EPA Superfund
Record of Decision:
PB98-964401
EPA 541-R98-076
October 1998
California Gulch OU 3
Leadville, CO
5/6/1998
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RECORD OF DECISION
STOCKPILED FINE SLAG
ARKANSAS VALLEY SMELTER SLAG PILE
CALIFORNIA GULCH SUPERFUND SITE (OPERABLE UNIT 3)
LEADVILLE, COLORADO
May 1998
U.S. Environmental Protection Agency
999 18th Street, Suite 500
Denver, Colorado 80202
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RECORD OF DECISION
STOCKPILED FINE SLAG
ARKANSAS VALLEY SMELTER SLAG PILE
CALIFORNIA GULCH SUPERFUND SITE (OPERABLE UNIT 3)
LEADVILLE, COLORADO
The U.S. Environmental Protection Agency (EPA), with the concurrence of the Colorado
Department of Public Health and Environment (CDPHE), presents this Record of Decision
(ROD) for stockpiled fine slag at the Arkansas Valley smelter slag pile of Operable Unit 3 (OU
3) within the California Gulch Superfund Site in Leadville, Colorado. The ROD is based on the
Administrative Record for California Gulch OU3, including the Remedial Investigation/
Feasibility Study (RJ/FS), the Proposed Plan, and the public comments received. The ROD
presents a brief summary of the RJ/FS, actual and potential risks to human health and the
environment, and the Selected Remedy. EPA followed the Comprehensive Environmental
Response, Compensation, and Liability Act, as amended, the National Contingency Plan (NCP),
and appropriate guidance in preparation of the ROD. The three purposes of the ROD are to:
1. Certify that the remedy selection process was carried out in accordance with the
requirements of the Comprehensive Environmental Response, Compensation, and
Liability Act, 42 U.S.C. 9601 et seq., as amended by the Superfund Amendments
and Reaulhorization Act (collectively, CERCLA), and, to the extent practicable,
the NCP;
2. Outline the engineering components and remediation requirements of the Selected
Remedy; and
3. Provide the public with a consolidated source of information about the history,
characteristics, and risk posed by the conditions of the stockpiled fine slag at the
Arkansas Valley Smelter slag pile of OU 3, as well as a summary of the cleanup
alternatives considered, their evaluation, the rationale behind the Selected
Remedy, and the agencies' consideration of, and responses to, the comments
received.
The ROD is typically organized into the following three distinct sections:
1. The Declaration section functions as an abstract for the key information
contained in the ROD and is the section of the ROD signed by the EPA Acting
Regional Administrator and the CDPHE Director;
2. The Decision Summary section provides an overview of the OU 3 characteristics,
the alternatives evaluated, and the analysis of those options. The Decision
Summary also identifies the Selected Remedy and explains how the remedy
fulfills statutory requirements; and
Record of Decision
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3. The Responsiveness Summary section addresses public comments received on
the Proposed Plan, and other information in the Administrative Record. However,
since the EPA did not receive any written public comments, this ROD will not
contain a Responsiveness Summary.
Record of Decision
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DECLARATION
Record or Decision
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DECLARATION
SITE NAME AND LOCATION
Stockpiled Fine Slag
Arkansas Valley Smelter Slag Pile
California Gulch Superfund Site (Operable Unit 3)
Leadville, Colorado
STATEMENT OF BASIS AND PURPOSE
This decision document presents the Selected Remedy for stockpiled fine slag at the Arkansas
Valley smelter slag pile of Operable Unit 3 within the California Gulch Superfund Site in
Leadville, Colorado. EPA, with the concurrence of CDPHE, selected the remedy in accordance
with CERCLA and the NCP. Note that this decision addresses stockpiled fine slag only. Other
activities required for OU3, including other slag piles, the railroad easement, and the railroad
yard, are addressed under a Consent Decree with the Denver & Rio Grande Western Railroad.
This decision is based on the Administrative Record for the stockpiled fine slag at the Arkansas
Valley smelter slag pile of OU 3 within the California Gulch Superfund Site. The
Administrative Record (on microfilm) and copies of key documents are available for review at
the Lake County Public Library, located at 1115 Harrison Avenue in Leadville, Colorado, and at
the Colorado Mountain College Library, in Leadville, Colorado. The complete Administrative
Record may also be reviewed at the EPA Superfund Records Center, located at 999 18th Street.
5th Floor, North Terrace in Denver, Colorado.
ASSESSMENT OF THE SITE
The stockpiled fine slag at the Arkansas Valley smelter slag pile does not present an imminent or
substantial endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The Selected Remedy is the No Action Alternative, which was presented in the Final Stockpiled
Fine Slag Feasibility Study Report (FS) (Terranext, 1996a). The FS used a comparative analysis
to evaluate several alternatives and identify the advantages and disadvantages of each. Selection
of the No Action Alternative was based on this analysis. For the stockpiled fine slag, the
Selected Remedy leaves the slag piles in their existing condition with no remediation,
engineering controls, long term maintenance, or clean up planned. The Selected Remedy is
protective of human health and the environment, and is considered effective because 1) no
complete human or ecological exposure pathways were identified for the stockpiled fine slag and
2) the potential for release of metals in leachate from the stockpiled fine slag is minimal.
The Selected Remedy provides a contingency for resource utilization, which may be undertaken
in the future if regional market demand exists for the material. Resource utilization involves the
Record of Decision
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use or reuse of the slag material as a commerciaJ product. Due to concerns about the potential
for release of airborne particulates if resource utilization is undertaken, the EPA has determined
that resource utilization of the stockpiled fine slag is only appropriate if it is encapsulated for
reuse. Encapsulation can include the use of fine slag in concrete or asphaJt aggregate; or as road
base, backfill or other construction material as long as the fine slag is chemically bound or
physically separated from any exposure scenario by a barrier consisting of another material.
Dust suppressants to control paniculate emissions and best management practices to control
stormwater runoff would also be employed to contain contaminant releases from the fine slag
stockpile and during implementation of the contingency remedy. Resource utilization must also
take into consideration any toxic leaching potential for the fine slag.
DECLARATION STATEMENT
No remedial action is necessary to ensure protection of human health and the environment.
Max H. Dodson Date
Assistant Regional Administrator
Ecosystems Protection and Remediation
U.S. Environmental Protection Agency, Region VIII
Record of Decision
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DECISION SUMMARY
Record of Decision
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TABLE OF CONTENTS
LIST OF FIGURES DS-iii
LIST OF TABLES DS-iv
LIST OF ACRONYMS AND ABBREVIATIONS DS-v
1.0 SITE NAME, LOCATION, AND DESCRIPTION DS-1
2.0 OPERABLE UNIT HISTORY AND ENFORCEMENT ACTIVITIES DS-3
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION DS-5
4.0 SCOPE AND ROLE OF OPERABLE UNIT , DS-7
5.0 SUMMARY OF SITE CHARACTERISTICS DS-9
6.0 SUMMARY OF SITE RISKS DS-13
6.1 RESIDENTIAL EXPOSURE TO SLAG DS-13
6.2 RESIDENTIAL EXPOSURE TO IMPACTED GROUND WATER DS-14
6.3 RECREATIONAL USER EXPOSURE TO SLAG DS-14
6.4 WORKER EXPOSURE TO SLAG DS-14
6.5 ENVIRONMENTAL EXPOSURE TO SLAG DS-15
6.5.1 AQUATIC EXPOSURE DS-15
6.5.2 TERRESTRIAL EXPOSURE DS-15
7.0 DESCRIPTION OF ALTERNATIVES DS-16
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES DS-18
8.1 EVALUATION AND COMPARISON CRITERIA DS-18
8.1.1 THRESHOLD CRITERIA DS-18
8.1.2 PRIMARY BALANCING CRITERIA DS-18
8.1.3 MODIFYING CRITERIA DS-18
8.2 EVALUATING THE STOCKPILED FINE SLAG ALTERNATIVES ... DS-19
8.2.1 OVERALL PROTECTION OF HUMAN HEALTH AND THE
ENVIRONMENT DS-19
8.2.2 COMPLIANCE WITH APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS (ARARs) DS-19
8.2.3 LONG-TERM EFFECTIVENESS AND PERMANENCE DS-19
8.2.4 REDUCTION OF TOXICITY, MOBILITY, OR VOLUME
THROUGH TREATMENT DS-20
8.2.5 SHORT-TERM EFFECTIVENESS DS-20
8.2.6 IMPLEMENTABILITY DS-21
RecordoT Decision
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8.2.7 COST DS-21
8.2.8 STATE ACCEPTANCE DS-22
8.2.9 COMMUNITY ACCEPTANCE DS-22
8.2.10 SUMMARY DS-22
9.0 SELECTED REMEDY DS-24
10.0 STATUTORY DETERMINATIONS DS-25
10.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT . .. DS-25
10.2 .COMPLIANCE WITH ARARs DS-26
10.3 COST EFFECTIVENESS DS-26
10.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE
TREATMENT TECHNOLOGIES (OR RESOURCE RECOVERY
TECHNOLOGIES) TO THE MAXIMUM EXTENT POSSIBLE DS-26
10.5 . PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT DS-26
11.0 DOCUMENTATION OF SIGNIFICANT CHANGES DS-27
12.0 REFERENCES . , DS-28
APPENDIX A
ARARs DS-30
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LIST OF FIGURES
FIGURE
Figure 1 General Location Map, California Gulch Superfund Site
Figure 2 California Gulch Superfund Site and Operable Units.
Figure 3 Arkansas Valley Slag Pile Current Surface Areas, Volumes, and Angles of
Repose
Figure 4 Arkansas Valley Slag Pile Sample Locations and Reconnaissance Information
Record of Decision
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LIST OF TABLES
TABLE
Table 1 Estimates of Costs for Remedial Alternatives
Table 2 Grid Comparison Method for Alternatives Analysis
Record of Decision
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LIST OF ACRONYMS AND ABBREVIATIONS
AMSL Above Mean Sea Level
AOC Administrative Order of Consent
ARAR Applicable or Relevant and Appropriate Requirements
AV Arkansas Valley
BMP Best Management Practices
CDPHE Colorado Department of Public Health and Environment
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
CFR Code of Federal Regulations
D&RGW Denver and Rio Grande Western Railroad
EPA ' U.S. Environmental Protection Agency
FS Final Stockpiled Fine Slag Feasibility Study
mg/kg milligram per kilogram
mph miles per hour
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NPL National Priorities List
OU Operable Unit
ppm parts per million
PRPs Potentially Responsible Parties
RI/FS Remedial Investigation/Feasibility Study
ROD Record of Decision
SFS Screening Feasibility Study
SPLP Synthetic Precipitation Leaching Procedure
Record of Decision
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1.0 SITE NAME, LOCATION, AND DESCRIPTION
Stockpiled Fine Slag
Arkansas Valley Smelter Slag Pile
California Gulch Superfund Site (Operable Unit 3)
Leadville, Colorado
The California Gulch Superfund Site is located in Lake County, Colorado, in the upper Arkansas
River basin, approximately 100 miles southwest of Denver (see Figure 1). The Site encompasses
approximately 16.5 square miles and includes the towns of Leadville and Stringtown, a portion
of the Leadville Historic Mining District, and the portion of the Arkansas River from its
confluence with California Gulch downstream to the Lake Fork Creek confluence. The
California Gulch Superfund Site has been organized into 12 operable units (OUs). Figure 2
shows the Site boundaries and the location of OU 3.
Operable Unit 3 (Figure 2) includes three slag piles (Arkansas Valley, La Plata, and Harrison St.)
owned by Denver and Rio Grande Western Railroad (D&RGW), a railyard right-of-way through
Leadville and a railyard in the area of Leadville known as Poverty Flats. This Record of
Decision (ROD) addresses only the fine slag1 stockpiled as a subpile of the Arkansas Valley
(AV) Smelter Slag Pile. In addition, D&RGW has identified a small volume of fine slag in the
railyard (Poverty Flats). D&RGW has prepared a plan which addresses removal of the fine slag
from this area to the AV Smelter Slag Pile (EPA, 1996).
The AV Smelter Slag Pile is the largest and westernmost of the three slag piles owned by
D&RGW in the Leadville area (Figure 2). This pile was generated from slag produced primarily
by the AV smelter facility, which operated from 1882 to 1960. The pile covers approximately 40
acres and is approximately 9,800 feet above mean sea level (AMSL). Based upon aerial
photography, the pile volume in the late 1950s was approximately 1.2 million cubic yards.
Today, approximately 422,000 cubic yards of slag remain on the AV Smelter Slag Pile. The
volume of stockpiled fine slag at the AV Smelter Slag Pile is approximately 190,000 cubic yards.
The slag pile was purchased by D&RGW from ASARCO in 1961 for use as ballast (Terranext,
1996a).
The AV Smelter Slag Pile is bounded by Leadville Sewage Treatment Plant property and State
Highway 24 to the south, old smelter works to the north, wooded property to the west, and other
smelter-related wastes and Stringtown to the east. California Gulch runs adjacent to the slag pile
vicinity for approximately 1/5 its length. D&RGW has performed work near the California
Gulch to minimize the direct contact of surface water with the slag piles. In the vicinity of the
AV Smelter Slag Pile, clean fill has been bermed along the toe of the slag to prevent direct
surface water from contacting the slag (Terranext, 1996a).
'Fine slag is sorted slag which is less than 3/8 inch. Sorted slag is slag that has been physically separated
into size fractions for the purpose of railroad ballast production (Terranext, I996a).
Record of Decision
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Lake County is relatively small (380 square miles) and is predominately rural, with a 1990
population of 6,007 (U.S. Department of Commerce, 1990). About half of this population
resides within the City of Leadville. The population of Lake County has fluctuated with the
mining industry-. The population increased to about 9,000 between 1960 and 1981 and then
declined throughout the 1980's. Land surrounding OU3 is predominately dedicated to mining,
commercial, and residential uses.
The climate of Lake County is dry but otherwise typical of most alpine regions in the southern
Rocky Mountains. The average annual maximum temperature in the Leadville area is 50.5
degrees Fahrenheit and the average annual minimum temperature is 21.9 degrees Fahrenheit,
with an annual mean temperature of 37.3 degrees Fahrenheit. The south-central portion of the
county, at an elevation near 9,000 feet AMSL, receives about 10 inches of precipitation annually.
Wind is predominantly from the northwest, with speeds typically from 0 to 30 miles per hour
(mph) (WCC, 1993). Populated areas of Leadville are predominantly upwind of the AV Smelter
Slag Pile.
Record of Decision
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2.0 OPERABLE UNIT HISTORY AND ENFORCEMENT ACTIVITIES
The California Gulch Superfund Site is located in the highly mineralized Colorado Mineral Belt
of the Rocky Mountains. Mining, mineral processing, and smelting activities have produced
gold, silver, lead, and zinc for more than 130 years in the Leadville area. Mining and its related
industries continue to be a source of income for both Leadville and Lake County. The Leadville
Historic Mining District includes an extensive network of underground mine workings in a
mineralized area of approximately 8 square miles located around Breece Hill. Mining in the
District began in 1860, when placer gold was discovered in California Gulch. As the placer
deposits were exhausted, underground workings became the principle method for removing gold,
silver, lead, and zinc ore. As these mines were developed, waste rock was excavated along with
the ore and'placed near the mine entrances. Ore was crushed and separated into metallic
concentrates at mills, with mill tailing generally slurried into tailing impoundments.
Approximately 17 smelter facilities are reported to have once operated within the Site. Most
operations ceased by about 1900, although some facilities continued to operate into the 1960's.
At present, nearly all of the mines within the Site boundaries are inactive; only a few small-to-
moderate-sized mining operations exist. All of the mills and smelters which operated onsite are
inactive and/or demolished.
Due to historic mining, milling, and smelting operations, the Site contains many tailings
'impoundments, fluvial deposits, slag piles, waste rock piles, and mine water drainage tunnels.
Slag on the Site is the mineralized waste byproduct of smelting, and results from the processing
of lead ore in high temperature furnaces. Three major slag piles and several smaller piles remain
at the Site (Figure 2). In 1961. D&RGW purchased the AV Smelter Slag Pile from ASARCO for
use as railroad ballast. D&RGW purchased the La Plata slag pile from the Leadville Sanitation
District in 1970. Additionally, D&RGW purchased the Harrison Street Slag Pile from NL
Industries in 1983 (EPA, 1996).
The California Gulch Site was placed on the National Priorities List (NPL) in 1983, under the
authority of the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) of 1980. The Site was placed on the NPL because of concerns about the impact of
mine drainage on surface waters in the California Gulch and the impact of heavy metals loading
into the Arkansas River (EPA, 1996). Several subsequent investigations were conducted within
the California Gulch Superfund Site that have addressed the slag at the three D&RGW-owned
piles.
In 1986, the EPA's contractor, CH2M Hill, sampled surface water, groundwater, and numerous
mine waste piles, and three D&RGW slag piles as part of the California Gulch Site Remedial
Investigation (RI) (EPA, 1989). The objective of the mine waste and slag sampling was to better
characterize the materials in the California Gulch Superfund Site. This was the first time that the
EPA had sampled slag at the Site.
In 1988, James P. Walsh and Associates, Inc. conducted a Soils Investigation. The stated
objectives of this study were to define potential action levels for soil, determine background
Record of Decision
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metals content of soils, delineate the extent of soil contamination, and determine sources of soil
contamination. This study was initiated by ASARCO, another potentially responsible party
(PRP) at the Site. Three samples of slag were collected as part of this study: one from the
Harrison Street pile, one from the La Plata pile, and one from an area west of Leadville. This
study did not include the AV Smelter Slag Pile (MK, 1992).
In May 1989, Jacobs Engineering performed a second sampling of slag for the EPA. The
purpose of the study was to determine the concentrations of metals in the three D&RGW slag
piles and to evaluate the potential for migration of these metals to soil, water or air. Potential
hazards to the environment and public health from the slag in Leadville were evaluated.
On December 3, 1991, EPA and D&RGW entered into an Administrative Order on Consent
(AOC), CERCLA - VIII - 92006, for the performance of a remedial investigation/feasibility
study (RI/FS) of the lead slag piles. Prior to the AOC, EPA had studied the slag piles as part of
other investigations at the Site. In 1992, D&RGW performed an RI (MK, 1992) that addressed
seven lead slag piles, including the Arkansas Valley, Harrison, and La Plata slag piles, and one
zinc slag pile. Following the RI, a Site-Wide Screening Feasibility Study (SFS) was undertaken
as a joint effort between the PRPs and EPA. The SFS was completed in March 1993. It
screened several remediation alternatives for all types of slag located at the AV Smelter Slag Pile
based on specific criteria, such as relative cost, implementability, and effectiveness. The three
alternatives retained for further evaluation were: no action, institutional controls, and resource
utilization (EPA, 1996).
On December 15, 1993, D&RGW entered into a Consent Decree with EPA to perform the
remainder of their site work. The Consent Decree stated EPA's concerns regarding the fine
fraction of the stockpiled slag and the potential for particulate release during ballast operations as
a potential human health exposure pathway. The Consent Decree required D&RGW to perform
a feasibility study for stockpiled fine slag and to submit an operations plan before initiating any
ballast operations. In July of 1995, D&RGW submitted a ballast operations plan to EPA.
Following EPA's approval of the plan, ballast operations commenced in August 1995 (EPA,
1996).
In May of 1996, D&RGW submitted a feasibility .study for the stockpiled fine slag (the FS) at the
AV Smelter Slag Pile, according to the terms of the Consent Decree. The existing fine slag
subpile and fine slag potentially generated from future ballast production were the focus of the
FS. The FS provided a detailed analysis of the three retained remediation alternatives from the
SFS as applied to the stockpiled fine slag. The result of the Feasibility Study for the stockpiled
fine slag was a Proposed No Action Plan for the stockpiled fine slag as a subpile of the AV
Smelter Slag Pile (EPA, 1996).
Record of Decision
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3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
Public participation is required by CERCLA Sections 113 and 117. These sections require that
before adoption of any plan for remedial action to be undertaken by EPA. the State, or an
individual (PRP), the lead agency shall:
1. Publish a notice and brief analysis of the Proposed Plan and make such plan
available to the public; and
2. Provide a reasonable opportunity for submission of written and oral comments
and an opportunity for a public meeting at or near the Site regarding the Proposed
Plan and any proposed findings relating the cleanup standards. The lead agency
shall keep a transcript of the meeting and make such transcript available to the
public. The notice and analysis published under item # 1 above shall include
sufficient information to provide a reasonable explanation of the Proposed Plan
and alternative proposals considered.
Additionally,-notice of the final remedial action plan set forth in the ROD must be published, and
the plan must be made available to the public before commencing any remedial action. Such a
final plan must be accompanied by a discussion of any significant changes to the preferred
remedy presented in the Proposed Plan along with the reasons for the changes. A response
(Responsiveness Summary) to each of the significant comments, criticisms, and new data
submitted in written or oral presentations during the public comment period must be included
with the ROD.
' EPA has conducted the required community participation activities through presentation of the
RJ/FS and Proposed Plan, a 30-day public comment period, a formal public hearing, and
presentation of the Selected Remedy in this ROD. However, since the EPA did not receive any
written public comments on the Proposed No Action Plan for the Stockpiled Fine Slag, this ROD
does not contain a Responsiveness Summary.
The Proposed No Action Plan for Stockpiled Fine Slag at the AV Smelter Slag Pile was released
for public comment on September 27, 1996. The RJ/FS and the Proposed No Action Plan were
made available to the public in the Administrative Record located at the EPA Superfund Records
Center in Denver and the Lake County Public Library in Leadville. A formal public comment
period was designated from September 27, through October 28, 1996.
On October 3, 1996, the EPA hosted a public meeting to present the Proposed Plan for
Stockpiled Fine Slag at OU 3 of the California Gulch Superfund Site. The meeting was held at
7:00 pm in the Mining Hall of Fame in Leadville, Colorado. Representatives from the EPA and
D&RGW presented the Proposed Plan. Three alternatives were discussed: No Action,
Institutional Controls, and Resource Utilization. The No Action alternative was presented as
EPA's and D&RGW's preferred alternative. A portion of the hearing was dedicated to accepting
formal oral comments from the public. Only two questions were raised during this public
Record of Decision
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meeting. These questions were in regard to the volume of the fine slag proposed for No Action
and the nature of the soil beneath the Harrison St. slag pile, which is not relevant to this ROD.
Record of Decision
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4.0 SCOPE AND ROLE OF OPERABLE UNIT
The California Gulch NPL Site covers a wide area (Figure 2). EPA has established the following
OUs for the cleanup of geographically-based areas within the Site. The OUs are designated as:
OU1 Yak Tunnel/Water Treatment Plant
OU2 Malta Gulch Fluvial Tailing/Leadville Corporation Mill/Malta Gulch Tailings
Impoundments
OU3 D&RGW Slag Piles/Railroad Easement/Railroad Yard and Stockpiled Fine Slag
OU4 Upper California Gulch
OUS ASARCO Smelter/Slag/Mill Sites
OU6 Starr Ditch/Penrose Dump/Stray Horse Gulch/Evans Gulch
OU7 Apache Tailing Impoundments
OUS Lower California Gulch
OU9 Residential Populated Areas
OU10 Oregon Gulch
OU 11 Arkansas River Valley Floodplain
OU12 Site Water Quality
The purpose of the D&RGW Slag Piles/Railroad Easement/Railroad Yard OU RI/FS was to
gather sufficient information to support an informed risk management decision on which
remedies are the most appropriate for the D&RGW Stockpiled Fine Slag portion of OU3. The
RJ/FS was performed in accordance with the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), 40 Code of Federal Regulations (CFR) Part 300, and CERCLA
Section 104, 42 U.S.C. § 9604.
The objectives of the RJ/FS were to:
• Determine the nature and extent of metals in source areas and other affected areas within
the D&RGW Slag Piles/Railroad Easement/Railroad Yard OU;
• Define the potential pathways along which metals can migrate, as well as the physical
processes and, to the extent necessary, the chemical processes that control these
pathways;
• Determine risk assessment information including potential receptors, exposure patterns,
and food chain relationships; and
• Develop, screen, and evaluate remedial alternatives and predict the consequences of each
remedy.
Based on the findings of previous investigations and the results of the D&RGW Slag
Piles/Railroad Easement/Railroad Yard OU RI/FS, the sources and areas of environmental
contamination at the Stockpiled Fine Slag (AV Smelter Slag Pile) portion of OU3 have been
adequately delineated.
Record of Decision
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The remedy outlined in this ROD represents the final remedial action only for the stockpiled fine
slag at the AV Smelter Slag Pile. Remedial actions undertaken at the Stockpiled Fine Slag
portion of OU3 are intended to be consistent with the remedial action objectives and goals
identified for the California Gulch NPL Site and other OU investigations.
Record of Decision
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5.0 SUMMARY OF SITE CHARACTERISTICS
As a result of D&RGW processing the slag for use as railroad track ballast, the AV Smelter Slag
Pile is actually composed of several sub-piles (Figure 3). The subpiles of the AV Smelter Slag
Pile site include sorted fines, water-quenched fines, ballast-sized material, oversized material,
and unsorted air-cooled slag. The subpiles of sorted fines consist of the less than 3/8 inch
diameter slag. The ballast-sized subpile is composed of material with particle sizes ranging from
approximately 3/8 inch to 2-1/2 inches in diameter. Two subpiles of oversized material from
ballast processing consist of slag that is greater than 2-1/2 inches in diameter, some brick, and
some scrap iron. The existing fines piles and fines potentially generated from future ballast
production are the focus of this ROD. Figure 3 also depicts the location of stockpiled fine slag at
the AV Smelter Slag Pile. This and a small amount of fine slag in the railyard are the only
locations within the California Gulch Superfund Site with stockpiled fine slag. The volume of
stockpiled fine slag at the AV Smelter Slag Pile is approximately 190,000 cubic yards. The
volume of stockpiled fine slag at the railyard was estimated at approximately 220 cubic yards
(Terranext, 1996b). As noted previously, the small amount of fine slag at the railyard has been
moved to the AV Smelter Slag Pile. The total volume of fine slag moved from the railyard to the
AV Smelter Slag Pile was approximately 1200 cubic yards.
The following paragraphs discuss the primary contaminants of concern, summarize the nature
and extent of contamination, and provide a brief description of contaminant fate and transport.
Site Characterization Summary - Stockpiled Fine Slag
" During the Lead Slag Pile RJ (MK, 1992) a total of 18 slag samples were collected from the AV
Smelter Slag Pile (Figure 4). Four of these samples were collected from the sorted fines and four
from the water-quenched fines subpiles. These samples were collected from the surface to a
depth of 3 feet. In addition, four subslag samples were collected from four coreholes drilled at
the AV Smelter Slag Pile. Two of these subslag samples were collected from directly below the
water-quenched fines subpile. Each sample was submitted for laboratory compositional and
leachability analysis. Material from the finer-grained slag piles was also submitted for particle
size testing. Compositional analyses included total metals, water-soluble anions, and acid-base
accounting. Leachability testing included Synthetic Precipitation Leaching Procedure (SPLP)
(EPA Method 1312) and column leach tests, which were intended to simulate, as closely as
possible, in situ conditions (Terranext, 1996a).
Compositional results showed that the slag is an iron magnesium silicate, with residual base
metals. Concentration means for the four primary metals of concern collected from fine slag
sample locations at the Site are as follows:
• Arsenic means; 435 milligram per kilogram (mg/kg) -sorted fines, 909 mg/kg
water quenched fines
• Cadmium means; 11.9 mg/kg-sorted fines, 16.6 mg/kg water-quenched fines
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• Lead means; 10,800 mg/kg-sorted fines, 9,650 mg/kg water-quenched fines
• Zinc means; 44,000 mg/kg-sorted fines, 73,000 mg/kg water-quenched fines
Compositional results for the two subslag soil samples (AVB103 and ABV104) collected
beneath the water-quenched fines showed concentrations of metals of concern to be significantly
lower than those for the slag material, and within the range of literature values for metals
occurring naturally in soil (MK, 1992-Table 4-15). These samples showed the lowest value for
arsenic (5.7 mg/kg), lead (84.8 mg/kg) and for zinc (188 mg/kg) from all subslag soil samples
collected. Site-specific background has not been established, however, ranges for metals of
concern in Colorado soils are as follows: arsenic (1.2-24 mg/kg), lead 15-150 mg/kg) and zinc
(16-300 mg/kg) (Terranext, 1996a). The subslag soil samples collected from beneath the water-
quenched fine slag at AV exhibited a negative acid-forming potential.
Leaching analysis, which included both SPLP and column leach studies, showed minimal
leaching of metals of concern. Synthetic Precipitation Leaching Procedure results for all
elements tested in slag were below the toxicity characteristic criteria, listed in 40 CFR 261.24.
Mean values for the contaminants of concern were generally two orders of magnitude lower than
these regulatory thresholds. Column leach tests showed similar low levels of leaching
(Terranext, 1996a).
Particle size data and site-specific meteorological data were used to determine whether slag .in
the fine-grained piles has the abHity to become airborne. Threshold friction velocities (the wind
speed above which the surface material becomes airborne) were calculated using the mode of the
aggregate size distribution. Wind data and the height of the piles were used to calculate the
friction velocity. Results for the two fines piles are:
Threshold Friction Velocity
sorted fines 1.0 meters per second (m/sec)
water-quenched fines 0.58 m/sec
Friction Velocity 0.55 m/sec
A friction velocity lower than the threshold friction velocity demonstrates that sustained wind
gusts (0.55 m/sec, MK 1992) in Leadville are not fast enough to cause wind erosion of the fines
slag piles.
Groundwater
A site-wide monitoring program will be developed at the California Gulch Superfund Site once
all source areas have been addressed. Groundwater in the vicinity of the stockpiled fine slag has
not been fully characterized. As noted above, the subslag material showed concentrations of
metals of concern to be significantly lower than those for the slag material, and within the range
of literature values for metals occurring naturally in soils. These results suggest that surface
water infiltration through the slag piles does not significantly impact groundwater nor does it
impact the soils beneath the slag piles, as evidenced by the results of the soil analyses (Terranext,
I996a).
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Surface Water
No discreet conveyances of surface water runoff from the AV area have been noted.
Additionally, the berm placed along the California Gulch is designed to eliminate surface water
runoff from directly entering the California Gulch (Terranext, 1996a).
Soils
Analysis of subslag soils from beneath the fine slag piles show the lowest concentration for lead,
arsenic and zinc of any of the subslag samples collected (Terranext, 1996a).
Discussion of Fate and Transport
Existing pathways for potential migration of metals of concern include wind, leaching, mixing by
human activities, runoff, and direct contact.
Release Mechanism 1 - Wind
The air pathway analysis results indicate that wind erosion is not a viable release mechanism for
the lead slag piles, including the AV water-quenched and sorted fines piles.
Release Mechanism 2 - Leaching
Testing in subslag material does not indicate that leachate from slag contributes to elevated
metals concentrations in the vadose zone beneath the slag piles. This conclusion is supported by
the lack of acid-generating potential and the neutral-to-basic pH of the slag and subslag
materials.
Release Mechanism 3 - Mixing bv Human Activities
Transport of slag by human activities has occurred, as it was historically used for road
maintenance within the Site by Lake County and the Colorado Department of Transportation.
This mechanism will not continue in the future as reuse of the slag material is controlled as
specified in this ROD.
Release Mechanism 4 - Surface Water Runoff
No evidence of transport of slag fines by surface water runoff was observed at any of the
examined piles. Slag does not appear to be transported from piles onto adjacent soils in rivulets
or channels. Pile integrity, especially for fines piles where this is most critical, appears intact.
This potential release mechanism for slag is not a concern at the AV Smelter Slag Pile.
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Release Mechanism 5 - Direct Contact
Due to the physical characteristics of the slag piles, direct contact with the slag piles was
considered unlikely in EPA's Preliminary Baseline Human Health Risk Assessment (EPA 1991).
Therefore, it was eliminated as a release mechanism.
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6.0 SUMMARY OF SITE RISKS
In the Preliminary Baseline Human Health Risk Assessment (EPA, 1991) lead and arsenic were
identified as the primary chemicals of potential concern at the California Gulch NPL Site. Since
the completion of the preliminary risk assessment, several important studies were completed that
provided more extensive and more reliable data on environmental concentrations and on human
and ecological exposures. Leadville officials and business leaders expressed concern over
possible risks and liabilities associated with commercial and recreational uses within the Site.
Therefore, in the final baseline risk assessment, risks posed by environmental contamination to
current or future workers in the commercial and business district of the community and to people
who engage in recreational activities in and around the community were evaluated. The
assessment was conducted to determine if environmental contamination was of concern at any
locations presently zoned commercial/industrial and to address concerns regarding the
development of a proposed bike path around the community (EPA. 1996).
In 1995, EPA completed two parts of the Baseline Human Health Risk Assessments for the
California Gulch Superfund Site. These are: Part A Risks to Residents from Lead (EPA,
1995b), and Pan C Evaluation of Recreational, Worker Scenarios (EPA, 1995c). Part A
evaluates risks to residents from lead; and Part C evaluates risks to workers in the commercial
and business district and to recreational users in areas in and around the community. The
following paragraphs summarize results of the final baseline risk assessment as they relate to the
stockpiled fine slag at the AV Smelter Slag Pile.
Terrestrial and aquatic risks associated with exposure to site chemicals were also evaluated by
EPA. Aquatic risks were evaluated in the Final Baseline Aquatic Ecological Risk Assessment
(EPA, 1995d) and terrestrial risks were evaluated in the Ecological Risk Assessment for the
Terrestrial Ecosystem (EPA, 1997).
6.1 RESIDENTIAL EXPOSURE TO SLAG
The evaluation of exposure to contaminants at waste piles included consideration of slag pile
data, with an exposure scenario conservatively evaluating a child playing on the waste piles who
may come in contact with contaminants through inadvertent ingestion or dermal (skin) contact.
The dermal contact pathway was determined to be minimal and was not considered further. The
residential risk assessment also determined that non-lead metals in most waste piles pose either
no risk or only low risk from direct contact while playing on the piles. For the evaluation of lead
exposure at the waste piles, the data were found to be too limited to derive reliable estimates of
the potential impact of direct exposures to children who play on waste piles. Therefore a
quantitative evaluation was not performed. As stated in the preliminary risk assessment and the
SFS, direct contact of residents with the slag piles is not expected to occur.
Wind erosion and direct contact were not considered viable release mechanisms for the
stockpiled fine slag. However, based on the results of the risk assessment, there is some concern
about the potential for paniculate release and human exposure should resource utilization of the
stockpiled fine slag be undertaken. For example, inhalation of slag particles could occur if the
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material is disturbed from its current state. If the resource utilization option is exercised,
measures would be required to prevent contaminant releases.
6.2 RESIDENTIAL EXPOSURE TO IMPACTED GROUNDWATER
The remedial action objective in the 1993 SFS was to prevent leaching of metals of concern in
concentrations that would have an adverse impact on soils, surface water, or groundwater in the
area near the slag piles. The 1996 FS determined that testing of material under the slag pile did
not indicate that migration of contaminants by leaching from the slag contributes to elevated
metals beneath the slag piles. In addition, the final baseline risk assessment determined that
groundwater from this aquifer is not currently used for drinking, and it is relatively unlikely that
it will be used for drinking in the future. It has been determined that there is a minimal potential
for release of metals in leachate from the stockpiled fine slag, and that the stockpiled fine slag
poses an insignificant impact on water quality (EPA, 1996).
6.3 RECREATIONAL USER EXPOSURE TO SLAG
The AV Smelter Slag Pile area is situated in an area presently zoned as industrial/mining and is
not considered a recreational use area, thus, there is no complete exposure pathway.
6.4 WORKER EXPOSURE TO SLAG
There are no current worker exposure pathways to the stockpiled fine slag. The Selected
Remedy provides a contingency for resource utilization, which may be undertaken in the future.
The EPA has determined that resource utilization of the stockpiled fine slag is only appropriate if
it is encapsulated for reuse, to deter the potential release of airborne particulates and eliminate
potential risk associated with resource utilization activities. Encapsulation can include the use of
fine, slag in concrete or asphalt aggregate; or as road base, backfill or other construction material
as long as the fine slag is chemically bound or physically separated from any exposure scenario
by a barrier consisting of another material. Dust suppressants to control paniculate emissions
and best management practices to control stormwater runoff would also be employed to contain
contaminant releases during implementation of the contingency remedy.
In response to concerns raised by Leadville officials and business leaders over potential liability
associated with business development within a Superfund Site, EPA developed action levels to
determine if chemical concentrations were of concern at any locations presently zoned for
commercial and industrial purposes. Action levels were developed only for arsenic and lead, the
contaminants of most concern at the Site. The action levels were developed only for soil and
dust ingestion; exposure to other media (e.g., slag piles, waste piles) and exposure to soil/dust via
other pathways (e.g., dermal) are considered of insignificant concern for workers.
The soil action level for lead based on commercial/industrial exposure to soil and dust ranged
from as low as 2,200 parts per million (ppm) to as high as 19,100 ppm with central tendency
values in the 6,100 to 7,700 ppm range. Lead concentrations in soils in and around the slag piles
(maximum lead concentration of 794 ppm) were well below the lead action level (EPA 1996).
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Soil action levels for arsenic based on commercial/industrial exposure to soil and dust ranged
from as low as 330 ppm to as high as 1,300 ppm, with central tendency values in the 610 to 690
ppm range. Arsenic concentrations in soils in and around the slag piles (maximum arsenic
concentration of 5.7 ppm) were well below the lowest arsenic action level.
6.5 ENVIRONMENTAL EXPOSURE TO SLAG
6.5.1 AQUATIC EXPOSURE
There are no aquatic exposure pathways to stockpiled fine slag due to the lack of release
mechanisms. No evidence of transport of slag fines by surface water runoff was observed at any
of the examined piles. Slag does not appear to be transported from piles onto adjacent soils in
rivulets or channels. Pile integrity, especially for fines piles where this is most critical, appears
intact. Surface water runoff is not a potential release mechanism for the AV Smelter Slag Pile.
Additionally, air pathway analysis results indicate that wind erosion is not a viable release
mechanism for the lead slag piles, including the AV water-quenched and sorted fines piles.
Leaching to groundwater is also not a pi•-. ntial release mechanism. Testing in subslag material
indicates that leachate from slag does not contribute to elevated metals concentrations in the
vadose zone beneath the slag piles. This conclusion is supported by the lack of acid-generating
potential and the neutral-to-basic pH of the slag and subslag materials.
6.5.2 TERRESTRIAL EXPOSURE
Terrestrial exposure pathways to the stockpiled fine slag are unlikely to be significant. The slag
piles do not offer any viable habitat or sustenance for terrestrial receptors. Although terrestrial
receptors (i.e., birds, mammals) could access the slag piles, there is no habitat or food source to
attract these receptors. As stated above, wind erosion, leaching, and surface water runoff are not
considered potential release mechanisms for the slag piles, which considerably reduces the
potential for terrestrial receptors to contact slag in more attractive environs.
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7.0 DESCRIPTION OF ALTERNATIVES
A brief description of the three alternatives evaluated in the Stockpiled Fine Slag FS for the AV
Smelter Slag Pile (Terranext, 1996a) is provided below. All alternatives presented in the FS
were evaluated against the nine criteria described in the next section, and then compared with
each of the other options.
Alternative 1; No Action
This alternative leaves the stockpiled fine slag in place with no remediation, engineering or
institutional controls, or long-term maintenance. Generally, the No Action Alternative is
provided for consideration as a baseline against which other technologies can be compared, in
accordance with the NCP. No Action is protective of human health and the environment, and is
considered effective because no complete human or ecological exposure pathways were
identified. However, a site-wide surface and groundwater monitoring program will be developed
once all source areas have been addressed. Monitoring will continue until EPA determines that
such monitoring is no longer necessary to ensure that human health and the environment are
protected. D&RGW would conduct any required monitoring at the stockpiled fine slag pile to
ensure that it poses no threat to human health or the environment. This alternative is technically
feasible and cost-effective, since it does not rely on any technology and has no cost (EPA, 1996).
Alternative 2: Institutional Controls
Institutional controls involve restricting access or activities that could result in human contact
with the slag or increase the potential for leaching from stockpiled fine slag. Controls include
fencing, land-use restrictions, or deed restrictions. Additionally, community awareness programs
could be implemented to alert the community to any physical hazards associated with the fine
slag. Controls could be implemented separately or in combination. The option considered is to
fence and maintain the stockpiled fine slag located at the A V Smelter Slag Pile. Fencing would
eliminate the potential direct contact pathway with the fine slag piles, would be protective of
human health and the environment because no complete human or ecological exposure pathways
would exist (that is, children would not have access to the piles), and potential for release of
metals in leachate from the stockpiled fine slag would remain minimal. Fencing would also be
technically feasible. Costs associated with fencing are $163,970 with inspection and
maintenance costs of $8,443 for a 30-year period (EPA, 1996).
Alternatives: Resource Utilization
The utilization of stockpiled fine slag as a resource could involve a number of activities and/or
processes. At present, although options have been identified, it is not possible to ascertain if or
when the entire volume of stockpiled fine slag could be reused. Two options for the resource
utilization (materials reuse) were identified in the FS: 1) to process the slag as aggregate for
asphalt or concrete, 2) to use slag materials for stand-alone material in construction, such as
backfill for roadbase material or pipe bedding.
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Resource utilization would be protective of human health and the environment because
appropriate environmental controls for particulates emissions and stormwater runoff would be
required to control contaminant releases. Consideration must also be given to any toxic leaching
potential for the fine slag. Resource utilization may marginally decrease the minimal metals
concentrations in the stockpiled fine slag leachate through overall volume reduction. However,
the effectiveness and implementability of this alternative would be affected by the regional
market demand for the material. Efforts conducted to identify markets have been unsuccessful to
date, but a potential for future markets exists. Therefore, the EPA has determined that this
alternative should be included as a contingency with "No Action" as the preferred alternative
(EPA. 1996). However, resource utilization of the stockpiled fine slag is only appropriate if it is
encapsulated prior to its use or reuse. Cost effectiveness is hindered by the distance the slag
material is located from a major market and the cost associated with sorting the slag. Cost for
use of the fine slag as aggregate is estimated as a $1,120,000 loss after resale, while the cost for
use as fill material is estimated as a $244,625 loss after resale (EPA, 1996).
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8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
Section 300.430(e)(9) of the NCP requires that the agencies evaluate and compare the remedial
cleanup alternatives based on the nine criteria listed below. The first two criteria, (1) overall
protection of human health and the environment and (2) compliance with applicable or relevant
and appropriate requirements (ARARs) in Appendix A, are threshold criteria that must be met
for the Selected Remedy. The Selected Remedy must then represent the best balance of the
remaining primary balancing and modifying criteria.
8.1 EVALUATION AND COMPARISON CRITERIA
8.1.1 THRESHOLD CRITERIA
1. Overall protection of human health and the environment addresses whether or not a
remedy provides adequate protection and describes how potential risks posed through
each pathway are eliminated, reduced, or controlled through treatment, engineering
controls, or Institutional Controls.
2. Compliance with ARARs addresses whether or not a remedy will comply with identified
federal and state environmental and siting laws and regulations.
8.1.2 PRIMARY BALANCING CRITERIA
3. Long-term effectiveness and permanence refers to the ability of a remedy to maintain
reliable protection of human health and the environment over time.
4. Reduction of toxicity. mobility and volume through treatment refers to the degree that the
remedy reduces toxicity, mobility, and volume of the contamination.
5. Short-term effectiveness addresses the period of time needed to complete the remedy and
any adverse impact on human health and the environment that may be posed during the
construction and implementation period until cleanup goals are achieved.
6. Implementabilitv refers to the technical and administrative feasibilities of a remedy,
including the availability of materials and services needed to carry out a particular option.
7. Cost evaluates the estimated capital costs, operation and maintenance costs, and present
worth costs of each alternative.
8.1.3 MODIFYING CRITERIA
8. State acceptance indicates whether the State (CDPHE), based on its review of the
information, concurs with, opposes, or has no comment on the preferred alternative.
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9. Community acceptance is based on whether community concerns are addressed by the
Selected Remedy and whether or not the community has a preference for a remedy.
8.2 EVALUATING THE STOCKPILED FINE SLAG ALTERNATIVES
The following is a brief summary of the agencies' evaluation and comparison of stockpiled fine
slag alternatives. Additional details evaluating the alternatives are presented in the FS. This
section evaluates the performance of the stockpiled fine slag alternatives against the nine criteria
discussed above, and compares it with the other possible options. Information for this section
was obtained from the Final Stockpiled Fine Slag FS (Terranext, 1996a).
8.2.1 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion is based on the level of protection of human health and the environment afforded
by each alternative. All of the alternatives are protective of human health. No complete human
or ecological exposure pathways have been identified. Based upon the chemical composition of
the slag and soil sampling conducted beneath the slag, the potential for release of metals in
leachate from the stockpiled fine slag is minimal. The stockpiled fine slag has, at most,
insignificant non-point source impact on water quality.
The physical features of the slag piles have remained relatively unchanged for many decades.
That fact, combined with the determination that the only potential release pathway is through
leachate, suggests that the status of the slag is not likely to change in the near or long term.
Therefore all three alternatives are protective of human health and the environment.
8.2.2 COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS (ARARs)
This criterion is based on compliance with chemical-, location-, and action-specific ARARs.
ARARs are presented in Appendix A. All of the alternatives meet ARARs. Groundwater quality
is a function of the active interchange with surface water degraded by the release of more mobile
metal species from the multitude of other contaminant sources in the vicinity. The potential for
non-point source metals loading to surface water from stockpiled fine slag leachate is minimal to
nonexistent. The use of institutional controls on the stockpiled fine slag will not have any effect
on groundwater quality. Non-point source, Best Management Practices (BMP) to-be-considered
criteria have been implemented along the slag piles contacting California Gulch.
8.2.3 LONG-TERM EFFECTIVENESS AND PERMANENCE
This criterion is based on the magnitude of residual risk and adequacy and reliability of controls.
No Action is an effective long-term alternative. The only identified release pathway determined
to have any potential to contribute to human or environmental risks is the potential for metals to
leach from the stockpiled fine slag. Based upon subslag sampling, metals have not leached and
will not leach from the stockpiled fine slag in concentrations that will have an adverse impact on
soils, surface water or groundwater in the vicinity. Based upon the hardness of the slag, the lack
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of acid-generating potential and the absence of significant metals in soils beneath the slag, the
potential for exposure to metals of concern found in the slag is unlikely to change in the long
term. Institutional controls can be effective in the long term, but are not permanent. Fencing
requires inspections, maintenance and community awareness, and must be renewed or replaced
periodically. Resource utilization represents a reliable alternative which uses known
technologies, limited only by the regional market demand for the stockpiled fine slag. Resource
utilization will not have a dramatic effect on the residual risk, as the pre-resource utilization risks
are minimal.
8.2.4 REDUCTION OF TOXICITY, MOBILITY, OR VOLUME THROUGH
TREATMENT
This criterion is based on the treatment process used; the amount of contamination destroyed or
treated; the reduction of tdxicity, mobility, and volume; the irreversible nature of the treatment;
the type and quantity of residuals remaining; and the statutory preference for treatment.
Institution controls and No Action do not further reduce the very limited toxicity or mobility of
metals of concern in the stockpiled fine slag. In the absence of complete exposure pathways,
there is no indication that toxicity and mobility of hazardous substances in the slag pose a human
health risk. From a land-use perspective, the slag volume is not an issue as tourists come
specifically to observe historic mining practices. Implementation of institutional controls or the
No Action alternative, however, will not reduce the volume of the fine slag found at the site.
Over time, reuse could reduce the very limited potential toxicity and potential mobility of the
stockpiled fine slag. From a land-use perspective, the change in the total volume of all types of
slag will not be significant if only the stockpiled fine slag is utilized.
8.2.5 SHORT-TERM EFFECTIVENESS
This criterion is based on the degree of community and worker protection offered, the potential
environmental impacts of the remediation, and the time until the remedial action is completed.
No action and institutional controls do not create additional risk to the Leadville community
during implementation. For institutional controls, workers and the community can be adequately
and reliability protected if fencing were to be installed.
Resource utilization can also be implemented with no additional risk to the Leadville
community. Workers and the community can be adequately and reliably protected from fugitive
particulates and changes in storm-water drainage when the stockpiled fine slag is utilized.
8.2.6 IMPLEMENTABILITY
This criterion is based on the ability to perform construction and implement administrative
actions. No Action is technically feasible as it does not rely on any technology. As the status
quo, no action is implementable.
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Institutional controls are technically feasible, as reliable fencing can be procured and installed
readily by local contractors. Land-use restrictions would require action by either the Lake
County Commissioners or the Leadville Town Council. Therefore, because further action is
needed by a third party, the potential of implementability of land-use restrictions cannot be
predicted.
Resource utilization is also technically feasible but there are unknowns as to the marketability of
the resource. Demand for the stockpiled fine slag will be dependant on a number of factors,
including but not limited to, the level of construction activity in the vicinity of Leadville.
8.2.7 COST
Alternative 1: No Action
As there are no costs associated with No Action, it is the most cost effective alternative.
Alternative 2: Institutional Controls
Institutional controls involve fencing and maintenance of the stockpiled fine slag located at the
AV Smelter Slag Pile. Fencing the AV pile would have present value capital and labor costs of
$161,000 and inspection and maintenance costs of $8,500 to inspect and maintain over a 30-year
period indicated in the summary in Table 1.
Alternative 3: Resource Utilization
Resource utilization does not presently appear to be a cost-effective option even if market
demands for the material are identified. Efforts conducted to identify markets have been
unsuccessful to date. The options considered are 1) to process slag for use as a concrete or
asphalt aggregate in construction, and 2) to utilize slag materials for a stand-alone material in
construction, such as a backfill or pipe bedding.
The cost effectiveness of these options is hindered by the distance the slag material is located
from a major market and the cost associated with sorting the slag. Cost estimates and a cost
summary are included in Table 1. Estimates have been provided for use of the fine slag for
aggregate ($1,120,000 loss after resale) and for use in fill material ($244,625 loss after resale).
8.2.8 STATE ACCEPTANCE
The State has been consulted throughout this process and concurs with the Selected Remedy.
8.2.9 COMMUNITY ACCEPTANCE
Public comment on the RJ/FS and Proposed Plan was solicited during a formal public comment
period extending from September 27 to October 28, 1996. It is assumed that the community is
generally supportive of EPA's No Action alternative since no comments were generated during
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the formal public comment period. In addition, only two oral comments were raised during the
public meeting held October 3, 1996. These comments were in regard to the volume of the fine
slag pile and the nature of the soil beneath the Harrison St. slag pile, which is not relevant to this
ROD.
8.2.10 SUMMARY
The FS used a comparative analysis to qualitatively evaluate the performance of each alternative
in relation to each specific evaluation criterion. The purpose of this comparative analysis is to
identify the advantages and disadvantages of each alternative relative to one another so that key
tradeoffs could be identified.
A grid comparison method was used to rank the alternatives and their attainment relative to the
NCP criteria set forth in the SFS. Alternatives were ranked on a scale of 1 to 5, with 5 being the
highest attainment of the criterion. Total scores for each alternative were: Alternative 1: No
Action at 41; Alternative 2: Institutional Controls at 39; and Alternative 3: Resource Utilization
at 36. Table 2 provides a grid comparison method to rank the alternatives and their attainment
relative to the following criteria.
• Protection of Human Health and the Environment - All three alternatives are protective of
human health and the environment.
• Attainment of ARARs - All three alternatives attain ARARs.
• Long-Term Effectiveness - All three alternatives have similar long-term effectiveness.
Reuse of the stockpiled fine slag would marginally reduce the residual risk because of
volume reduction. None of the alternatives are subject to technology failure from age or
wear and tear.
• Reduction of Toxicity, Mobility or Volume - None of the three alternatives reduce the
toxicity and mobility of metals of concern found in the fine slag.
• Short-Term Effectiveness - All three alternatives can be implemented in a manner which
protects the Leadville community and the workers implementing the remedy. The No
Action alternative eliminates disturbances of the fine grain slag and requires no workers.
Implementability - All three alternatives are implementable. Deed restrictions are in
effect. Land use restrictions may not be implementable from and administrative
perspective as they require approval by the Lake County Commissioners. Reuse requires
that there be a commercial market or internal need for the stockpiled fine slag which, at
this time, is uncertain.
Cost - No Action is the most cost-effective approach to meeting the remedial action
objectives and attaining ARARs. There are essentially no costs associated with this
remedial option.
• State Acceptance - CDPHE has been consulted throughout the RI/FS process.
• Community Acceptance - The community has been consulted throughout the RI/FS
process.
Selection of the No Action alternative was based on this analysis.
Record of Decision
Stockpiled fine Slat: (OU 3)
5I293I'.\3280-OU'.FINALRODOU3ROD2.WI'D
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9.0 SELECTED REMEDY
Based upon consideration of CERCLA requirements, the detailed analysis of alternatives, and
public comments, EPA has determined that the No Action alternative presented in the Proposed
Plan, with no modifications, is the appropriate remedy for the stockpiled fine slag at the AV
Smelter Slag Pile of OU3 within the California Gulch Superfund Site. The No Action alternative
leaves the stockpiled fine slag in its existing condition with no control or cleanup planned. The
No Action alternative, as described in the Proposed Plan, includes a contingency for future
utilization of the slag, if it is encapsulated prior to its use or reuse.
The No Action alternative is protective of human health and the environment, and is considered
effective because no complete human or ecological exposure pathways were identified and
because the potential for release of metals in leachate is minimal. Based on subslag sampling.
metals have not leached and will not leach from the stockpiled fine slag in concentrations that
will have an adverse impact on soils, surface water, or groundwater in the area. Slag hardness,
the lack of acid-generating potential, and the absence of any significant metals beneath the slag
also indicate that the potential for exposure to metals of concern found in the slag is unlikely to
change in the long term. This alternative is technically feasible and cost effective, since it does
not rely on any technology and has no cost.
Resource utilization would only implemented if future regional market demand exists for the
material. Encapsulation of the fine slag ensures that the contingency remedy is also protective of
human health and the environment. Encapsulation can include the use of the fine slag in
concrete or asphalt aggregate; or as road base, backfill or other construction material as long as
the fine slag is chemically bound or physically separated from any exposure scenario by a barrier
consisting of another material. Dust suppressants to control paniculate emissions and best
management practices to control stormwater runoff would also be employed to contain
contaminant releases during implementation of the contingency remedy.
Record of Decision
Stockpiled Fine SbB (OK 3)
5l293P:'.32gO-0|4-.FINALRODOU3ROD:.WPD
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10.0 STATUTORY DETERMINATIONS
Under CERCLA Section 121, EPA must select a remedy that is protective of human health and
the environment; that complies with ARARs; is cost effective; and utilizes permanent solutions,
and alternative treatment technologies, or resource recovery technologies to the maximum extent
practicable. In addition, CERCLA includes a preference for remedies that include treatment
which permanently and significantly reduces the volume, toxicity, or mobility of hazardous
wastes as a principal element. However, the Selected Remedy, No Action, does not satisfy the
statutory preference for treatment as a principal element of the remedy. Treatment was
considered unnecessary as the Selected Remedy is protective of human health and the
environment. The following sections discuss how the Selected Remedy meets statutory
requirements.
10.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The selected remedy is protective of human health and the environment because 1) no complete
human or ecological exposure pathways were identified and 2) metals have not leached and will
not leach from the stockpiled fine slag that will have an adverse impact on soils, surface water or
groundwater in the area.
Because the estimated action levels for recreational land-use scenarios are significantly above
current surficial soil concentrations for both lead and arsenic, there appears to be relatively little
uncertainty in the conclusion that current surface soils do not pose unacceptable risk levels to
recreational site visitors anywhere within the OU boundaries (EPA, 1995b). In addition, the AV
Smelter Slag Pile area is situated in an area presently zoned as industrial/mining and is not
considered a recreational use area (EPA, 1996).
There are no current worker exposure pathways to the stockpiled fine slag. The Selected
Remedy provides a contingency for resource utilization, which may be undertaken in the future.
The EPA has determined that resource utilization of the stockpiled fine slag is only appropriate if
it is encapsulated prior to its use or reuse, to deter the potential release of airborne particulates
and eliminate potential risk associated with resource utilization activities. Dust suppressants to
control paniculate emissions and best management practices to control stormwater runoff would
also be employed to contain contaminant releases during implementation of the contingency
remedy.
The soil action level for lead based on commercial/industrial exposure to soil and dust ranged
from as low as 2,200 parts per million (ppm) to as high as 19,100 ppm with central tendency
values in the 6,100 to 7,700 ppm range. Lead concentrations in soils in and around the slag piles
(maximum lead concentration of 794 ppm) were well below the lead action level (EPA 1996).
Soil action levels for arsenic based on commercial/industrial exposure to soil and dust ranged
from as low as 330 ppm to as high as 1,300 ppm, with central tendency values in the 610 to 690
ppm range. Arsenic concentrations in soils in and around the slag piles (maximum arsenic
concentration of 5.7 mg/kg) were well below the lowest arsenic action level.
Record of Decision
Stockpiled Fine Stif (OU .1)
5I298P:U280^)M'.FINALROD1OU3ROD2.WPD
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10.2 COMPLIANCE WITH ARARs
The Selected Remedy will comply with all ARARs identified in Appendix A to this ROD. No
waiver of ARARs is expected to be necessary.
10.3 COST EFFECTIVENESS
Section 300.430(f)(ii)(D) of the NCP requires evaluation of cost effectiveness. The Selected
Remedy is cost effective because it has no cost.
10.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE
TREATMENT TECHNOLOGIES (OR RESOURCE RECOVERY
TECHNOLOGIES) TO THE MAXIMUM EXTENT POSSIBLE
No remedial action is necessary to ensure protection of human health and the environment. The
contingency allows for resource recover,' if supported by regional market demand.
10.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
Treatment of the stockpiled fine slag at the AV Smelter Slag Pile was not considered because the
No Action alternative is protective of human health and the environment.
Record of Decision
Slockpilcd Fine Shf (OU 3)
5I29SP.O:80-OI4-.FINALROD-OU3ROD: WPD
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11.0 DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for stockpiled fine slag at the AV Smelter Slag Pile was released for public
comment in September 1996. The Proposed Plan identified Alternative 1, No Action, as the
preferred alternative, with the contingency that resource utilization may be undertaken in the
future. Resource utilization of the stockpiled fine slag would only be appropriate if it is
encapsulated prior to its use or reuse. No comments were received during the public comment
period. Subsequently, EPA determined that no significant changes to the remedy, as it was
originally identified in the Proposed Plan, were necessary.
Record of Decision
Stockpiled Fine Slay (OU 3)
5l29gP.U:SO-OI4TJNAI.ROD'.OU3ROD2 WPD
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12.0 REFERENCES
Morrison Knudsen Corporation (MK). 1992. Report for Lead Slag Pile Remedial Investigation
at the California Gulch Site Leadville, Colorado, prepared for Denver & Rio Grande Western
Railroad. December 11.
Terranext. 1996a. Final Stockpiled Fine Slag Feasibility Study, prepared for Denver & Rio
Grande Western Railroad. May 13.
Terranext. 1996b. Work Plan Consolidation of Fine Slag. Prepared for Denver & Rio Grande
Western Railroad. November. 12.
U.S. Department of Commerce. 1990. Selected Population and Housing Characteristics.
Bureau of the Census.
U.S. Environmental Protection Agency (EPA). 1997. Ecological Risk Assessment for the
Terrestrial Ecosystem. California Gulch NPL Superfund Site, Leadville, Colorado. Prepared by
Roy F. Weston, Inc., January, 1997.
U.S. Environmental Protection Agency (EPA). 1996. Proposed No Action Plan for Stockpiled
Fine Slag, Arkansas Valley Smelter Slag Pile, California Gulch Superfund Site, Leadville,
Colorado. September.
U.S. Environmental Protection Agency (EPA). 1995a. Draft Final Findings of Metal Speciation
Investigations at the California Gulch NPL Site, Prepared by John W. Drexler and Roy F.
Weston, Inc., October 1995.
U.S. Environmental Protection Agency (EPA). 1995b. Baseline Human Health Risk
Assessment for the California Gulch Superfund Site - Part A - Risks to Residents from lead
prepared by Roy F. Weston, Inc., Draft final November 6, 1995.
U.S. Environmental Protection Agency (EPA). I995c. Baseline Human Health Risk
Assessment for the California Gulch Superfund Site - Part C - Evaluation of Recreational and
Worker Scenarios prepared by Roy F. Weston, Inc., April 17, 1995.
U.S. Environmental Protection Agency (EPA). 1995d. Final Baseline Aquatic Ecological Risk
Assessment. California Gulch NPL Site. Prepared by Roy F. Weston, Inc., September, 1995.
U.S. Environmental Protection Agency (EPA). 1991. Preliminary Human Health Baseline Risk
Assessment for the California Gulch NPL Site, Leadville, Colorado. Prepared by Roy F.
Weston, Inc. for the U.S. EPA, December 1991.
Record of Decision
Stockpiled Fine Slalom)
-------
U.S. Environmental Protection Agency (EPA). 1989. Draft Phase II Remedial Investigation
Technical Memorandum, 1986-1987, California Gulch Site. Leadville. Colorado. U.S. EPA,
Prepared by CH2M Hill, May 1989.
Woodward Clyde Consultants (WCC). 1993. Draft Terrestrial Ecosystem Evaluation Report,
California Gulch Site, Leadville, Colorado. April.
Record of Decision
Stockpiled Fine Slag (OU 3)
5l298P:V3280-OI4-.JrINALRODOU3RO[?2.WPD
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FIGURES
-------
CALIFORNIA GULCH
SUPERFUND SITE
CUV FEDERAL PROGRAMS CORPORATION
! C«*v fr«M«r k UcX«« kw.
GENERAL LOCATION MAP
CALIFORNIA GULCH SUPERFUND SITE
LEADVILLE, COLORADO
figure 1
-------
ARKANSAS VALLEY
OpeiiiWe Units tint)
Aicas o
CALIFORNIA GULCH SUPERFUNO SITE
AND OPEFtABLE UNITS
LEADVILLE, COLORADO
-------
N 510.500
\ Cj ownma (A« CZOUD) >i iff
SOHIO rim (AU-CDOUI) aft
mm umoom iii-ccaa/*»n
•MUSI-SI aa
OT AIM-ODOO KM
<«u or WOK buaunix icnog
«-s stcnoN imnriuna
LECENQ
J" $uw«cf eatiau* IHIIXVA
»oo 1000* 10 ctcvArioN UMIOUKS
•ua oumon (>n-ooaat
GENERAL LOCATION MAP
CURRENT SURFACE AREAS
VOLUMES AND ANGLES OF REPOSE
ARKANSAS VALLEY SLAG PIL£
LEADVILLE. COLORADO
-------
V
.«« ffiswar ,. •••<•
SSSSR,.;.:.---^
LECEWQ
r BJWMZ ctxcoo" rnitnvji
ciivAtiOMi AMC VALUC nut 1.0001
*KMOOU
"*niiai*ii-aao)>ii/r
''"OaHrB AU-GDOUB
«o>-ie nia i.u.coao, 0/r
"•"««ua>«1io.ojUO«,,|1€J
' N
GENERAL LOCATIONS
AND RECONNAISSANCE INFORMATION
ARKANSAS VALLEY SLAG PILE
LEADVILLE. COLORADO
figure 4
-------
TABLES
-------
TABLE I
ESTIMATES OF COSTS FOR REMEDIAL ALTERNATIr-ES
OPTION I
INSTITUTIONAL CONTROLS (I)
FESCE THE A V FINE SLAG PILE
CALIFORNIA GULCH
ARKANSAS VALLEY SLAG PILE
LEADWLLE
ALTERNATIVE:
ITEM:
DIRECT CAPITAL COSTS.
(Includes Labor. Equipment and Materials. Unless Otherwise Noted)
COSTS
COMPONENT
/. Mobilize Materials
.'. Office/Storage trailer (8'x30')
3. Earthwork (-150 hp bulldozer)
4. Utilities
Electric
Phone
Sanitary Station
5. Fence Materials
Fencing
Comer Post
Braces
Double Swing Gales
Locks
TOTAL DIRECT COSTS
INDIRECT CAPITAL COSTS (% ojDirect Capital Costs)
I. Engineering and Design (10% of Capital Costs)
2. Contingency Atlo wance (20% of Capital Cost)
3. Other Indirects
Regulatory License/Permits (}% of Direct Capital Costs)
TOTAL INDIRECT COSTS
PRESENT VALUE OF OPERATION AN!) MAINTENANCE COSTS
Annual Inspection atuj maintenance
TOTAL COS1S
ASSUMPTIONS/COMMENTS:
UNfT
Lump
Lump
Cubic Yards
Month
Month
Month
Lineal Feet
Each
Each
Opening
Each
QVASTITf
1
I
5.000
1
1
1
5.300
50
106
3
3
u\/r
COSTS
S:. '00.00
SI.SOOOO
$: so
SI. 300.00
S6.0II.OU
590.011
$16.00
S9500
335.00
svo.on
SIS 00
TOTAL
CAPITAL
COSTS
$2. -00
SI.800
S12.SOO
SI. 300
S600
590
584.800
5-t. 750
S3.- 10
52.910
SJS
Ytar
30
3-50 on
5115.205
sn.i:i
323.0-11
55.760
S-I6.0S1
SH.-t-iS
SI 63.970
I. Eight (8) loads of fencing materials will be hauled using flatbed trailers.
2. Includes mob and demob, set-tip and leveling. teor~down and monthly leasing charge.
3. Earthwork consists of consolidating sorted and wale r-quenchedfine slags before fencing: no nnth or demoh, onsne contractor utilized.
•f. Fencing is 6 go. Galvanized wire. 6' high, no barbed wire.
5. Gales are 20' wide and include posts oitd hardware.
Source: Teirane«i. 1996a
P:V3280-OI4WP\ROD\TABLEI.WPD
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CALIFORNIA GULCH
LEADVILLE. COLORADO
ALTERNATIVE:
ITEM:
TABLE I (Continued)
ESTIMATES OF COSTS FOR REAtEDIAL ALTERNATH'ES
RESOURCE UTILIZATION (I)
FINE SLAG ADDITIVE MATERIAL IN CONSTRUCTION
Aggregate for concrete or asphalt, additive to building materials, additive to
grout, concrete end slurry formations)
DIRECT CAPITAL COSTS
(Includes Labor. Equipment and Materials, Unless Otherwise Holed)
COMPONENT
I. Rescreen material
UNIT
Cubic Yards
Cubic Yards
Cubic Yard
Cvbic Yard
QUANTITY
190.000
190.000
2. Load and haul
TOTAL DIRECT COSTS
INDIRECT CAPITAL COSTS (% of Direct Capital Costs)
I. Engineering aiuJ Design (10% of Capitol Costs)
2. Contingency Allo wance (20% of Capital Cost)
3. Other Indirect!
Regulatory License/Permits (5% of Direct Capital Costs)
TOTAJ. INDIRECT COSTS
CREDITS FROM SALE OF PRODUCT A U TER1AL
I. Additive
2. Backfill Material
TOTAI. CREDIT
TOTAL COSTS/PROriT(S)
ASSUMTTIONStCOMMENTS-
I. A Vfine stag pile volumes are used to compute costs.
}. 90% of material wilt be suitable for use as additive.
3. 10% of material used as backfill material.
•/. No operations and maintenance costs are necessary over an extended period
J. Credits from sale of product material ha\'e been reduced to reflect tranxportalum casts to a major market.
Source: Terranext, 1996a
COSTS
S5.68
S3.2S
n.ooo
19.000
S6.SO
S3.10
TOTAL
COS1S
Sl.0-9.200
S61-.SOU
SI. 696.700
5169.670
S8J.833
S593.84!
5(1.111.500)
5(i8.900)
S(I.I70.JOO)
SI.I20.I-IS
P:\3280-0 M\WFJIOD\TABLE I .WPD
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CALIFORNIA GULCH
LEADWLLE. COLORADO
ALTERNATIVE:
ITEM:
TABLE I (Continued)
ESTIMATES OF COSTS FOR RE\(EDIAL ALTERNATIVES
RESOURCE UTILIZATION O
USED AS STAND ALONE MATERIAL IN CONSTRUCTION
(Fill material)
UNIT QUANTITY
Cubic Yards IVO.OOO
DIRECT CAPITAL COSTS:
(Includes Labor. Equipment and Materials. Unless Otherwise Noted)
COMPONENT
I. Load and Haul
TOTAL D1RECTCOSTS
INDIRECT CAPITAL COSTS (% of Direct Capuol Costs)
I. Engineering and Design (10% oj Capital Costs)
2. Contingency Allowance (20% oj Capital Cost)
3. Other Indirect*
Regulatory License/Permits (}% of Direct Capital Casts)
TOTAL INDIRECT COSTS
TOTAL COSTS (Dirtci plus Indirect)
CREDITS FROM SALE OF PRODUCTMATF.RJAl.
I. Backfill Material
TOTA1. CREDIT
TOTAL COSTS/PROFITS)
ASSUlfl'TIOSirOMMENlS:
I AI' Fine slop volumes are used to compute costs.
?. 100% of material will he suitable fur use ar backfill.
3. l.oad and haul isjor conveyattce losuttahle rail loading Jock.
•f Credits from sale of product material have been reduced due to transportation costs to a major mark*!.
1. Annual Operations and Maintenance costs are included in estimate.
Source: Terranext, I996a
CAPITAL
COSTS
. Cubic t'ard
190.000
33.10
TOTAL
COSTS
3617.100
36 1. ' '10
S12J.100
S30.8-S
31 1 6.i:i
383J.6H
3(189.000)
3(189.000)
32 '-1-1.61 5
P:U280-OH\WPlROD\TABLEI.WPD
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TABLE 2
GRID COMPARISON METHOD FOR ALTERNATIVES ANALYSIS
Criterion
1 ) Protection of Human Health and
Environment
2) Attainment of ARARs
3) Long term Effectiveness
4) Reduction of Toxicity, Mobility or
Volume
5) Short term Effectiveness
6) Implementability
7) Cost
8) State Acceptance
9) Community Acceptance
Total
Alternative 1
No
Action
5
5
4
2 .
5
5
5
5
5
41
Alternative 2
Institutional
Controls
5
5
4
2
4
5
4
5
5
39
Alternative 3
Resource
Utilization
5
5
5
2
3
3
3
5
5
36
Notes: Scale of 1-5, where 5 = Highest Attainment
Source: Terranext, 1996a
P:\J280-OI4\WP\ROD\TABLE2.WPD
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APPENDIX A
ARARs
-------
SUMMARY OF FEDERAL AND STATE ARARS
Standard, Requirement,
Criteria, or Limitation
Ciiatlon
Applicable
Relevant and;
....; Appropriate
Description
FEDERAL
Clean Air Act,
National Primary and Secondary
Ambient Air Quality Standards
National Historic Preservation
Act (NHPA)
Executive Order 11593
Protection and Enhancement of
the Cultural Environment
Hazardous Materials
Transportation Act
40 CFR Part 50
!6USC§470etseg.
40 CFR §6.30l(b)
36 CFR Part 63, Part 65,
Part 800
16 USC §470
49 USC § 1801-1813
49 CFR 107, 171-177
No
Yes
Yes
Yes
(for contingency
reuse only)
No
—
—
National ambient air quality standards (NAAQS) are
implemented through the New Source Review Program and
State Implementation Plans (SIPs). The federal New
Source Review program address only major sources. There
will be no emissions associated with the chosen remedial
action in OU3. Emissions associated with the contingency
remedy will be limited to fugitive dust associated with
moving and sorting the slag for reuse. These activities will
not constitute a major source. Therefore, attainment and
maintenance of NAAQS pursuant to the New Source
Review Program are not ARARs. See Colorado Air
Pollution Prevention and Control Act concerning
applicability of requirements implemented through the SIP.
Expands historic preservation programs; requires
preservation of resources included in or eligible for listing
on the National Register for Historic Places.
Directs federal agencies to institute procedures to ensure
programs contribute to the preservation and enhancement
of non-federally owned historic resources. Consultation
with the Advisory Council on Historic Preservation is
required if removal activities should threaten cultural
resources.
Regulates transportation of hazardous materials.
P \J280-OI4\FINALROD\OU3ARAR.FNL
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SUMMARY OF FEDERAL AND STATE ARARS (Continued)
Standard, Requirement,
Criteria, or Limitation
Citation
Applicable
Relevant and
Appropriate
Description..
STATE OF COLORADO
Colorado Air Pollution
Prevention and Control Act
5CCR 1001 .Regulation I,
Section III.D
Yes
Requires all sources of paniculate emissions to apply
technically feasible and economically reasonable control
measures. APCD has the authority to ask for a fugitive
emission control plan from any location, if blowing
paniculate matter is a problem. The site does not need to
be in active use for this requirement to apply. Technically
feasible and economically reasonable control measures will
be applied to reuse of the stockpiled fine slag.
Colorado Air Pollution
Prevention and Control Act
5CCR 1001-3;
Sections III.D.i.b.c.d.
Sections III.D.2.b,c,e,f,g.
Regulation I
Yes (for contingency
reuse only)
Regulation No. I provisions concerning fugitive emissions
for storage and stockpiling activities, haul roads, and haul
trucks are applicable (5 CCR 1001-3; Sections
llr.D.2.b,c,e,f,g.) to the reuse contingency.
Colorado Air Pollution
Prevention and Control Act
5 CCR 1001-4;
Regulation 2
Yes (for contingency
reuse only)
Provisions concerning odors would be applicable if
contingency reuse were to cause objectionable odors.
Colorado Air Pollution
Prevention and Control Act
5 CCR 1001-5
Regulation 3
APENs
Yes (for contingency
reuse only)
Substantive provisions of APENs will be met.
Colorado Air Pollution
Prevention and Control Act
5 CCR 1001-10
PartC(l)&(ll)
Regulation 8
Yes
(for contingency
reuse only)
Regulation 8 sets emission limits for lead. Applicants are
required to evaluate whether the proposed activities would
result in the Regulation 8 lead standard being exceeded.
There are no emissions associated with the chosen remedial
action. The contingency reuse in OU3 is not projected to
exceed the emission levels for lead, although some lead
emissions may occur. Compliance with Regulation 8 will
be achieved by adhering to a fugitive emissions control
plan prepared in accordance with Regulation No. I.
P:V3280-OM\RNALROD\OU3ARAR.FNt
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SUMMARY OF FEDERAL AND STATE ARARS (Continued)
Standard, Requirement,
Criteria, or Limitation
Colorado Air Pollution
Prevention and Control
Colorado Water Quality Control
Act, Storm Water Discharge
Regulations
Colorado Noise Abatement Act
Citation
5 CCR 1001-14;
Ambient Air Quality
Standards
5 CCR 1002-2
CRS§§ 25-12-101 to 108
Applicable
Yes (for contingency
reuse only)
Yes
Yes (for contingency
reuse only)
Relevant and
Appropriate
—
Description
Provisions concerning State TSP standards and Federal
PM- 10 standards would apply if contingency reuse occurs,
or if the Site is the subject of fugitive emission complaints.
In such a case, compliance with the applicable provisions of
the Colorado air quality requirements will be achieved by
adhering to a fugitive emissions control plan prepared in
accordance with Regulation No. 1 .
Establishes requirements for storm water discharges (except
portions relating to Site-wide Surface and Groundwater).
Substantive requirements for storm water discharges
associated with construction activities are applicable.
Establishes maximum permissible noise levels for
particular time periods and land use.
P:\3280-OI4\FINALROD\QU3ARAR.FNL
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