PB95-963152
EPA/AMD/R08-95/107
February 1996
EPA Superfund
Record of Decision Amendment:
Portland Cement Co.,
(Kiln Dust 2 & 3) (O.U. 1 & 2),
Salt Lake City, UT
9/29/1995
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DECLARATION STATEMENT
FOR THE
AMENDED RECORD OF DECISION
PORTLAND CEMENT CO. (KILN DUST #2 AND #3)
COMBINED OPERABLE UNITS 1 AND 2
SALT LAKE CITY, UTAH
SITE NAME AND LOCATION
Portland Cement Co. (Kiln Dust #2 and #3)
Salt Lake City, Utah
STATEMENT OF BASIS AND PURPOSE
This decision document is an amendment to the Records of Decision (RODs) for Operable
Units (OUs) 1 and 2 signed on July 19, 1990 and March 31, 1992, respectively for the
Portland Cement Co. (Kiln Dust #2 and #3) Superfund Site (the Site). In June 1992, EPA
and UDEQ combined OUs 1 and 2 to facilitate RD/RA. The OU-1 and OU-2 combined
remedies are hereinafter referred to as the combined remedy. During remedial design (RD)
of the combined remedy, EPA and the Utah Department of Environmental Quality (UDEQ)
received new information which prompted modifications to the combined remedy. This
document sets forth the modified combined remedy for the Site. This ROD Amendment is
undertaken pursuant to the requirements delineated in Section 400.345 (c)(2)(ii) of the
National Contingency Plan (NCP) and Section 117 of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA).
This document explains the basis for modifying the selected remedy for the Site that was set
forth in the original RODs. The information that forms the basis for this remedial action
decision is contained in the administrative record for the Site, and is summarized in the
attached Decision Summary.
The State of Utah concurs with the modified combined remedy for the Site as set forth
herein.
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 ROD, may present an imminent and
substantial endangerment to public health, welfare, or the environment.
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DESCRIPTION OF THE MODIFIED COMBINED REMEDY
The modified combined remedy addresses the contaminant sources at the Site including
cement kiln dust (CKD) and chromium-bearing brick. The modified combined remedy also
addresses CKD-contaminated soil underlying the CKD. EPA and UDEQ are addressing
contaminated groundwater at the Site through a separate OU, OU-3. UDEQ is the lead
agency for the on-going remedial investigation/focused feasibility study for OU-3.
The modified combined remedy includes the following major components:
• Removal and off-site disposal of CKD and contaminated soil. Disposal could
occur in various types of facilities;
• Removal and off-site treatment and disposal of chromium-bearing bricks;
• Reuse of non-hazardous debris as Site fill material; and
• Following removal activities, covering the site with a minimum of 18 inches of
clean backfill.
STATUTORY DETERMINATIONS
The modified combined 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 the
maximum extent practicable and, in part, satisfies the statutory preference for remedies that
employ treatment that reduces toxlcity, mobility or volume as a principle element.
Because the modified combined remedy will leave highly alkaline soils on site, a review will
be conducted within five years following the commencement of remedial action to ensure that
the remedy continues to provide adequate protection of human health and the environment.
ltt/LT Duprey, DirectorJ \ Date
ous Waste Management Division
EPA Region Vm
Dianne R. Nielson, Executive Director Date
Utah Department of Environmental Quality
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DECISION SUMMARY
AMENDED RECORD OF DECISION
PORTLAND CEMENT CO. (KILN DUST #2 & #3)
COMBINED OPERABLE UNITS 1 AND 2
SALT LAKE CITY, UTAH
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DECISION SUMMARY
TABLE OF CONTENTS
I.
INTRODUCTION 2
H. DESCRIPTION OF ALTERNATIVES AND REASONS FOR MODIFYING
1. Original Combined Remedy 3
2. Reasons For Modifying The Remedy (New Information): 4
3. Modified Combined Remedy 7
4. Summary of Changes to The Combined Remedy 8
m. EVALUATION OF ALTERNATIVES 8
IV. THE SELECTED REMEDY 11
V. STATUTORY DETERMINATIONS 13
List of Tables
Table 1 MODIFIED COMBINED REMEDY COST ESTIMATE 15
Table 2 REMEDY COST ESTIMATE PRESENT WORTH CALCULATIONS . . 16
Table 3 ARARs for MODIFIED COMBINED REMEDY 17
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DECISION SUMMARY
FOR THE
AMENDED RECORD OF DECISION
PORTLAND CEMENT CO. (KILN DUST #2 & #3)
COMBINED OPERABLE UNITS 1 AND 2
I. INTRODUCTION
This document sets forth the modified selected remedy for the Portland Cement Co. (Kiln
Dust #2 & #3) Superfund Site (Site), Combined Operable Units 1 and 2. This document also
summarizes the basis for modifying the original remedy. This ROD amendment was
developed to fulfill the requirements of the Comprehensive Response, Compensation, and
Liability Act of 1980 (CERCLA) as amended by the Superfund Amendment and
Reauthorization Act of 1986 (SARA) §117 and the National Contingency Plan (NCP) 40
CFR Part 300.435(c)(2)(ii).
The Site is located in Salt Lake City, Utah within a triangular area defined by Indiana
Avenue, Redwood Road, and the Jordan River Surplus Canal. The 70 acre Site is a former
dumping ground for cement kiln dust (CKD) and chromium-bearing kiln bricks, by-products
of the cement manufacturing process. There is an estimated 500,000 cubic yards of CKD
and 360 tons of chromium-bearing bricks at the Site.
The State of Utah Department of Environmental Quality (UDEQ) is the lead agency for
conducting remedial design and remedial action (RD/RA) at the Site. The U.S.
Environmental Protection Agency (EPA) is the support agency at the Site.
The RODs for Operable Units (OUs) 1 and 2 were signed on July 19, 1990 and March 31,
1992, respectively. In June of 1992, EPA and UDEQ combined OUs 1 and 2 to facilitate
RD/RA. The OU-1 and OU-2 combined remedies are hereinafter referred to as the
combined remedy. During RD of the combined remedy, EPA and UDEQ received new
information which prompted a reevaluation of the original combined remedy. This
information is described in detail in the Section n of this document.
This document does not attempt to fully summarize the basis for remedial action at
the Site. The original RODs and the administrative record (AR) for the Site provide this
basis and should be referenced for this information.
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In accordance with the NCP section 300.825(a)(2), this ROD amendment is part of
the AR for the Site. The AR for this Site is currently located at the following locations:
EPA Superfund Records Center
999 18th Street, Fifth Floor
Denver, Colorado 80202
Hours: M-F 8:00 a.m. to 4:30 p.m.
Chapman Library
577 South 900 West
Salt Lake City, Utah 84104
Hours: M-Th 10 a.m. to 8 p.m.
Fr/Sat 10 a.m. to 6 p.m.
H. DESCRIPTION OF ALTERNATIVES AND REASONS FOR MODIFYING THE
REMEDY
Both the original combined remedy and the modified combined remedy address all
contaminant sources and the contaminated soil at the Site.
1. Original Combined Remedy
The original combined remedy involves removal and off-site disposal of CKD in a
landfill constructed specifically for the Site waste. Co-disposed chromium-bearing bricks
would be separated from the CKD and temporarily stored on-site. Co-disposed, non-
hazardous materials at the Site, such as construction debris, would also be removed and
disposed of in the landfill along with the CKD.
The landfill would be located in the general vicinity of the Salt Lake Valley Landfill
in Salt Lake County. It would be constructed as an industrial waste, double-lined landfill
equipped with leak detection. The landfill would have a layered cover system with a
synthetic membrane and a six foot chain link fence to provide security.
Site soils contaminated above the action levels would be excavated. Contaminated
soils that exhibit characteristics of a hazardous waste, as defined by the Resource
Conservation and Recovery Act (RCRA), would be treated on-site. The stored chrome
bricks at the Site would also be treated on-site. Treated materials and contaminated soils
would be disposed of off-site at an appropriate facility. The soil action levels would be, for
lead, 500 parts per million (ppm) and, for arsenic, 70 ppm. Chromium-bearing bricks would
be treated through chemical fixation followed by solidification and the soils that exhibit
characteristics of a hazardous waste would be treated by solidification.
Following removal activities, the entire Site would be covered with a minimum of 18"
of clean backfill.
Ground water at the Site would be monitored both before and after removal of the
CKD and contaminated soils. The purpose of this monitoring would be to assess the need
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for ground-water remediation in the future.
If necessary, institutional controls in the form of deed restrictions would be imposed.
These controls would be designed to control, as necessary, future ground water and land use
at the Site. The need for institutional controls would be assessed during remedial design.
Operations and maintenance (O&M) of the remedy would include, at a minimum, 1)
routine inspections of the new landfill site, 2) maintenance, as necessary, of the new landfill
cap and the 18 inch soil cover at the Superfund Site, and 3) annual monitoring of the ground
water quality surrounding the new landfill.
The remedy would cost $19.3 million in present worth dollars. This cost assumes
that the total capital costs would be $23.5 million spent over a five year period and annual
O&M costs of $5',000 for a thirty year period. A summary of this cost estimate is provided
in Table 2 and in the RODs for OU-1 and OU-2.
The major applicable or relevant and appropriate requirements (ARARs) for the
remedy would be 1) State Hazardous Waste Storage regulations, 2) RCRA Land Disposal
Regulations, and 3) Federal and State Air Quality Rules. Major rules which would apply to
offsite activities include: 1) the State and Federal Solid and Hazardous Waste Rules, 2) the
CERCLA Offsite Rule, and 3) the Department of Transportation Hazardous Materials
Transport Rules. A complete listing of the ARARs for the remedy is provided in the RODs
dated July 19, 1990 and March 31, 1992.
2. Reasons For Modifying The Remedy (New Information):
Since signing the Site RODs, EPA and UDEQ have received new information which
has prompted consideration of a modified remedy. This information is as follows:
a. Unsolicited Proposals from Commercial Landfills: Several existing commercial
landfills have contacted UDEQ with unsolicited proposals to accept the Site CKD. Some of
these offers indicate that disposal in commercial landfills could be as or more cost-effective
than constructing a new landfill.
b. Public Concerns Regarding Landfill Location; Members and leaders of the Salt Lake
City and County and Magna communities have expressed opposition to constructing a new
landfill in Salt Lake County. Summaries of the concerns raised by these communities can be
found in the responsiveness summaries for the OUs 1 and 2 RODs and this ROD
amendment.
d. EPA Reevaluation of RCRA Applicability; Since signing the OU-2 ROD, EPA has
concluded that soils contaminated with CKD are exempt from regulation under the RCRA
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Subtitle C law (as is CKD).1 Previously, EPA took the position that soils contaminated with
CKD were considered a RCRA hazardous waste and subject to RCRA Subtitle C
requirements. One such RCRA Subtitle C requirement is that the waste be treated prior to
disposal. Under EPA's new RCRA interpretation, soils that are contaminated with CKD do
not need to be treated prior to disposal.
e. Value Engineering; During value engineering sessions held during Site remedial design,
EPA and UDEQ made two cost saving determinations:
1) Since soils do not need to be treated prior to disposal, chrome bricks can be
treated less expensively off-site than on-site because of the economies of scale. If
only the chromium-bearing bricks require treatment, it becomes more expensive to
design, mobilize, and operate a treatment facility on the Site than to send the
materials to an existing treatment facility off-site.
2) Non-hazardous debris which has been disposed along with the CKD at the Site can
be safely re-used at the Site as fill material following removal of the CKD. Studies
indicate that there are approximately 300,000 cubic yards of construction debris
mixed with soil fill at the Site, mostly concentrated in the west portion. Value
engineering indicates that this soil and debris may provide a safe and cost-effective fill
material for the Site.
Based on the new information set forth in this section, EPA proposed a modified
combined remedy in November 1993. This proposal was set forth in an EPA and UDEQ
public fact sheet entitled: Explanation of Significant Differences and Proposed Plan to Amend
the Records of Decision for Operable Units 1 and 2. dated November 1993 ("the Proposed
Plan"). Since issuing the Proposed Plan, events have occurred that have prompted changes
to the proposed Modified Combined Remedy. These events are as follows:
a. Start of OU-3 RI/FFS; In early 1994, EPA and UDEQ agreed to commence work
on a remedial investigation/focused feasibility study (RI/FFS) for the ground water operable
unit at the Site (OU-3). Previously, EPA and UDEQ planned to address QU-3 following
removal of the CKD and soil. During remedial design it became apparent that it was
possible, from a technical standpoint, to complete the RI/FFS process for OU-3 concurrent
with remedial design and remedial action for OUs 1 and 2.
Starting the OU-3 RI/FFS affects the combined remedy in that groundwater
1 This determination was set forth in a memorandum from EPA headquarters offices to
EPA Region VTH dated June 30, 1993. The subject of the memorandum is "Clarification of
RCRA Application to Soils Contaminated by Cement Kiln Dust". This memorandum is in
theAR.
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monitoring and institutional controls, which were part of the combined OU-1 and OU-2
remedies, will now be addressed through implementation of the OU-3 remedial process.
b. State Assurances for Operations and Maintenance In February 1995, EPA
awarded UDEQ a cooperative agreement (CA) for OU-1 and OU-2 remedial action at the
Site. As part of the CA, UDEQ assured the future maintenance of the remedy as necessary
to abate a direct and immediate threat to public health and the environment. In performing
operations and maintenance, UDEQ will be taking appropriate measures to assure that there
is not unacceptable exposure to the alkaline residual contamination which will remain at the
Site following completion of remedial action. UDEQ and EPA are negotiating with the
property owners to place deed restrictions on the Site to reduce the risk of unacceptable
exposure to contaminants as described above. However, if UDEQ and EPA are unable to
reach an agreement with the property owners, UDEQ may rely upon its statutory authorities
and powers to satisfy its assurance, so finalization of the agreement with the property owners
to place deed restrictions on the Site is not a prerequisite to implementing the remedy.
The original combined remedy called for institutional controls, as necessary, to
control exposure to residual contamination at the Site. Since UDEQ has assured the future
maintenance of the remedy as described above, IC's for this purpose are no longer a
necessary component of the remedy.
c. Summitville Feasibility Study; In the Proposed Plan, EPA and UDEQ proposed
using the Site CKD as an acid neutralizing agent as part of EPA's emergency response at the
Summitville Mine in Colorado. Since issuing the Proposed Plan, EPA has determined that
the Site CKD cannot be cost-effectively transported to the Summitville mine. Therefore, use
of CKD as a resource is no longer a component of the combined remedy.
d. Design Site Characterization One remedial design task involved more-accurately
defining the vertical extent of contamination at the Site. The primary purpose of this task
was to quantify the volume of materials to be removed so that remedial action contractors
could more accurately and competitively bid the project. Results of the design site
characterization indicate that contaminated soil above the action levels and underlying the
CKD extends to a maximum depth of 18". In some areas of the Site the design sampling
showed residual contamination extending beyond 18", however, those areas were in all cases
below the water table. These areas will be addressed through the OU-3 (groundwater)
remedial process.
The OU-2 ROD calls for removal of all Site soil above the action levels. However,
the ROD does not specify a maximum remediation depth. Based on results of the site
characterization sampling and to address remedial action contracting concerns, EPA and
UDEQ have modified the remedy so that it requires excavation and disposal of all
contaminated soils to a maximum depth of 24".
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3. Modified Combined Remedy
Based on analysis of the new information presented above, the following modified
remedy was developed:
CKD would be removed and disposed of off-site. Disposal could occur in either a
commercial landfill or a landfill constructed off-site specifically for the Site CKD (as in the
original remedy). Based on information received during remedial design, disposal in a
commercial landfill would provide the best balance of the NCP's nine criteria (these criteria
are summarized in Section EL of this document). Final selection of the disposal option
(commercial versus constructing a new landfill) would be made following evaluation of bids
received from commercial landfills during the remedial action contractor procurement
process. Construction of a new landfill would be considered only if disposal in a commercial
landfill is found to provide an unacceptable balance of the nine evaluation criteria.
The landfill chosen or constructed would be lined and capped according to applicable
laws and would comply with EPA's Off-site Rule. Co-disposed non-hazardous materials at
the Site would either be disposed of off-site or used at the Site as backfill (this decision
would be made during remedial action and would be based on whether it is economically
feasible to separate CKD from non-hazardous debris).
CKD-contaminated soils would be removed to a maximum depth of 24" and disposed
of off-site. Contaminated soils would not be treated prior to disposal. Chrome bricks would
be separated from the CKD and be treated and disposed of off-site. Chrome bricks would be
treated and disposed of in accordance with applicable RCRA land disposal regulations.
Following removal activities, the entire Site would be backfilled with a minimum of 18" of
clean backfill.
O&M of the remedy would include: 1) routine inspections of the new landfill site (if
one is built), 2) maintenance, as necessary, of the new landfill cap, and 3) maintenance, as
necessary, of the 18 inch soil cover at the Superfund Site. If a new landfill is not
constructed, O&M would be limited to only item 3): maintenance, as necessary, of the 18"
cap at the Site.
The remedy would cost $ 18.6 million in present worth dollars. This cost assumes
that the total capital costs would be $ 21.8 million spent over a five year period and annual
O&M costs of $5,000 for a thirty year period. A summary of this cost estimate is provided
in Tables 1 and 2.
The major ARARs for the remedy would be 1) State Hazardous Waste Storage
regulations and 2) Federal and State Air Quality Rules. Major rules which would apply to
off site activities include: 1) the State and Federal Solid and Hazardous Waste Rules, 2) the
CERCLA Off-site Rule, and 3) the Department of Transportation Hazardous Materials
Transport Rules. Table 3 provides a complete analysis of the ARARs for the modified
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remedy.
4. Summary of Changes to The Combined Remedy.
The differences between the original and proposed modified combined remedies are
summarized below. This summary also indicates which changes to the remedy EPA and the
State consider fundamental2 changes rather than significant changes:
. Original Combined Remedy:
Fundamental Changes*
o Treat contaminated soils to meet land-ban restrictions o
(apply RCRA subtitle C to soils).
o Non-hazardous debris at the Site is to be removed and o
disposed of off-site.
Significant Changes:
o Removal and off-site disposal of CKD. Construct o
landfill near Salt Lake Valley Landfill.
Modified Combined Remedy:
Do not treat contaminated soils prior to disposal.
Non-hazardous debris would either be used as Site
backfill or disposed of off-site.
Removal and off-site disposal of CKD. Consider the
following options for disposal:
a. Dispose of CKD in a permitted
commercial landfill.
b. Construct a landfill off-site.
o Use double liner for landfill interior and cap with
vegetated layer. .
o Treat chrome bricks on-site.
Type of liners used would depend on regulations
governing the landfill chosen for disposal.
Treat chrome bricks off-site.
HI. EVALUATION OF ALTERNATIVES
This section provides the comparative analysis of the Original Combined Remedy and the
Modified Combined Remedy with respect to the nine key criteria established in the NCP.
These criteria are:
(1) Overall protection of human health and the environment;
(2) Compliance with ARARs;
(3) Use of treatment to achieve a reduction in the toxicity, mobility or volume of
contaminants;
2 The criteria used to classify changes as significant and fundamental are set forth in the
NCP.
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(4) Long-term effectiveness and permanence in protecting human health and the
environment;
(5) Short-term effectiveness in protecting human health and the environment;
(6) Implementability;
(7) Cost-effectiveness;
(8) State acceptance; and
(9) Community acceptance.
Criteria 1 and 2 are threshold criteria and must be met by the selected remedial action
alternative. Criteria 3,4,5,6, and 7 are balancing criteria. The final two are modifying
criteria which are used to evaluate the alternatives based on UDEQ and community concerns.
The strengths and weaknesses of the alternatives were weighed to identify the alternative
providing the best balance among the nine criteria. This section provides a summary of this
analysis.
Overall Protectiveness of Human Health and the Environment
Both alternatives would equally reduce risks to human health and the environment at the
Site in that both alternatives provide for complete removal of waste sources and soils
contaminated above action levels.
Compliance with ARARs
Both Alternatives would comply with all ARARs at the Site.
Long-term Effectiveness
At the Site, both alternatives equally provide for long-term effectiveness and permanence
in that both alternatives provide for complete removal of waste sources and soils
contaminated above action levels.
Off the Site, the modified combined remedy is more effective in the long-term because, if
an existing commercial landfill is used for disposal, there will not be the added operations
'and maintenance requirements associated with maintaining a new landfill for the waste CKD
and soil.
Reduction of Toxicitv. Mobility, and Volume Through Treatment
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The modified combined remedy is less-effective at reducing the toxicity of contaminated
soil since soils would not be treated prior to disposal.
Both alternatives provide for reduction of mobility of CKD and contaminated soils in that
the wastes will be disposed of in accordance with EPA's Off-site Rule. However, the
original combined remedy would provide better reduction of the mobility of CKD because
the waste would definitely be disposed of in a double-lined landfill.
Both alternatives equally provide for reduction of mobility and toxicity of chromium-
bearing bricks through off-site treatment and disposal.
Short-term Effectiveness
The modified remedy is more effective in the short-term because it could potentially be
implemented by the end of 1995. The original remedy, on the other hand, would likely take
2 to 3 years longer because of the time associated with permitting and constructing a new
landfill. However, the modified remedy is less protective in the short-term due to risks
associated with transporting contaminated materials because bricks will be treated off-site and
soils would not be treated prior to disposal.
Implementability
The modified remedy is more implementable because there are more options for disposal
of CKD. As described above, several existing commercial landfills are interested in
receiving the CKD. Moreover, alternatives for disposal of CKD that do not require
constructing a new landfill are more viable since there are uncertainties associated with
successfully obtaining a new landfill permit. In addition, because soils no longer require
treatment, design and development of a treatment system is no longer necessary.
Cost
The modified remedy costs the same as or less than the original remedy in the following
areas:
1. A commercial facility would be used for disposal of CKD only if it is as or more
cost-effective than constructing a landfill. As discussed in Section n., remedial
design estimates indicate that the costs for transportation and disposal of CKD in a
newly constructed landfill are comparable to disposing it in a commercial landfill.
2. The modified remedy would not include the cost of treating the contaminated soils
prior to disposal. This amounts to a savings of approximately $2.9 million in capital
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cost.3
3. By treating the chromium-bearing brick off-site instead of on-site a treatment process
does not need to be designed and a treatment plant does not need to be mobilized.
Design estimates indicate that treating the bricks off-site would save approximately
$1,358.50 per ton of brick4.
4. Reusing the non-hazardous construction debris on the West site as backfill could save
up to $29 per ton of material reused5.
State Acceptance
UDEQ has worked in partnership with EPA throughout the ROD Amendment process and
concurs with the selected remedy for the Site.
Community Acceptance
Community input on the proposed modified remedy was solicited by EPA and UDEQ
during the public comment period from November 1, 1993 to December 1, 1993. No
opposition to the proposed modified remedy was expressed with the exception of one written
comment. This comment expressed opposition over the possibility of constructing a new
landfill near Magna's residential areas (as called for in the original combined remedy).
Responses to community comments are in the attached responsiveness summary.
IV. THE SELECTED REMEDY
EPA and UDEQ believe that the Modified Combined Remedy meets the threshold
evaluating criteria of the NCP and provides the best balance of the remaining criteria among
the two alternatives considered. EPA and UDEQ have therefore selected the Modified
Combined Remedy, as described above, to address risks posed by the Site.
Remedial Action Objectives: J
The objectives of the modified combined remedy are:
1) to remove the source of soil and ground water contamination;
3 This figure is based on the cost estimate for soils treatment provided in the OU2 ROD.
4 This.figure is based on URS estimates published in memo from Ralph Rice to Steven
Thiriot dated May 26, 1993. This figure assumes disposal at the ESI facility.
5 This figure is based on the engineer's cost estimate published by URS consultants.
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2) to reduce risks associated with:
a. direct contact with waste CKD;
b. exposure to windblown dust from the waste CKD;
c. exposure to soils with elevated levels of lead, arsenic, and alkalinity; and
d. exposure to chromium
3) to minimize restrictions on future use of the Site; and
4) to comply with all CERCLA requirements and all identified ARARs and applicable
laws and regulations for off-site work.
Remediation Goals and Performance Standards!
"Remediation goals are designed, to attain the remedial action objectives. Since no Federal
or State chemical specific ARARs exist for soils, action levels were developed through a site-
specific risk analysis. The action level for lead is 500 ppm and is based upon an acceptable
blood-lead level in children exposed to the soil through ingestion. At the lead action level,
no more than 5% of children exposed to soil at the Site are predicted to have a blood-lead
level above the acceptable level of 10 /ig/DL.
The action level for arsenic in soil is 70 ppm. Although arsenic levels above 70 ppm
have not been detected on the site, the action level is established because arsenic can not be
ruled out by statistical analysis as a contaminant of concern. Soil containing arsenic at the,
action level concentration pose a 2 x 10'5 risk of contracting cancer as a result of ingesting
soil and a 5 x 10~J risk of contracting cancer as a result of ingesting vegetables grown in the
soil.
An action level for alkalinity was not determined since there is currently no method of
quantifying risks due to exposure to alkaline soils. Therefore, the selected remedy does not
require removal of soil exceeding a specific pH or alkalinity. However, the selected remedy
requires placement of a clean layer of fill to a minimum depth of 18" following removal of
site wastes. This clean layer is designed to provide protection from exposure to high pH soil
remaining on the Site, to enhance Site soil pH equalization to levels near background, and to
limit the need for restrictions on future use of the Site.
In summary, the remediation goals for the Site are:
1. All CKD will be removed and disposed of off-site;
2. Soils with contaminant concentrations above the action levels will be removed to a
maximum depth of 24" and disposed of off-site. The action level for lead is 500 ppm
and the action level for arsenic is 70 ppm;
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3. All chromium-bearing kiln bricks will be removed and transported off-site where they
will be treated and disposed of. The chromium-bearing bricks will be treated to
comply with all applicable laws.
4. Following removal of the CKD, chrome bricks, and contaminated soils, the entire site
will be covered with a minimum of 18 inches of clean fill.
The estimated cost of the Modified Combined Remedy is summarized in Tables 1 and 2.
V. STATUTORY DETERMINATIONS
The selected remedy meets the statutory requirements of Section 121 of CERCLA. The
statute requires that remedial actions undertaken at Superfund sites be protective of human
health and the environment. The statute also mandates that the selected remedy comply with
applicable or relevant and appropriate standards established under Federal and State
environmental laws unless a statutory waiver is justified. In addition, the selected remedy
must be cost-effective and utilize permanent solutions and alternative treatment technologies
or resource recovery technologies to the maximum extent practicable. The statute also
includes a preference for remedies that employ treatment that permanently and significantly
reduces the volume, toxicity, or mobility of hazardous substances as their principal element.
The following sections describe how the selected remedy meets these statutory requirements.
Protection of Human Health and the Environment:
The selected remedy would remove contaminant sources from an area of relatively high
population that is subject to increased urbanization, thereby providing the maximum
reduction of the risks of direct contact and exposure to blowing dust and removing a potential
source of groundwater contamination. The chromium-bearing bricks will be treated to
eliminate or reduce associated health risks both on the Site and at the off-site disposal
facility. The selected remedy is considered to be highly protective of human health and the
environment. The implementation of the remedy will not pose unacceptable short-term risks.
The selected remedy will facilitate the final remediation of the Site by removing potential
sources of groundwater contamination.
Attainment of Applicable or Relevant and Appropriate Requirements f ARARs) of
Environmental Laws;
The primary requirements that are applicable or relevant and appropriate to the selected
remedy are:
• EPA's CERCLA Offsite Rule governing the offsite transfer of CERCLA waste;
• Federal and State solid and hazardous waste disposal regulations;
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• Federal land disposal restrictions pertaining to storage of hazardous waste;
• Federal land disposal restrictions pertaining to the treatment of hazardous waste prior to
land disposal; and
• Federal and state air regulations on total suspended paniculate and fugitive dust
control.
The selected remedy will meet all ARARs. A summary of ARARs and guidelines to be
considered (TBCs) for the selected remedy is presented in Table 3.
Cost-Effectiveness;
The selected remedy is cost-effective in mitigating the Site risks posed by GKD,
contaminated soils, and chromium-bearing bricks. Section 300.430(f)(ii)(D) of the NCP
states that once a remedial action satisfies the threshold criteria (i.e., overall protection of
human health and the environment and compliance with ARARs), cost-effectiveness is
determined by evaluating the relationship between overall effectiveness and cost.
The component of the modified combined remedy which addresses CKD waste is more
cost-effective than the original remedy since it provides better overall protectiveness than the
original remedy at a comparable cost. This component requires less-long term O&M since a
new landfill will not need to be maintained.
The component of the modified combined remedy which addresses contaminated soils is
less-effective overall. The modified remedy provides for less reduction of the toxicity of the
contaminated soils since the soil will not be treated prior to disposal. Moreover, the
modified combined remedy poses more short term risks since the contaminated soils will be
transported to a disposal site without prior treatment. However, because the modified
combined remedy addresses contaminated soil less-expensively, its cost-effectiveness is equal
to or better than the original remedy.
Utilization of Permanent Solutions and Alternative Treatment Technologies:
The modified combined remedy utilizes permanent solutions and treatment technologies to
the maximum extent practicable. The modified combined remedy reduces the toxicity of the
chrome-bearing bricks through treatment. The modified combined remedy reduces the
mobility of all Site wastes through disposal in a landfill or facility which meets the
requirements of EPA's Offsite Rule.
Preference for Treatment as a Principal Element:
The modified combined remedy in part satisfies the statutory preference for remedies that
employ treatment as a principal element. Chromium-bearing bricks will be treated using
proven technologies to reduce available levels of chromium. Neither the CKD nor the CKD-
contaminated soil, however, will be treated prior to disposal. The remedy will not include
treatment of these materials because they are high-volume, low-toxicity wastes, exempt from
RCRA Subtitle C as a result of the BevUl Amendment.
14
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TABLE 1
Portland Cement Co| (Kiln Dust 2 & 3) Superfund Site
MODIFIED COMBINED REMEDY COST ESTIMATE
Item
1
2
3
4
5
6
7
8
g
10
11
Description
New Landfill:
Permits
Land Aquisition
Disposal of CKD + Soil
Haul, treat, and dispose chrome brick
Mobile sampling/analysis
Haul, grade, and compact clean fill
Subtotal:
Contingency [20% of subtotal] (2)
Engineering (4)
Mobilization [4% of subtotal] (2)
Construction Management [15% of subtotal] (2)
TOTAL CAPITAL COSTS:
O&M |5k/yr for 30 years] (2)
TOTAL PRESENT WORTH: (5)
Modified
Unit
1
30
523.000
360
10
169,400
Modified
Unit Cost
50,000 (2)
12,500 (2)
22 (2)
219 (3)
850 (2)
12(2)
Modified
Total Cost
50,000
375,000
11,506,000
78,840
8,500
2,032,800
14,051,140
2.810,228
2,100,000
562,046
2.107.671
$21,631,085
150,000
$18,514.458
(1) These estimates are designed to be accurate to at least +50 percent or -30 percent.
(2) Based on estimates set forth in original ROD for OU-1 or OU-2.
(3) Refer to URS Memo dated 5/26/93.
(4) Based on existing remedial design contract between UDEQ and URS Consultants.
(5) See Table 2 for discounting assumptions.
15.
-------
TABLE 2
ORIGINAL COMBINED REMEDY COST ESTIMATE
Capital costs
present worth @ 7% (3)
annual O&M
pw of O&M @ 7% year 0
Total present worth:
Totals:
23,517,000(2)
19.284,869
5,000
44,237
$19,329,106
years:
1
4,703,400
Portland Cement Co. (Kiln Dust 2 & 3) qifefund Site
Annual Expenditures:
234
4,703,400 4,703,400 4,703,400
4,703,400
MODIFIED COMBINED REMEDY COST ESTIMATE
Capital costs
present worth @ 7%
annual O&M
pw O&M @ 7% year 0
Total present worth:
Totals:
21,631,085
18,463,811
5,000
50,647
$18,514,458
years (4):
1 2
2.100,000 9,765,543
9.765,543
4
0
5
0
Notes:
(1) These estimates are designed to be accurate to at least +50 percent or -30 percent.
(2) Capital costs for the Original Combined Remedy are from the originalRODs for OU1 and OU2.
(3) Discount rate based on OSWER Directive No. 9355.3-20, dated June 25, 1993.
(4) Modified remedy can likely be implemented in three years based on current design schedule.
(5) Assumes year 1 incurs design costs only.
16.
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TABLE 3
ARARs for MODIFIED COMBINED REMEDY
Portland Cement Co. (Kiln Dust tfl & #3) Supermini! Site
Table 3, Page I
REQUIREMENT
CITATION
Applicable?/
Relevant and
Appropriate?
Applicable
Offsile
Law?
CHEMICAL-SPECmC ARARS - FEDERAL
CLEAN WATER ACT
- Effluent Limitations
- Toxic and Pretreatment Effluent
Standards
- NPDES
CLEAN AIR ACT
- National Primary and Secondary Ambient
Air Quality Standards
RESOURCE CONSERVATION AND
RECOVERY ACT
• Identification of Hazardous Waste
- Land Disposal Restrictions
COMMENTS
Section 301
Section 307
40 CFR Parts 122-125
yes/no
yes/no
no/no
yes
yes
yes
If site dewatering requires discharge of water to adjacent water body or POTW, this will
apply.
Would apply to discharge of dewatering effluent into POTW
Would apply to discharge of dewalering effluent into adjacent water bodies.
42 USC $§7401-7642
40 CFR Part SO
42 USC
§ §6907(a)(3) ,6944(a),6949(a)
40 CFR Pact 261
40 CFR Part 268
no/yes
yes
Dust control will be required before, during, and after construction.
yes/no
yes/no
yes
yes
Applies to task of identifying and segregating hazardous wastes on-sile. TSD facility
may run tests on chrome bricks to characterize waste.
Applies to offsite TSD facilities receiving chrome bricks. Portions either apply or are
relevant and appropriate to on-site activities such as segregation, identification, and
temporary storage of hazardous wastes on-site.
17.
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TABLE 3
ARAR.S for MODIFIED COMBINED REMEDY
Portland Cement Co. (Kiln Dust #2 & 13) Superfund Site
Table 3. Page 2
REQUIREMENT
CHEMICAL-SPECIFIC ARARS - STATE
UTAH WATER QUALITY RULES
- Utah Pollution Discharge Elimination
System
- Wastewaler treatment
UTAH AIR CONSERVATION ACT
- Air Pollution Prohibited
- Notice of Intent *. Approval Order '
- Non-attainment Area Requirements- New
Source
- Visible Emissions
- Sulphur Content of Fuels
- Control of Fugitive Dust Emissions
CITATION
-•; ,-. --. . -:. •...-. • • ...• •- : .-..•.
R3I7-8
R3I7-3.R317-4, R3I7-5.
R3 17-10
UCA Title 19 Section 19-2-101
R307-I-2.I
R307-I-3.I
R307-I-3.3
R307-I-4.I
R307-M.2
R-307-1-4.5
Applkable?/
Relevant and
: ADnroDriate?
no/no
yes/no
yes/no
no/yes
yes/no
yes/no
yes/no
yes/no
Applicable
Qffsite
..-. .-.iUw?.v.vt:.
yes
yes
yes
yes
yes
yes
yes
yes .
COMMENTS
-• • . • - ... .. ...... ... ....
Would apply to discharge of dewatering effluent into adjacent water bodies.
Would apply to discharge of dewatering effluent into POTW.
Prohibits any emissions which cause air pollution as defined in § 1 . 1 1
Some portions of this requirement may be relevant and appropriate to non-major sources
at the Site or off-site facility to which the waste is transferred.
Site is in a non-attainment area.
Visible emissions at Site must be controlled before, during, and after construction.
Visible emissions must not exceed 20% opacity.
Applies if certain fuels are burned at the Site.
Dust control will be required during construction
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TABLE 3
ARARs for MODIFIED COMBINED REMEDY
Portland Cement Co. (Kiln Dust #2 & #3) Superfiind Site
Table 3, Page 3
REQUIREMENT
UTAH SOLID AND HAZARDOUS
WASTE ACT
- Exclusion
- Characteristics of Hazardous Waste
- Lists of Hazardous Waste
- Land Disposal Restrictions
- Appendices
- Corrective Action Clean-up Standards
(Except Those Pertaining to Groundwater
Protection)
CHEMICAL SPECIFIC ARARs - LOCAL
SALT LAKE CITY ORDINANCE-
WASTEWATER CONTROL
ORDINANCE/RULES AND
REGULATIONS
ACTION-SPECIFIC ARARS • FEDERAL
CERCLA
- Offsile Rule
CLEAN WATER ACT
- Best Available Technology Effluent
Treatment Requirements
- Effluent Monitoring Requirements
CITATION
Applicable?/
Relevant and
Appropriate?
Applkable
Offsite
Law?
UC A Title 19 Chapter 6
R3 1 5-2-4
R3 15-2-9
R3 15-2- 10
R315-I3
R3 15-50
R315-I01
Title 37 revised ordinance of
Salt Lake City Corporation
yes/no
yes/no
yes/no
yes/no
yes/no
yes/no
:- : '•••
yes/no
yes
yes
yes
yes
yes
yes
yes
' ':"T"":CpMKlENTS ' •••.:•••:. ..
Applies in that it is used to determine which waste at the Site is a hazardous waste.
Applies in that it is used to determine which waste at the Site is a hazardous waste.
Applies in that it is used to determine which waste at the Site is a hazardous waste.
Applies to offsile disposal of chrome bricks.
Applies in that it is used to determine which waste at the Site is a hazardous waste.
Sets minimum clean-up standards for hazardous waste.
Applies if site water is discharged to sewer system.
40 CFR Part 300.440
40 CFR Part 122.44(a)
40 CFR Parts I22.4l(i) and
136.1-136.4
no/no
yes
Applies to off-site facilities to which the Site wastes are transferred.
yes/no
yes/no
yes
ye»
Would apply if dewatering effluent is discharged to water body as a point source. May
apply to off-site facilily(ies) to which Site wastes are transferred.
Would apply if dewatering effluent is discharged to water body as a point source. May
apply to off-site faciliry(ies) to which Site wattes ire transferred.
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Portland Cement Co. (Kiln Dust <7 & #3) Super-fund Site
Tahle3, Page 4
TABLES
ARARs for MODIFIED COMBINED REMEDY
REQUIREMENT
- Best Management Practices fnr Treatment
Effluent
- Discharge to POTW Requirements
- Storm water requirements ,
SOLID WASTE DISPOSAL ACT
- Land Disposal of Solid Waste
RESOURCE CONSERVATION AND
RECOVERY ACT
- Standards for Hazardous Waste
Generators
- Standards for Transporters of Hazardous
Waste
- Container Storage of Hazardous Waste
- Waste piles
- Chemical, Physical and Biological
Treatment
- Land Disposal Restrictions
CiTATION
40 CFR Parts 125.100
40 CFR Part 403 .5
40 CFR Part I22.26(c)lii
42 USC §§6901-6987
40 CFR Part 241
Applicable?/
Relevant and
Appropriate?
yes/no
yes/no
yes/no
Applicable
Offsite
• - .-i*W?,:;jv
yes
yes
yes
COMMENTS
Would apply if dewatering effluent is discharged to water body as a point source. May
apply to off-site facility (ies) to which Site wastes are transferred.
Would apply if dewatering effluent is discharged to POTW as a point source. May
apply to off-site faciliry(ies) to which Site wastes are transferred.
Applies to open excavations exceeding 4 acres. Excavations during remedial action will
likely exceed this amount. May apply to off-site facility (ies) to which Site wastes are
transferred.
yes/no
yes
Applies to off-site facilitiei to which Site waste is transferred. Will apply if non-
hazardous debris is used as Site backfill.
42 USC j)56907(a)(3),6944(a),6949(a)
40 CFR Part 262
40 CFR Part 263
40 CFR Parts 264.171-173
and 264.176-178
40 CFR Parts 264 .25 land
268.2
40 CFR Part 265.400 et seq.
40 CFR Part 268
yes/no
no/no
yes/no
yes/no
no/no
yes/yes
no
yes
yes
yes
yes
yes
Applies because EPA/UDEQ become generators by excavating chrome brick.
Applies to off-site transport of bricks.
Will apply if containers are used to temporarily store hazardous waste on-site.
Applies to temporary stock piling of chrome brick.
Applies to owners and operators of hazardous waste treatment facilities. The off-site
facility that will treat the bricks will comply with all waste handling, storage, reporting,
record keeping and manifest requirements.
Applies to offsite TSD facilities receiving chrome bricks. Portions either apply or are
relevant and appropriate to on-site activities such as segregation, identification, and
temporary storage of hazardous wastes on-site.
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TABLE 3
ARARs for MODIFIED COMBINED REMEDY
Portland Cement Co. (Kiln Dusl M. &. #3) Superftind Site
Table3. PageS
REQUIREMENT
- Definition of Inorganic Soil and Debris
- Waste-specific Prohibition- Third Third
Wastes
- Prohibition on Storage of Restricted
Wastes
- Hazardous Waste Permit Program
SURFACE MINING CONTROL AND
RECLAMATION ACT
- Erosion Control
- Backfill and Grading
- Revegetation
DEPARTMENT OF TRANSPORTATION
HAZARDOUS MATERIAL TRANSPORT
REGULATIONS
CITATION
40 CFR Part 268 (g,h)
40 CFR Part 268.35
40 CFR Part 268.50
40 CFR Part 270
30 CFR Part 816.41
30 CFR Part 816.102
30 CFR Part 816.11
40 CFR Parts 107, 171-179.
Applkable?/
Relevant and
Appropriate?
yes/no
no/no
yes/no
no/no ' .
no/yes
no/yes
no/yes
no/no
Applicable
Offcite
Law?
yes
yes
yes
yes
no
no
no
yes
COMMENTS
Depending on,- among other things, their size at the time of disposition, chrome brick
could be considered "soil and debris".
Muy apply to disposal of chrome bricks and mixtures thereof in off-site facilities.
May apply to temporary storage of chrome bricks if storage time exceeds threshold
amount.
Applies to off-site TSDs.
Relevant and appropriate to open excavations during RA.
Relevant and Appropriate to regrading the Site following remediation.
Relevant and Appropriate to re-vegetating the Site following remediation.
Applies to transportation of Site wastes, including CKD and chrome brick.
Action-Specific ARARs - Slate
UTAH SOLID AND HAZARDOUS
WASTE ACT
- Residues of Hazardous Waste in Empty
Containers
- Discarded Waste
- Application and Plan Approval
Procedures for TSDFs
- General Facility Standards for Owners
and Operators of TSDFs.
UCA Title 26 Chapter 14
R3 15-2-7
R3 15-2-11
R3I5-3
R3 15-8-2
yes/no
yes/no
no/yes
no/yes
yes
yes
yes
yes
Applies to use of hazardous waste container* at the site.
Applies to the Site in the event discarded wastes are discovered.
Substantive portions of these requirements are relevant and appropriate to temporary
storage of Site hazardous waste. Applies to off-site TSDFs.
Substantive portions of these requirements are relevant and appropriate to Site. Applies
to off-site TSDFs.
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Portland Cement Co. (Kiln Dust #2 & #3) Superfund Site
Table 3. Page 6
TABLE 3
ARARs for MODIFIED COMBINED REMEDY
REQUIREMENT
- Preparedness & Prevention
- Contingency Plan & Emergency
Procedures
- Closure and Post-Closure
- Use and Management of Containers
- Surface Impoundments
- Waste Piles
- Landfills
- Emergency Controls
UTAH AIR CONSERVATION ACT
- Emission Reporting
- Variances Authorized
- General Burning
- Emission Testing
- Unavoidable Breakdown
CiTATiON
R3 15-8-3
R3 15-8-4
RSI 5-8-7
R3 15-8-9
R3 15-8-1 1
R3 15-8- 12
R3I5-8-U
R3I5-9
UC A Title 19 Section 19-2-
101
R307-I-2.2
R307-I-2.3
R307-I-2.4
R307-I-3.4
R307-1-4.7
Applicable?/
Relevant and
.Appropriate?
no/yes
no/yes
no/yes
• yes/no
yes/no
yes/no
no/no
yes/no
yes/no
yes/no
yes/no
yes/no
yes/no
ACTION SPECinC ARARs - LOCAL
SALT LAKE CITY/COUNTY HEALTH
DEPARTMENT, HEALTH
REGULATIONS NO. 1, SOLID WASTE
MANAGEMENT FACILITIES
UCA Section 26A-I -121
yes/no
Applicable
OfTsite
taw? ;
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
COMMENTS
Substantive portions of these requirements are relevant and appropriate to Site
hazardous waste. Applies to off-site TSDFs.
Substantive portions of these requirements are relevant and appropriate to Site. Applies
to off-site TSDFs.
Substantive portions of these requirements are relevant and appropriate to Site. Applies
to off-site TSDFs.
Applies to use of containers at Site.
Applies if "surface impoundments" are constructed at the Site or Off-site TSDF.
Applies if "waste piles" are constructed at the Site or Off-site TSDF.
Applies to Off-site TSDFs.
Applies if hazardous wastes or materials are spilled at the Site.
Applies if "stationary source(s)" are constructed and operated at the Site or the facility to
which the Site wastes are transferred.
Variances may apply lo the Site.
Open burning of trash is prohibited at the Site.
Required if Site or off-site facility is considered a "source".
Applies to breakdown situations at the Site.
yes
These requirements may apply to disposal of non-hazardous debris at the Site. These
requirements would apply as "off-site" to the construction a landfill to dispose CKD.
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TABLE 3
ARARs for MODIFIED COMBINED REMEDY
Portland Cement Co. (Kiln Dust tfl & #3) Superhind Site
Table3, Page 7
REQUIREMENT
CITATION
Applicable?/
Relevant and
Appropriate?
Location-Specific ARARs - Federal
CLEAN WATER ACT
- Permits for Dredged or Fill Material
ARCHAEOLOGICAL AND HISTORIC
PRESERVATION ACT
HISTORIC SITES, BUILDINGS, AND
ANTIQUITIES ACT
ENDANGERED SPECIES ACT
EXECUTIVE ORDER ON FLOODPLAIN
MANAGEMENT
EXECUTIVE ORDER ON PROTECTION
OF WETLANDS
33 USC § 404
16 USC §§470
40CFRPart 6.30l(b)
40 CFR Part 6. 301 (a)
16 USC §§1531-1543
50 CFR Pans 17 & 402
40 CFR Part 6.302(h)
Exec. Order 11988
Exec. Order 11990
yes/no
yes/no
yes/no
yes/ no
no/no
yes/no
Applicable
Offsite
Law?
yes
yes
yes
yes
yes
yes
COMMENTS
Would apply to dredge or fill which may occur within the City Drain
Applies if artifacts are encountered during remedial action.
Applies if historic structures are encountered at the Site.
Applies if endangered species are encountered.
Site is not in any delineated iloodplain.
Site was a wetland before CKD fill occurred. Some wetland areas exist at the site.
LOCATION-SPECIFIC ARARS - STATE
Utah Antiquities Act
Utah Code Unann.
Title 9, Chapter 8 and Title
76, Chapter 6
yes/no
yes
The Utah Historical Society will review the intermediate design to ensure that Native
American artifacts are not adversely impacted. Risk is minimal because of the small
amount'of native soil that will be disturbed.
-------
RESPONSIVENESS SUMMARY
AMENDED RECORD OF DECISION
PORTLAND CEMENT CO. (KILN DUST #2 & #3)
COMBINED OPERABLE UNITS 1 AND 2
SALT LAKE CITY, UTAH
-------
RESPONSIVENESS SUMMARY
Table of Contents
A. OVERVIEW 2
B. BACKGROUND ON COMMUNITY INVOLVEMENT 3
C. SUMMARY OF COMMENTS RECEIVED DURING PUBLIC COMMENT
PERIOD 3
D. SUMMARY OF RECENT COMMUNITY RELATIONS ACTIVITIES 7
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FOR THE
AMENDED RECORD OF DECISION
PORTLAND CEMENT CO. (KILN DUST #2 & #3)
COMBINED OPERABLE UNITS 1 AND 2
SALT LAKE CITY, UTAH
A. OVERVIEW
In July 1990 and March 1992, EPA and UDEQ issued records of decision (RODs) describing
selected remedies for Operable Units 1 and 2 (OU1 and OU2), respectively. The public was
invited to comment on each of the proposed plans for these RODs, as required, and
Responsiveness Summaries were prepared for each ROD.
In May 1992 the OUs for the Portland Cement Co. (Kiln Dust #2 and #3) Superfund Site (Site)
were combined to facilitate remedial design (RD) and remedial action (RA). The selected
remedies for the two operable units were also combined and entailed removal and off-site
disposal of cement kiln dust (CKD); removal, on-site treatment and off-site disposal of
contaminated soil and chromium-bearing bricks; and placement of a protective layer of backfill
on the Site. This remedy is referred to as the "original combined remedy." RD began in
January 1993. In November 1993, EPA and UDEQ issued an Explanation of Significant
Differences (ESD)/Proposed Plan which proposed several modifications to the original combined
remedy, including:
• Disposal of CKD in one of three types of new or existing off-site facilities, rather than
in an off-site landfill built specifically for the CKD, or possible re-use of the CKD;
• Disposal of contaminated soil without prior treatment, rather than treating the soil before
disposal;
• Treatment of chromium-bearing bricks off-site, rather than on the Site; and
• Reuse of non-hazardous Site debris as fill material on the Site, rather than disposing of
the debris off the Site.
During the 30-day public comment period that followed the issuance of the ESD/Proposed Plan,
EPA and UDEQ received written and verbal comments from concerned citizens, elected officials
and representatives from community organizations. Based on these comments, it was concluded
that area residents and property owners would support the modified combined remedy, provided
the remedial action was effective in reducing the risk associated with the Site and did not create
environmental problems elsewhere.
-------
The following sections of this Responsiveness Summary address community involvement and
comments and responses received from the community.
B. BACKGROUND ON COMMUNITY INVOLVEMENT
Community involvement with the remedial process at the Site prior to July 1990 and March 1992
is discussed in the OU1 and OU2 RODs, respectively. In July 1992, the Community Relations
Plan for the Site was updated. The Portland Citizens Committee was formed in February 1993
to provide a forum for communication among concerned citizens, local government officials,
UDEQ and EPA. Periodic committee meetings open to the public were held in Salt Lake City
between February and May 1995 and are expected to continue throughout RD and RA. A series
of informational fact sheets has also enabled community participation.
C. SUMMARY OF COMMENTS RECEIVED DURING PUBLIC COMMENT
PERIOD
All public response to the proposed modifications to the combined remedy was received during
a public meeting held in Salt Lake City on November 10, 1993. One written comment was
received and the remainder were presented verbally at the meeting. Transcripts of the public
meeting are available at administrative record repositories in Denver and Salt Lake City. The
comments follow and are categorized by relevant topic.
Decision Process
Comment: A representative from the Salt Lake Community Action Program asked if the
community in the vicinity of the Summitville Supertund Site (Summitville) had
been informed about the possible receipt of CKD from the Portland Cement Site.
Response: The public was informed in the July 1993 Engineering Evaluation/Cost Analysis
(EE/CA) document for Summitville that an amendment such as CKD or lime may
be used to treat the acid-producing waste rock. The public was invited to
comment on the EE/CA before it was finalized.
This concern is no longer relevant because since issuing the Proposed Plan, EPA
has determined that the Portland Cement CKD cannot be cost-effectively
transported to the Summitville mine. Use of the CKD for this purpose is
therefore no longer a viable option.
Comment: A representative from the Salt Lake Community Action Program asked why the
contaminated soils have been reclassified as a non-hazardous waste.
Response: During RD, EPA Region Vffl reviewed the laws and regulations governing
hazardous waste. After their review, Region Vffl staff asserted that because the
-------
source of soil contamination was CKD, which is exempted from being a
hazardous waste, the soil should also be exempted from being a hazardous 'waste.
Region Vm formally requested an interpretation on this issue from EPA
Headquarters. EPA Headquarters subsequently ruled that soils contaminated with
CKD, given certain conditions, should be exempt from regulation as a hazardous
waste under RCRA Subtitle C. This ruling was published in a memo from Sylvia
Lowrance and Lisa Friedman/EPA Headquarters to Robert Duprey/EPA Region
VIH dated June 30, 1993. The CKD and contaminated soil will be disposed in
accordance with EPA's regulations regarding off-site disposal of wastes from
Superfund Sites.
Comment: An area resident asked if the proposed modifications to the remedy, including use
of the CKD at Summitville, are acceptable to the States of Utah and Colorado.
Response: The State of Utah supports the remedy modifications and concurs with EPA's
determination that the Summitville disposal option should be ruled out because the
CKD cannot be cost-effectively transported to the Summitville mine.
The State of Colorado's only authority regarding the proposed modifications to
the remedy relate to use of CKD at Summitville. Since disposal of the CKD at
the Summitville Mine is no longer an option, EPA has not formally solicited the
State's opinion it.
Proposed Handling. Treatment and Disposal of CKD. Contaminated Soil and Chromium-
Bearing Bricks
Comment: Representatives from the Salt Lake Community Action Program and the West Salt
Lake Community Council asked if the CKD from the Site could be put to
beneficial uses other than as a neutralizing agent at Summitville.
Response: Yes. There may be other beneficial uses for the CKD from the Site, provided the
approach better satisfies the nine criteria including implementability, cost
effectiveness and compliance with applicable laws than the disposal options being
considered. To date, no other uses which satisfy these criteria have been
formally proposed to EPA or the State.
Comment: An area resident asked how much CKD from the Site could be accepted by
Summitville and how Summitville plans to utilize the CKD. Also, who would
own the CKD after it is taken to Summitville?
Response: Summitville could use all of the CKD on the Site, provided it could be cost-
effectively transported to the mine and tests indicated that the CKD could serve
as an effective neutralizing agent. The owner of the mine pit would own all
waste rock and amendments, such as the CKD from the Site, placed in the mine
-------
pit.
Comment: An area resident asked if UDEQ or EPA has previously remediated sites
containing CKD.
Response: Yes. A ROD database search revealed three sites (two in Iowa and one in
Florida) containing CKD that are being remediated under the Super-fund program.
UDEQ and EPA have also successfully remediated large amounts of bulk
materials such as mine tailings and contaminated soils. CKD's unique properties
are well documented and have been and will continue to be considered during the
remedial process.
Comment: In a written comment, representatives from the Magna Area Council and the
Magna Water Improvement District expressed opposition to constructing a new
landfill near Magna1 s residential areas. They also asked about the commercial
facilities under consideration to receive Site wastes.
Response: Construction of a new landfill would be considered only if an existing commercial
landfill were not able to legally and cost-effectively accept the waste. If a new
landfill is built, areas outside of the Salt Lake Valley will be considered in
response to community concerns. Six existing commercial landfills are
considered to be potential recipients of Site wastes: Grassy Mountain and East
Carbon Development Corporation (ECDC) in Utah; Envirocare Services Inc.
(ESI) in Idaho; Conservation Services Inc. (CSI) and Highway 36 in Colorado;
and US Ecology in Nevada.
Comment: An area resident asked where the bricks would be disposed.
Response: The facility which will treat and dispose of the chromium-bearing bricks will be
determined during the bidding process. The bricks, which are hazardous waste,
must be treated and disposed in a permitted facility. Grassy Mountain, ESI,
Highway 36 and US Ecology are permitted to treat and dispose of hazardous
waste and may be used by the construction contractor to dispose of the bricks.
Comment: A nearby property owner asked about coordinating the timing of shipping the
CKD from the Site to Summitville.
Response: Had the Summitville disposal option proved viable, close coordination between
the contractors at the Portland Cement and Summitville Sites would have been
very important.
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Protect Background and Status
Comment:
Response:
Comment:
Response:
Comment:
Response:
Comment:
Response:
Cost
Comment:
Response:
Several meeting participants asked about Site background, previous and on-going
sampling events, contamination and associated risks, and the original and
modified combined remedies.
Reports containing this information have been prepared for UDEQ and EPA by
various contractors and can be found in the administrative record files located at
the EPA Region VHI in Denver and the Chapman Library in Salt Lake City.
A nearby property owner requested that the owners of affected adjacent properties
be considered during clean-up activities, and that this concern be noted on the
record.
This concern has been noted. Additional locations-on and adjacent to the Site
have been sampled and tested for contamination. These data along with those
collected during RA will enable the full horizontal extent of contamination
associated with the Site to be identified and remediated to the extent practicable.
A nearby property owner asked if all soil sampling on and adjacent to the Site has
been completed.
RD-related sampling has been completed. Confirmation testing of soil will be
conducted after excavation to verify that CKD and contaminated soil has been
removed. This may extend off the Site as necessary.
An area resident asked how long the current groundwater monitoring program
will continue and at what level the groundwater is considered uncontaminated.
EPA and UDEQ have commenced work on a remedial investigation/focused
feasibility study (RI/FFS) at the Site to address the groundwater operable unit.
Groundwater monitoring will be conducted as part of this RI/FFS. The cleanup
remedy selected as a result of the RI/FFS process will establish the duration of
the monitoring program.
An area resident asked about the final capital cost of remediation and the status
of the PRPs.
The ROD Amendment cites an estimated present worth cost for the modified
remedy of $18.6 million. An engineer's estimate of the construction costs is
being developed as part of the RD and will provide a better estimate of the cost
of construction. The estimate will be further refined during the bidding process
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and execution of the construction contract. However, the actual final costs will
be available when the clean-up is completed.
Lone Star Industries, which purchased the Portland Cement Company of Utah,
is the primary PRP at the Site. Property owners who leased their property to
Portland Cement/Lone Star are also considered PRPs. EPA and UDEQ entered
an agreement with Lone Star whereby Lone Star would pay EPA and the State
approximately $18.3 million to use toward clean up of the Site. EPA and UDEQ
are currently negotiating settlement agreements with the other PRPs at the Site.
D. SUMMARY OF RECENT COMMUNITY RELATIONS ACTIVITIES
The Community Relations Activities at the Portland Cement Co. (Kiln Dust #2 & #3) Superfund
Site since the issuance of the OU2 ROD has included the following:
April 1992
February 3, 1993
April 14, 1993
May 1993
June 16, 1993
August 25, 1993
October 27, 1993
November 1, 1993
November 1 -
December 1, 1993
November 10, 1993
December 15, 1993
February 16, 1994
Update/Fact Sheet published.
Citizens Committee meeting, Salt Lake City.
Citizens Committee meeting, Salt Lake City.
Fact Sheet published.
Citizens Committee meeting, Salt Lake City.
Citizens Committee meeting, Salt Lake City.
Citizens Committee meeting, Salt Lake City.
The ESD/Proposed Plan was distributed to everyone on the
mailing list prior to beginning the public comment period. Also,
an ad was placed in local newspapers to announce the comment
period.
Public Comment period for ESD/Proposed Plan.
Public Meeting to receive comments on the ESD/Proposed Plan,
Salt Lake City.
Citizens Committee meeting, Salt Lake City.
Citizens Committee meeting, Salt Lake City.
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April 20, 1994
July 1994
November 1994
November 16, 1994
February 15, 1995
May 3, 1995
May 10, 1995
June 22, 1995
Citizens Committee meeting, Salt Lake City.
News Release on Lone Star Settlement.
Conducted additional community interviews.
updated Community Relations Plan.
Citizens Committee meeting, Salt Lake City.
Citizens Committee meeting, Salt Lake City.
Updated the Salt Lake City Mayor's Office.
Citizens Committee meeting, Salt Lake City.
Citizens Committee meeting, Salt Lake City.
reviewed and
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