to  limit exposure.   These
programs may include, but are not limited to, information on establishing and maintaining
a proper vegetative cover in yards,  protective measures to use when  excavating soil
during activities such as yard work, ways to minimize the tracking of soil into homes, and
overall personal health and hygiene practices to reduce ingestion of potentially contam-
inated soil and dust. Atthogh exposures from lead-based paint are not addressed by the
remedial action objectives for lead, this pathway could be important in homes with peeling
or chalking lead-based paint.  Educational programs could  include ways to test for and
to mitigate this exposure pathway.


Common Components of Active Soil Remediation Alternatives
      (Alternatives S-4, S-5, and S-6)

Components that  are common to the four active remediation alternatives (treatment
[Alternatives S-4 and S-5] or removal [Alternatives S-6a and S-6b]) are discussed here
as a group in order to limit  redundancy in the subsequent discussion of the individual
alternatives. These components include the following.
•     Access agreements for soil sampling and remediation would be requested from af-
      fected residents and/or property owners.
•     During remediation activities, dust from the work area would be controlled through
      the use of a water spray. Air monitoring to insure effectiveness of dust control will
      be conducted during remediation activities.

•     Soil would be removed, where appropriate. For example, if a soil sample on a
      small portion of property exceeds the final remediation levels and other techniques
      are not feasible or would not achieve the desired remediation levels, then removal
      of soil from only that portion of the property may be  conducted.

•     Portions of residential land use areas (such as unpaved driveways and alleyways)
      may be addressed by capping (without prior soil removal or treatment) and/or
      mixing surface soil.

•     Remediation of occupational and recreational land use areas may include, capping
      (without  prior soil  removal or treatment), mixing of surface soil, institutional
      controls, and vegetation enhancement.  For  example, dirt parking lots  may be
      capped with rock or asphalt.
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      Upon completion of remediation activities, the area would be returned to original
      grade.  Trees, shrubs,  and plants that were removed or damaged would be
      replaced with  similar quality plants.  Topsoil would be  placed on the ground
      surface and the affected area would be revegetated.  Fences and other structures
      that were removed or damaged would be restored to preconstruction conditions.

      Institutional controls (e.g., educational programs, fencing, deed restrictions) would
      be continued or implemented as appropriate. Maintenance procedures would also
      be included in  the institutional controls.
Alternative S-4: Ex Situ Mixing and Stabilization

This alternative would provide treatment by mixing phosphate with the soil to reduce the
bioavailability and mobility of lead.  The soil would be excavated to a maximum depth of
two feet and  transported to a staging area.  A phosphate amendment would then be
added and mixed with the soil in a cement mixer or comparable equipment.

T re stability studies are currently underway to quantify the effectiveness of phosphate
treatment of soils in Bartlesville. The phosphate amendments and lead in the soil may
form phosphate minerals that have extremely low solubilities. Geochemical modeling and
laboratory testing have indicated a likelihood that these minerals will not dissolve to an
appreciable degree in acidic pH solutions and, therefore  may be less readily  absorbed
into the body. Mixing (both in situ and ex situ) and stabilization using phosphate amend-
ment would be designed to provide sufficient phosphate in soil to immobilize lead by
forming a stable mineral that would not be bioavailable. As described in the RI/FS, the
formation of insoluble phosphate minerals in soils is reported to be a naturally occurring,
irreversible process, if sufficient phosphate is present.  The concentration of phosphate
currently present in Bartlesville soil is inadequate for complete formation of leaded phos-
phate minerals. The portion of  lead that is adsorbed to the surface of soil particles, and
is believed to be the most bioavailable, may react to form pyromorphite (Pbs(PO4)3CI)
when excess phosphate is added to the soil. The lead present as discrete mineral
phases in Bartlesville soil (described in Section 4.1.5 of the remedial investigation report)
reacts more slowly than the surface adsorbed  lead, but over time will dissolve and alter
in the soil environment to form pyromorphite.  Because of the presumed insolubility of
pyromorphite in the gastrointestinal tract, lead bioavailability may be reduced upon forma-
tion of this naturally occurring phosphate mineral.  However, there are insufficient data
to determine, at this time, the actual effectiveness  of this technique.

Cadmium  and arsenic may also be incorporated in the  pyromorphite crystal structure
during the mineral forming process, decreasing the bioavailability of these elements as
well. However, less is  known about the effects of phosphate on cadmium and arsenic
bioavailability. Therefore, this treatment is only considered relevant for lead in soil.

After mixing, the treated soil would then be transported back to the yard from where it
was removed and placed back  on  the ground. The yard restoration activities would be
conducted and the soil would be monitored after completion of remediation to demon-

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strate that the remedial action objectives and final remediation levels have been met. If
ongoing phosphate treatment studies are successful, the remediation levels and decision
matrix for phosphate-amended soil will be determined by ODEQ following completion of
the phosphate treatability studies in early 1995.
Alternative S-5:  In Situ Mixing and Stabilization

This alternative would also provide treatment by adding phosphate to the soil to reduce
the bioavailability and mobility of lead. Several variations of this alternative exist because
of the different types of phosphate amendments and application methods. The option de-
scribed below is considered representative. However, other variations, such as controlled
spray application of liquid phosphate on the ground surface without disturbing the existing
vegetation, could be viable and may be considered during remedial design.

A fertilizer spreader would be used to evenly spread the dry phosphate amendment on
the ground surface.  A small tractor would be used to pull a rototiller to mix the amend-
ment into the soil to a depth of approximately 6 in. A sufficient number of passes would
be made to homogenize the soil. After mixing is completed, the yard restoration activities
would be conducted.  The soil would be monitored after completion of remediation to
demonstrate that the  remedial action objectives and final remediation levels have been
met. As discussed above, ODEQ will determine the remediation levels for phosphate-
amended soils if completion of the ongoing treatability studies in early 1995 indicate the
treatment would be successful.
Alternative S-6a:  Removal and Offslte Disposal

Soil samples in residential yards would be analyzed to determine whether it exceeds the
remedial action goals and removal would be required. The soil would be excavated to
the predetermined depth. After soil removal, subsurface soil samples would be analyzed
to determine whether the final remediation levels have been met. If the sampling results
indicate that the final remediation levels are exceeded, then additional soil would be re-
moved to a maximum depth of 24 inches. If the sampling results indicate the final reme-
diation levels are still exceeded at the 24-inch depth, a geotextile fabric (designed to pre-
vent mixing of subsoil with the new topsoil) would be placed on the excavated ground
surface prior to backfilling with  clean soil.

The excavated soil would be transported to a staging area and sampled to determine the
leachability, using  EPA's Toxicity Characteristic  Leaching Procedure (TCLP), of the
Chemicals of  Potential Concern in order to determine proper management and final
disposal of the excavated soil. If the soil fails the leaching test, then it would be stabilized
(e.g., lime, fly ash,  or a comparable amendment would be added to it) until it passes the
leaching test.  The  soil would then be disposed of at a nonhazardous waste landfill. The
excavated areas would be  backfilled with clean soil and the yard restoration activities
would be conducted.
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Alternative 6b:  Removal and Onsite Disposal

This alternative would be the same as Alternative 6a except that the soil would be trans-
ported to the  ZCA facility for disposal.  The soil would be disposed of in a manner that
is compatible with activities at the facility, acceptable to  ODEQ, and consistent with
applicable, relevant, and appropriate requirements (ARARs).
ODEQ's Preferred Alternative

OOEQ's preferred alternative is a combination of the alternatives summarized above. The
preferred  alternative includes  elements of Alternatives S-2  (no  further  action), S-3
(institutional controls), S-5 (in situ mixing and stabilization), and S-6 (removal and dispo-
sal).

The ODEQ's preferred alternative for the National Zinc Site (Figure 2) combines aspects
of some of the alternatives presented in the feasibility study. None of the alternatives if
applied individually to the National Zinc Site would be adequate.  ODEQ has, therefore,
proposed  a  remedy for Operable Unit One based on the type  of land use category.
Specific remedies and remediation  levels are set for each category.  Two  land use
categories are to be established. One is for Residential and Recreational lands (Category
1) and the other is for Commercial and Industrial Lands (Category 2). Removal (Alterna-
tive S-6a and/or S-6b) is the primary remedy for Category 1 areas.  In Category 2 areas,
a detailed soil screening program will be used to determine which of a variety of options
would be applied to  each parcel of land.  Different remedial action goals will be set for
each land use category based on differing exposure scenarios.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

The alternatives in the feasibility study were evaluated based on the criteria described in
Table 4.  The following  is a summary of the evaluation.
Overall Protection of Human Health and the Environment

The soil removal alternatives (Alternatives  S-6a and S-6b, and  ODEQ's preferred
alternative) would reduce potential exposure by removing the surface soil that exceeds
remediation levels.   The no further action  alternative (Alternative S-2) would also
somewhat represent a reduced potential exposure since a portion of the surface soil that
exceeds remediation levels has already been  removed.  The addition of phosphate
amendments for the stabilization alternatives (Alternatives S-4 and S-5)  may reduce
bioavailability and mobility within a determined range of lead concentrations.  If successful
results from ongoing treatability studies are obtained in early 1995, the concentration of
lead (and potentially cadmium  and arsenic) that is protective following phosphate amend-
ments will be quantified.  ODEQ's preferred alternative has been modified in this Record
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of Decision to include a blood lead testing program. The blood lead testing program will
be used to evaluate the effectiveness of the Remedial Action in protecting human health.


Compliance with ARARs

Alternatives S-1, S-2,  and  S-3 do not  adequately address the contaminated soils
remaining on the Site.  Unacceptable human health risks would not be addressed by
these alternatives if they were to be applied individually to the entire Site. Concentrations
of chemicals of potential concern would remain onsite under conditions that constitute a
public nuisance under the Oklahoma Environmental Quality Act.

The active soil alternatives are essentially comparable for this criterion. Some additional
air monitoring and/or control measures may be necessary for the alternatives that include
soil removal and handling of soil (Alternatives S-2,  S-4, S-6a, S-6b, and ODEQ's
preferred alternative) in order to verify compliance during implementation of the remedy
with  applicable air quality standards.   For  the alternatives that  include soil removal,
stockpiled soils would require testing and possibly stabilization.  These steps will be
required prior to disposal in order to comply  with state and federal regulations (40 CFR,
Part  261).  These alternatives involve disposal of excavated soils in a landfill which  is
required to  meet applicable state regulations regarding permitting,  construction,  and
operation of a solid waste disposal facility. Additionally, Alternative S-6b would have to
meet  any requirements that would  be imposed under state and federal /regulations
associated with the RCRA Subtitle C program.

The "Other Remedial Technologies" discussed in conjunction with the ODEQ's preferred
alternative can be  implemented on portions of the Site without violating any ARARS.
Mixing of surface soils  in place (without addition of phosphate amendment) has been
conducted at other similar sites  elsewhere  in the country. In order for this particular
approach to be used on a given parcel of land, test plots will be required to verify its
effectiveness prior to full scale implementation. Likewise, capping of contaminated areas
has been utilized on similar sites involving  the same metals as those present on the
National Zinc Site.  As part of OOEQ's preferred alternative, more detailed specifications
and applicability of these "other remedial technologies" will be described in the document
summarizing the screening results of Category 2 lands for individual parcels of land. The
use of capping to address unpaved alleyways or similar areas in Category 1 lands will be
detailed in the Remedial Design.  An institutional control plan will be developed as part
of the Remedial  Design to detail the use of institutional controls on the Site.
Cost

No action (Alternative S-1), by definition, has the lowest costs. The costs ($8.3 million)
for no further action (Alternative S-2) will have already been incurred and are included in
the costs for the other alternatives.  Institutional controls (Alternative S-3) has  the next
lowest cost.  The in situ stabilization alternative (Alternative S-5) has the lowest estimated
costs of the active soil remediation alternatives (Alternatives S-4 through S-6b).  In order

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of lowest to highest cost, the remaining active remediation alternatives are removal and
onsite disposal, ex situ stabilization, and removal and offsite disposal (Alternatives S-6b,
S-4, and S-6a, respectively). The cost for ODEQ's preferred alternative is estimated to
be $32.6 million. The cost for each alternative is outlined in Table 5.
Long-Term Effectiveness and Permanence

This evaluation criterion addresses the results of a remedial action in terms of the risk re-
maining at the Site after the final remediation levels have been met.  Since the chemicals
of potential concern are metals and they cannot be destroyed, permanence of remedial
alternatives must be judged in terms of the elimination of exposure to these compounds
and/or altering their bioavailability.  All of the active soil remediation alternatives (Alter-
natives S-4 through S-6b) are somewhat comparable for this criterion.  However, there
is more certainty with the permanence of the removal alternatives (Alternatives S-6a and
S-6b).  The use of phosphate amendments for remediation of soil is an innovative tech-
nology and, therefore, its long-term effectiveness would need to be determined through
the treatability study and long term monitoring.  Alternatives S-1, S-2, and S-3 would not
adequately address all of the soil that exceeds preliminary remediation goals.  ODEQ's
preferred alternative involves the application of some of the other alternatives (Alterna-
tives S-2, S-3, S-6a, and possibly S-5 and S-6b) to various portions of the Site. Mixing
of soil (without  phosphate amendment) and capping are also  included as options in
ODEQ's preferred alternative. Mixing and capping have been used with success at other
similar sites contaminated with metals.  The ODEQ's preferred alternative will eliminate
exposure to significantly elevated levels of the chemicals of potential concern.  ODEQ's
preferred alternative has been modified in this Record of Decision to include a blood lead
testing program. The blood lead testing program will be used to evaluate the long term
effectiveness of the Remedial Action in protecting human health.
Short-Term Effectiveness

There are some differences in short-term effectiveness among the alternatives with
respect to the potential effects on the community and workers during the construction and
implementation phase until the final remediation levels have been met. No further action
and institutional controls (Alternatives S-2 and S-3, respectively) could be implemented
in less time than the other remedial action alternatives. The in situ stabilization alternative
(Alternative S-5) would take about half as much time to implement as the alternatives that
involve soil excavation (Alternatives S-4, S-6a, and S-6b). However, the formation rates
of the phosphate minerals in soil upon addition of the phosphate amendments are still
being studied.  Therefore, the time required to achieve final remediation levels for the
stabilization  alternatives cannot be fully assessed unless the treatability studies, to be
completed in early 1995, prove successful  enough to predict the time required for
stabilization. The short-term effectiveness of the soil removal and disposal alternatives
(Alternatives S-6a and S-6b) can be evaluated. Those alternatives would be effective in
the short term for removal of the soil with  elevated chemicals of potential  concern.
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However, the overall risk may increase for the short term with the soil transporting activi-
ties (i.e., traffic accidents).
Reduction of Toxicity, Mobility, and Volume Through Treatment

The phosphate amendment alternatives (Alternatives S-4 and S-5), if successful, would
reduce both bioavailability and mobility of lead, and potentially that of cadmium and
arsenic. Alternatives S-6a and S-6b would reduce mobility for any contaminated soils that
would require stabilization in order to meet the criteria of the leaching test (TCLP test).
The  degree to  which Alternatives  S-5, S-6a  and/or S-6b and the  "Other Remedial
Technologies" (mixing and capping) are utilized in OOEQ's preferred alternative will  be
determined in the  Remedial Design phase of the project   Thus, OOEQ's preferred
alternative will meet this criterion to the extent deemed practicable based on the results
of treatability studies and further soil screening.  None of the other alternatives would
result in reduction in toxicity, mobility, or volume.
Implementability

The high clay content of the soil in certain areas and the limited depth of rototillers could
limit the use of phosphate amendment alternatives (Alternatives S-4 and S-5) at some
locations. The other alternatives including OOEQ's preferred alternative (and the "Other
Remedial Technologies") are readily implementable.
Community Acceptance

The acceptance of the preferred alternative and/or other alternatives by the Bartlesville
Community was evaluated through the public participation process and comments receiv-
ed during the formal public comment period. These comments are addressed in this
ROO in the Responsiveness Summary located in Appendix A. In some cases, comment-
ers expressed concerns about specific issues related to the preferred alternative proposed
by ODEQ in the Proposed Plan. Some commenters did propose modifications to OOEQ's
preferred alternative, such as the addition of a blood lead testing program. No comments
indicated a preference for another alternative over OOEQ's preferred alternative.
State/Federal Acceptance

State acceptance is typically the  criteria used in the Superfund process.   However,
because the project is being led by a state agency, federal acceptance will be evaluated
in lieu of state acceptance.  Federal acceptance is based on comments received during
the formal public comment period from EPA or other federal agencies. The comments
received are addressed in the Responsiveness Summary of this ROD.
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THE SELECTED REMEDY

The selected remedy is ODEQ's preferred alternative. ODEQ's preferred alternative is
a combination of several of the other alternatives discussed in the Feasibility Study.  The
preferred alternative includes elements of Alternatives  S-2 (no further action),  S-3
(institutional controls), S-5 (in situ mixing and stabilization), and S-6 (removal and dispo-
sal).
Medical Monitoring

A blood lead monitoring program will be included as part of OOEQ's selected remedy.
Blood lead testing will be provided during soil removal and following completion of the
remedial action. Each summer during the time soil is being removed under the remedial
action, an opportunity for blood lead monitoring will be available to children living on the
westside of Bartlesville.   Under the  direction  of the Washington  County Health
Department, with coordination from the Oklahoma State Department of Health, blood lead
clinics  will be operated, at  no charge, on the westside with walk-in appointments  for
children six months to six years of age. All appropriate medical and environmental follow-
up will  be provided for children with blood lead levels equal to or greater than 10 ng/dl.
In  addition to the voluntary monitoring program, an interim blood-lead study will  be
conducted in the summer of 1995. Two years following the completion of the remedial
action, and again five years after the completion of the remedial action, more comprehen-
sive blood lead testing events  for  children  six months to  six years of age will  be
conducted in Bartlesville.  These studies will be similar to those conducted in November,
1991, and September, 1992, and will be used to help evaluate the effectiveness of the
remedial action. Medical and environmental follow-up activities will also be provided to
any children identified with elevated blood lead levels in these studies.
Composite Sampling

A combination of discreet and composite sampling techniques will be employed at the
Site. Any obvious play areas for children and any visible facility-related waste, in yards
or lots, will be sampled discretely.  Composite sampling will be used to determine if
further discrete sampling of a yard or lot is required, according to a comparison with
results from the area surrounding the yard or lot.  A confirmation sampling plan will be
developed in the remedial design and carried out during the remedial action.
Soil Remediation

The ODEQ's preferred alternative for the National Zinc Site (Figure 2) combines aspects
of some of the alternatives presented in the feasibility study.  None of the alternatives if
applied individually to the National Zinc Site would be adequate. ODEQ has, therefore,
selected a remedy for Operable Unit One of the Site based on the type of land use
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category. Specific remedies and remediation levels are set for each category. Two land
use categories are being established:

      (1) Residential and Recreational Lands
      (2) Commercial and Industrial Lands
Category 1 Residential and Recreational Lands

Alternative S-6 shall be employed for these types of properties (Rgure 3).  Disposal shall
occur in a landfill meeting criteria established by ODEQ and EPA, without regard to the
location of the landfill. In other words it may be either an offsite or onsite landfill. The
landfill shall be required to meet applicable regulatory requirements.  The methods to
implement Alternative S-6 shall be consistent with those being used currently by the
Removal Program in residential areas. Additionally, house dust abatement shall also be
applied to residential homes in the area This includes all homes in the areas dealt with
in both removal and remedial activities.  The house dust abatement shall include vacu-
uming with high efficiency vacuum cleaners and appropriate handling and disposal of
collected house dust as well as replacement of carpet, as necessary. The specific criteria
for determination of the necessity for carpet replacement will be developed in the remedial
design.  House dust abatement is to be instituted after soil remediation is complete in a
given area  Also capping of areas such as unpaved alleyways in residential areas with
asphalt or some  other suitable material shall be required if samples exceed remedial
action goals.  Asphalt or the equivalent shall be the capping material used in the more
highly contaminated areas and those areas that may be frequented by children.  Institu-
tional Controls, Alternative 3, will be necessary to insure continued maintenance and that
activities such as utility repair on the Site will be conducted in a manner protective of the
remediated areas.

The following total concentrations are the remediation levels for soils in areas classified
as Category 1 :

      Lead         925 mg/kg
      Cadmium     100 mg/kg
      Arsenic       60 mg/kg
Category 2 Commercial and Industrial Lands

The Category 2 properties  are  of greater variety than the Category 1 properties,
particularly in terms of the types and degrees of risks posed by contaminated soils.
Therefore one alternative is not appropriate for every area within Category 2.  A variety
of alternatives shall be available to address the differing situations in these areas.  There
will be common elements that will be required for all actions in Category 2 areas.
Alternative 3, Institutional Controls, will be required in order to apply the  remediation
levels for Category 2.  Buffer zones shall be established along the portions of borders
between Category 1 and Category  2 areas to insure adequate protection of residential

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areas. The criteria for establishing buffer zones will be developed in the remedial design.
The following total concentrations are the remediation levels for soils in areas classified
as Category 2:

      Lead       2000 mg/kg
      Cadmium    200 mg/kg
      Arsenic      600 mg/kg

Detailed soil screening, for chemicals of potential concern, of the Category 2 area shall
be conducted. Screening sampling shall be performed according to methods to be devel-
oped during the Remedial Design. These methods are subject to the approval by ODEQ.
During the screening phase for Category 2. the majority of project resources will be
dedicated to the implementation of the Remedial Action in Category 1 areas.  Once the
screening is completed, each area of Category 2  shall be evaluated individually to
determine which available remedial optfon is most appropriate. A document summarizing
the screening results and recommending how the available remedial alternatives will be
applied to each  of the various parcels of land in Category 2 shall be drafted. This docu-
ment  shall be made available for review and comment by the public and EPA prior to
implementation. The key activities for Category 2 lands are shown in Figure 4.

The evaluation of Alternative 5, In Situ Mixing and Stabilization, for Category 2 land use
types shall continue. Studies of the affect on bioavailability of metals by treatment of
contaminated soil  will continue. If, by the completion of the soil  screening effort, ODEQ
is not convinced  that treatment of the contaminated soil can  effectively reduce the
bioavailability of the target metals then this remedial alternative shall not be made avail-
able as one of the options for Category 2 (Rgure 2).
Description of Category 2 Options

    Institutional Controls

An Institutional Control Plan will be developed as part of the Remedial Design.  The
Institutional Control Plan will be developed in coordination with the appropriate  local
governments in the area. This plan will include, at a minimum, the following items.

•     The installation of security fences around commercial or industrial properties, as
      appropriate, to limit access.

•     The development of a system for establishing zoning restrictions for non-residential
      properties that exceed the residential remediation levels.

•     The development of a system to require protective soil management and dust con-
      trol procedures during  construction  activities as well  as  the development of a
      system which addresses continued maintenance of capped areas.
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      The establishment of a public education program to inform and educate the public,
      particularly parents and children, in ways to reduce potential exposure to lead, cad-
      mium, and arsenic.

      An assessment of the feasibility of placing restrictions upon future use of shallow
      groundwater potentially impacted by Site contaminants.
    Amend Soils with Phosphate

This alternative  (S-5) is conditional upon  ODEQ's evaluation  of  the  results of the
treatability tests which will be completed in early 1995.  In vitro tests  have indicated that
if lead in the Bartlesville soil can be converted to pyromorphite (a mineral form of lead
and phosphate), it has the potential to significantly reduce the bioaccessibility (and
therefore the hazard) of the lead. Ongoing bench- and field-scale treatability studies are
being conducted that involve the addition of phosphate amendments to Bartlesville soil
to assess the extent and rate of formation of pyromorphite and the potential reduction in
the bioaccessibility of lead (the effects on cadmium and arsenic are also being evaluated).
Thus, in situ stabilization is conditional upon acceptable results of these treatability
studies.  If ODEQ finds that the treatability study results indicate that the phosphate
amendment alternative is not acceptable, then a soil removal alternative (Alternative S-6)
shall be selected. Rgure 3 shows the decision path for selecting a  remedial action for
site soils.

If the treatability studies demonstrate that lead bioavailabiltty can  be  effectively reduced
within an acceptable time frame as  determined by OOEQ, then this technology (Alter-
native S-5) will be used on soils that meet the following conditions.

•     Cadmium and arsenic concentrations in soil samples do not exceed the remedia-
      tion levels of Category 2.

•     Lead concentrations in soil samples do not exceed the limitations of the phosphate
      amendment.

•     Soil remediation levels of soil samples are not exceeded below the effective depth.
      Treatability studies have shown that phosphate can be effectively mixed to a depth
      of 6 inches with small equipment suitable for residential yards. Similar treatability
      studies shall be conducted to establish  an effective depth for  the types of equip-
      ment suitable for Category 2 lands. If sampling indicates that elevated concentra-
      tions of lead are below the  mixing depth for phosphate amendment, another
      alternative shall be selected by ODEQ.

•     Soils are physically suitable for mixing with the phosphate amendment.  Soils that
      are too dense (too much clay) or too rocky and are  not suitable for phosphate
      amendment will be subject to another available alternative.
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    Remove and Dispose of Soils

Soil removal (Alternative S-6)  may also be instituted for some Category 2 soils not suit-
able for other options.  The removed soils shall be disposed of at one or more offsite
landfills and/or at certain locations within the ZCA facility.  The disposal facility shall be
subject to the same criteria as set for Category 1 soils.
    Other Remediation Technologies

The selection of the above alternatives shall not preclude the use of other remedial tech-
nologies where they are most appropriate. Mixing and/or capping may be deemed appro-
priate by ODEQ as described below.

•     Mixing surface soil (without the addition of phosphate amendment), as appropriate.
      If surface soils (e.g., those from 0-3 in.) only slightly exceed the final remediation
      levels and mixing the soil, for homogenization purposes to a greater depth (e.g.,
      from 0-6 in.) would result in meeting the final remediation levels, then mixing may
      be  conducted,  such as that proposed  by EPA  for the Sunset Place Park
      remediation during the 1992 Removal Action.

•     Portions of commercial  and industrial land use areas may be addressed by
      capping (without prior soil removal or treatment and with appropriate maintenance),
      as  appropriate,  to reduce exposure to soil with elevated concentrations of
      chemicals of potential concern.  Asphalt  or the  equivalent shall be the capping
      material used for parking lots or similar areas in the more highly contaminated
      areas and those areas that may be frequented by children.

Table 6 summarizes the alternatives for Category 1  and Category 2 land uses for the
chemicals of potential concern at various soil concentrations.
Statutory Determinations

    Protection of Human Health and the Environment

The selected remedy for Operable Unit 1 will be effective in eliminating or reducing risks
to public health. The selected remedy will achieve these goals through a combination of
the removal of contaminated soils, the use of engineering controls, the use of institutional
controls, and  where appropriate the treatment of contaminated soils. The remediation
levels that will be used are sufficiently protective of human health and fall within the range
of such standards established at similar sites across the nation.

Any potential  cross-media impacts that might occur as a result of the implementation of
the selected  remedy can  readily be  controlled through  standard monitoring  and
engineering controls.  The  selected remedy  calls for  air monitoring to  be conducted
throughout construction activities  and dust control measures to be instituted when
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necessary.  No unacceptable short-term risks will be caused by the implementation of the
selected remedy.
    Compliance with ARARs

The selected remedy will comply with the ARARs listed in Table 6. The potential location
specific ARARs which were identified by EPA are not expected to apply to the selected
remedy for Operable Unit One. It is anticipated that there will be several location specific
ARARs applicable to Operable Unit Two.
    Cost-Effectiveness

The selected remedy is currently estimated to cost 32.6 million dollars. This estimate is
equal to  the estimate for the alternative, removal and  offsite disposal (S-6a).  The
completion of soil screening activities for Category 2 areas will provide more accurate
information to determine the degree to which the various soil remediation alternatives will
be used.  At that point a more accurate, and possibly lower, cost estimate for the selected
remedy can be incorporated into the Remedial Design.
    Utilization of Permanent Solutions and Alternative Treatment Technologies or
    Resource Recovery Technologies to the Maximum Extent Practicable (MEP)

As stated previously, the Chemicals of Potential Concern are metals and they cannot be
destroyed,  permanence of remedial alternatives  must be  judged in  terms of  the
elimination  of exposure to these compounds and/or the degree of alteration  of their
bioavailability.   Removal  of contaminated soils from residential areas is the  most
permanent solution possible in terms of the elimination of the potential for exposure.  The
selected remedy allows for the use of phosphate amendment, an innovative treatment
technology, if it proves effective in reducing the bioavailability of the chemicals of potential
concern.  Any soils that are destined for offsite disposal will be stabilized if they fail to
meet the criteria associated with the toxicity characteristic leachate procedure (TCLP).
    Preference for Treatment as a Principal Element

At this time there is no known effective treatment technology for the chemicals of potential
concern that would allow treatment to be a principle element of the selected remedy. The
treatment of soils by phosphate amendment is still under consideration but its effective-
ness has not yet been demonstrated.
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DOCUMENTATION OF SIGNIFICANT CHANGES

Three significant changes were made to the  preferred alternative presented in the
Proposed Plan by ODEQ. A medical monitoring program to allow for blood lead testing
during and after the Remedial Action has been incorporated into the selected remedy.
An institutional control plan to be developed during the Remedial Design was also added
to the selected remedy. The remediation level for residential and recreational areas for
arsenic has been changed from 68 mg/kg to 60 mg/kg in the selected remedy.
RESPONSIVENESS SUMMARY

Several changes were made to the preferred alternative presented by OOEQ in the
Proposed Plan, based on the comments received. The three significant changes noted
in the previous section were also made as the result of the agency's response to public
comments. The entire responsiveness summary is quite voluminous and has, therefore,
been included as Appendix A.  Appendix B contains the complete text of the comments
received from the Technical Advisory Team for the Bartlesville Coalition.
WHATS NEXT?

The Remedial Design report will be completed by March 1995. The selected remedial
action alternative will be implemented  once the Remedial Design is completed  and
approved by ODEQ.
FOR MORE INFORMATION

The RI/FS reports or any other documents contained in the updated Administrative
Record file for the National Zinc Site, are available at one of the information repositories
listed below.

      Bartlesville Public Library
      600 S. Johnstons
      Bartlesville, Oklahoma 74005

      Bartlesville Chamber of Commerce
      201 S.W. Keeler
      Bartlesville, Oklahoma 74004

      Westside Community Center
      501 S.W. Bucy
      Bartlesville, Oklahoma 74004

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      Department of Environmental Quality
      Waste Management Division
      1000 NE 10th Street
      Oklahoma City, Oklahoma 73117-1212
If you have any questions about this project, please call:

   Ms. Monty Elder at (405)271-1420 or
   Mr. Scott Thompson at (405)271-7213.
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GLOSSARY
Applicable or Relevant and Appropriate Requirement (ARAR) — The federal and
state laws or regulations that a cleanup must usually attain.  An applicable requirement
is  a promulgated federal or state standard that  specifically addresses a hazardous
constituent, remedial action, location, or other circumstance at a site.  To be applicable,
the remedial actions or the circumstances at the Site must be within the intended scope
and authority of the requirement.  A relevant and appropriate requirement is a promul-
gated federal or state requirement that addresses problems or situations similar to those
encountered at a site, even though the requirement is not legally applicable.

Operable Unit — A distinct portion of a Superfund site or a distinct action at a Superfund
site. An operable unit may be established based on a particular type of contamination,
contaminated  media (e.g., soils,  water), source of contamination, or  some physical
boundary or restraint.

Remedial action alternative — A potential method for cleaning up a site. Remedial ac-
tion alternatives are developed from general response actions (e.g., removal and  dispos-
al), technologies (e.g., chemical treatment), and process options (e.g., stabilization) after
screening.  Possible remedial action alternatives include  no action, institutional controls,
onsite containment with no treatment, and removal and disposal options with or  without
treatment.

Remediation level — The final cleanup level (i.e., specific contaminant concentration in
soil) that is established upon completion of the remedial investigation, feasibility study and
any other necessary additional studies.

Remedy or remedial action — Those actions consistent with the permanent remedy
taken instead of, or in addition to,  removal action in the event of a release of hazardous
substances to the environment so that they do not cause substantial danger to present
or future public health or welfare or the environment.

Removal action — The cleanup or removal of released hazardous substances from the
environment to minimize or mitigate damage to the public health or welfare or to the envi-
ronment.
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TABLES

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            Table 2.  Areas and Volumes of Potential
                         Concern for Soil
                                                  Residential Soil"
 Gross area (ft2)0                                       6.600,000
 (area includes streets and structures)

 Subarea (ft2)"                                         3,300,000
 (area excludes streets and structures)

 1994 removal (ft2)'                                    1,000,000

 Net area (ft2)                                          2.300,000

 Net volume (yd3)'	85.000

• Areas of potential concern for occupational land use could not be estimated
accurately with indicator kriging because of the low number of samples that
exceed PRGs. Field sampling may be conducted during remedial design to
delineate the occupational land  use areas, if any. that exceed PRGs.

" Recreational land use areas with elevated concentrations of CoPCs have
already been remediation during EPA's removal action conducted in 1992.

c The gross area  was estimated by a geostatistteal method Known as
indicator kriging.  This method involves creating a grid of 75x75 ft cells over
the site and counting the cells that have a greater than 30 percent probability
of  exceeding one of the three PRGs.  This was done for each of the  three
land types (residential, recreational, and occupational).

d A factor of 50 percent was used to estimate the  area not occupied by
streets, buildings, or other structures.

• it is assumed that the 1994 removal program will result in removal  of an
area of soil roughly equivalent to this amount.

1 Based on an average depth of 12 in.

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                Table 3.  Summary of Soil Remedial Action Alternatives
S-1    No action*

S-2    No further action"

S-3    institutional controls

S-4    Ex situ mixing with stabilization0, backfill with treated soil, and revegetation*

S-5    In situ mixing with stabilization', addition of topsoil, and revegetatjond

S-6a   Removal, oflsite disposal, backfill with clean soil, and revegetation4

S-6b   Removal, onsite disposal, backfill with clean soil, and revegetation*

* No action consists of the baseline conditions at the Site as it existed prior to the implementation of
any removal actions that commenced in 1992. It assumes that no past present, or future removal
actions or remedial actions have been or will be conducted at the Site.

0 No further action includes all removal actions conducted at the Site through 1994.  No additional
actions would be conducted after 1994.

e Phosphate amendments to reduce lead bioavailabil'rty.

4 Alternatives may include other remedial actions for portions of the Site, as appropriate.  These
remedial actions may include, but are not necessarily limited to, capping (without prior soil removal or
treatment), mixing of surface soil (without the addition of phosphate amendments), institutional controls.
and vegetation enhancement.  For example, unpaved driveways or alleyways may be capped with
asphalt.

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                               Table 4. Evaluation Criteria
Threshold Criteria

     1.   Overall protection of human health and the environment
              How well does the alternative protect human health and the environment, both during
              and after construction?

     2.   Compliance with federal and state environmental standards
              Does the alternative meet all applicable or relevant and appropriate state and federal
              laws?
Balancing Criteria

     3.   Cost
              What are the estimated costs of the alternative?

     4.   Long-term effectiveness and performance
              How well does the alternative protect human health and the environment after
              completion of cleanup?
              What, if any, risks remain at the Site?

     5.   Reduction of toxicrty. mobility, or volume through treatment
              Does the alternative effectively treat the contamination to significantly reduce the
              toxicity, mobility, and volume of the hazardous substance?

     6.   Short-term effectiveness
              Are there potential adverse effects to either human health or the environment during
              construction or implementation of the alternative?
              How fast does the alternative reach the cleanup goals?

     7.   Implementabilrty
              Is the alternative both technically and administratively feasible?
              Has the technology been used successfully on other similar sites?
Modifying Criteria

     8.   State acceptance
              What are the state's comments or concerns about the alternatives considered and
              the preferred alternative?

     9.   Community acceptance
              What are the community's comments or concerns about the preferred alternative?
              Does the community generally support or oppose the preferred alternative?

Note: The Oklahoma Department of  Environmental Quality (DEQ) uses nine criteria to evaluate the
remedial action alternatives. With the  exception of the no action alternative, all alternatives, must meet
the first  two threshold* criteria.  DEQ uses the next five criteria as •balancing" criteria for comparing
alternatives and selecting a preferred alternative. After public comment. DEQ may alter its preference
on the basis of the last two "modifying' criteria.

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                      Table 5.  Cost of Alternatives
Alternatives
S-1 No Action
S-2 No Further Action
S-3 Institutional Controls
S-4 Ex Situ Stabilization
S-5 In Situ Stabilization
S-6a Removal and Offsite Disposal
S-6b Removal and Onsite Disposal
ODEQ's Preferred Alternative
Cost ($ Million)
0
8.3
8.6
28.1
15.7
32.6
26.9
32.6
The cost figures for Alternatives S-3 through S-6b and ODEQ's Preferred Alternative include
the cost of S-2. No Further Action.

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Table 6. Chemical and Action Specific ARARS
          for the National Zinc Site
CHEMICAL SPECIFIC
ARARS
Standard, Requirement, Criteria Citation Application
or Limitation
Federal
Solid Waste Disposal Act &
Resource Conservation and
Recovery ACT (RCRA)
Clean Air Act
National Ambient Air
Quality Standards
40 CFR Part 261
40 CFR Part 50
Applicable. Some of
the soils that will be re-
moved from the Site
could exhibit the char-
acteristic of toxicity.
Any soils that exhibit
this characteristic will
require treatment.
Relevant and Appropri-
ate during construction
activities
State
Oklahoma Hazardous Waste
Management Regulations
Oklahoma Environmental Quality
Act
Oklahoma Air Pollution Control
Regulations
OAC 252:200
27A Oklahoma
Statutes, Supp.
1993
Section 1-1-101
OAC 252:100
Applicable. Same
reason as 40 CFR Part
261.
Applicable. Soil con-
tamination is a public
nuisance.
Applicable if air con-
centrations are above
the maximum allow-
able increase due to
remedial action.

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Table 6. Chemical and Action Specific ARARs
       for the National Zinc Site (cont.)
ACTION SPECIFIC
ARARS
Standard, Requirement, Crite- Citation Application
ria, or Limitation
Federal
Solid Waste Disposal Act
RCRA Subtitle C
Occupational Safety and
Health (OSHA)
Regulations
40 CFR Parts 261
264 & 265
29 CFR 1910
Applicable.
Portions may be rele-
vant and appropriate to
storage and treatment of
waste for off-site ship-
ment.
Applicable. During the
remedial action at the
Site, it is the responsibil-
ity of employers in-
volved in activities on
the Site to conform with
the requirements of
OSHA.
State
Oklahoma Hazardous Waste
Management Regulations
Oklahoma Air Pollution Con-
trol Regulations
Oklahoma Solid Waste Man-
agement Regulations
OAC 252:200
OAC 252:100
OAC 252:5004 510
See criteria for 40 CFR
Parts 261 , 264, and 265
Applicable if sufficient
emissions were generat-
ed as a result of con-
struction activities.
Applicable to any offsite
disposal of nonhazard-
ous waste. Relevant
and appropriate to any
possible onsite disposal
options.

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FIGURES

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Figure 1. Site location.

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NATIONAL ZINC SITE PROPOSED PLAN
DEQ PREFERRED ALTERNATIVE


Category 1 - Residential & Recreational Uses
Removal and Disposal of Contaminated Soils
Capping Alleyways with Asphalt or Similar Material
Housed ust Abatement Measures

Category 2 - Commercial and Industrial Uses
Available Options
Institutional Controls
Mixing Soils
* With Phosphate Amendment, if passes study
* Without Phosphate Amendment
Removal and Disposal of Contaminated Soils
Capping with Suitable Materials
Vegetative Control


Figure 2. DEQ Alternatives

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   NATIONAL ZINC SITE PROPOSED PLAN
 CATEGORY 1 - RESIDENTIAL & RECREATIONAL LANDS
               Screening of Yards
         If Cleanup Goals are Exceeded,
         then Soil Removed and Disposed
Alleyways, Driveways, and Other Areas of Slag
May be Capped in Place with Asphalt or Similar Mate
     After Other Planned Actions Are Complete,
     Housedust Abatement in Homes
          Figure 3.  Category 1 Activities

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 NATIONAL ZINC SITE PROPOSED PLAN
CATEGORY 2 - COMMERCIAL & INDUSTRIAL LANDS
          Screening of Lands
          and Reporting of Results
   DEQ Plan Detailing How Available Options
   would be Implemented in these Areas
        Public Review and Comment
       Revise DEQ Plan and Implement
         Figure 4. Category 2 Activities

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         APPENDIX A.
 ODEQ Responsiveness Summary
to Commments Received regarding
 National Zinc Site Proposed Plan

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                    National Zinc Site Proposed Plan
                       Responsiveness  Summary
1.     A comment was received concerning the work done during the 1994 removal
      action carried out by a contractor for the PRPs under a UAO issued by EPA. The
      comment indicated  pleasure at the quality of work done, the cooperativeness of
      the workers, and willingness of the contractor to work with the property owner to
      achieve a good result.

            The ODEQ appreciates the comment and passed the  information
            along to EPA and the PRPs.  It is the intent of the ODEQ that such
            high  quality  work be  continued  during the remedial action to
            implement the Record of Decision.

2.     A comment was received questioning the status of the old "Somex  Plant" under
      the Proposed Plan.  The commenter is  concerned about the  sewer connection
      from the plant into the city system particularly in light of "contribution to the heavy
      metals problems in  the past" from the Somex facility.  Part of the area is  being
      utilized by the PRP  contractor, during the 1994 removal action, as a staging area
      and the commenter is concerned that equipment stored in the area may have
      "caused some contamination in addition to what might have been there all along.

            The Somex plant has not been exempted from evaluation under the
            Proposed Plan.  The Somex  facility will be considered as part of
            Category 2 (Commercial and Industrial Lands) activities. Relevant
            historical information such as that available from the previous closure
            of the  facility will be considered in the  evaluation.

3.     A comment was received regarding the inability of property  to be remediated
      without permission of the recorded landowner. The commenter is aware that some
      families are caring  for and paying taxes on property that is  in the name of a
      deceased parent. The surviving family members cannot  afford the legal process
      to have the property properly recorded. The commenter asks for a simple solution
      to allow property caretakers to allow remediation if the landowner of record is
      deceased.

            ODEQ concurs that it is desirable to address such properties and will
            seek out  available legal avenues to facilitate their inclusion  in the
            project.

4.     A comment was received regarding the unproven record of the method described
      in the proposed plan as Alternative S-5, spray application of liquid phosphate. The
      comment went on to urge ODEQ  to use caution in considering this alternative.

            ODEQ concurs with this comment.

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5.    Two comments were received asking for the ODEQ to include monitoring of blood
      lead levels in children in the Record of Decision.

            ODEQ agrees with the commenters and monitoring of blood lead
            levels in children is included in the Record of Decision.  The specific
            protocols and procedures will be described in the Remedial Design.
            The general outline for continued blood lead monitoring during the
            Remedial Action  and confirmatory  blood  lead sampling  after
            completion of the Remedial Action is included in the Record of
            Decision.  Under the  direction of the  Washington County Health
            Department,  with  coordination  through  the  Oklahoma  State
            Department of Health, blood lead testing clinics  will be available to
            children 6 months through 6 years of age each summer during the
            Remedial Action.  These clinics will be conducted on the westside of
            Bartlesville within the area of the Remedial Action. In addition to the
            voluntary  monitoring,  an  interim study will  be conducted in the
            summer of 1995.   Two years after completion of the Remedial
            Action, and, if necessary, again 5 years  after completion of the
            Remedial Action, as pan of the required after action  monitoring
            activity, comprehensive blood lead studies including door-to-door
            surveys, as well as blood lead clinics for children 6 months to  6
            years old will be conducted in Bartlesville. Appropriate medical and
            environmental follow-up will be part of all blood lead testing activities.

6.    A comment was  received asking for air monitoring data to be collected for lead,
      cadmium,  and dust during any  soil removal activities  conducted during  the
      remedial action.

            Air monitoring activities are planned for any soil removal activities.
            Air monitoring plans will be detailed for all aspects of the remediation
            in the Remedial Design (RD) document.

7.    A comment was received concerning the transfer of real estate in the area of
      contamination. Specifically is there a mechanism to have property, within the area
      of contamination, tested if it has been previously tested, what is the mechanism
      to have contaminated property remediated in a timely manner to facilitate sale of
      the  property, and how  can a buyer  have assurance that a property has been
      remediated?

            The Remedial Design is the  next step in the  process once the
            Record of Decision is  finalized.  ODEQ will develop procedures in
            the  Remedial Design to try to facilitate the resolution of such issues
            in property transactions.  Until the Remedial Design is finalized it is
            recommended that anyone who is dealing with a specific situation of
            this nature contact ODEQ  staff who are  working  on this project
            directly.  Documentation concerning property that has already been
            remediated can be obtained from ODEQ and/or EPA.  Also as part

Responsiveness Summary/NZC Site                                             Page A-2

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             of the Remedial Design procedures for routinely providing  such
             documentation to property owners will be developed.

8.    A comment was received expressing concern that a property was tested for lead
      and cadmium, the report sent to the property owner stated that the levels of lead
      and cadmium in the soil on the property "were very low1, but the neighboring
      property has levels of lead or cadmium high enough to require soil removal. The
      comment asks if this scenario is possible,  and if the test results can be verified?

             It should be noted that the current Removal Action being conducted
             by EPA is using 1500 mg/kg of lead and 90 mg/kg of cadmium as
             the concentrations which target a lot for removal. In the Remedial
             Action that will be conducted under the direction of OOEQ a lower
             concentration of lead, 925 mg/Kg, and a slightly higher, 100 mg/Kg,
             concentration  of cadmium will be used to target lot for removal.
             Some  lots that have been  "skipped' under the  current Removal
             Action will be cleaned up under the Remedial Action.  Yes, it is
             possible that levels of contamination may vary significantly from one
             residential lot to the next.  Verification of the degree of contamination
             is possible, ODEQ may choose to verify levels of contamination on
             a particular lot as part of the Remedial Action.  This choice will be
             dependant upon  the individual  situation.   The specific decision
             criterial will be developed in the remedial design. ODEQ project staff
             should be contacted directly by anyone with such a concern so that
             the specific situation may be discussed.  One example of a situation
             that would warrant verification as part of the Remedial Action would
             be a case where a landowner brings to  the attention of ODEQ that
             they had placed a few inches of "clean topsoil" over the surface of
             the lot.  The  lot would need  to be evaluated in more  detail to
             determine whether any  of  the  subsurface  soils needed to be
             removed as part of the  Remedial Action.

9.    A commenter asks that OOEQ consider "examine the deaths, the cancer death
      rates on the west side."

             The ATSDR reviewed as a pan of the Public Health Assessment'
             for the site reviewed cancer mortality data on 30 anatomical sites for
             Washington County utilizing data available from the National Center
             for Health Statistics.  Information specific to the city of Bartlesville or
             specifically the west side is not currently available.  Of the 30
             anatomical sites  evaluated,  the number  of  deaths for  multiple
             myeloma and ovarian cancer in  Washington County were greater
      1      Agency for Toxic Substances and Disease Registry.  1994.  Public Health Assessment for
            National Zinc Company, Bartlesville.  Washington  County, Oklahoma, CERCLIS No.
            OKD000829440.  Atlanta, GA.

Responsiveness Summary/NZC Site                                             Page A-3

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            than would be expected as compared to the rates for the State of
            Oklahoma. There is not evidence that lead and cadmium can cause
            those two cancers.  For Washington County, the occurrence of lung
            and kidney cancer was as expected from the rates for the State.
            The ODEQ is not in the position,  due to lack of resources and
            jurisdiction, to conduct a specific cancer mortality and morbidity study
            on the west side of Bartlesville. The ODEQ has made the Oklahoma
            State Department of Health and the ATSDR aware of a request for
            such a study.

10.    A comment was received questioning the possibility that if phosphates are used
      in soil remediation, phosphate material could migrate into streams, creeks, or the
      Caney River.

            Any application  of phosphate, if approved by ODEQ, would be
            required to be done in a manner that did not cause any significant
            contamination of surface waters. If phosphate treatment is approved
            for industrial/commercial properties by ODEQ, the exact mechanism
            and details of the  treatment will be described in  the Remedial
            Design.

11.    A comment concerning alternative S-6A was received that expressed concern that
      the use of the Osage Landfill (currently  used by Bartlesville) could be seriously
      affected if soil, removed during the remedial action, was disposed of at the Osage
      Landfill.

            There are no plans to use the Osage Landfill facility for final disposal
            of the contaminated soils.  That facility is being used during the
            Removal Action being conducted by EPA to store soils prior to their
            transport to another facility.  During the Removal Action, ODEQ set
            requirements on the permanent disposal of contaminated soils which
            included defined,  stringent qualifications for landfills receiving such
            material.  At the present time, the Osage Landfill facility does not
            meet these more stringent criteria.  ODEQ plans to use the same
            criteria for landfills receiving contaminated soil removed during the
            Remedial Action.

12.    A comment was received expressing that the idea of paving driveways and other
      similar areas was excellent.

            The comment is noted.

13.    A comment was received which praised  the ODEQ for its effort working together
      with the PRPs to find a solution which meets the need of cost effective, sensible,
      but effective management of the process.

            The comment is noted.

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14.   A commenter suggests that two  additional possible relevant and  appropriate
      requirements be considered by the ODEQ in developing the Record of Decision.
      These are found in pages 10 through 12 of the Interim Soil Lead Guidance for
      CERCLA Sites and RCRA  Corrective Action Facility, an  EPA  draft guidance
      document dated  May 27th,  1994, as well as the Oklahoma Lead Based Paint
      Reduction and Regulation Act, Title 27A, Section 2-12-110.

            The referenced guidance and the Oklahoma Lead Based Paint
            Regulation act are not applicable to the activities planned to address
            the contaminated soils. ODEQ cannot require that lead based paint
            abatement activities in residential homes  be conducted by the
            potentially responsible parties as part of the Remedial Action.   The
            concerns about lead based paint hazards are noted and ODEQ will
            strive  to  assist the  community  with this issue within our legal
            authority and available resources.

15.   A comment questions the use of composite soil samples as the basis for remedial
      decisions regarding property clean-up. The commenter feels this indicates a bias
      against dealing with hot spots and is therefore, the wrong "way to route" in terms
      of how well we deal with" those situations.

            The concern regarding composite sampling is noted and a general
            explanation of sampling has been added to the language in the ROD
            on page 17.  More detail will be developed in the Remedial Design.
            Compositing would be allowed under specific circumstances. These
            circumstances include the method by which a composite sample
            value might be used to determine if discrete sampling of a lot is
            necessary, individual sampling of play areas, individual sampling of
            visible facility related waste, and a confirmation sampling schedule.
            Complete  sampling  details will  be  determined as part of the
            Remedial  Design.   Given the high degree of concern in  the
            community over composite  sampling, as evidenced by the number
            of comments received by ODEQ relative to this issue, any sampling
            plan developed in the Remedial Design will be presented, in detail,
            to the community at a public meeting as well as  to each group
            commenting on sampling protocol, if requested.

16.   A commenter asks if the PRPs are in agreement or "alignment" with the Proposed
      Plan?

            In general, yes.
Responsiveness Summary/NZC Site                                      .      Page A-5

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17.   A comment was received which asks how remedial activities at the present Zinc
      Corporation of America facility, regulated under RCRA, will be coordinated with
      National Zinc Site remedial action activities, supervised by ODEQ.

            ODEQ recognizes the importance of coordination between the two
            programs, RCRA and Superfund, for the success of the overall
            project. The EPA and ODEQ RCRA program staff and the EPA and
            ODEQ Superfund staff are meeting on a regular basis to discuss this
            issue to insure that the programs efforts are coordinated on these
            two projects.  ODEQ Superfund staff will encourage the ODEQ and
            EPA RCRA program  staff to hold public meetings in Bartlesville to
            explain the RCRA activities at  the Zinc Corporation of America
            facility.

The following comments, 18 through 31, were submitted by Robert C. Williams,
P.E., DEE, Director, Division of Health Assessment and Consultation on behalf of
the Agency for Toxic Substances and Disease Registry.

18.   We suggest  that if the  lead cleanup levels  are to be based on  the  U.S.
      Environmental Protection Agency's (EPA) Integrated Exposure Uptake Biokinetic
      Model for lead in children (IEUBK), the  most current version should be used
      (Version 0.99D). However, ATSOR believes that the IEUBK should not be the sole
      basis for selecting the lead cleanup level at this or any other  site. The IEUBK is
      not validated for all sites and situations and does not take into account all of the
      health aspects needed to be considered when selecting a soil cleanup level.  For
      example: the type and variation of soil cover within the cleanup area, the nutritional
      status of the  population within the cleanup area, and the possible interactions
      between lead and the other site-related contaminants (see the discussion  below)
      may  all  influence  exposure  and need  to be considered and evaluated  before
      selecting an appropriate lead cleanup level.

            Version 0.5 of the U.S. Environmental Protection Agency's Integrated
            Exposure Uptake Biokinetic Model (UBK) was utilized to derive lead
            cleanup levels because this model had been utilized in the baseline
            risk assessment for the site. Additionally,  Version 0.5-predicted
            geographic distributions of elevated blood values have been overlain
            with actual geographic distributions of blood lead values measured
            in the community and found to be reflective of the distributions within
            the community.  Additionally, the 0.5 version of the UBK model has
            been validated in several studies; however, this is not the case with
            the 0.99D version of the model.  Therefore, the ODEQ  believes that
            the 0.5 version is the  most appropriate for use at this Site.

            The ODEQ recognizes the  limitations associated with  the  UBK
            model; however, the ODEQ considers the cleanup level selected for
            use in Bartlesville to  be sufficiently protective to  account for the
            conditions raised by the commenter. Further, there are no accepted

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            quantitative methodologies by which to adjust soil cleanup levels to
            account for the factors identifed by the commenter.

19.    Although the bioavailability  study  conducted by  .PTI  Environmental  Services
      appears to have been conducted appropriately, there are some limitations that
      should be considered before the  study results are used to supersede the default
      values in the IEUBK  model.  The primary limitation of the bioavailability study is
      that the rodent is not the best model for representing bioavailability in a child. The
      pig is thought to be a better animal model for total bioavailability studies. (CP Weis
      and JM Lavelle.  Characteristics to consider when choosing an animal model for the
      study  of lead bioavailability.  Chemical Speciation  and Bioavailability. 1991;3(3-
      4):113-.  In addition,  the regimen of introducing the contaminants with the feed
      may alter bioavailability.  A child may ingest soil or dust on an empty stomach.
      This would result in more lead uptake. The animal model also does not represent
      a child or infant with poor nutrition,  a possible situation at the National Zinc site.
      As discussed above, the nutritional status  of the site population  needs to be
      considered in addition to the IEUBK results. Because of these limitations. ATSOR
      recommends that the results of the rodent bioavailability study not be used in the
      IEUBK version 0.990. The default IEUBK values should be used.

            Any bioavailability study conducted on animal models is limited in its
            ability to  reflect unusual exposure scenarios such as described by
            the commenter. The default bioavailability value in the UBK model
            is 0.3 in comparison to 0.2 utilized by ODEQ in development of the
            remediation level.  This value was in pan based on the results of the
            rodent bioavailability study conducted on behalf of the PRPs as well
            as a review of the available literature which indicated that 0.2  was
            consistent with other bioavailability studies for similiarly contaminated
            soils from other geographic areas. USEPA has indicated that the
         •   issue of bioavailability for soil is a major source  of uncertainty in the
            UBK model and does not itself attempt to come to a clear consensus
            regarding the quantitative definition of unusual exposure conditions.
            It is more valid to utilize critically reviewed data which is site-specific
            than  to  rely  on  default  assumptions which   may  have limited
            relevance to the site.

20.    It is not clear from the available information whether the occupational cleanup level
      was selected so that it is protective of the fetus.  The cleanup  level should be
      selected so that the fetus is protected.  As with the IEUBK model, the Bower's et
      al., occupational soil/dust ingestion model has not been validated for all situations
      and should not  be used as the sole criteria for selecting a cleanup level.
Responsiveness Summary/NZC Site                                               Page A-7

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            As is indicated in the  Technical  Memorandum  *, all possible
            endpoints including protection of the fetus were considered in the
            development of the cleanup level for the occupational scenario. A
            target geometric mean blood lead for the population of 3.49 ug/dL
            based on a default GSD value of 1.9 ug/dL and a mean  adult blood
            lead from the Bartlesville area of 2.6 ug/dL was utilized. The  95th
            percentile estimate for this value is between 6 and 10  ug/dL  An
            adult blood lead level of 10 ug/dL  has been determined  by the
            Maternal and   Child  Health  Division  of  the Oklahoma State
            Department of Health as protective of the fetus.

            Given that ATSDR and USEPA have not developed specific
            methodologies   for determination  of non-residential adult
            screening levels, it was necessary for the ODEQ to identify an
            appropriate method for use at this Site.  Other models for
            adult exposure available in the literature  were reviewed and
            although the Bowers et al. model has not been specifically
            validated for all situations, it is the only model identified which
            described  a direct means  of relating  soil and dust  lead
            concentrations   to  blood lead levels for adults.  It  is  the
            judgement  of   the  ODEQ that  it  represents  the most
            appropriate method for deriving a remediation level for the
            occupational scenario.

21.   The soil slope factor  used to  calculate  the  occupational lead cleanup levels
      appears to be too low (i.e., 0.375  ug/dl per ug/day).  There are numerous soil
      slope factors published  in  the scientific  literature  (please   see Table  2-5,
      Toxicological Profile for Lead. ATSDR, 1992). The most commonly reported slope
      factors range from 0.5 to 15 ug/DI per 1,000 mg Pb/Kg soil/dust. The selection of
      the slope factor should be considered more carefully.

            Biokinetic slope factors have not been directly measured for adults
            exposed to lead in soil/dust.  The slope factor utilized by ODEQ was
            obtaJned from Bowers et al3 who based it on the work of Pococket
            al4 for  drinking water.   The 0.375 ug/dL per ug/day  compares
      2     Oklahoma Department of Environmental Quality.   1994.  Technical Memorandum -
            Preliminary Remediation Goals  for the  National Zinc  Site. Bartlesville, Oklahoma.
            Oklahoma City. OK.

      3     Bowers. T.S., Beck, B.D. and H.S. Karam.  1994. Assessing the Relationship Between
            Environmental Lead Concentrations and Adult Blood Lead Levels. Risk Analysis 14:183-
            189.

            Pocock, S.J..  Shaper. A.G.. Walker. M.. Wale. C.J.. Clayton. 8.. Delves, T.. Lacey, R.F.,
            Packham, R.F.. and P. Powell.  1983.  Effects of Tap Water Lead, Water Hardness,
            Alcohol, and Cigarettes on Blood Lead Concentrations. Jour. Epidem. Comm. Health 37:1-
            7.

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            favorably with the biokinetic slope factor in the USEPA UBK model
            of 0.3 ug/dL per ug/day.  Further in Table 2-5 of the Toxicoloaical
            Profile for Lead5 referenced in the comment, the soil slope factor
            for a mixed population in that table is cited to range from 0.002 to
            0.016 ug/dL per mg Pb/kg. Since the slope factor utilized compares
            favorably  the value  from the USEPA  UBK model and is more
            conservative than the values cited by ATS OR, the ODEQ believes
            that it has selected an appropriate slope factor for use.

22.   Within the risk calculations for  cadmium, absorption factors  were used in the
      ingestion intake calculation and the Hazard Index calculation.  Because the RfD
      developed by EPA is  an internal dose, absorption should only be taken into
      account in the ingestion dose calculation (i.e., 2.5t).  Not in the hazard index.  In
      addition, we question the validity of adjusting the RfD for background exposures.
      ATSDR  recommends that the calculations assume that 100% of an individual's
      exposure to cadmium come from the site.

            Adjusting  the RfD to account for exposures sources other than
            soil/dust represents a more conservative approach for determination
            of a soil remediation level.  Essentially, in this case it allows only
            about 30  percent of a person's daily exposure to cadmium be
            derived from exposures to soil and/or dust. In other words, utilizing
            ATSDR's suggested approach, the resultant remediation goal would
            have been approximately 300 mg/kg which is clearly unacceptable
            to the ODEQ.

23.   ATSDR recommends that the hazard of inhaling contaminated dust be evaluated
      when developing a cleanup level for cadmium.   The inhalation exposure to
      contaminated dust and soil should be greater than that of dermal exposure.

            Based on the results of the baseline risk assessment,  the Rl, and
            ODEQ analysis of the body of data for the  site, the air exposure
            pathway does not appear to be a significant route of exposure and
            was, therefore, eliminated from further consideration in development
            of remediation levels.  Further, any disturbance of materials during
            remediation is required to be conducted in  such a manner as to
            minimize fugitive dust emissions.
                t

24.   Cadmium  is  classified by  EPA as  a Bl carcinogen  by  the inhalation route.
      Therefore, the possible cancer risk associated with inhaling contaminated soil/dust
      should be evaluated.

            The comment is noted; see response to comment 23.
      5      Agency for Toxic Substances and Disease Registry.  1993. lexicological Profile for Lead.
            ATSDR/TP-92/12. Atlanta. GA.

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25.   An age-adjusted ingestion rate was used to calculate the ingestion and inhalation
      doses for cadmium.   This  type of analysis does not permit the evaluation of
      whether short term exposures are a concern.  In order to evaluate short term
      exposures, ATSDR recommends that the cadmium calculation be conducted for
      children specific ingestion rates and body weight. This type of analysis would help
      determine what cleanup level would be protective of public health.

            The comment is noted; however,  the ODEQ does not concur that
            short-term exposures present a concern at this site which would
            warrant a specific remediation level for short-term exposure  to
            children.  The  removal action currently underway should more than
            address the short term exposure issue.

26.   Because inhalation exposure to inorganic arsenic is associated with increased risk
      of lung cancer, ATSDR recommends that the hazard of inhaling contaminated dust
      be evaluated when developing a cleanup level for arsenic.

            The comment  is noted; see response to comment number 23.

27.   The arsenic RfD and  cancer slope factor developed by EPA were developed from
      estimated human exposures to external doses.  Therefore, use of an absorption
      factor to  estimate ingestion,  inhalation, and dermal exposure levels is  not
      recommended.

            The absorption  factor was utilized in the  development of the
            remediation levels for arsenic for an ingestion of soil scenario only.
            No estimates  related to inhalation  and dermal exposure  were
            developed.  The absorption factor reflect the reduced absorption of
            arsenic from soil relative to absorption from water; the factor was
            based on bioavailability data for arsenic in soil6.

28.   In addition to evaluating the cancer risk  associated with arsenic contamination,
      ATSDR recommends that the non-cancer systemic  affects for children also be
      evaluated. Children  specific ingestion rates and weights should  be used in this
      analysis.

            The comment  is noted.

29.   Toxicological  studies indicate that  arsenic,  cadmium,  and  lead  may be
      neurotoxicants.  In addition, lead and cadmium are nephrotoxicants.  Therefore,
      cleanup levels should be selected after considering whether the simultaneous
    6  Freeman, G.B.. S.C. Liao, and N.J. Trigg. 1994. Determination of the bioavilability of soulbluble
      arsenic and arsenic in soil and dust impacted by smelter activities following oral administration in
      Cynomolgus monkeys.  Battelle. Columbus, OH.

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      exposure to all of the site-related contaminants may have an additive toxicological
      affect.

             Consideration was given to the potential additive  effects of the
             contaminants at the site; however, due to the inherently conservative
             nature of the remediation level development process and since there
             are no recognized quantitative methodologies nor sufficient data in
             the literature by which to derive such a relationship, this approach
             was considered to be inappropriate.

30.   There is some evidence that zinc is also a nephrotoxicant.   Given the very high
      zinc contamination levels at this site, ATSDR recommends that the interaction of
      zinc with the other site-related contaminants be considered when selecting cleanup
      levels.   In  addition,  zinc  at high levels  can cause  adverse health affects.
      Therefore, it may be necessary to develop a cleanup level for zinc in  order to
      conduct this type of analysis.

             A remediation level for zinc  will be developed as a part of Operable
             Unit 2.  Zinc appears to be a more significant concern relative to
             environmental effects, e.g. plant growth and aquatic life. Therefore,
             it was determined that it was appropriate to evaluate zinc when the
             data was available by which to address the most sensitive effects,
             e.g. environmental.  Further, elevations in zinc in soil appears in the
             same areas with elevated  levels of lead  and cadmium,  thus as
             remediation  for  lead  and cadmium   takes place  the  higher
             contaminated zinc soils will  also be dealt with.

             With  regards to interaction  with  other site-related contaminants, in
             general increased intake of zinc appears to have a protective effect
             against cadmium  toxicity 7.  Similarly, zinc appears  to  have  a
             protective role in lead intoxication by reversing the enzyme-inhibiting
             effects  of lead *.  Further,  there are not  recognized quantitative
             methods for adjusting toxicity to account for interactions between
             chemicals.   If interactions  with zinc  were  accounted for in the
             remediation levels for cadmium, lead, and,  to some extent arsenic,
             it is likely that the remediation levels would be much higher than
             those developed for use at  the Site.

31.   ATSOR agrees with the Oklahoma Department of Environmental Quality's decision
      that the paired house dust and soil study does not predict the relationship between
    7  Agency for Toxic Substances and Disease Registry.  1992.  Toxicological Profile for Cadmium.
      Atlanta. GA.

    8  Agency for Toxic Substances and Disease Registry.  1993.  Toxicological Profile for Lead.
      ATSDR/TP-92/12. Atlanta. GA.

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      the two study parameters  (i.e., the regression model  used to fit the data only
      accounted for 33.4%, of the total data variation and no controls for housekeeping
      frequency or the presence of children and/or  pets were incorporated into the
      study).                                       ' .

            The comment is noted.

The following comment, number 32, was received from the Honorable Ernest J.
Istook, Jr., Member of Congress, representing the  Fifth Congressional District of
Oklahoma.

32.   I would like to  present my comments on the  ODEQ's  Proposed  Plan, dated
      September 1, 1994, for Remedial Action of the National Zinc Site in  Bartlesville.

      Since protection of public health is the top priority. I would like to know why blood
      lead screening was not included in the Proposed Plan.  I know several rounds of
      tests for elevated levels of blood lead  have  been conducted  in  Bartlesville.
      However, the last round of comprehensive screening was done two years ago.
      Now comes a plan  outlining remedial action for the next 4-5 years and there is
      nothing pertaining to additional blood lead testing or follow-up.

      I am sure you are  familiar with the publication "Preventing Lead Poisoning in
      Young Children"  released in October 1991 by the Center for Disease Control and
      Prevention. Throughout that document, the CDC states the importance of testing
      children for elevated levels  of lead in the blood.

      I refer you to chapters 5 and 6. In Chapter 5, "The Role  of State and Local Public
      Agencies", it states the public health agency should do  the following:

      -Ensure that necessary screening services are provided.

      -Analyze surveillance and other data to identify exposure patterns and high-risk
      population.

      -Develop and implement a primary prevention plan that focuses on the highest risk
      sources and populations.

      -Coordinate prevention  activities  with  other  pertinent health,  housing  and
      environmental agencies.

      In  Chapter 6, entitled "Screening" it states
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      -"Virtually all children should be screened for lead poisoning.  Screening
      children with a high probability of exposure  to high-dose sources is the
      highest priority."

      -"Screening should be done using a blood lead test."

      -"Children at greatest risk for high-dose lead exposure should be screened more
      frequently."

      This chapter also includes  rescreening schedules which vary depending on the
      initial  blood  lead result.   However, the fact remains the CDC  recommends
      subsequent measurements of blood lead in children. This leads me to question
      not only the  absence of follow up testing in the  Proposed Plan, but the lack of
      testing throughout the ongoing Emergency Soil Removal.

      I would like to see continuous blood lead screening for all children ages 6 months
      to 72 months be included as part of the Proposed Plan.  It is important to  know
      what effect past, present, and future cleanup activities are  having on the levels of
      lead in children.  After all, that is why the cleanup is taking place.

      I commend you and the ODEQ for the work you have done to date.  I appreciate
      your continued willingness  to openly and honestly work with the  citizens of
      Bartlesville in this ongoing project.

      Thank you for the opportunity to express my views on this matter.

            ODEQ agrees that blood lead monitoring of children during and after
            the Remedial Action is appropriate. See the response to Question
            5 fora description of blood lead testing activities which are included
            in the Record of Decision.

The  following  comments,  numbers  33  through  67,  were submitted by the
Bartlesville  Coalition.   These  comments were arrived at,  in  part,  through
consultation with a Technical Advisor, Dr. Frederick Oehme, and his team, provided
for through a Technical Assistance Grant.  These comments  summarize the
comments made by Dr. Oehme's group.  Anyone wishing to read the comments
from the Technical Advisor, in their entirety, may refer  to Appendix B.

33.   The Coalition is very concerned that the proposed plan does not include a plan to
      continually perform blood lead  testing of our children  as recommended in the
      Center for Disease Control and Prevention  (CDC)  document1 and the recent
      ATSDR Health Assessment. This plan should not only involve screening of our 6
      months - 6 yr. olds, but following  analysis  of that  blood lead data, a primary
      prevention and education plan should be implemented.  The state is in the  prime
      position to help the Bartlesville  community coordinate lead exposure prevention
      activities with other pertinent health, housing and environmental agencies. We
      think this coordination is imperative to prevent or reduce  lead exposures to our

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      children from all sources of lead. Rather than propose a plan, the Coalition refers
      you to a plan they deem adequate in the publication, "Preventing Lead Poisoning
      in Young Children", Oct. 1991, Center for Disease Control and Prevention; Chapter
      5 and 6, entitled respectively, "The Role of State and Local Public Agencies" and
      "Screening. "

            ODEO concurs with the comment.  Please see response to comment 5 for
            an outline of the blood lead testing program.  Prevention and Education
            plans will be developed more fully in the Remedial Design.

34.    Another area of major concern is  the proposed onsite  disposal.   The onsite
      disposal alternative as  presented in the plan, Alternative 6b, is not acceptable to
      the Coalition.  The Coalition wants an opportunity to comment on this alternative
      should it be seriously considered. I understand under CERCLA no public comment
      is normally allowed for putting a landfill on-site. Since Bartlesville has been a pilot
      project  with various new approaches, we hope you will continue to  consider the
      community's input and acceptance of the ongoing process and  allow us to
      comment on this important issue.

            The only "onsite" option that has been considered by ODEQ is on
            the site of the Zinc Corporation of America (ZCA) facility.  Even
            though the site boundary, as described, does not include the ZCA
            facility, the label "onsite" was used to identify this option as one in
            which disposal would be very near the site and within the area of
            contamination, as well as, within the City of Bartlesville.  Discussion
            of  an onsite disposal alternative is a common  component of any
            feasibility study where  the possibility of removal of contaminated
            material exists.  The actual feasibility of disposing of any materials
            from the Remedial Action on the ZCA facility is questionable and
            complex. Since the ZCA facility is currently regulated under RCRA,
            any disposal would have to be done in compliance with that set of
            state and federal regulations.  Construction of a  disposal cell,  a
            landfill structure, would have to meet the requirements established
            by ODEQ for facilities receiving heavy metal contaminated soil over
            and above the requirements of Subtitle D for landfill structures. Also
            ZCA would have to be willing to cooperate with such an action. Any
            serious consideration of the disposal of materials from the Remedial
            Action on the ZCA facility would be discussed with the public in
            Bartlesville prior to any final decision by ODEQ.

35.    Since this is an innovative project with national implications, the Coalition certainly
      commends the state for considering the phosphate treatment  alternative.  The
      Coalition views this project with guarded optimism.  However, the Coalition wants
      to reinforce that this is an unproven technology.

      The Coalition understands that the ODEQ recognizes  this and  will only  allow its
      use for in treatment after it has been fully demonstrated to reduce bioavailability

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      of the target compound, lead. The Coalition encourages the ODEQ to continue
      to closely evaluate all data surrounding this innovative project. We would hope
      that rather than setting a deadline for the data, which might serve as a disincentive
      to continue this  important work,  the ODEQ would  consider this a feasible
      alternative at any time throughout the remediation process should convincing data
      become available.

            The comment is  noted. If convincing enough data should become
            available at a later point in  the project, ODEQ would consider the
            appropriateness of amending this ROD.

36.   The Bartlesville Coalition requests  that the public be allowed to comment on the
      Record of Decision.  The  Plan  lacked detail in many areas, therefore, it was
      difficult to fully comment.

            The public is welcome to comment directly to ODEQ staff at any
            point during the project. A formal public comment period will not be
            established for the ROD.  The level of detail in  which many of the
            commenters  have  expressed interest will  be provided in the
            Remedial Design. ODEQ will consider establishing a limited public
            comment period for that document. However, the schedule required
            by EPA to complete the Remedial Design  will  necessitate a very
   i         limited time frame for comment.

37.   Pg. 2, top paragraph:  "...,  including associated  surface waters, in certain areas
      surrounding the ZCA facility."

      Please give specifics as to which areas around the ZCA facility.

            This statement was meant to convey that not all properties  within a
            certain  distance  of the  ZCA  facility are contaminated.   The
            contamination is not uniform. The text has been modified to reflect
            that "portions of the  area within a three-mile radius surrounding the
            ZCA facility".  Greater detail  of the extent of contamination  is
            contained in the Remedial Investigation report.

38.   Pg. 2, middle  second paragraph: "The most recent data indicate that the average
      blood lead concentration in west Bartlesville children (approximately 5. 6 ug/dL) is
      slightly above the range... "

      As presented, it is difficult to compare Bartlesville blood lead data to  the EPA
      predicted  national baseline.   The plan should compare ranges to ranges or
      averages to averages.

            The ODEQ agrees with the comment.  Recent data  from the Third
            National Health  and Nutrition  Examination Survey  (NHANES III)
            indicates the average blood lead level in the  U.S. varies with age,

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            race, income level, and geographic location.  The text in the Record
            of Decision will be changed to reflect the average blood lead level for
            children ages  1 through 5 in  the U.S. for the years 1988 through
            1991 as observed in the NHANES III study, 3,9 ug/dL.
39.   Remedial Action Objectives and Preliminary Remediation Goals:

      "Metals concentrations measured in air have not exceeded regulatory limits.

      Please be more specific and state which metals you  are referring to, what the
      average  levels measured in the air were, and what regulatory limits they were
      being compared to per unit time.

      How many measurements per metal were taken? What was the amount of time
      these measurements were usually taken over, i.e., 3 hrs., 8 hrs.,? The Coalition's
      concern is that the air monitoring during the early evaluation phase was insufficient
      to suitably evaluate this route of exposure.  During remediation  the reduction of
      airborne lead should be quantified.

            The air data is discussed in detail on pages 69 and 70  of the Rl
            document * as well as in the Human  Health Risk Assessment
            prepared  for USEPA by  CH2MHHI  ".   Air sampling has been
            conducted for  TSP, arsenic, lead,  cadmium,  and  zinc.   No
            concentrations exceeding the National Ambient Air Quality Standards
            or state air quality standards have been noted. Most of the samples
            have been found to have metals concentrations below the analytical
            detection limit.

40.   Top of Pg. 3, first sentence:  "concern for Operable Unit 2 because metals may be
      transported from the ZCA facility to the surface water south of the facility.

      The use of the word may indicates it is unknown whether metals were or were not
      transported from the facility. The top, left hand column of pg. 2 indicates there
      was metal contamination, "including associated surface waters.  " Please make this
      more clear.

            This statement refers to the possible contamination of the stream
            south of the ZCA facility by contaminated groundwater discharging
            to  the surface water.   It is obvious that the  stream receives
    9  PTI Environmental Services.  1994. Remedial Investigation Report, National Zinc Site, Volume 1.
      Bellevue. WA.

    10 CH2MHHI.  1994.  Human Health Risk Assessment, National Zinc Site.  CH2MHHI Project No.
      TEX68008, Denver. CO.

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            discharges of shallow groundwater. It is not know at this time if that
            shallow groundwater is contaminated significantly with metals. This
            issue is to be resolved as part of Operable Unit 2 and/or the RCRA
            actions on the ZCA facility.
41.   Pg. 3, Left Column: "The remedial action objectives derived for soil are intended
      to: prevent ingestion ... : "

      RAOs do not prevent ingestion.  RAOs allegedly prevent adverse health effects
      when ingestion of metal-containing soils occurs.

      "The resultant blood lead levels are [not] to exceed a greater than 5 percent
      probability... "

            The comment is noted; the language in the ROD has been modified
            to reflect the commenter concerns.

42.   Pg. 3, Left Column:  "Remedial decisions... will be based on whether the chemical
      analysis of composite  soil samples	

      Please explain why the plan switched to composite samples.

            See response to comment number 15.

43.   Pg. 4, left column, 2nd paragraph: Tfte primary risk associated with the site is
      related to ingestion of and/or direct contact... "

      Since metals are not absorbed through the skin, how does direct contact present
      a risk? If dermal contact was not what was meant, be more specific.

            Several sources, including the Toxicological Profile for Cadmium "
            prepared by the Agency for Toxic Substances and Disease Registry,
            indicate that small amounts of cadmium can be absorbed through
            the skin.   Therefore,  direct  contact  was  used correctly in the
            sentence and did refer to dermal contact, specifically of cadmium, of
            contaminated soils.  On page 9 of the Technical Memorandum '*
            prepared by the ODEQ, dated September 1,1994, the equation used
            to calculate dermal intake of cadmium, as well as the equation for
            calculating the  Hazard Index including dermal intake, is explained.
    " Agency for Toxic Substances and Disease Registry. 1992.  Toxicological Profile for Cadmium.
      Atlanta. GA.

    12 Oklahoma Department of Environmental Quality.  1994. Technical Memorandum • Preliminary
      Remediation Goals for the National Zinc Site. Bartlesville, OK. Oklahoma City. OK.

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44.   Pg. 4, left column, 2nd paragraph: "Exposure to lead in the concentration ranges
      found on the National Zinc site can be associated with developmental problems in
      this age group.  "

      Please provide data or a reference that makes this link.  The EPA's UBK model
      which "predicts" blood leads from soil lead levels has  repeatedly been shown to
      be flawed for areas with inactive smelters.  There is not data to support certain soil
      lead levels result in a statistically  significant group of children with developmental
      problems.  This sentence makes a  leap  of faith and either needs to  be more
      explicit or references provided.  The question  is not that blood lead levels of a
      given level cause the indicated endpoint, but that a study exists that takes soil lead
      levels to  measured blood lead levels to showing a statistically significant health
      effect, i.e. "developmental problems."

            ODEQ agrees that the sentence is misleading.   The text in the
            Record of Decision has been modified to reflect that exposure to
            lead in the concentration ranges found at the National Zinc Site has
            been associated with an increased risk of elevated blood lead levels
            which may result in developmental problems.   References for .a
            connection between elevated levels of lead in soil, particularly levels
            above  1,000 mg/Kg, and elevated blood lead levels in children is
            extensive.     Evidence  was presented by  Pees "  than  an
            association between elevated soil lead levels and elevated blood
            lead levels in children specifically living in BartlesviHe existed.

45.   Pg 4, bottom, right hand column: Alternative S-3: Institutional Controls

      "First paragraph: "Institutional controls would consist of.

      The Coalition is concerned  about the extensive use of "may" in this paragraph.
      We understand at this point decisions are being made, but the community as
      represented by the Coalition can not comment on things that may or may NOT
      happen.    Doesn't   it  seem  prudent  to   have  zoning   restrictions  on
      commercial/industrial properties? Not enough information has been provided.

            As part of the Remedial Design an  Institutional Control Plan will be
            developed to detail the institutional control options available.  The
            development and implementation of institutional controls will require
            the input and involvement of all the local governments that have
            jurisdiction over the site or portions of the site.  This will be a long
            process.   If ODEQ  and/or EPA are not satisfied that  adequate
            institutional controls will be instituted in a given commercial and/or
   13 Pees, N.A.  1985. Community Health Aspects of Environmental Contamination with Lead and
      Cadmium from a Primary Zinc Smelter. Doctoral Dissertation. University of Oklahoma. Oklahoma
      City, OK.

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            industrial area, then the use of non-residential remedial action goals
            will not be allowed in that area.

46.   Pg. 4, bottom, right hand column:  "In addition, restrictions may be implemented
      for dust control and soil management during construction activities.  "

      Not enough information is provided. If soil lead levels are below a given value this
      may be acceptable, if above a certain level this may NOT be acceptable.  Not
      enough information has been provided for the coalition to effectively comment.

            The criteria for  implementation of dust control measures during
            construction activities will be the equivalent of those being used in
            the removal action that is being  overseen by EPA.

47.   Pg.4, bottom, right hand column:  "Requirements for continued maintenance of
      areas addressed by capping may be necessary.  "

      Not enough information is provided for us to comment.

            Detail regarding  any capping that may be proposed in Category 2
            areas will be provided either in the Remedial Design  or in the report
            regarding the results of more detailed soil screening of Category 2
            areas.   If any contamination above  remedial action  goals is left
            onsite, there will be requirements to properly maintain  any caps, or
            other remedies, that were instituted as part of the Remedial Action.

48.   Pg. 5, left column: "Public education programs.... to limit exposure.

      These public education programs need to be  in three tiers; Tier 1,  general
      information for the general public as described in the plan.   However,  this
      approach does not appear to be very effective if attendance at public meetings can
      be used as an indicator of interest. Tier II needs to  be directed, and focused at
      children with blood lead levels equal to  or greater than 10 ug/dL  Tier III needs to
      be directed at children with blood leads between 5-10 ug/dL.

      This public education  program has to be  dovetailed  into  a  child  blood lead
      monitoring program.   If  this  is  not done the  program will fail because the
      community will see no reason to pay attention to it.

      The additional programs that are listed in that same  paragraph;

      "These programs may include ...to reduce ingestion of potentially contaminated
      soil and dust.  "

      [sic] are to be commended, but must be focused at the most effected population.
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            ODEQ agrees with the comment.  ODEQ has been engaged in an
            effort  similar  to that described as Tier I since the fall of  1991.
            Among the more visible components of this effort are not only the
            over 30 public meetings in Bartlesville, but also local media coverage
            of exposure prevention techniques, educational materials provided
            to all  licensed day cares  and home care providers, letters  to all
            parents of children in licensed day care, development of educational
            brochures which were distributed to every  home  in the targeted
            areas  for biomedical monitoring phases I and II, as well as outreach
            through  the OSDH to the local medical community.  The  effort
            described in  the  comment as  Tier  II,  has  been an ongoing
            component of the  efforts of both the OSDH and the ODEQ.  The   .
            parents of all children with blood lead levels over 10 ug/dL have
            been personally contacted and given educational material concerning
            effective  ways  to  prevent or lessen  exposure to lead in the
            environment  In addition, all residences of children with blood lead
            levels  over 10 ug/dL have been investigated to determine all
            environmental sources of lead.  Following this investigation, parents
            were informed about potential sources of lead found in  the home
            environment and provided with educational materials, as well as
            advice, specific to those hazards.  These efforts will continue for any
            children, living within the area of contamination, identified with blood
            lead levels over 10 ug/dL either during the Remedial Action or during
            the  period of After Action Monitoring described in the Record of
            Decision.   Details of additional, specific educational  programs
            directed toward the affected community will be provided in the
            Remedial Design.

49.   The community would welcome "ways to test for and to mitigate" exposure to lead-
      based paint.

            The comment is noted.  See response to comment number 14.

50.   Pg. 5, top, right column: "Monitoring to insure effectiveness of dust control will be
      conducted during remedation activities.  "

      In  conversations with one of the crews involved in the present  removal, it was
      stated air monitoring was when the trucks were being loaded.  Please state how
      long.on  average,  and what metals will  be monitored.   There is  not enough
      information provided to assure the Coalition  that effective  dust control will be
      achieved or maintained.

            A specific health and safety plan will be provided in  the Remedial
            Design.  That plan will require continuous monitoring at sites during
            contaminated soil  removal.  For  the  Removal Action,  this has
            included both real time monitoring for particulates and collection
            followed by analysis for lead and cadmium.   When ODEQ staff

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            observed the Removal Action, monitoring devices were operating
            and in place during  the actual dirt removal.  Enforcement of the
            health and safety plan during the Removal Action is the responsibility
            of EPA. ODEQ will strictly enforce the health and safety plan for the
            Remedial Action. The  criteria for implementation of dust control
            measures during construction activities will be the equivalent of those
            being used in the removal action that is being overseen by EPA and
            will be detailed in the Remedial Design.

51.    Alternative S-4: Ex Situ mixing and stabilization:

      The depth for soil removal is not discussed.  Please provide.  For the S-4 and S-5
      options there was no mention of the 2 inch cap of clean soil as was discussed in
      the RI/FS.  Please explain.

            The text of the Record of Decision has been modified to reflect soil
            excavation  to a maximum depth  of two feet  If this alternative is
            selected for use in industrial/commercial areas, details for excavation
            depths for specific lots would be included in engineering designs.  In
            reviewing  the  Feasibility  Study,  4.1.5,   "Ex Situ  Mixing  and
            Stabilization," ODEQ could not find a reference to a 2 inch cap of
            clean soil.  Any disturbed area wouldhave to be resodded.

52.    Pg 6, lower left column, and top right paragraph: "If ongoing phosphate treatment
      studies are successful... phosphate-amended soil will be determined by ODEQ
      following completion of the phosphate treatability studies in early 1995 ".

      The Coalition requests that the community be provided this information and be
      allowed to comment on this data.

            ODEQ agrees with the  comment.  Treatability study results will be
            provided to citizens for comment as an amendment to the ROD.

53.    Alternative S-5: In situ Mixing and Stabilization

      The Coalition requests that they be allowed to comment further if this alterative is
      selected.  Please  see technical advisors comments in Appendix B.

            ODEQ agrees with the.comment.  If the remedy is selected, citizens
            will  be provided with  feasibility results,  along with engineering
            designs, and will be asked for comment at that time.

54.    Alternative S-6a: Removal and Offsite Disposal

      The Coalition supports offsite disposal as presently performed.

            The comment is noted.

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55.   Alternative S-6b: Removal and Onsite Disposal

      Onsite disposal as presently described is NOT supported by the Coalition. Overall
      Protection of Human Health and the Environment.

            The comment is noted; see also response to comment numbers 11
            and 34.

56.   Cost.  Figure 4 should be changed to  Rgure 3.

            The comment is noted.  The ROD was modified so  that text and
            tables agree.

57.   Short  term effectiveness:

      It is difficult to accept that soil remediation Alternatives S-6a and S-6b have short
      term effectiveness.  Soil removal  has been in progress for two construction
      seasons remediation has been repeatedly projected to take 6 more years.  Soil
      removal is a slow process and there is no reduction in toxicity, merely relocation.

            ODEQ agrees that soil removal will take a relatively longer time to
            implement than some of the other alternatives.  When evaluation
            criteria for all alternatives are  compared, Figure 3,  p. 22 of the
            proposed plan, soil removal scores lower than some alternatives and
            higher than some alternatives on short term effectiveness.  When
            other criteria, such as long term effectiveness, are evaluated, soil
            removal has the highest  score.  Only  alternatives meeting  the
            threshold criteria, protectiveness and compliance with ARARs, can
            be considered as a possible remedy at a site.   If more than one
            alternative meets the  threshold criteria, then remedy selection is
            based on the overall performance of the alternatives compared to all
            balancing criteria.  Soil removal is the alternative with the greatest
            degree of certainty. Elimination of the potential for exposure is the
            key when dealing with metals. The phosphate treatment alternatives
            have not yet proven capable of reducing toxicity.  ODEQ's preferred
            alternative for   the  industrial/commercial  areas  includes   the
            opportunity to utilize all of the alternatives that prove  feasible and
            should be able  to be implemented in a shorter time  frame than if
            either Alternatives 6a or 6b were applied to the entire site.

58.   Pg. 8  Hand column: "ODEQ's Preferred Alternative

      ODEQ's flexibility is to be commended. The Coalition appreciates the diversity of
      this site and  realizes that flexibility will be required to do the best job, in the
      shortest amount of time, so that disruption of the community is kept to a minimum.
      Documentation for the  rational of the selected alternatives should be provided.
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      Since very little definition is provided in this plan,  the Coalition requests the
      opportunity to comment on the Record of Decision.

            See response to comment number 36.

      "Two land use categories are proposed.

      The Coalition wants to add emphasis to the word "use".  Zoning anomalies have
      been noted in west Bartlesville.  Therefore, we want to emphasize that the clean
      up should be based on present land use and not zoning.

            ODEQ concurs with  the  comment.   See response  to comment
            number 45.

59.   Pg. 9,  Left Hand  Column:  "Additionally ODEQ is proposing that house  dust
      abatement also be applied to  residential homes .... after  soil  remediation is
      complete in a given area. "

      The Coalition believes after two full construction years  of removal that this process
      could begin immediately. Especially, since removal supposedly addressed areas
      of highest concern. More details of what constitutes  "a given area" are needed.
      Is this intended for ail homes in the area? Intended for only homes "remediated"
      and not homes where "removal" took place? Will other institutional programs such
      as educational efforts on personal hygiene be provided?

            ODEQ will alter the text to clarify that homes in areas addressed
            under  removal  and remedial activities  will be  included.   Some
            residential lots that have been skipped in the removal activities will
            be  addressed in remedial activities.   The determination of the
            appropriate size of a "given area" will be made in the Remedial
            Design. Care should  be taken not to initiate house dust abatement
            until all construction activities are completed in a given area.  ODEQ
            intends to continue with public education activities.

60.   Pg. 9, Left Hand Column: "..such as utility repair on the site would be conducted
      in a manner protective of the remediated areas (Figure 5)."

      Please explain.

            An example:    Assume the  remedial action  is  complete in the
            residential areas and a utility company excavates contaminated soil
            (that was left in place because it was greater than two feet deep or
            it was in an  unpaved alleyway and capped with  asphalt). If there are
            no  institutional  controls, such as city ordinances,  to regulate the
            handling of the excavated material then the contaminated soil might
            be  left exposed on the surface and contaminate a  "clean" area.
            Some standard operating procedures must be developed to insure

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            that the remedy is not adversely  affected by  routine activities
            conducted on the site in the future.

61.    Category 2 Commercial and Industrial Lands: "Institutional controls will be needed
      to assure that Category 2 areas ... are not used for residential purposes in the
      future. "

      This comment needs more detail to assure the community appropriate actions are
      taken.   We  need  some  assurance that  the institutional  controls  can be
      implemented in a fair and consistent manner and that they will be maintained.

            ODEQ concurs  with this comment.  See response to comment
            number 45.

62.    The Coalition would like an explanation of why the  rank order of the RAOs for
      different land uses for chemicals of potential concern are different.

     Residential/Recreational Lands:        Commercial/Industrial Lands:

      Lead                                      Lead
      Cadmium                                 Arsenic
      Arsenic                            '       Cadmium

            No ranking was intended.  The contaminants were  merely listed
            incidentally in a different order.  The text of the Record of Decision
            will be modified to list the contaminants in the same order for both
            types of land use.

63.    Pg. 9, Right Hand Column:   'During the screening phase  for Category 2, the
      majority of project resources would be dedicated to.... Category 1 areas.  "

      This statement appears to say not many resources will be used to define Category
      2 lands.   Please explain and give more specifics.  How will this effect future
      conversion of commercial property to residential property which is possible at this
      site considering the intermix of zoning.

            ODEQ's  priority is  to address the residential areas in as timely
            manner as possible.  The project resources are finite and ODEQ
            desires to dedicate the majority of those  resources to completion of
            the Remedial Action in residential areas.  As appropriate, resources
            will be shifted to commercial/industrial  areas when they become
            available.  This does not  mean  that Category  2  areas will be
            neglected. It is difficult to predict at this point all of the issues of the
            potential conversion of commercial property to residential use in the
            future.  Any such situation will have to be dealt with based upon the
            particular circumstances.  All property used for residential purposes
            will have to meet the residential remediation goals.

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64.   Pg. 9, Right  Hand Column:   "ODEQ proposes that the PRPs be allowed to
      continue with evaluation of.. in situ mixing and stabilization... "

      The ODEQ and the PRPs are to be commended for pursuing this innovative
      technology.  The state-wide, as well as  national ramifications of this study is
      understood and appreciated.  We want to approach this new technology with
      caution, and feel that a time schedule should NOT be imposed. Rather, at any
      time,  before the completion of the remediation of this site, should all parties
      concerned be convinced that this technology is useful, it should be used.

            Please see response to comment number 35.

65.   Pg. 10, Left Hand Column:  "In conjunction with the City of Bartlesville... develop
      a system for establishing zoning restrictions... "

      The Coalition's concern is that zoning restrictions were in place, but not adhered
      to on the west side of Bartlesville.  The Coalition welcomes ideas for mandated
      zoning that is enforceable.

            The concern is noted.  See response to comment number 45.  .

66.   Pg. 10, Right Hand Column:  "Lead concentrations in composite soil samples...
      See technical advisors  comments in Appendix B.

            See response to comment number 15.

67.   Pg. 11, Right Hand Column: "For example, dirt parking lots may be capped with
      rock, asphalt, or other suitable material. "

      The Coalition requests that asphalt be used in parking lots that are more highly
      contaminated and highly used by children, i.e., churches, schools, community
      center.

            ODEQ concurs with  this comment.   This issue will be more clearly
            addressed in the Remedial Design.

The following comments, number 68 through 86, were submitted by the U.S.
nvironmental Protection Agency, Region VI.

68.   Naturally occurring Levels  of  Arsenic: EPA has not concluded that there are
      naturally occurring  levels of arsenic in area soils as high as 50 milligrams per
      kilogram (mg/kg) as was stated in the Proposed Plan. The Phase I soil sampling
      by EPA indicated  what  appeared  to be high background levels of arsenic.
      However, the Phase I arsenic data is of questionable quality and is not considered
      by EPA to be acceptable for quantitative use.

            The comment is noted.

Responsiveness Summary/NZC  Site                                             Page A-25

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69.   Effects of Soil Concentration on Soil/Oust Relationship: A site specific relationship
      between outdoor soil and indoor dust concentrations was developed for each of
      the chemicals of concern (arsenic, lead, cadmium and zinc).  The relationships
      derived were then used in calculating risk-based preliminary remediation  goals
      (PRGS) for the metals in soil. The relationships were based on a linear regression
      or nonlinear models and the fit of the models was evaluated  using  standard
      regression diagnostics.

      The models selected were presented in the RI/FS report. The model selected for
      arsenic had  an r 2 value of 0.334, which means that the selected  regression
      equation  explains 33.4 percent of the  total variation.   This indicates that the
      selected regression equation does not properly reflect the relationship between
      outdoor soil and indoor dust. In addition, Appendix H shows a statistical evaluation
      of the regression equation.

      Arsenic had a p-value of 0.000, indicating a strong rejection of the  null hypothesis.
      The null hypothesis for the test was not defined. The fit of the model evaluation
      using standard  regression diagnostics was not clear.  A "Lack  of Fit and,Pure
      Error"  analysis  (i.e. ANOVA  showing Lack-of-Fit)  will add  significantly  to
      understanding  the adequacy of the selected model.  The same model-fitting
      concerns apply  to  models used for the other chemicals of  concern.   The
      methodology for the application of these models to the PRG value was not clear.

             The ODEQ shared the commenters concern relative to the soil/dust
             relationship data  presented in the  Rl;  therefore,  the ODEQ
             determined that it was inappropriate for use in development of the
             remediation levels.  Based on historic data  from the site and data
             from  other smelter sites reported in  the literature,  the ODEQ
             concluded that a default relationship of 0.5 would be  utilized for
             development of remediation levels.

70.   Bioavailability Studies: The doses used to calculate the bioavailability of lead in soil
      were not shown in the RI/FS report to be comparable to the soil ingestion rate (100
      mg/day) for a child. This is important since high doses of lead may greatly weaken
      the utility of an experimental study.

      The  regimen of introducing chemical with the feed given to the test animals
      reduces bioavailability greatly.  A  child  may introduce soil or dust on an empty
      stomach  and not only with food because of mouthing behavior.  Therefore the
      bioavailability study may not properly represent bioavailability in a child.

      The animal model used was not clearly justified to appropriately represent a child
      or infant living in low income housing and in a possibly undernourished condition.

             The comment is noted; see the response to comment number 19.
Responsiveness Summary/NZC Site                                              Page A-26

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71.   Lead Integrated Exposure Uptake Biokinetic (IEUBK) Model Version 0.5 Versus
      IEUBK Model Version 0.990: The old lead uptake model version 0.5 was used
      instead  of the newly developed version 0.99D. There are a lot of changes in
      exposure parameters in the new version  that makes the newer version more
      conservative than the old version, one of the significant changes is a change in the
      Geometric Standard Deviation (GSD) value. Using the GSD value in the new lead
      model version 0.99D of 1.6 will give a more conservative cleanup number than the
      old model GSO value.  There was no clear  or strong justification for using the old
      model version 0.5 instead of the new version 0.990.

            Comment is noted; see response to comment no. 23.

72.   Arsenic  Toxicity: The RI/FS document emphasized the conservative aspects
      considered in the development of the  cancer slope factor (CSF) and that the
      overestimate may be more than an order of magnitude. However, the document
      did not  point out  that the overestimation  of the CSF was based on treatable
    •  nonlethal skin cancer and failed to reference recent studies that associate arsenic
      ingestion with internal cancer (liver,  lung, bladder and kidney) which tend to be
      fatal.

            Comment is noted; the ODEQ utilized a 3 x iff9 for incremental
            carcinogenic risk instead of the less restrictive 1 x Iff4 requested by
            the PRPs.

73.   Absorption of Arsenic: A 25 percent absorption factor for arsenic  was used in the
      calculation for the arsenic PRG based on  studies done on soil from Anaconda,
      Montana. Absorption factors are site specific and soil data from the National Zinc
      site should be used to determine the relative bioavailability for soil.

            The  Rl document and  other materials  prepared by the PRPs
            provided evidence based on mineralology and in vitro bioavailability,
            that persuaded the ODEQ that absorption factors from Anaconda
            were appropriate for use for this Site.

74.   Soil Arsenic PRG for Residential Exposure: The residential exposure PRG in the
      Proposed Plan for arsenic in soil (68 mg/kg) is higher than typical remediation
      levels selected in Record of Decisions (RODS) at comparable  Superfund sites
      nationwide.

            Comment is noted; the ODEQ believes that the soil arsenic PRG for
            residential exposure is duly protective of public health.

75.   Adding Background Levels to Calculated Cleanup Levels: The residential exposure
      cleanup level for arsenic was calculated to be  60 mg/kg and then adjusted for a
      background level of 8 mg/kg to end up with a PRG value adjusted for background
      of 68 mg/kg.  Normally, a risk-based cleanup level is compared to background
      level and not added  to it.  For example, if the  soil  background  level  of  a

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      contaminant is higher than the risk-based soil cleanup level, then the decision
      could be made to cleanup to background levels.

            ODEQ concurs with the comment.  The ROD was modified to reflect
            a PRG value for arsenic for residential areas of 60 mg/kg.

76.   Adjusting Cadmium RfD Value to Background Levels: The RfD value for cadmium
      was adjusted to background levels in food, air, drinking water and cigarette smoke
      by subtracting estimates of background cadmium intake from the absorbed dose
      cadmium  RfD value.   Typically, EPA does  not adjust RfD  values based on
      background absorbed dose.  However, by using an EPA standard calculation for
      soil ingestion and dermal contact, the risk based concentration in soil associated
      with a hazard quotient of 1 is estimated to be about 70 mg/kg. The PRG of 100
      mg/kg is within an acceptable range.

            Comment is noted; see response to comment no. 22.

77.   Soil Lead PRO for Residential Exposure: The PRG in the Proposed Plan for lead
      in soil (925 mg/kg) for residential exposure is higher than the value associated with
      a 95 percent probability that a child would have a blood lead level less than 10
      ug/dl based on the IEUBK  runs in EPA's baseline human health risk assessment
      for  the site.  However, the 925  mg/kg value is within the range of  soil  lead
      remediation levels selected in RODs at comparable  sites  nationwide.  Post
      remediation blood lead testing of children,in the remediated area is suggested as
      a means of monitoring the achievement of.the blood lead reduction goal, that no
      more than 5 percent of the children in the remediated area have blood lead levels
      greater than 10 ug/dl.

      A 925 mg/kg soil lead remediation level may be adequate to achieve the blood
      lead reduction goal.   However, there  is the possibility that the  925 mg/kg
      remediation level may not be adequate. A lower soil remediation  level may need
      to  be considered.   If soil in an area is  excavated  only to the depth  that
      corresponds to a soil lead concentration of 925 mg/kg, there is the possibility that
      additional excavation to a greater depth corresponding to  a lower remediation level
      might need to be considered in the same area at a later date. To prevent this
      possibility,  it  is suggested that excavation  in properties  or areas selected for
      remediation based on the 925 mg/kg level be to the depth corresponding to a 500
      mg/kg soil lead remediation level.

            The comment is  noted;  the  IEUBK mns in the baseline  risk
            assessment did  not  take  into account site-specific information
            developed during the RI/FS which account for the differences in the
            values associated with the 95 percent probability  that a child would
            have a blood lead level of 10 ug/dL.
Responsiveness Summary/NZC Site                                             Page A-28

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78.   Occupational PRG for Lead: EPA has not yet produced a screening number for
      adult exposure to lead based on the protection of the fetus.

            The comment is noted; see the response to comment no. 20.

79.   Onsite  Disposal at ZCA Facility: Zinc Corporation of America (ZCA) is in the
      process of complying with a Resource Conservation and Recovery Act S 3008(h)
      Administrative Order on Consent with an effective date of September 1,1993. Any
      decision to dispose of soil or sediment on the ZCA's facility should be carefully
      considered while work  required  by the  corrective action is incomplete.  Any
      disposal at the ZCA facility should  be consistent with work required  under the
      Order.

            ODEQ concurs with the comment.

80.   Soil Screening and  Remedial  Recommendations for Category  2  Areas:  -The
      Proposed Plan (Figure 6) references the ODEQ Plan., detailing how available
      options would be implemented in  Category 2 areas, that is to be made available
      for public review and comment prior to implementing remedies for these areas.
      The phosphate amendment treatability studies should be included as a part of
      ODEQ Plan documentation for review and comment.

            ODEQ concurs with the comment.

81.   Completion of Removal  Action: The "Background" section of the  Proposed Plan
      references the removal action continuing until the end of 1994.  As a clarification,
      the  February 12, 1994, Unilateral Administrative Order for  the removal action
      currently in progress states that:

      "The Removal Action to be taken pursuant to this Order shall be conducted by the
      Respondents for a total  of two years unless the scope of the Removal Action is
      completed in less than two years, or the activities required by this Order are being
      conducted as part of the Remedial Action."

      No decision has been made by EPA to discontinue the removal action at the end
      of 1994.

            ODEQ concurs with the comment.

82.   Start of the Remedial Action: As a clarification to the "What's Next?" section of the
      Proposed Plan, remedial design is separate from and precedes  the remedial
      action.

            The text of the ROD has been changed to reflect the comment.
Responsiveness Summary/NZC Site                                           Page A-29

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83.    Compliance with ARARS: The ARARs information and analysis presented in the
      Appendix B of the FS report did not reference EPA's ARARs Analysis Technical
      Memorandum of June 1994, prepared by CH2M HILL. The ARARs analysis in the
      FS should  be  compared with EPA's ARARs analysis for  consistency.   The
      compliance with ARARs section of the Proposed Plan was very brief and should
      be expanded on in the ROD for each alternative considered.

            ODEQ concurs with comment and the text in the ROD has been
            expanded.

84.    Other Remedial Technologies: The Other Remedial Technologies sections in the
      Proposed Plan and  the FS were very brief and sketchy. The "other" remedial
      technologies were not adequately evaluated  in accordance with the evaluation
      criteria included in Table 4 of the Proposed Plan.

            ODEQ concurs and the text in the ROD has been expanded.  The
            "other remedial technologies" are  discussed as part of ODEQ's
           preferred alternative.

85.    Groundwater: The justification and reasons for not remediating groundwater should
      be expanded upon.  Consideration should be  given to using institutional controls
      to  control the future use of  contaminated groundwater for drinking and other
      purposes.

            ODEQ concurs and has modified the text of the ROD.

86.    Administrative  Record: The following documents  should   be added  to  the
      administrative record:

      a.  Resource Conservation and  Recovery Act  S 3008(h) Administrative order on
      Consent for the Zinc Corporation of America facility at Bartlesville. Oklahoma with
      an effective date September 1,  1993.

      b. Human Health Risk Assessment for the National Zinc Site,, dated March 1994,
      prepared by CH2M HILL for EPA.

      C. Data Evaluation Technical Memorandum for the National Zinc Site, dated March
      1994, prepared by CH2M HILL for EPA.

      d. ARARs Analysis Technical Memorandum for the National Zinc Site, dated June
      1994, prepared by CH2M HILL for EPA.

      e. Consent Agreement and Final Order for the Remedial Investigation,  Feasibility
      Study, and  Remedial Design for the National Zinc Site between the Oklahoma
      Department of Environmental Quality and potentially responsible parties, effective
      April  1994.
Responsiveness Summary/NZC Site                                            Page A-30

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      f. Consent Agreement and Final Order between the Oklahoma State Department
      of Health and Zinc Corporation of America, effective date July 1992.

      g. ODEQ plan detailing how the available options would  be implemented for
      Category 2 areas that is to be made available for public review and comment prior
      to implementing remedies for these areas.

      h. Any and all announcements or records of opportunities given to the public to
      comment or participate.

           ODEQ concurs and will include the documents in the Administrative
           Record.

The  following  comments,  comment  87 through 114, were  submitted by PTI
Environmental Services on behalf of Cyprus Amax Minerals Company, Salomon,
Inc., and the City of Bartlesville.

87.   Page 1, second column, second complete paragraph, first and second sentences

      Reference to Rgure 1  would'be more appropriate at the end of the second
      sentence because the figure shows the ZCA facility, not the National Zinc facility.

           ODEQ concurs with the comment and has incorporated the comment
           into the ROD.

88.   Page 2, column, second complete paragraph, second sentence

      Use of the term "addressed" is ambiguous. We would prefer that ODEQ state
      that: "In 1992, EPA contractors evaluated soils at 54 high access areas and the
      decision was made to remediate soils at 25 of those areas. Similarly, in 1993,
      soils  in 22 residential yards were evaluated and the decision  was  made to
      remediate soils at 10 residences.  "

           ODEQ concurs with the comment and has incorporated the comment
           into the ROD.

89.   Page 2, second column, second complete paragraph, fifth sentence

      We recommend replacing "until the end of 1994" with "through October 1994.

           ODEQ concurs and the text of the ROD has been modified to reflect
           the comment.
Responsiveness Summary/NZC Site                                           Page A-31

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90.   Page 3, first column, three bulleted items

      In  each of these bulleted items, we  recommend inserting "and associated
      activities" after "historical smelting operations. "

            ODEQ concurs and the text of the ROD has been modified to reflect
            the comment where appropriate.  The bulleted items, as such, do not
            appear in the text.

91.   Page 3, second column, first paragraph, last two sentences

      We recommend moving -(i.e., residential, occupational [includes both industrial and
      commercial land uses], and recreational)" from the end of the last sentence to the
      end of the next-to-last sentence because it  describes the land use categories
      considered. •

            The comment is rioted.  The text referred to in the comment does
            not appear in the  ROD.

92.   Page 4, first column, first incomplete paragraph, first complete sentence

      We suggest inserting a new sentence: "Spillage and wind transport of ore concen-
      trates from rail cars may  have  contributed to elevated metals at the site. " before
      the sentence starting -Solid waste..." The following sentence could then begin with
      "In addition, solid waste...

            ODEQ concurs and the sentence has been inserted into the text of
            the ROD.

93.   Page 4, first column, fourth complete paragraph, second sentence

      We are unaware of any evidence of "poor vegetation quality in the area. " ODEQ
      should either provide evidence of such effects or delete the clause  "which may
      have resulted in the poor vegetation quality in the area"

            The  community   has  reported  on  numerous  occasions  to
            representatives of the  ODEQ that there have been difficulties in
            raising garden crops, ornamental plants, and grass in the area.

94.   Page 4, first column, fourth complete paragraph, fifth sentence

      We recommend replacing "During Operable  Unit 1" with "During remediation of
      Operable Unit 1."

            ODEQ  concurs and the comment has been incorporated into the
            ROD.
Responsiveness Summary/NZC Site                                           Page A-32

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95.   Page 5, first column, second paragraph, second sentence

      We suggest deleting the word "ongoing. "

            ODEQ concurs and the comment has been incorporated into the ROD.

96.   Page 7, second column, first complete paragraph, last sentence

      With reference to compliance with ARARS, it is understood that ODEQ agrees that
      the "no action" and -no further action" alternatives do not meet the requirements
      of  the Oklahoma Environmental  Quality Act.  As indicated by ODEQ at the
      September 8,  1994 meeting of the Lead Oversight Committee, the Record of
      Decision (ROD) will include or refer to relevant sections of this law.

            ODEQ concurs and the comment has been incorporated into the ROD.

97.   Page 8, second column, last paragraph, first sentence

      We suggest moving the reference to Figure 4 from the end of the sentence to after
      the word "alterative" in the first line and removing the word "by" from the third line
      of the sentence.

            ODEQ concurs and the comment has been incorporated into the
            ROD.

98.   Page 9, first column, first paragraph, first sentence

      We suggest moving the reference to Figure 5 from the end of the paragraph to the
      end of the first sentence of the paragraph.

            ODEQ concurs and the comment has been incorporated into the
            ROD.

99.   Page 9, first column, first paragraph, ninth sentence

      We recommend inserting -unpaved- before "alleyways" and changing the end of
      the sentence from "...would be required" to "...would be required (if composite soil
      samples exceed remedial action goals)."

            ODEQ concurs and has incorporated the comment into the ROD with
            the exception that the word composite has been stricken.
Responsiveness Summary/NZC Site                                           Page A-33

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100.  Page 9. first column, third paragraph, sixth sentence
      We recommend changing the end of the sentence from "...in the future" to "...in the
      future without appropriate remediation. "
           ODEQ concurs and the comment has been incorporated into  the
           ROD.
101.  Page 9, second column, first paragraph, first sentence
      We recommend deleting ", of the entire area" from the end of the sentence.
           The word "entire" has been stricken  from the text of the ROD.
102.  Page 9, second column, first paragraph, third sentence
      We recommend deleting the entire sentence  because the  screening  methods
      would be different.
           ODEQ does not concur.
103.  Page 9, second column, first paragraph
      We suggest adding the following sentence to the end of the paragraph: The key
      activities for Category 2 lands are shown in Figure 6.
           ODEQ concurs and the  comment has been incorporated into the
           ROD.
104.  Page 9, second column, second paragraph, second sentence
      We recommend rephrasing the end of the sentence to state  "...based on metals
      concentrations, ground cover conditions, current site use, public access, and other
      factors."
           The comment is noted.   The text referred to in the comment does
           not appear in the ROD.
105.  Page 9, second column, third paragraph, first and second sentences
      We recommend replacing the first and second sentences with the following
      sentence: "'ODEQ proposes that evaluation of Alternative 5, In Situ Mixing and
      Stabilization (i.e., phosphate amendment treatability studies), continue for Category
      2 land use types.  "
           ODEQ concurs and the comment has been incorporated into the
           ROD.
Responsiveness Summary/NZC Site                                            Page A-34

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106.  Page 9, second column, third paragraph
      We suggest adding as a new concluding sentence: "On the other hand, if the
      results of the phosphate treatability studies demonstrate that lead bioavailability will
      be significantly and permanently reduced, ODEQ will consider amending the ROD
      to include Alterative 5 as a component of the remediation for Category 1  lands."
            ODEQ  does not disagree,  but  will  not include the  suggested
            language in the text of the ROD.
107.  Page 10, second column, second bulleted item, last sentence
      We recommend adding ", or capped" to the end of the sentence.
            The comment is noted.   The text referred to  in the comment,
            specifically the example portion of the bulleted item, was removed
            when the ROD was written.
108.  Page 11, first column, second bulleted item
      We recommend replacing  -residences" with  "properties" because there  are no
      residences among the Category 2 lands.
            The comment is noted. The text referred to does not appear in the
            text of the ROD.
109.  Page 11, first column, last paragraph, first sentence
      We recommend changing -the above 4 alternatives"- to "the above 3 alternatives."
            ODEQ agrees to strike the "4" in the text.
110.  Page 11, first column, last paragraph, second sentence
      We recommend changing "'mixing and capping" to "mixing or capping."
            ODEQ has modified the text of the ROD to indicate "mixing and/or
            capping."
111.  Page 11, second column, first complete bulleted item
      We recommend replacing "residential' with "commercial and industrial" and deleting
      "(such as unpaved driveways and alleyways)."
            ODEQ concurs and has modified the text of the ROD to reflect the
            comment.
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112.  Page 11, second column, second complete bulleted item

      We recommend deletion of the entire first sentence of this bulleted item and
      insertion of the second sentence at the end of the preceding bulleted item.

            ODEQ agrees to strike the bulleted item.

113.  Tables

      As announced at the  September 8, 1994. public meeting, it is understood that
      ODEQ will prepare a corrected version of this table with the following changes:
                                                  I
      •The first two cadmium concentration categories will be < 100 mg/kg and 100 to
           200 mg/kg

      •The first two arsenic concentration categories will be < 68 mg/kg and 68 to 600
           mg/kg.

            ODEQ  concurs with  the  comment except  that  the residential
            Remedial Action Goal for Arsenic will be 60 mg/Kg.

114.  Figure 5, first box

      We recommend that "Screening of Yards" be changed to "Screening of Lands

            ODEQ will agree to change "yards" to "lots".

The following comments, comments 115 through  127, were submitted by the
elect Oversight Committee on Lead/Cadmium Issues, an advisory body of eleven
diverse citizens appointed by the Mayor of the City of Bartiesville with the advice
of the members of the Bartlesvllle City Council.

115.  Composite Sampling of Soil

      We have  very grave doubts about the Proposed Plan's use of composite soil
      samples as the determining basis for whether remedial action will be taken. In
      reaction to the incredibly burdensome and wasteful requirement imposed by the
      Environmental Protection Agency in the removal work plan, that any single sample
      above action levels on a particular property targets  the entire property for soil
      removal, the potentially responsible parties have proposed in the RI/FS, and the
      ODEQ has tentatively accepted in the Proposed Plan, an approach that swings the
      pendulum to the opposite end. and  one that exposes the community to the
      prospect that excessive levels of contaminants  will be left behind unremediated to
      pose future health risks.

      We DO NOT AGREE with the removal plan  approach that requires an  entire
      property to undergo soil removal based on a single target level sample.  However,

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      we recognize the logic that properties very close to the former smelter have in all
      likelihood been subjected to uniformly dispersed airborne contamination, and that
      for such properties multiple sampling only adds expense to confirm the obvious.
      While we believe that the community would have learned much from multiple-shot
      sampling of ALL properties, including those very close to the former smelter, we
      appreciate the  cost of such sampling and  we  understand  why, in  cases of
      overwhelming likelihood of total contamination, the EPA On-Scene Coordinator has
      waived the requirement of multiple-shot samples.

      But, to our minds, the logic of single samples, and particularly composite samples,
      breaks  down completely as close as one  or two blocks from the former smelter
      perimeter.  The EPA's Phase III sampling results and the results of sampling
      during the 1994 removal work demonstrate that at this distance contamination is
      no longer uniform,  and is in many cases no longer at a level to warrant emergency
      action under the standards of the EPA's removal order.

      At the  same time, there  is clear evidence submitted in the RI/FS of intense
      concentrations of  contamination that appear to have resulted  from intentional
      transport of contaminant materials.  This evidence includes samples taken from
      railroad  rights-of-way that adjoin  residences, the Boys and Girls Club and the
      Concern Day Care Center and also samples taken "opportunistically" on the basis
      of reports from property owners of discovery of smelter by products having been
      used as fill material.

      Composite sampling can mask these particularly pernicious "hot spot" deposits.
      If, for example, a young family with small children is living on a property on which
      an old  garage,  now torn  down, had a cinder floor of smelter waste, but the
      property was otherwise unaffected by airborne deposits  of contaminants, a
      composite sampling protocol would be likely to leave the old cinder base (perhaps
      now covered over with a  thin  layer of soil  and vegetation) unremediated, in
      essence purified through dilution with other, uncontaminated soils on the property.

      We believe this  is  the exact opposite of the result the Plan should achieve.  The
      bias of  composite  sampling is AGAINST discovery of "hot spots" • the approach
      we would like to see is to ENCOURAGE discovery of "hot spots." As noted above,
      a "hot spot" should not demand that an entire yard be removed. EPA itself, when
      it did residential removal work through an ERCS contractor in 1993, did not impose
      on itself an "entire yard removal" regime.  In  one widely  observed residential
      removal, at 1014 Armstrong,  the EPA's ERCS contractor in July 1993 removed
      only that portion of the front yard of a residential property lying to the north of the
      sidewalk the south half of  the front yard and the entire rear yard were left alone.

      This example, we think, was the sensible and correct approach.  In  1994, the
      removal work plan imposed by the EPA has been excessive and penal in nature.
      The fact that it has been carried out by and large in very close proximity to the
      former smelter, and has been  relatively unburdensome in practice, does not make
      it less  objectionable.  But the  proper "fix" for this excessive and  unfair  work

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      requirement  is not to abandon knowledge and not to abandon the search for
      discrete areas of contamination that should not be left behind.

      We therefore respectfully urge ODEQ to reject a protocol of composite sampling
      as a remediation decision tool.

      Instead, ODEQ  should  require individual grid sampling and  permit  specific
      remediation of discrete areas of contamination.

            ODEQ concurs with the concern expressed in this  comment.  The
            details of soil screening will be developed in the Remedial Design
            and the degree of compositing that may be allowed will be clarified
            at that point.  Please see comment  15.

116.  Additional ARARs

      We suggest  two  additional applicable or relevant and appropriate  requirements
      (ARARS) for the  remedial action.  In our view, the Oklahoma Lead-Based Paint
      Reduction and Regulation Act, Title 27A, Sections 2-12-101 through 2-12-111, is
      an applicable requirement that sets out  standards for the  implementation  of
      institutional controls to alleviate health risk.

      We further believe that Section 2-12-105 of Title 27A affords an opportunity in the
      context of institutional controls as well as in industrial or commercial remediation
      to conduct investigation and field testing of methods of abating lead hazards that
      the remedial investigation has demonstrated exist at the  Site.  We particularly
      direct OOEQ's attention to the data in Table 17 of the RI/FS, illustrating that in the
      course of conducting paired sampling of soil, paint and house dust  on sixty
      residential properties, the RI/FS contractor uncovered extraordinarily high levels
      of lead in household paint in seven residences. It has been a consistent goal of
      the Bartlesville community, and particularly of the City Council, to explore for and
      identify all sources of potential threat to health. We believe that these residences
      may present such a potential threat to their occupants, and we expect that further
      inquiry, including further sampling such as that carried out in the course of the
      RI/FS, would yield evidence of additional potential threat linked to lead paint.

      We therefore urge the inclusion of the Oklahoma Lead Based Paint Reduction and
      Regulation Act as an applicable requirement, and the inclusion in the final plan of
      a measured program of response to the RI/FS data about paint that fosters
      compliance with the Act.  Insofar as it would be thought that the remedial process
      should not deal with paint, we submit as an additional relevant and appropriate
      requirement  the  May  27,  1994 draft United States Environmental Protection
      Agency Memorandum  "Revised Interim Soil Lead Guidance f or CERCLA Sites
      and RCRA Corrective Action  Facilities."

      We appreciate  and recognize that the  draft Guidance  Memorandum is  not
      "applicable," because it is a draft. We also  understand that the draft's instructions

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      indicate that it is generally not to be applied if risk assessments  have been
      completed.   In our view, this instruction does not render the draft Guidance
      Memorandum inapplicable, because (i) the ecological risk assessment remains to
      be completed and (ii) the human health impact study conducted by the Agency for
      Toxic Substances and Disease Registry has not yet been promulgated, so that the
      human health risk assessment cannot be regarded as completed for the purpose
      of implementing the draft Guidance Memorandum. Therefore, we regard the draft
      Guidance Memorandum as available for consideration as a requirement for the
      Site.

      We focus  particularly  on the material at pages 10-12 of the draft Guidance
      memorandum, under the heading "Issues for Both Programs -  Cleanup  of Soils
      versus Other Lead Sources." This issue has been paramount on the minds  of
      many Bartlesville citizens, and it remains a critical issue for the City Council that
      appointed this Select Oversight Committee.

      The draft Guidance Memorandum supports the addition of a component to address
      potential threats to health from lead paint to the overall remediation Plan. We urge
      ODEQ to consider its mandate under the Oklahoma Lead-Based Paint Reduction
      and Regulation Act in the light of the draft Guidance Memorandum and the lead
      paint data contained in the RI/FS, and to design and include such a component
      in the final Plan.

      In making this request, we understand and agree that lead-based paint was not
      deposited by historic smelter operations, that the federal CERCLA statute does not
      provide a basis for large-scale lead-based paint abatement, and that potentially
      responsible parties who may have been former owners or operators of the National
      Zinc smelter facility are not legally responsible for wholesale abatement  of lead-
      based paint hazards in Bartlesville.

      But the Oklahoma Lead-Based Paint Reduction and Regulation Act affords an
      opportunity unique in the United States for a state agency in the lead agency role
      in overseeing an environmental cleanup to bring to that cleanup mandated and
      funded power to develop and implement a pilot scale study that can provide the
      first  hard  tangible evidence of  the  relative  impact  in  a  Superfund-quality
      remediation action of soil remediation, lead-based paint remediation, and a tandem
      effort to remediate soil and paint.

      We see no compelling reason why the scope of this pilot study must  expand
      beyond the seven residences identified during the RI/FS, but if statistically-valid
      information that can be applied generally to studies of other sites requires a larger
      sample of properties to be crossremediated, controlled and examined for health
      impact on  residents, we believe that our City and community resources can be
      made available so as not to impose an unfair burden on potentially responsible
      parties who may  feel that they do not wish to contribute to  this  activity (although
      they have vastly  superior resources than the City or community and  at least an
      equal stake  in learning whether remediation of lead-based paint could  make a

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      greater contribution to protect health than remediation of soil) because they have
      no legal responsibility for the possible paint hazard.

             See response to comment number 14.  ODEQ is willing to explore
             ways to innovatively approach issues such as lead based paint with
             the community, however,  we cannot include any such activities as
             enforceable provisions of the ROD.  Some issues involving lead
             based paint may not fall under the jurisdiction of the ODEQ or the
             Superfund law.

117.  Institutional Controls

      We believe the  Proposed Plan devotes inadequate  attention  to the subject of
      institutional controls  and  makes unwarranted assumptions about the ability to
      implement institutional controls and their acceptance at the local level. Further, the
      Proposed Plan  takes inadequate  account  of the  interrelationship between
      institutional controls  and  other remedial actions and as a result contemplates
      remedial actions that may prove cost ineffective or impossible to implement.

      We urge the  ODEQ  to explore the process by which institutional controls were
      adopted and woven into the remedial action at the Bunker Hill Superfund Site in
      the Silver Valley of  Northern Idaho, as an instructive example of the role of
      institutional controls and the layer of complexity they add.  We are transmitting
      herewith copies of those portions  of the Records of Decision for both  the
      residential soils operable unit and the non-residential soils operable unit of  the
      Bunker Hill Site dealing with institutional  controls for  ODEQ.s information in this
      regard. The  National Zinc Site is similar to Bunker  Hill both in size and in  the
      number of local jurisdictions involved.

      If any  program  of institutional  controls is to be effective, each  of  the local
      jurisdictions must be involved. The Proposed Plan makes reference to the City of
      Bartlesville and to Osage County.  However,  it inexplicably omits reference to
      Washington County, the jurisdiction in which the former smelter facility  rests.  As
      the RCRA response at  the  former smelter  facility proceeds,  the  people  of
      Bartlesville and surrounding areas want and expect the former smelter facility to
      be restored to productive and acceptable use.  We foresee that that restoration
      could take the form of periodic partial disassembly of  the facility property, just as
      the present 137 acre  facility was assembled over a number of years. Washington
      County, Oklahoma is thus a vital local government entity that will need effective
      and protective institutional controls  in order to foster restoration of the former
      smelter facility in a protective manner.

      But Washington  County   would  not appear to be  the  only  local jurisdiction
      overlooked by the Proposed Plan as a provider of institutional controls.  Local
      anecdotal evidence seems to suggest that smelter by-products were transported
      to the City of Dewey, a suggestion that appears to be supported by EPA Phase
      III sampling data.  Rail transportation of smelter by-products appears to have been

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      a likely if not certain source of deposition of contaminants. If so, in addition to the
      cities of Bartlesville and Dewey, the towns of Copan, Ochelata and Ramona would
      have a role to play in implementing and enforcing protective institutional controls.

      While it seems clear to us that the list of jurisdictions participating in institutional
      controls must be  expanded, it is also our view that the  scope of institutional
      controls must be expanded.  We believe the first and foremost form of institutional
      control should be a Human Health Code and Compliance/Enforcement Program,
      no less effective than those implemented in Bunker Hill, Midvale and West Dallas,
      through which the  people affected or potentially affected by the National Zinc Site
      would enjoy a fully funded program of monitoring, health education and treatment
      or intervention.

      We also believe that a complete and effective institutional control program will
      include mandates  to abate exposure from lead-based paint. The demonstrated
      incidence of highly elevated levels of  lead  in paint and  the  regulatory  tools
      discussed elsewhere in this letter of comment in the context of additional ARARs
      lead us to ask for something more than an anemic suggestion (as set out on page
      5 of the Proposed  Plan) that, "Educational programs could include ways to test for
      and to mitigate this exposure pathway-"

      The cost figure quoted for the relatively minor and  less valuable institutional
      controls mentioned in the Proposed Plan, such as deed restrictions, amendments
      to local ordinances and educational materials, is $300,000.  The RI/FS estimate,
      on which this figure is presumably based, was calculated only with reference to
      upfront expert (primarily  legal)  fees for creation of the required  rules  and
      preparation of appropriate materials to  secure enactment.  The cost estimate
      appears to entirely overlook the costs of compliance, including  for example the
      costs to obtain permits, the costs  of handling of material excavated from beneath
      a cap and the costs of construction of fences for all commercial or industrial
      properties for which "fencing by institutional control" is the designated remedial
      action. We believe two things: (i) the cost estimate for institutional controls should
      be redrawn to capture ALL costs of such controls and (ii) the costs of compliance
      should NOT be passed through to innocent landowners, tradespeople and  small
      business, but  rather that the Plan should explicitly require that all costs of
      institutional controls be funded as part of the work plan under the Plan.

      We submit that the institutional control element of the Proposed Plan is at this time
      too vague  and  ill-defined  to be entitled  to community  acceptance.   Our
      recommendation is that ODEQ and the potentially responsible parties return to the
      drawing board  with  a particularly intense  effort  to define a comprehensive
      institutional controls program, and that the community be consulted with specific
      institutional controls plans, including the missing elements cited above.   If, for
      example, the community is not willing to accept substantial additional forbidding
      fencing for commercial properties in close proximity to residences (the community
      has, for example, expressed  considerable  interest  in  turning  the abandoned
      railroad spur that  formerly served the northern portion of the former smelter into

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      a  public access  greenbelt)  then  the premises  supporting  the preliminary
      remediation goals for clean up of such property are suspect. The SACM process
      must not be allowed to cause such a mistake in the name of speed.

            In general,  ODEQ concurs with this comment.  An institutional
            control plan will be developed as pan of the Remedial Design. This
            should provide more detail and  clarification of institutional control
            options.  See also response to comment number 45.  With regard to
            lead based paint issues see responses to comment numbers 14 and
            116.

118.  Cover and Page i:

      While we note  that colloquially the National Zinc Site is often described as , in
      Bartlesville, we would respectfully observe that the area of investigation extends
      over portions of rural Washington County and Osage County. Because the City
      of Bartlesville is included in its entirely in Washington County, we submit that the
      most efficient technically correct  description of the  location of the Site  would be
      "Osage and Washington Counties, Oklahoma," and we respectfully ask the ODEQ
      to so revise the Site location description.

            The site location  in- the ROD has been modified to include
            Bartlesville,  Oklahoma  and portions of Washington and Osage
            Counties, Oklahoma.

119.  Page 1, first paragraph, fourth line:

      Same comment as immediately preceding.

            Please see comment 118.

120.  Page 1, second paragraph, first four lines:

      1.  In its 'definition" of the Site for purposes of removal, the EPA was  careful to
      indicate an approximate area of spatial extent for the Site.  Similarly, the EPA has
      been very careful in communication with  the Select Oversight Committee to
      indicate that the Site will be defined by the extent of contamination determined with
      reference to remedial goals.

      2.  Scoping the Site  at a three-mile radius for purposes of remedial action vastly
      expands the area beyond the three-kilometer radius of the removal action, and
      presents the prospect of undue alarm and the more substantive  prospect of
      diminution of property lending capacity and reduction  of property  values.  We
      respectfully urge that the scope of the Site be referenced in the more normal and
      acceptable way, by reference to contaminant values, and that no arbitrary spatial
      boundaries be established for the Site in the absence of complete data concerning
      contamination.

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            The text has been modified to indicate that The Site consists of
            those areas within an approximate 3-mile radius of the ZCA facility
            with  concentrations of lead,  cadmium, or  arsenic which exceed
            remedial action goals."

      3.  The words "and operated" in the third line  indicate clearly that the  former
      Somex plant is NOT defined for purposes of the Proposed Plan as part of the ZCA
      facility, and is therefore a "commercial/industrial property" subject to study and
      remediation under the Proposed Plan. We applaud and support this action. We
      suggest an express clarification of this reference to the boundary between the
      National Zinc Site and the ZCA facility so that all members of the community will
      understand that the former Somex plant IS included in the Site and WILL be dealt
      with under the  Plan.

            ODEQ concurs and the text of the ROD has been modified to reflect
            the comment.
121.   Page 1, second paragraph, last two lines:
      We recommend that provision be made for possible future dismemberment and
      restoration to productive use Of portions of the ZCA facility. Our suggestion is that
      the sentence  be amended to read as follows: The term Site, as used in this
      Proposed Plan, does not, at the date hereof, include the ZCA facility, but may in
      future include  any portion or portions of the ZCA facility that have been the subject
      of RCRA investigation  and remediation (if  required) and are proposed to be
      severed from  the remainder of the ZCA facility."

            ODEQ does not concur with the comment.  The ZCA facility will be
            addressed under the RCRA program.

122.  Page 2, fourth full paragraph  (right column):

      1.  Sixth line  - should the small "s" in "site" be a capital, so as to refer to the
      defined "Site"?

            ODEQ concurs with this comment and this has been corrected in the
            language in the ROD.

      2. Last sentence - this observation, with which we agree, tends in our view to lend
      support for individual sampling, rather  than composite sampling of soil.  See the
      discussion elsewhere in this letter of comment.

            The comment is noted.
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123.  Page 3, second full paragraph:

      This statement of the purposes of remedial action objectives for soil incorporates
      a disappointingly limited  scope for the activity, capturing for remediation only
      contamination "originating from historic smelting operations." We had hoped that
      any Plan would capture and attempt to resolve contamination from whatever
      source.  To our minds, limiting remediation to contamination from "historic smelter
      operations" and ignoring transport of  raw  materials, transport of wastes or lead
      deposits from other sources is analogous to a child washing one hand before
      dinner.

      If, as OOEQ says in the fourth full paragraph on page 2 of the Proposed  Plan,
      aerial deposition  of metals is the source for the majority of contamination, then
      there is no need to arbitrarily limit the remedial action objectives to require that
      they only address such deposition.  Such a limit invites potentially responsible
      parties to limit their actions by asserting that speciation tests or other indicators
      point to a source of a particular instance of contamination as other than plant
      emissions, and thereby claim immunity from responsibility for remedial action on
      the basis that such particular contamination can be left alone without doing  injury
      to the remedial action objectives. Such a perverse result cannot be permitted, and
      the limiting phrase "originating from historic smelter operations" should be deleted
      from each bullet point of this paragraph.

            This phrase should not be interpreted  to mean  that only aerially
            deposited contamination is subject to this ROD.  Solid waste or
            product spillage that was deposited as a result of transportation to
            or from the facility is also included.  In order for contaminated soils
            to be exempted from this HOD and the subsequent remedial action,
            it would have to be demonstrated that no ore or smelter waste was
            present.   The remedial investigation demonstrated that although
            there may be other sources of metals in the area which may have
            contributed to soil contamination  smelter  related materials are
            present throughout the areas with soil contamination.

124.  Page 4. fourth  full paragraph:

      The assertion that "Zinc is not a significant threat to human health  ..."  at the
      beginning  of this paragraph may warrant at least qualification. The results of a
      study  at Massachusetts  General Hospital published in the September  2. 1994
      issue of Science magazine and reported in the Wall Street Journal on the  same
      date (see enclosed text), suggests that perhaps zinc is not as benign as previously
      thought, but may instead  actually have some contributing role in the creation of
      some of the physiological conditions associated with Alzheimer's disease.

      While the Massachusetts study is preliminary and not definitive, its indications are
      of significance to the community affected by the National Zinc Site because (i)
      there are a large number of elderly people living on or in proximity to the Site and

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      (ii) the community has been advised that zinc and cadmium are customarily found
      in tandem in soil samples at the Site, and zinc has the effect of reducing the
      availability of cadmium to human receptors.  Unfortunately, we now discover at
      least one hint that the chemical that was letting us relax about cadmium may itself
      be an  independent source of worry.

            The ODEQ concurs with the comment.   Zinc will be specifically
            considered in Operable  Unit 2; see the response to  comment
            number 30.

125.   Page 5, second column, sixth "Common Component" bullet point.

      As we are confident that the ODEQ personnel most familiar with Bartlesville would
      be aware, restoration of damaged fences or other structures "to preconstruction
      conditions" is likely in many cases to be impossible or  unacceptable.  The
      community does not want ramshackle structures or jerry-rigged fences restored to
      their "preconstruction" state.  We believe the standard for repair should be "to a
      workmanlike standard at least as good as preconstruction conditions."

            The ODEQ concurs with the comment. During the Removal Action
            overseen by EPA, the situation described has occurred many times.
            For example, some fences  that had to be removed in order to
            facilitate soil removal were chicken wire.  It was not appropriate to
            reconstruct the fence from chicken wire.  Instead the EPA replaced
            the  fence with chain  link fencing.   ODEQ would expect similar
            sensitivity to replacing substandard construction.  Details  of how
            reconstruction will be accomplished, when necessary, will be given
            in  the  Remedial  Design.     The   specific language   about
            "preconstruction conditions" does not appear in the ROD.

126.   Page 7, second column, "Cost" paragraph.

      The estimates appear in Rgure 3, not Figure 4.

            The comment is noted. The  text of the ROD has been modified to
            assure agreement between text and Figures.

127.   Page 9, Category 1  Preferred Alternative.

      We  are  very pleased  to see attention paid to interior dust abatement.   We
      enthusiastically support the use  of high efficiency vacuum cleaning. The Select
      Oversight Committee asked the potentially responsible parties working under the
      removal order (through their removal contractor) to make high efficiency vacuums
      available to residents on completion of removal.  No response to this request was
      received, so  the inclusion of  a mandate for vacuuming  is  most welcome.  We
      would suggest that the  Plan make clear that the scope of  the mandate extends to
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      ALL residences in the  Site,  including those that were the subject of removal
      actions in 1994 and prior years.

      We are also  pleased to see other indoor remediation efforts reflected in the
      Proposed  Plan.   Replacement  of carpet will be  welcomed by a number  of
      residents.  We do recognize that carpet is expensive, and we do wonder about the
      relationship between benefits and cost for this activity. However, we do particularly
      note the value of carpet replacement in households where very young children are
      present, and therefore on balance support inclusion of carpet replacement in the
      Plan.

            The comment is noted.  The Remedial Design will give specific
            details about indoor dust remediation activities.

128.  General Comments - Process/Further Action.

      When the Select Oversight Committee wrote to the EPA in March in support of a
      state delegation pilot project  for the National Zinc Site, we  were confident that
      potentially responsible parties working under state oversight could arrive  more
      quickly at a less expensive  plan to  deal effectively with contamination in our
      community. As our Chairman in his individual capacity has already observed, this
      goal has been realized, through promulgation of a Proposed Plan that incorporates
      a savings of $40 million or more for potentially responsible parties from the costs
      they would have incurred under an EPA-managed remediation.

      We welcome these savings and we salute the potentially responsible party group
      for its very large role in discerning the route to these  savings.  These savings
      present a real opportunity for these potentially responsible parties to make other
      positive productive investments.

      But we recognize that the ODEQ Proposed Plan provides most of these savings
      by doing LESS to alleviate contamination than EPA had proposed. We had hoped
      for a Plan that would identify and adopt LESS EXPENSIVE TECHNIQUES to
      alleviate contamination, but the Proposed  Plan's savings come in large measure,
      not from process improvements, but rather from LESS ALLEVIATION.

      An opportunity for real alleviation of contamination, with an  innovative and less
      expensive technique of phosphate amendment to form pyromorphite, may  be at
      our fingertips.  We appreciate ODEQ's willingness to  study this technique and
      willingness to  employ it  in appropriate circumstances.

      However, we are frustrated that SACM, as it is being applied and administered to
      the National Zinc Site and the lives of the people of Bartlesville and surrounding
      areas, does not appear able to give this innovative technology a fair hearing and
      opportunity for evaluation. The penchant for measuring progress under SACM with
      reference to cubic yards of soil removed dooms this innovative technology to a too-
      late arrival for the people of Bartlesville.

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      We know and understand that this is not entirely ODEQ's doing.  We do recognize
      that under the interagency memorandum of understanding between ODEQ and the
      EPA, the latter calls the tune,  and the tune is seamless progress that can  be
      measured in  tangible terms  and shown to visitors without the patience of soil
      chemists.   But the result of this relentless push to  dig, dig,  dig is the clever
      tweaking of remediation goals, the turn to composite samples and perhaps other
      yet-to-be discovered techniques to "lessen the  load" and contain costs.

      In its haste to demonstrate continuous, seamless progress, the  EPA has created
      a division  between the interests of the potentially responsible parties  and the
      interests of the people at the Site, as the only available open avenue of cost
      containment for the potentially responsible parties is to find ways to do less, and
      not more, alleviation of contamination. We think there is another way to continue
      with seamless SACM progress and provide a better result.

      We believe the first fundamental task of any remediation work plan is to study and
      define the problem. In this regard, we take the lesson we have learned from our
      careful investigation of the RCRA activities on the ZCA facility.  The first task, to
      our minds,  is completion of the ENTIRE sampling program for residential and
      commercial/industrial properties.  We believe individual grid samples should  be
      taken in all instances in which total property contamination is not obvious, with the
      net result being the first deliverable to a remedial action a complete definition of
      the site,  defined by contamination, not intuition or geography.

      Simultaneously, work should ensue on institutional controls.  Examples should be
      generated and discussed with the community,  so that intelligent choices can  be
      made.  Once the community's acceptance of a level  of institutional control is
      established, remedial goals can be set based not on  intuition or some "norm"
      established with reference to what negotiators on two sides can agree, but on site
      specific risk factors and informed community acceptance.

      Study of soil chemistry and the phosphate amendment technique should continue.
      OOEQ should offer the opportunity for voluntary  pilot efforts, and  should not
      foreclose participation by residential properties. We would particularly support, in
      conjunction with health monitoring under the Human Health Code we expect as an
      institutional control, a residential pilot study that would combine lead based paint
      remediation and phosphate treatment of soil.

      We  know  perhaps  2-5%  of  what we  need  to  know  to   evaluate  the
      phosphate/pyromorphite manufacture technique. If the technique receives no more
      encouragement than set forth in the Proposed Plan, we expect it will drift away
      in the scientific literature, perhaps to be revived and  again advanced at another
      site by other  potentially  responsible parties. Until then, the opportunity for real
      technological  gain is lost, at least for these  potentially responsible parties on this
      Site,and probably for other sites where no solvent potentially responsible parties
      exist and no alternative to removal is now available.
Responsiveness Summary/NZC Site                                             Page A-47

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     Conclusion

     SACM should not be administered in such a way as to cause a loss of opportunity
     for real technological gain at the National Zinc Site.  We would like to see ODEQ
     stand up for a seamless work program such as we suggest, one in which gain is
     measured by progress,  not by  counting dump trucks.   We appreciate the
     opportunity to make our views known and respectfully request that our views be
     made a part of the Agency administrative record relating to the remedial action
     plan.

           ODEQ concurs with this comment.
Responsiveness Summary/NZC Site                                             Page A-48

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            APPENDIX B.
Comments from the Technical Advisors
     for the Bartlesville Coalition

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                       TEL  No.                           igp   /, ^u  u.uo NU.UUO
                                   COMMENT UPON

                 THE PROPOSED PLAN FOR REMEDIAL ACTION
               NATIONAL ZLNC SITE BAKTLKSV1LLE, OKLAHOMA
       BACKGROUND:  The comments and any levels reported  in previous reports are
 complicated by the  fact that any  levels of metals, especially  lead may be complicated by;
 origination from multiple sources, suggesting that all of the metals measured were not emitted!
 from the source proposed for remediation. In addition, Minitech Inc (on behalf of Cyprus Amax
 Minerals Company (Salomon IncJ) and the City of Uartlesville began removal actions for certain
 residential yards, suggesting the possibility that concentrations may be  lower in soil.  Finally,
 an essential approach in the remediation of the soil is not as yet proven to be effective.       <

       Remedial action objectives relate to ingesting sufficiently low amounts of contaminated:
 soil  that no significantly elevated concentrations of blood  lead (5% probability), no doses \n(
 excess of EPA establish reference doses and significant risk of cancer (10 cancers/million) would!
 accrue. No significant consideration has been given to Inhalation hazards fronv  _
 total suspended particulars summarized  in the report (volume 1) preceding tnTJTpr
       SITE CONTAMINANTS AND RISKS TO HUMAN HEALTH are indicated in this;
proposal, children 6 months—2 years. From lead soil concentrations equal to or exceeding those'
reported from measurements taken in this  report, blood lead concentrations were elevated.in;
approximately 10% of the children measured.  These levels were lower than those reported from;
earlier times  (1977), indicating some reduction of the human consequences of high soil lead.j
The increased blood lead in these children suggests that significant consequences have occurred:
from these soil lead levels.  These levels are properly described as significant probability of
learning disabilities, attention deficit disorders and perhaps hearing impairments. Most literature
consulted and reviews substantiated these statements.                                      •
                                                                                     i
       The probable health risks  for cadmium which were described were supported literature
sources.                                                                            .  j

       SUMMARY OF REMEDIAL ACTION ALTERNATIVES: Alternatives S-l and S-2
are adequately described.                                                               :

       Alternative S—3 is intriguing. Certainly, people living in Bartlesville will consider that
mscituciof»f-eentrols from the past are a part of the problem today.  This alternative doesn't
consider the possibility for continued exposure to airborne lead. If this alternative is pursued
with soils with the highest lead concentration, airborne lead should be monitored in more detail.'
The relationship of panicle size to lead concentration should be further defined and these data;
used in updated risk estimation. The security of these fences in the past and in the present is not;
described.  For example, what will be the probability of exposure to human children to these;
contaminated  soils by ingestion.

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            TEL MB .
                                                Sep   3.3d 10:49  No.001  P.O
    2. Are soil lead concentrations the best measure of this objective? Since the
    objective la to Keep Wood lead concentrations below 10 ug/dl_ a blood lead
    sampling program should be implemented as part of the remedy to ensure
    that the remedial action objectives art met Measuring only soil lead
    concentrations (an Indirect indicator of blood lead levels) provides only
    indirect and inconclusive evidence that the remedial action objective for lead
    is met.

PRO'S for both cadmium and arsenic are lower than those proposed by PTI In
the RI/FS, and are more In line with PRG's from similar sites, and with ATSDR's
recommended soil concentrations considered to be protective.
The Oklahoma Department of Environmental Quality's (ODEQ's) preferred
alternative Is e composite of several of the alternatives put forward by PTI in the)
RI/FS. As such It Is probably the most appropriate alternative discussed. The
Bartlesville Coalition and the community affected by the stte should be aware of
several things that are not made entirely clear from the proposed plan.
    1. The phosphate amendment approach to In-situ treatment of soils la an
    Innovative technology, and has the potential to reduce the bloavallablllty of
    these compounds (and thus the risk), it la also en unproven technology. In
    theory, pyromorphtte should form  In sods, but there is no direct evidence from
    the treatiblfity study done In the R1/F8 that It does. OOEQ recognizes this.
    and only allows use of Irvsltu treatment after It has been fully demonstrated
    to reduce the bioavailabilrty of the target compounds. If this technology
    cannot be demonstrated, commercial and Industrial soils contaminated above
    the PRO'S will either be removed or capped In place.
  *  2. Soils from residential and recreational lands would be removed and
    disposed of in a landfill. The most likely scenario is the development of an
    on-site landfill for these materials. When the ROD te signed and If the option
  ("for an on-site landfill is Included, the landfill could be sited without any
  [required further input from the public. Sites remediated under CERCLA
    authority using on-sHe remediation and/or disposal are only required to meet
    the technical requirements of other laws and regulations. Administrative
    requirements (such as a public comment required to site a landfill) are
    replaced by the administrative requirements of CERCIA
    The distinction between an on-site and off-site landfill Is Important. An on-site
    landfill which did not meet the administrative requirements  of appropriate
    state and federal laws (SWDA, RCRA..etc.) could only accept materials from
    this site. No materials from off-site could be disposed of In  such a landfill.
    Administrative requirements for siting an oftalte landfill would still be required
    or the materials could be disposed of In an existing licensed landfill.
 09/02/94

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                   TEL Nc .
Sep   3.94  10:49 No.001 P.04
          ODEQ might not site a landfill on the site based upon the ROD without
          further pubflc comment, but they would not be required by federal law to
          provide additional comment in order to do so. The BarUesvUle coaflUon
          should carefully consider the location of a landfill in thla community for the
          disposal of contaminated soils removed from this cite.

          3. ODEQ has basically divided the cleanup into two types of contaminated
          solla, residential/recreational, and occupational/industrial. For the
          residential/recreational soils, they are recommending the more proven
          technology -removal and disposal. Thla technology wttl be more effective In
          the long term, but will take more time to implement and will be more
          disruptive to the community. ODEQ Is recommending that long-term
          effectiveness using a proven technology la more important in thla ease than
          the possible benefits in cost, time and short-term effectiveness that might be
          available with the unproven in situ treatment option. The Bartteavilie coalition
          and the local community should assess this recommendation carefully to
          ensure It Is aligned with their deslraa.
Specific Comments

      The following comments daal mostly with the administrative requirements Of
      CERCLA/SARA and the NCR for issuing a ROD. While ODEQ'e preferred
      alternative is not an incorrect choice, the documentation of now that
      determination was made is inadequately provided within the proposed plan.
      The following requirements are given in the NCP:
          § 300.430 (f)(1)(i) The criteria noted in paragraph (e)(9)(iii) [The nine
          criteria/ of this section an used to detect the remedy.
          § 300.430 (0(2; The proposed plan In the first step In th» remedy
          selection process, the lead agency shall identify the alternative that
          best meets the requirements In § 300.430 (f)(1), above, end shall
          present that alternative to the public in a proposed plan. The lead
          agency,  in conjunction with the support agency and consistent wltti
          § 300.515 (e), shall prepare a proposed plan that briefly describes the
          remedial alternatives analyzed by the lead agency, proposes a
          preferred remedial action alternative, and summarizes the Information
          relied upon to select the preferred alternative.

      While ODEQ clearly states what the preferred alternative Is, they give no,
      rationale In the proposed plan for the basis of making this the preferred     .   •
      alternative. Perhaps more Importantly, the information needed to maka thiaj
      decision based upon the requirements of § 300.430 (0(1)0) we not provided.
      In order to clearly meet the requirements of the above applicable sections of the
      NCP. ODEQ should provide for tha public the following Information: Whether or
       09/02/94

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              i CL. "u .        *                   .iep   J i au  itj.ua nu.uui
 not the preferred alternative meet* the threshold criteria; and information specific
 to the preferred alternative regarding the five balancing criteria. Although the
 elements of the prefeired alternative are each discuMOd separately under the
 alternatives 1 -6, the Information relevant to the preferred alternative la not
 provided. Perhaps more importantly, the preferred alternative Is not discussed in
 the Evaluation cfRtmetSal Action Alternatives section of the proposed plan.
 The failure to follow the letter of the requirements of the NCR may open the ROD
 to legal chaflenge by dissenting parties. The Bartasvilie coalition should carefully
 consider the impact such challenge might have on the time frame for cleanup
 when making its final comments known to ODEQ.
  It is my understanding that this site is not on tn« National Priority Ust, but Is
 being remediated by the state under CERCLA 104(0) authority, and therefore the
 above sections of the NCP are relevant It Is possible however, that this action b
 being undertaken under § 300.415 as a non-tbne-critfeaJ removal action under
 the Superfund Accelerated Cleanup Model (SAGM). In that case the above
" requirements would not be binding. However, given the scope of the cleanup,
 and the dose adherence by ODEQ to the remaining requirement! of § 300.430
 this does not appear to be the case.
  09/02/94

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                        TEL  No.                            Sep    2.94 UU3 NO .UUy  P.03
        We are interested in  public education programs.  On the  one hand, education will!
 probably help to reduce exposure to lead.  If coordinated properly and involving public eager
 to reduce contamination, they could be quite effective.   Involvement of persons at  risk is
 mandatory to its success.  Public surveys of this section of Barclesvillc suggest that some skill
 will be required to involve persons at risk in these efforts.  The interest to  these persons is.
 obvious from the subject areas listed. Beyond this almost no detail is provided.              I

        Common components of active soil remediation alternatives S—4, S—5 and S—6 are-
 adequately described. During remediation  activities airborne dust will be reduced with the use:
 of water spray. Depending upon particle size, this alternative will most likely reduce airborne'
 lead.  The amount of the reduction  should  be quantified by air sampling.

       Alternative S—4, ex situ mixing and stabilization  introduces the alternative of mixing
 phosphate with soil, thereby reducing the lead concentration in the soil, or at least reducing the'
 bioavailabilily of lead in the soil following the formation of pyromorphites.  Unfortunately, thisj
 alternative is as yet undocumented for efficacy.  This proposal states that trcatability studies are
 currently underway.  Any preliminary results addressing efficacy would be helpful in assessing
 the potential efficacy of this alternative, specifically the rate at which pyroraorphite is formed'
 and factors which  influence the formation.  This proposal tells us that soil will be removed,'
 treated an
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                       TEL No.                            Sep   2.94 13:43 No.008  P.O
 them to be concerned, frustrated, but not angry and unresponsive. These characteristics m
 be weighed in making a selection.

        COS'I'S: Costs range from no action ($0), an option no longer adopiable to 8.3 million
 (minimum cost possible at this site) to 18.5 million (ex situ stabilization).                   ;

        Removal is weakest in reduction of toxicity and has considerable weaknesses with respect
 to short-term  effectiveness.  This is expected, because it is slow,  and toxins are  merely being
 relocated,  not neutralized.  Two alternatives of removal (company responsibility  or  external
 responsibility) arc not regarded by the preparers of this proposal as different in efficacy.  Their
 projected costs differ about 15-20%.                                                      >

        Stabilization (ex situ or m situ; phosphate used to form pyromorphite) have significant
 weaknesses in long-term  effectiveness and implementability.    Both characteristics  are
 understandable, because this method has not been tested extensively, and efficacy has not been
 established. That in situ stabilization is weaker than ex situ is an extension of this property.  For!
 this reason, the control of ex situ stabilization has considerable attractiveness, even though it is
 much  more expensive.   This reviewers sense  is  that in situ  stabilization  is much more;
 implementable, and almost assuredly more sustainable because of public acceptance. Certainly.!
 an  innovative public education program would be required  to increase  the possibility of its
 success. No program has been proposed for this option that is any different from other options:
 This lack of understanding of the importance of public education could be a significant weakness
 of implementing these remediations.                                                       '
                                                                                         i
       DEQ's preferred method of approaching this problem is most likely appropriate.
 I understand it. the approach  is  to remove  the  highest concentrations,  exercise approprid
 institutional controls and stabilize the intermediate to high concentrations.  We agree in con
 to this approach.  However, more performance data for the geotextile fabric and its schedule
 and/or need for replacement would increase confidence in the removal option.  Likewise, pilot
 testing of both stabilization options would increase confidence in the removal options.  Finally,
 the performance data  of the parent company or their designated  contractors in  situations of
 institutional control or waste disposal would be useful in detailed planning of decontamination
of this site.                                                                           . .   ;

       DEQ's remedial action goals would appear to be obtainable,  because they  (category 1;
and certainly category 2) are higher concentrations than most samples selected for speciation
 (Table 3*1, Volume 1).  It  would appear that little cleanup  may be obtained if their guidelines
are rigorously adhered to.

       Category 2 options,  Institutional Controls are adequately defined with the following
exceptions.
 •      We are not entirely clear  on how the  City of Bartlesville will use current construction
       permits to require protective soil management. However, we support with the concept..
 •      More detail is required for the public education program which would be central  to the
       success of this option.

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               TEL No.                           Sep   2.94  U:a.i  NO.UUb P.05
Amending soils with phosphate are adequately defined with these exceptions.       !
The rationale  for choosing 50% reduction  of lead concentrations  is far from clear,'
although it is attractive.
Soil remediation levels or composite soil samples should not exceed remediation goals
below the effective depth.  We agree that this is important, but what about stabilization
with geotextile fabric.                                                           j

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                                 TEL No•                              Sep    2.94  13:43 No.008  P.t
                                     The Proposed Plan for Remedial Action
                                    National Zinc Site Bartlcsville, Ok I shorn «
                                              Review Comments
                                              Gary M. Pierzynski


       This document lays out the OOEQ proposed plan for remediation action for the National Zinc Site in
       Banlcsville.~OK.  The document adequately describes the situation and the post and current remedial
       actions.  ODEQ might want to state the depth of soil removal for the current soil removal actions as a
       point of companion for the proposed removal actions.  Are the proposed removal actions the some as,
       belter than or wane than the current actions?

       I appreciate the lower PRO for Cd.  While 60 mg Cd/Vg is still high when compared to
       uncontaminatcd soil, it is much more acceptable than 190 mg/kg, especially for ecological reasons.

       There is a wording problem  in the first full paragraph on page 4.  The second and third sentence*
       need to be combined.                                                                      .

       I agree with the assessment that we do not know enough about Cd and As to conclude that the P
       additions will reduce their bioavailabilities.  Therefore, I also agree that H additions cannot be
       considered if a particular sample has As or Cd concentrations above their respective PRG's.

    ^   There arc several omissions that 1 noted in the "Summary of Remedial  Action Alternatives" section.
/     For the S-4 and S-3 options  there was no mention of the 2 inch cap of clean soil as was discussed In
\.  - the RI/FS.  Was this intentionally omitted or have the plans changed? For the S-4 option they do not
  ^^   discuss  the depth to which soil will be removed  for the ex situ mixing. Would it be 6 inches as is the
       goal for mixing with the In situ option?

       I agree with the decision to go with soil removal in the residential areas.  1 don't like the soil removal"
       option but it does appear to be the only acceptable alternative at this point in time, at least from a
       regulatory standpoint. Additional information is needed on the house dust abatement program. Who
       is going to supply the equipment for high efficiency vacuum cleaning and make provisions for
       collection and disposal of house dust? What plans are there to educate the individual homeowners on
       the proper procedures for these activities? Will other institutional programs be used, such as
       educational efforts on personal hygiene?

       1 am pleased that OOEQ will allow the In situ mixing alternative to continue to be evaluated and
       possibly used for commercial and industrial  lands.  I  must emphasize, however, that the studies
       proposed by PTI (Soil Treatability Studies - Bench Scale Study of Phosphate Fixation and Reaction
       Rates and the Pilot Scale Phosphate  Amendment work) do not adequately address whether the P
       amendment approach will reduce Pb biosvailability to organisms.  Specific comments with regard to
       these studies will follow. The studies may show (hat the Pb phosphates form in soils within an
       acceptable time frame and may show that Pb bioavailability is reduced  by the in vitro bioaccessibility
       procedure but I would prefer to sec a reduction in Pb bioavailability as indicated by an oral
       bioavailability  study using P amended soil (i-c., repeat the rat study with proper measurement*).  I
       would also note that the only data that wo have showing that the P amendments might work are from
       the in vitro bioaccessibility procedure showing that soil with pyromorphite added had a lower Pb
       bioaccessibility than the equivalent amount of Pb from the contaminated soil.  We cannot assume.
       however, that pyromorphite added to  » soil (as o source of Pb) is the same as  Hb converted  to

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                          TEL  No .
Sep   2.94  13:43  No.008 P.07
 pyromorphite within a soil. Factors such as crystallinity and particle size can influence solubility and
 dissolution rales which can then influence bioavailability.  Also, the in vitro bioaccessibility procedure
 needs to be evaluated more thoroughly before I feel comfortable with the results. Again we come
 back to the need to feed the soil to rats.  Soil chemistry can tell us a lor but a live organism is tho
 best indicator of bioavailability.

 The second  point in the "Amend Soils with Phosphate" (page 10) section needs clarification. The
 authors stated that if the P amendment reduces Pb bioavailability by 50% in a soil containing 3000 mg
 Pb/kg the bioav ail able Pb would be  1300 mg/kg.  They then compare this with the PRG of 2000 mg •
 Pb/kg.  This  is not  a valid comparison because the PRG of Pb is based on the total Pb concentration  '
 in the soil, not the bioavailable concentration.  The 2000 mg/kg value is  then entered into  the UBK
 model with the bioavailable proportion factor (35% for Pb as determined by the rat study) giving  •
 bioavailable concentration of 660 mg/kg. Therefore, to reduce the Pb bioavailability by 50% would
 give a bioavailable  proportion factor of 17.5%.  If you then back calculate this allows  a PRG for Pb of
 3771 rag/kg (660/0.173) instead of 2000  mg/kg (660/0.35).

 1 have some comments on the information that was sent to me on August 23  from PT1 regarding tho
 soil treatabiltly studies.

        The first study is called "Bench Scale Sludy of Phosphate Fixation and Reaction Rates, PT1
 Contract C626-07-23."  The basic experimental designs in  this study arc  acceptable. I take exception
 to one comment regarding soil pH.  It is  stated that "... which should buffer the pH at approximately
 7, approximating the typical Bartlcsvillc soil pH." The only soil pH data that 1 have been able to Cad
 in all of the information that we have obtained was that of the soil used in the oral bioavailabilily
 study, which was 7. 1 looked in the soil  survey for Washington County, OK  and found that there are
 five soil series that  occur extensively in and around Bartlesville. The series and the typical reaction of
 the surface layers are:  Batcs-ColHnsvillc complex, 5.6-6.5; Eram clay loam. 5.6-6.5; Mason  tilt loam,
 6.1-7.0; Osagc clay, 6.1-7.3; and Verdigris clay loam, 5.6-6.5. There arc other soils in the area but
 the point is that the typical pH is probably not 7 but something less than 7.  Our activities often      ;
 acidify soils even more, particularly things like adding N fertilizers to our lawns and gardens or
 adding large quantities of organic materials to gardens. In  section 3.4 of this  document  a study is     '
 described where soil samples  will be equilibrated with water for 24 hours and then the chemical
 composition of the water will be used to  infer the presence of Pb or Cd phosphates. They really don't
 provide enough detail to critically evaluate this but I have serious reservations about how successful
 this might be given my own experience with similar experiments.  The theory is sound but from a
 practical basis you can never  bo sure whether the water is in equilibrium  with the soil  and  you have •
 diil'iculty taking into account  all of the possible interactions for Pb and Cd in solution.   You havo a
 lack of knowledge about things like binding constants  for Pb and Cd and dissolved organic matter or
 (he possibility of solid phases of mixed mineralogy. I know that some PTI scientists have published
 work where they have predicted that Pb phosphates will form  in model systems but that is much
 different than real soil.  From an academic standpoint, something might be learned from all of this.  I
 would have more confidence in the electron tnicroprobe analysis (T consider this to be  essential) than
any solution spccialion work if 1 clearly wanted to show Pb phosphate formation.

       The second  study is called "Pilot  Scale Phosphate Amendment, PTI Contract C626-07-24."  I
hove some serious reservations about the  field test plot aspect of this work (section 3.3). I have
 already stated 1 do not think that applying P in liquid form will work well because the P will not
move very far down in the soil and will not be mixed  adequately with the soil.  I feel  that the
treatments iHcy have proposed will address lliis because if they gel incomplete conversion  of Pb to Hb
phosphates in the top 3 inches it will likely show up in the bioacccssibilily work. However, the

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                               No.       •                       Sep   2.94  13:43  No.008  P.O
electron microprobc analysis may still show Pb phosphates because they are using a composite of the '
top 3 inches. Pb phosphates may form in the top 1 inch and they would be mixed in with the
remaining sample.  The most serious problem with this study is shown in Figure 1 which indicates
that the treatments  are not randomized.  If results from this study were- submitted to  • rcfcreed journal
for publication the  lack of randomization would be sufficient reason for rejection.  Likewise, if I were
to review results from this study for our client I would also question them.  I spoke  with a PTI
scientist at the August 24 meeting and he indicated that they felt a need to place similar treatment*
next to one another because of difficulties in applying the treatments and that they could handle it    ',
statistically.  We routinely do similar experiments and have no difficulty in applying treatments when
similar treatments aro not physically next to one another and  I do not know of any way to handle the
lack of randomization statistically.

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                    TEL No
                                                 Sep   2.94 13:43  No.008 P.09
Comment on Bartlesvill proposed remediation plan* L.C. Davis
                                                                        I
The risk-based PRGs established in this document appear reasonable, given the !
high  zinc  levels  wtih consequent  likelihood that  cadmium  is  relatively !
unavailable. The proposed remediation plan appears good in concept. The main j  °
concern is the total lack of specificity in the plan. Before f inalizatlon, there must j
be  a much  more specific agreement  on what appropriately constitutes j
residential or other land In the site area. It will not  be e successful remediation j
if only the obvious (I.e. occupied residence) lots are remediated on a patchy
basis throughout the contaminated zone. This would undoubtedly depreciate I
the value of the whole area because the many vacant lots would be unavailable!
for  new construction. Renewal of the westside area is going to  require
significant investment in multifamily residential areas or a concerted effort to
build a large cluster of single family residential housing. This will not happen so
long as the zoning is patchy and segmented. Entire blocks need to be treated
and zoned for new building. Obviously these are sociopolitical comments for an
issue of the same  nature. That is where I think the remediation process is at
this point.

We need some assurance that the institutional controls can be Implemented in
a fair and consistent manner and that they will be maintained. Not knowing any
of the responsible parties, or the city government of Bartieaville, it is unclear to
me  how difficult it may be to establish appropriate zoning regulations and how
effective their implementation may be. The remaining issues are less for the real
health concerns, which I think are clearly established, and fairly dealt with in
the  document, than for the perceptions and values  that relate to them. Perhaps
my  concerns can be satisfied in the Engineering Design document which is to
be developed by March 1995. However, the proposed remediation plan would
instill more confidence that it will comply in spirit as well as letter of the law
with the scientific remediation goals, if there were some Indication that the City
of Bartiesville had  appropriate mechanisms in place to deal  with the land use
issues. That is the crux of the matter.                                   i

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                TEL NO-                    Sep  2.94 13:43 No.008 P.10
     REVIEW OF DRAFT OF PROPOSED PLAN FOR REMEDIAL ACTION

      The proposed plan is appropriate and reasonable.  The
levels  selected for action are reasonable if the community is
educated regarding preventive measures to minimize ingestion
of the  contaminants.  Some modifications which might improve
the  plan are described below.

      The educational programs described on page 5 should be
part of the remedial action plan.  All who have elevated
levels  of the contaminants in their  soil and all who have the
potential to have dust with elevated levels of the
contaminants in their homes should receive educational
information.   While the results with phosphate amendments are
not  finalized,  phosphate applications appear to have some
benefit.   The educational program on vegetative cover to
prevent blowing dust and direct contact should include
guidance on initial and annual fertilizer applications, to
have good vegetative cover and to reduce the bioavailability
of the  lead in the soil.

      On page 5.  the statement is made that dirt parking lots
may  be  capped with rock or asphalt.   In southeast Kansas,
chat from mining operations which is high in zinc,  lead,  and
cadmium has been used inappropriately as crushed rock on
roads and parking lots.   If rock is  used,  it should have an
acceptable composition.

      Table t>  could be modified to indicate that the
educational aspects of the Institutional controls alternative
would be included for all cases.

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                   I i. L iN 0 •
Date:     09/02/94

To:       Frederick W. Oehme

From:     J. Patrick McDonald/.fffififUZ//
Subject   Review of National Zinc Site Proposed Plan
       I've organized my comments Into two areas. General comments that I believe
       most closely represent the concerns of the local community; and specific
       comments that relate to the requlrementa of the Comprehensive Environmental
       Response Compensation and Liability Act (CERCLA) si amended by the
       Superfund Amendments and Reauthorizatton Act (SARA) and the National OB
       and Hazardous Substances Pollution Contingency Plan, 40 CFR Part 300 (NCP).
       From the point or view of most citizens, the degree to which the requirements of
      . the NCP are followed may not appear important However, the Record of
       Decision (ROD), is a binding legal requirement for cleanup under the Superfund
       program. Failure to property follow the necessary requirements leaves the ROD
       open to legal challenges which may delay cleanup. Therefore, the Bartlosvltle
       coalition may or may not wish to forward these comments to the Oklahoma
       Department of Environmental Quality.

General Comments
       Remedial Action Objectives (RAOs) for the site appear to be protective. The
       RAO for lead IS however assessed Indirectly. The objective states:
          The remedial action objectives derived for soil afe Intended to:
          prevent ingestion of soil/dust lead originating frorn historical smelting
          operations at the National Zinc facility that would result in a greater
          than 5 percent probability of an Indivtoual child or adult having a blood
          lead level concentration greater than 10 ng/dL;...

       This RAO is then implemented through a rlsK-based Preliminary Remediation
       Goal (PRO) for lead of 925 ppm in residential and recreational soils. This raises
       two Important questions.                       .
          1. Is the 925 ppm level protective of Human Health? The Agency for Toxic
          Substances and Disease Registry (ATSDR) generally considers soils
          contaminated with less than 1000 pom suitable {or Industrial use. However.
         -:or residential soils, lead concentration* below SJDO ppm are considered fully
          protective. Some discussion exists concerning lowering this figure to 400
          ppm. and using an even lower figura (260 ppm) for sensitive populations
          such as day  care centers.
       08/02/64

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