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
-------
APPENDIX A.
ODEQ Responsiveness Summary
to Commments Received regarding
National Zinc Site Proposed Plan
-------
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.
-------
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
-------
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.
Responsiveness Summary/NZC Site Page A-4
-------
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
-------
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
Responsiveness Summary/NZC Site Page A-6
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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.
Responsiveness Summary/NZC Site Page A-8
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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.
Responsiveness Summary/NZC Site Page A-9
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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.
Responsiveness Summary/NZC Site Page A-10
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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.
Responsiveness Summary/NZC Site Page A-11
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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
Responsiveness Summary/NZC Site Page A-12
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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
Responsiveness Summary/NZC Site . Page A-41
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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.
Responsiveness Summary/NZC Site Page A-42
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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.
Responsiveness Summary/NZC Site Page A-43
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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
Responsiveness Summary/NZC Site Page A-44
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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
Responsiveness Summary/NZC Site Page A-45
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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.
Responsiveness Summary/NZC Site Page A-46
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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 months2 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 S3 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 S4, S5 and S6 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 S4, 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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