IMMdStUM
Envhunm«nm Protection
Agency
ORkaof
EPA/ROO/R06-8aA)21
Juiw 1068
$ EPA Super-fund
Record of Decision:
Broderick Wood Products, CO
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REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R08-88/021
«. RecJptonTs Acc«Mlon No.
Itta end Subtitle
iUPERPUND RECORD OP DECISION
iderick Wood Products, CO
it Remedial Action
'88
author**)
8. Performing Organization Rept. No:
irganizatior
•nd Address
la Pro|ect/Task/Work Unit No.
11. ContracKQ or Grant(Q) No.
(O
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
19. Supplementary Note*
13. Typa of Report A Period Covered
800/000
14.
16. Abstract (Umlt: 200 words) " '
The Broderick Wood Products Company (BWP) site, is located in Adams County, Colorado,
and encompasses approximately 64 acres. It is situated in a primarily industrial area
and is bounded on the southwest and southeast by railroad tracks and on the north by
Fisher Ditch. The site is one-half mile south of Clear Creek, a perennial stream. The
nearest residences are less than one-eighth mile north of the property line. Major site
tures include two surface impoundments and a total of 19 buildings and structures.
iween 1947 and 1981, BWP operated a wood treatment facility to treat power poles,
hce posts, railroad ties and other wood products. Process wastes from the plant were
conveyed through a clay pipe to the two onsite, unlined surface impoundments, referred
to as the main and secondary impoundments and located in the northwest corner of the
facility. Records indicate that waste seepage was apparent just north of the site and
became so extensive that the waste was burned off, starting in 1955. Records also
indicate that four additional ponds periodically were utilized. In August 1980, BWP
submitted a RCRA permitting application and obtained interim status to operate its
facility but ceased operations in November 1981. Site investigations conducted by EPA
in April 1981 and July 1982 noted several violations of RCRA requirements. Another site
inspection in December 1982 revealed the possibility of serious contamination at a
(See Attached Sheet)
17. Document Analysis a. Descriptor* ' ~~
Record of Decision
Broderick Wood Products, CO
First Remedial Action
Contaminated Media: gw, soil
ifie*rier»RWm6tbSrTermFtais (lead), organics (dioxins, PAHs, PCPs), VOCs (benzene)
e. COSATI Field/Group
liability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
115
22. Price
(See ANSI-Z39.I8)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R08-88/021
» oderick Wood Products, CO
rst Remedial Action
16. ABSTRACT (continued)
trench in the vicinity of the surface impoundments that reportedly had only been used
for the disposal of solid waste. A black stain and oily puddle were noted at the bottom
of the.trench. Wood treating'chemicals also were detected in a ground water monitoring
well located immediately downgradient of the surface impoundments. A source of
contamination at the site that will be addressed in this remedial action is a,result of
a fire in July 1985 that damaged the treatment plant building. Water used to fight the
fire was contaminated with asbestos fibers from the building insulation. This
contaminated water was pumped to onsite holding vessels and some still remains in the
basement of the building. The main and secondary impoundments have been identified as
the major sources of site contamination. The main impoundment contains a surface layer
of oil and grease, a water layer, and a sludge layer. The secondary impoundment
contains primarily a sludge layer. The quantity of sludge from the two impoundments is
estimated to be approximately 4000 yd^, and is designated as RCRA K001 hazardous
waste. Approximately 31,000 yd^ of contaminated soil is estimated to be below the
impoundments. The primary contaminants of concern from the impoundments affecting the
soil and ground water are VOCs including benzene, organics including PAHs, PCPs,
dioxins, and metals including lead.
The selected remedial action for this site includes: installation of access
fstrictions; excavation and onsite mobile incineration of the sludge and oil in the
in and the secondary impoundments, with offsite disposal of the residual ash;
treatment of contaminated impoundment wastewater using carbon adsorption with disposal
through onsite evapo-transpiration or use as incinerator quench water; excavation of the
visibly contaminated soil beneath the impoundments, and onsite incineration if the
volume is less than 2,500 yd , or onsite storage for further studies, if the volume is
greater than 2,500 yd^; filtration of water from the facility area to remove asbestos
fibers, and treatment using carbon adsorption, with disposal through onsite
evapo-transpiration or use as incineration quench water; and ground water monitoring.
The estimated present worth cost for this remedial action ranges between $2,264,000 and
$3,603,200.
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SITE NAME AND LOCATION
Name: Broderick Wood Products Company
Location: Adams County, Colorado
STATEMENT OF PURPOSE AND BASIS
This decision document presents a selected remedial action for
the Broderick Wood Products Superfund site in Adams County,
Colorado. This document was developed according to the
requirements of the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA),
and, where appropriate, the National Contingency Plan (NCP, 40
CFR, Part 300).
This decision is based on an administrative record for the site.
The administrative record includes documents describing the
analysis of effectiveness and cost of the remedial alternatives
for an interim remedy at the Broderick Wood Products site.
Attached to this Record of Decision is an index to that
administrative record.
The State of Colorado has been consulted on the selected remedy,
and has not yet indicated whether or not it will concur on the
remedy.
DESCRIPTION OF THE SELECTED REMEDY
The remedy that EPA has selected is an interim remedy (first
operable unit) to address source control and the direct contact
exposure pathway. The remedy consists of several components to
control the major source of contamination at the site (the main
and secondary impoundments), and to address near term risks from
direct contact exposure to site contaminants. Future studies and
remedies will address the downgradient contaminant plume and
other contamination associated with the site.
The major components of the selected remedy and the concerns that
they address include the following:
Concerns Remedy
Site Access - Construct a security fence around the entire
site; the fence will be six feet high with
chain link, topped with three strands of
barbed wire. Install 20 warning signs around
the site.
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Concerns
Remedy
Impoundment
Contents
Soils Beneath
Impoundments
Facility Area
Contaminated
Surface Soils
Monitoring of
Remedies
Excavate and incinerate on-site the sludge and
oil in the main and secondary impoundments;
ash residues will be disposed in a hazardous
waste landfill.
»
Treat contaminated impoundment waste water
with a carbon adsorption treatment system; the
treated water will either be used as
incineration quench water or disposed of
through on-site evapo-transpiration.
Excavate the visibly contaminated soils
beneath the impoundments; these soils will
either be incinerated on-site (if the volume
is less than 2500 yd3) or stored in a waste
pile for further studies (if the volume is
greater than 2500 yd3).
Filter any contaminated water in the facility
area to remove asbestos fibers, followed by
treatment of the water in a carbon adsorption
system; the treated water will either be used
as incineration quench water or disposed of
through on-site evapo-transpiration.
No action at this time for remediating either
the buildings or vessels in the facilities
area. EPA has concluded that not enough
information is available to support selection
of a remedy at this time. Remedies to address
this problem will be developed in the early
part of the Phase III RI/FS.
No action at this time; not enough information
is available at this time to support selection
of a remedy. Remedies to address this concern
will be developed during future, continuing
RI/FS studies at the site.
A variety of techniques will be used to
monitor the effectiveness of the remedies;
these will include stack testing for the
incinerator, testing of ash residues, sampling
of water treatment effluent, and monitoring
for the ground water contaminant plume during
continuing RI/FL activities.
EPA notes that this decision includes some options that will have
to be exercised after more information is gathered during the
design stage of remedy implementation. In particular:
- 11 -
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If the option to dispose of treated water through use as
incineration quench water becomes infeasible, EPA will
consider the evapo-transpiration disposal method. Any
decision to implement the evapo-transpiration disposal
method would be preceded by a pilot test of the treatment
process. If determined to be non-hazardous, the water
could be treated and disposed of on-site.
EPA will decide whether to incinerate or stockpile
visibly contaminated soils after the actual volume of
these soils is determined. A volume less than 2500 yd3
will result in a decision to incinerate, while a volume
greater than 2500 yd3 will result in temporary storage.
A decision to store the soils temporarily will mean that
remedies in addition to incineration will be evaluated
for these soils during the continuing RI/FS process.
DECLARATIONS
I have determined that the selected remedy is protective of human
health and the environment, and that all components of the remedy
except one will attain all Federal and State requirements that
are applicable or relevant and appropriate to the selected
remedy. The one component of the remedy that may not achieve all
the requirements is the on-site discharge of treated water, which
is a backup remedy. If this component does not meet the
requirements, EPA will exercise a waiver on the basis that this
is an interim remedy, and that future (final) remedies would
address the problem.
I have determined that the selected remedy is cost-effective, and
that it will satisfy the CERCLA preference for remedies that
include treatment to reduce the toxicity, mobility or volume of
the hazardous substances as a principal element of the remedy.
The selected remedy also satisfies the CERCLA requirement to
utilize permanent solutions and alternative treatment to the
maximum extent practicable. I have determined that the selected
remedy will be consistent with possible future remedies for the
site.
Date// Jaro<£s/J. Severer
^ Regional Administrator
- iii -
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SECTION II - DECISION SUMMARY
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TABLE OF CONTENTS FOR DECISION SUMMARY SECTION
Chapter Page
A. Site Location and Description A-1
B. Site History B-l
1. History of BWP . B-1
2. History of Enforcement and Site Investigations at BWP B-2
C. Site Characteristics C-1
D. Public Health and Environmental Risks D-1
E. Scope and Role of Response Action E-1
F. Alternatives Evaluation F-1
1. Five Segment Approach • F-1
2. Remedial Action Objectives . F-1
3. Initial Screening _ F-2
4. Description of Alternatives for Detailed Evaluation F-2
5. Detailed Evaluation Process F-12
6. ARARs Considerations F-12
7. Cost Analysis F-14
8. Detailed Evaluation Results F-14
G. Community Involvement G-1
H. Changes Since the Proposed Plan H-l
1. The Proposed Plan H-1
2. Changes Since the Proposed Plan H-1
3. Recent Information H-2
I. Description of Selected Remedy 1-1
1. Site Access 1-1
2. Impoundments 1-1
3. Facilities Area 1-4
4. Surface Soils 1-5
5. Monitoring 1-5
J. Supporting Rationale J-l
1 . Technical Rationale J-1
2. Statutory Determinations J-5
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TABLE OF CONTENTS FOR DECISION SUMMARY SECTION (cont'd)
Figure A-1
Figure A-2
Figure A-3
Figure A-4
Figure A-5
Figure B-1
Figure C-l
Figure C-2
Figure C-3
Figure D-1
List of Figures •• . Page
Broderick Wood Products Site Location, A-4
Adams County, Colorado
Broderick Wood Products Site Features A-5
Schematic Geologic Cross Section of the A-6
Broderick Wood Products Site, Adams County,
Colorado
Potentiometric Surface Map of the Alluvial A-7
(Upper) Aquifer-July 17, 1986, Broderick Wood
Products Site, Adams County, Colorado
Potentiometric Surface Map of the Unweathered A-8
Bedrock (Lower) Aquifer-July 17, 1986,
Broderick Wood Products Site, Adams County,
Colorado
Locations of Surface Impoundments at the B-6
Broderick Wood Products Site, Adams County,
Colorado
Surface Water and Seep Sample Locations, C-9
Broderick Wood Products Site, Adams County,
Colorado
Ground-water Monitor Well Locations, C-10
Broderick Wood Products Site, Adams County,
Colorado
Surface Soil Sample Locations, Broderick C-11
Wood Products Site, Adams County, Colorado
Potential Surface and Subsurface Contaminant D-6
Migration Pathways at the Broderick Wood
Products Site, Adams County, Colorado
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Table C-1
Table F-1
Table F-2
Table F-3
Table F-4
Table F-5
TABLE OF CONTENTS FOR DECISION SUMMARY SECTION (cont'd)
List of Tables Page
Maximum Concentration of Indicator Chemicals C-8
in Various Media on the Broderick Wood Products
Site, Adams County, Colorado
Summary of Alternatives Considered for the F-16
Broderick Wood Products Site, Adams County,
Colorado
Alternative Evaluation Criteria for Interim F-18
Remedies at the Broderick Wood Products Site,
Adams County, Colorado
Applicable or Relevant and Appropriate F-21
Requirements for Interim Remedial Alternatives
At the Broderick Wood Products Site,
Adams County, Colorado
Comparisons of Costs of Key Alternatives F-26
for Operable Unit at BWP
Evluation of Interim Remedial Action F-34
Alternatives for the Broderick Wood Products Site,
Adams County, Colorado
Table 1-1 Summary of BWP Interim Remedies Selected by EPA 1-7
Other Sections of ROD:
I. DECLARATIONS SECTION (attached to front)
III. RESPONSIVENESS SUMMARY (attached at end)
IV. INDEX TO ADMINISTRATIVE RECORD (attached at end)
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ABBREVIATIONS AND ACRONYMS
AIC
ARAR
BOAT
BIC
BFI
BWP
CDD
CDF
CDH
CDI
CERCLA
cy
DOJ
EPA
HSWA
•ICI
ITC
MCL
MCLG
NAAQS
NCP
NPL
OU
PAH
PCD
penta, PCP
ppb
ppm
RAA
RCRA
RI/FS
SARA
SDWA
TCDD
TCLP
TMV
acceptable chronic intake
applicable or relevant and appropriate requirements
Best Demonstrated Available Technology
Broderick Investment Company
Browning Ferris Industries
Broderick Wood Products
chlorinated dibenzo-p-dioxin
chlorinated dibenzofuran
Colorado Department of Health
chronic daily intake
Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (generally including the
amendments from the Superfund Amendments and
Reauthorization Act of 1986)
cubic yard
U.S. Department of Justice
U.S. Environmental Protection Agency •
Hazardous and Solid Waste Amendments of 1984
Industrial Compliance Incorporated
International Technologies Corporation
maximum contaminant level
maximum contaminant level goal
national ambient air quality standards
National Contingency Plan
National Priorities List of Hazardous Waste Sites
Operable Unit
polycyclic aromatic hydrocarbon
partial consent decree
pentachlorophenol
parts per billion
parts per million
remedial action alternative
Resource Conservation and Recovery Act of 1976
remedial investigation/feasibility study
Superfund Amendments and Reauthorization Act of 1986
Safe Drinking Water Act
2,3,7,8-tetrachlorodibenzo-p-dioxin
Toxicity Characteristic Leaching Procedure
Toxicity, Mobility and Volume
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A. SITE LOCATION AND DESCRIPTION
The Broderick Wood Products (BWP) Superfund site is located in
unincorporated Adams County near Denver, Colorado, in Sections 9
and 10 of Township 3 South and Range 68 West (Figure A-1). The
site is mapped on the Arvada and Commerce City U.S. Geological
Survey quadrangles at latitude 39°47I56" north and longitude
109°58'48" west. The City and County of Denver corporate
boundary is about 3000 feet south of the site, and Interstate
Highway 25 at 58th Avenue is about one-half mile east of the
site.
The triangular-shaped BWP property encompasses approximately 64
acres and is situated in a primarily industrial area. It is
bounded on the southwest by a right of way of the Colorado and
Southern Railroad, on the southeast by a right of way of the
Denver and Rio Grande Western Railroad, and on the north by
Fisher Ditch. Also southeast of the BWP is the Koppers Company,
an active wood treating operation. The nearest residences are
less than one-eighth mile north of the property line.
The major site features (Figure A-2) include two surface
impoundments, a partially modified natural depression (Pond 4),
and a total of 19 buildings and structures. The structures
include several storage buildings, the main office, a change
room, a water pump house, two wood fabrication shelters, the
treatment and boiler building, a shop and engine house. Four
underground structures include a pit, the treatment building
basement, and two cylinder basements.
In addition, there are 11 tanks, two catchment basins, one air
cylinder and one pressure cylinder on the site. The capacities
of these containers range from 2400 to 50,000 gallons. The
contents of the containers have not been fully characterized, but
may contain pentachlorophenol (penta) or creosote. The total
volume of materials presently retained in these containers is
approximately 9250 gallons.
South Ditch, a buried water pipeline, crosses the eastern portion
of the property. A ditch owned by the United Water Company is
reported to cross the southern tip of the property.
While access to the site is not entirely restricted, the main
access road to the site is blocked by a locked gate. The main
and secondary impoundments are surrounded by a wooden-slat snow
fence. The fence is approximately three feet high and is not
adequately supported in some areas, allowing it to lean. The
treatment plant building is surrounded by a six-foot chain-link
fence posted with warning signs.
- A-1 -
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The site is situated on an elevated alluvial terrace more than
one-half mile south of Clear Creek, a perennial stream. The site
is not within the Clear Creek 100-year floodplain. The surface
of the site is relatively flat but dips gently to the northeast.
Surface elevations range from 5206 feet in the northeastern
corner of the site to 5227 feet in the southern corner.
There is little potential for surface drainage from the site
because of existing topographic restraints and man-made barriers
along the northern boundary. The railroad tracks along the
southwestern and southeastern property boundaries effectively
prevent surface water from entering the site.
There are three saturated or partially-saturated geologic units
immediately underlying the site (Figure A-3). In descending
order, they are:
1. Surficial Deposits - zero to 12 feet thick; silty, sandy
windblown material, soil and fill; partially saturated.
2. Slocum Alluvium - one to 14 feet thick; pebbly clay, silt,
sand and gravel; saturated.
3. Denver Formation - uppermost bedrock formation; about 350 to
450 feet thick; interbedded claystone, shale, siltstone,
sandstone and conglomerate.
The regional dip of bedrock is gently toward the north-northeast.
The upper seven to 15 feet of the Denver Formation are weathered
bedrock with vertical fracturing, which decreases with depth.
The unweathered bedrock below the weathered zone is consolidated
and only locally fractured. The Phase II Remedial Investigation/
Feasibility Study (RI/FS) by ITC treated the weathered portion
and the unweathered portion of the Denver Formation as two
separate hydrologic units. '
Ground water is present in a series of interconnected, water-
bearing geologic units beneath the site. These units are
recharged by subsurface inflow and infiltration of surface water.
The Phase II RI/FS identified two aquifers beneath the site. The
upper three geologic units (surficial deposits, alluvium and
weathered bedrock) function as a single water table aquifer. The
water table in this upper aquifer is three to 10 feet below the
ground surface. The lower aquifer ds in the upper portion of the
unweathered Denver Formation. The potentiometric surface of the
lower aquifer is generally about 2.5 feet below that of the upper
aquifer. There are local and seasonal v iriations in the levels
of these water tables on the site.
The ground-water flow is generally towards the north-northeast.
The upper and lower aquifer ground-water flow patterns for the
site are shown in Figures A-3 and A-4, respectively.
- A-2 -
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The soils and ground water at the BWP site have been affected by
contamination from:
creosote, penta and oils related to wood treatment
operations;
- metals such as arsenic, lead, cadmium and copper; and
other wastes including greases, paints, oils, degreasers,
and solvents.
A more detailed discussion of this contamination is presented
in Chapter C.
- A-3 -
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f .v) ~r
vdr^'f T"r«i -t^]
• r ~ r ^Ss*—*^^^ • \—' i.-^' / . ;>»— ,.
-_L • A- -p=- . %
m > • ><« •Hi
1. =\ .!? •-ill!
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HU - £==:•!
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zj...»:r-^Lr\»-%A\."<^.v-v'. ^Ir7/5?..i.e..jgi:' 1( -^
Mr '/i •;si '' " ';; ;'•' ^:! "yZT^'^'bll^"'-'
?rom USGS*ToVogrop"hic~Mops, Arvc.do 7 1/2' and Commerce City 7 1/2't Colo.,. 1980
1000 o
FIGURE A-l
BRODERICK WOOD PRODUCTS SITE LOCATION
Adams County, Colorado
1OOO 2000
•••
SCALE \N FEET
JACOBS ENGINEERING GROUP INC
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GORDON
LAKE
2
O
c
3
W. 62ND AVE.
BFI
LANDFILL
SECONDARY
IMPOUNDMENT
t
•
•
MAIN
IMPOUNDMENT
SOUTH DITCH
(BURIED)
CLAY WASTEWATER PIPELINE
(BURIED)
ISHER DITCH
I
MOUNTAIN STATES SUPPLY
BUILDINGS
TREATMENT PLANT/
SHOP AREA
KOPPEnS
C COMPANY. INC.
OREGON TIMBER
BUILDINGS
NEWMAN
REDWOOD. INC.
DEWEY
LAKE
W. 567H AVE.
MAIN ACCESS ROAD
1/8 UIL£
1/4 MILE
BRODERICK WOOD PRODUCTS SITE
RESIDENTIAL HOMES •
ROADS
RAILROAD TRACKS
BUILDINGS ON SITE |
D4RGWR.R. -DENVER & RIO GRANDE WESTERN
C4S R.R. -COLORADO fc SOUTHERN RAILROAD
FIGURE A-2
CURRENT SITE FEATURES
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sw
NE
Southwest Property Boundary
of BWP Site
Fisher Ditch
Northern Property Boundary
of BWP Site
Secondary
Impoundment
Main Impoundment
Ground Surface
SURFICIAL DEPOSITS
SLOCUM ALLUVIUM
WEATHERED BEDROCK ZONE I
-------
B
F I L o n d f i 11
Fisher Ditch
tftoii) ,ni ,- — 'V* I ^** i it
2&&-- XT «•; T^1^^.
jps**^-***)™* y /s *»r»
g
-------
B F 1 Landfill
Fisher Ditch
230
Secondary
Impoundment'**"*'
Approximate
Property
Boundary
SCALE IN FEET
LEGEND
Direction of Groundwater Flow
Contour Lines of Equal Potentlometrlc Level
Multiple Completion (Units C 88)
Alluvium ( Unit C)
Weathered Bedrock (Unit 8)
Unweathered Bedrock (Unit A)
O Unknown Completion
1? Fill/ Alluvium Piezometer
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B. SITE HISTORY
History of BWP Operations
The BWP Company operated a wood treating facility to treat power
poles, fence posts, railroad ties, and other wood products from
1.947 to 1981. Wood preserving agents used in the treatment
process were creosote and penta. Creosote was used throughout
the life of the facility, and was typically mixed with carrier
oil (for example, fuel oil). Penta (dissolved in carrier oil)
was used on a limited basis prior to 1953 and on a regular basis
from 1953 to 1980.
During the operational life of the facility, process waste from
the plant was. disposed of on the site, with much of it going to
two unlined impoundments located in the northwest corner of the
site (Figure B-1). The waste was conveyed to the impoundments
through a ten inch diameter clay bell-and spigot pipe.
The main impoundment is reported to have been constructed in 1946
by filling in the ends of a railroad cut. However, there are
still some unresolved inconsistencies among historical records
about disposition of wastes during the early years of plant
operation. Also, historical aerial photographs indicate that the
main impoundment extended much closer to the northern site
boundary during the early years.
In 1956, a secondary impoundment was constructed west of the main
impoundment for additional evaporation capacity and as an
overflow structure for the main impoundment.
According to historical documents, offsite migration of
contaminants related to wood treating (creosote and oil) was
noted as early as 1952, five years after the start of facility
operations. The presence of creosote and oil seepage became
apparent just north of the BWP site and eventually became so
great that it was burned off, starting in 1955. Over the next
five or six years, the seepage appeared to diminish.
Four other ponds that from time to time have been present on the
site were identified through historic air photo interpretation.
These ponds are designated Ponds 1 through 4 (Figure B-1).
Pond 1 was present from approximately 1950 to 1980. Pond 2 was
present from approximately 1953 to 1974. Pond 3 was present from
about 1963 to 1982, serving as an overflow structure for the
secondary impoundment. From photographs taken during the 1960s,
it appears that ditches ran between Pond 3 and the secondary
impoundment as well as between Pond 3 and Pond 4.
- B-1 -
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Pond 4 has been evident in photographs from 1966 to the present.
This pond is essentially a natural and man-modified depression
where site-related drainage collects and infiltrates or
evaporates. The areal extent of the pond varies with the amount
of runoff collected. At times this pond is dry and at other
times it may extend to the northeast corner of the site.
In 1958, a fire destroyed the shop building. During the same
year, a new shop building was constructed.
In 1962, the main and secondary impoundments caught fire and
burned for several hours.
In November, 1981, BWP ceased operations as a wood treater,
citing market conditions. Seven months later, in June 1982,
BWP's assets were liquidated into a trust-operated partnership
known as the Broderick Investment Company (BIG), a Colorado
limited partnership. The trustees of the partnership were the
First National Bank (now the First Interstate Bank of Denver) and
the Colorado National Bank of Denver. Shortly thereafter, the
BWP Company was officially dissolved, making BIC the successor to
BWP Company's business interest.
On July 12, 1985, the treatment plant building was damaged by a
fire started by the torch of a welder who was dismantling the
treatment facility. Some of the water used to fight the fire
reportedly remains in the basement of this building and at other
locations of the site.
History of Enforcement and Investigations at BWP
The recent history of the site has included numerous activities
and investigations of contamination on and off the site. Most of
these activities have been in response to or in coordination with
regulatory and legal actions by the U.S. Environmental Protection
Agency (EPA) and the Colorado Department of Health (CDH).
In August 1980, the BWP Company submitted a "Notification of
Hazardous Waste Activity" as required under Section 3010 of the
Resource Conservation and Recovery Act (RCRA). In November 1980,
BWP submitted Part A of the application for a hazardous waste
permit pursuant to Section 3005(e) of RCRA, thereby obtaining
"interim status" to operate its facility.
In April 1981, EPA conducted a site inspection at BWP, and
several violations of RCRA requirements were noted by the
inspectors. On July 7, 1981, EPA issued a Notice of Violation
(NOV) to BWP, citing BWP for not having the following required
documents: waste analyses from the settlement pond, waste
analysis plan, inspection plan, contingency plan, and operating
plan. On July 29, 1981, BWP responded to the NOV, submitting an
operating record, an inspection plan and a contingency plan.
- B-2 -
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A July 1982 inspection of the Site by EPA revealed both
continuing and additional violations of RCRA interim status
requirements. Inspectors also learned that BWP had ceased
operations in November, 1981, and that BWP had been dissolved,
with the assets being liquidated into BIG.
The continuing violations at BWP prompted EPA, on October 27,
1982, to notify the BIC trustees of EPA's intent to file suit
against BIC. This notice led to extensive communications between
the trustees and EPA.
EPA conducted another inspection of the site in December, 1982.
This inspection revealed the possibility of serious contamination
at BWP, including a 10-foot by 50-foot trench that was observed
about 40 feet north of the surface impoundments. This trench had
reportedly been used only for the disposal of solid wastes;
however, a black stain and oily puddle were noted at the bottom
of the trench.
Also in December 1982, Browning Ferris Industries (BFI), a waste
disposal company operating north of the site, reported that wood
treating chemicals had been detected in water from one of their
monitoring wells located immediately north of the surface
impoundments.
In March 1983, the EPA invoked CERCLA authority and conducted a
preliminary assessment and site investigation of the BWP site.
Penta was detected in soil and ground-water samples taken both on
and off the site.
Based on the information gathered during these investigations,
the BWP site was nominated for inclusion on the National
Priorities List (NPL) of hazardous waste sites in September 1983.
In September 1984, the nomination was finalized and the site was
placed on the NPL.
During 1984, EPA and CDH negotiated with BIC regarding studies to
be conducted and remedies to be implemented at the site. The
main focus of these studies and remedies was to be closure of the
RCRA impoundments.
One of the central issues of these negotiations was who would
conduct the studies, EPA or BIC. In February 1984, EPA issued
I04(e) Information Requests to the trustees to obtain the results
of studies that BIC had been conducting since early 1983. The
trustees response to this request was embodied in a March 1984
investigation report by a BIC consultant (the "Kuntz report").
After a review of the report, EPA became concerned aoout BIC's
ability to conduct an RI/FS properly, and concluded that it would
be appropriate for the Agency to take the lead on the
investigation.
- B-3 -
-------
BIC strongly objected to EPA's position on this matter. After
negotiating further with EPA, BIC was allowed to continue with
the RI/FS work. However, EPA insisted that the study be
conducted under a court-approved consent decree.
During 1985, EPA and the Department of Justice (DOJ) negotiated
with BIC and the trustees (collectively the "defendants") over
the terms of the consent decree. In late 1985, the parties
reached agreement on the terms of a Partial Consent Decree (PCD).
The PCD was filed simultaneously with the original complaint on
February 28, 1986, in the U.S. District Court for the District of
Colorado. The court approved the PCD on May 21, 1986.
Under the PCD, the defendants agreed to pay $100,000 for the
alleged violations of RCRA interim status regulations. The PCD
also established a framework for the defendants to conduct a
CERCLA-type remedial investigation and feasibility study (RI/FS),
with a corresponding stay of discovery and litigation pending
completion of the RI/FS and selection of remedies. Both parties
retained all rights regarding implementation of remedies. A
trust fund was established to finance RI/FS work.
The PCD contemplates the RI/FS being conducted in two or three
phases. Preliminary work done by BIC's first consultant (Kuntz)
in 1933-84 was considered Phase I. The decree covers conduct of
Phase II and, if-necessary, Phase III studies.
BIC and a new consultant (ITC) began work on the Phase II
remedial investigation in late 1985. Preliminary sampling of the
impoundments was conducted in March 1986, and more in-depth
sampling of soils and ground water was conducted through the '
spring and summer of 1986.
BIC's consultant (ITC) experienced difficulties in the conduct of
the Phase II RI/FS and requested a six week extension of the
original due date for the report. EPA granted this request and a
Joint Motion for Modification of the PCD was filed by the parties
on December 1, 1986.
The Phase II RI/FS report was eventually submitted by BIC on
December 5, 1986, twenty days after the extended due date. EPA,
its consultants and CDH reviewed the draft report and submitted
comments to BIC on March 26, 1987, identifying significant and
extensive deficiencies in the report. Based on this review, EPA
concluded that further studies (i.e., a Phase III RI/FS) would be
required to document the nature and extent of contamination and
to develop plans for a final remedy. Howeve:, EPA concluded that
sufficient information was available to implement certain interim
source control remedies, and requested BIC to revise the report
to evaluate such remedies (operable units).
- B-4 -
-------
After negotiations with EPA, BIG agreed to this approach. Since
the revisions could not be completed by the date required in the
PCD as modified, a second PCD modification was exercised to
address the change in approach. A Joint Motion for approval of a
second modification was filed with the court on June 15, 1987,
and approved on August 11, 1987. This modification affirmed
stipulated penalties for the late submission of the original
Phase II RI/FS report and required a revised Phase II report to
address options for an operable unit. BIC retained a third
consultant (Keystone) and submitted a revised Phase II RI/FS
report on the due date of July 24, 1987.
EPA reviewed the revised report and concluded that, with certain
modifications to the report, EPA would be able to propose certain
interim remedies in a proposed plan. In an August 26, 1987
meeting, EPA informed BIC that EPA would develop the proposed
modifications in a supplemental RI/FS report. The supplemental
RI/FS report was completed November 5, 1987.
In February, 1988, EPA published a proposed plan based on the
RI/FS studies and information to that date. EPA concurrently
initiated a 21-day public comment period to invite comments on
the proposed plan. A public meeting was held on February 22,
1988, and comments were received through the end of the comment
period. EPA has reviewed those comments, and the reponses are
presented in the attached Community Involvement Responsiveness
Summary.
- B-5 -
-------
B F 1 Landfill
Fisher Ditch
Impoundment \
290 0 250 900
/ Property
/ Boundary
\
\
o
0 /
\ A \
V \ \
\
FIGURE B-I
Locations of Surface Impoundments
at the Broderick Wood Products Site
Adams County, Colorado
From IT, 1986
JACOBS ENGINEERING GROUP INC
-------
SITE CHARACTERISTICS
In this chapter, the general nature and extent of contamination
at the.BWP site will be described, followed by a discussion of
the site and hazardous substance characteristics and conditions
using the five-segment, structure developed by EPA and BIC to
address interim site remedies in this operable unit. The five
segments are: site access; the waste impoundments; the facility
area structures, vessels and equipment; surface soils; and .
monitoring.
There will also be some discussion of additional information
relating to other areas of contamination, most notably
contamination of ground water. However, these areas will be
addressed further in the continuing (Phase III) RI/FS, and will
not be addressed in great detail here.
General
During the Phase I and II studies, hazardous substances were
detected in a variety of site media, including:
the surface impoundments
the treatment facility and shop area structures and
containers
surface soil (0-2')
subsurface soil (>2')
bedrock materials
surface water
ground water
Table C-1 presents information showing the presence and maximum
concentrations of the twenty indicator hazardous substances that
were detected on the site, and the media in which each chemical
was detected. These indicator chemicals were chosen because, in
general, they represent the most toxic, mobile and persistent
hazardous substances on site. However, it is possible that some
areas on the site containing hazardous substances have not yet
been identified.
Figures C-1 through C-3 show sampling locations at the BWP site.
1. Site access
Access to the BWP site is partially restricted by a combination
of fences, signs, and natural barriers. The location of the site
in an industrial area also serves to restrict the number of
people who would enter the site. However, neither the location
- C-1 -
-------
nor the barriers effectively prohibit site access. Trespassers
(sometimes with vehicles) have been frequently documented
entering and even camping on the site. The location of the site
next to a major railroad yard appears to exacerbate the
likelihood of trespass by transients and other unauthorized
persons.
2. Surface Impoundments
Of all the surface impoundments on the site, the main and
secondary impoundments contain the highest concentrations of
indicator chemicals. The main impoundment contains a surface
layer of oil, a water layer and a sludge layer, and the secondary
impoundment contains only a sludge layer.
a. Main Impoundment
The main impoundment has the following characteristics:
dimensions: 460 feet long by 40 to 90 feet wide
surface area: 0.9 acre
depth: about 5 feet from the ground surface
total volume (capacity): approximately 1,400,000 gallons
present contents:
o surface oil: approximately 3000 gallons
o water: approximately 560,000 gallons
o sludge: 280,000 gallons (1400 yd3)
o total contents: 843,000 gallons (60% full)
The surface oil layer is close to 100 percent oil and grease.
Thirteen indicator chemicals were detected in this layer and are
summarized in Table C-1. Polycyclic aromatic hydrocarbons (PAHs)
were present in concentrations exceeding 12,000 parts per million
(ppm). Penta was detected at a concentration of 160 ppm.
Dioxins and furans (expressed in equivalencies of 2,3,7,8 TCDD)
were present in concentrations of 20 parts per billion (ppb), and
small amounts of copper and lead were evident.
Samples from the water layer contained the lowest concentrations
of hazardous substances within the main impoundment. Thirteen
indicator chemicals were detected in the water (Table C-1). PAHs
are present in concentrations of less than one ppm. The water is
acidic (pH = 4.85).
The sludge layer of the main impoundment is a listed hazardous
waste under RCRA (KOOl) and is the most highly contaminated
medium on the site. Nineteen of the 20 indicator chemicals were
detected in this layer (Table C-1). Some PAHs were detected in
concentrations exceeding 100,000 ppm. Penta has been detected in
concentrations of 11,000 ppm. Dioxin equivalencies were 18 ppb
and the concentrations of metals (16 ppm copper, 12 ppm lead)
were an order of magnitude larger than those in the surface oil.
- C-2 -
-------
b. Secondary Impoundment
The secondary impoundment is triangle-shaped with the following
characteristics:
side dimensions of 320 to 360 feet in length
surface area is 1.8 acres
total volume (capacity): about 600,000 gallons
present contents: about 450,000 gallons (2200 yd3) of
partially dried sludge (about 75% full).
Although the secondary impoundment has only a sludge layer, some
liquids are usually present following precipitation. This liquid
reportedly evaporates during dry periods.
Seventeen indicator chemicals were detected in the secondary
impoundment (Table C-1). The indicator chemicals are similar to
those detected in the main impoundment sludge, with generally
lower concentrations. The indicator chemical detected at the
highest concentration was phenanthrene at 14,600 ppm. Penta was
detected in concentrations as high as 8600 ppm. Copper and lead
had concentrations of 20 and 29 ppm, respectively.
c. Other impoundments
As depicted in Figure B-1, Pond 1 was present from approximately
1950 to 1980. One sample, taken at location 49, tested the upper
two feet of soil in this area. No indicator chemicals were
detected, with the exception of 7.8 ppm copper and 11.2 ppm lead.
Pond 2 was present from approximately 1953 to 1974. No samples
were taken of the upper two feet of soil in this area.
Pond 3 was present from about 1963 to.1982. At location 46, a
soil sample was taken of the upper two feet and tested for the
presence of indicator chemicals. This location is at the south
end of the main impoundment, so it is unclear whether the source
of contamination is from Pond 3 or the main impoundment. This
sample contained 220 ppm penta. Eleven other indicator chemicals
with concentrations around 10 ppm were also detected. Lead was
detected at 39 ppm (Table C-1).
Pond 4 was evident on photographs from 1966 to the present. Five
surface soil and one surface water samples have been taken from
this area at locations 1, 2, 45, 50, and SB-15 (Figures C-1 and
C-3). A maximum of 0.26 ppm penta was detected at location 45
(Table C-1). Contamination was not detected in samples from
locations 1 and 2. The sample taken at location 50 contained
0.26 ppm cadmium, which is elevated over background levels.
- C-3 -
-------
d. Visibly Contaminated Soil Beneath the Impoundments
There are currently insufficient, data to determine the full
nature, extent or volume of the visibly contaminated soils
beneath the impoundments. The volume has been estimated as great
as 31,000 yd3 (if the visible contamination extends to the top of
the water table). It is also possible that "stringers" or
pockets of contamination may extend further into the soil than
the general mass of contamination.
It should be noted that the vertical extent of contamination in
soils beneath the impoundments may be veil below the top of the
water table. Sufficient geologic characterization of conditions
beneath the impoundments has not been attempted. The Phase III
RI/FS will address this concern.
3. Facility Area (Buildings, Vessels, etc.)
Contamination in the facility area (from the buildings, vessels,
equipment, etc.) of the site contribute to soil contamination,
airborne particulates, and physical hazards. Asbestos used to
insulate pipes is exposed in and around the plant and boiler
buildings. Some of the asbestos was exposed by the fire in 1985
when the protective tar paper which covered the asbestos burned
off. A July 1987 site visit verified that the asbestos
insulation is not covered adequately.
Analyses of samples of the firewater (that is, water used to
fight the 1985 fire) ponded in the basement of the plant building
detected seven ppm penta. Measurable quantities of dioxin and
furan were also detected. Other PAHs were not analyzed. An
unknown quantity of this water was pumped into one of the on-site
tanks. The tanks, catchment basins, and cylinders on the site
have not been sampled. The Phase III RI/FS will address this
concern.
4. Surface Soil
Much of the surface soil around the site is known or suspected of
having been in contact with wood-preserving chemicals. It is
also suspected that some surface soils may have been affected by
previous railroad and mineral smelting activities adjacent to the
site. There is evidence that portions of the site have been
extensively re-graded. Actual laboratory test data on the
surface soils are relatively sparse.
Approximately one-third of the surface of the site has been
identified on aerial photographs as having dark soil in the past.
It is not possible to positively determine the cause of dark
soils that were observed. These areas were identified to
document locations that may have been affected by wood treatment
- C-4 -
-------
operations. Possible causes of the dark soil areas include
spills of wood treating solution, disposal of sludges from
storage tanks, and seepage from the surface impoundments. Other
causes of dark soil could be related to precipitation or ponding
of runoff.
During an EPA RCRA inspection in 1982, surface soils apparently
saturated with a black oily substance were observed to the west
of the secondary impoundment. A hole dug by hand in this area
immediately filled with a black oily substance. Surface soils on
the eastern edge of the property were also identified as possibly
saturated with a black oily substance. No tests of surface soils
in these areas were documented in the Phase II RI/FS reports.
Surface soils in the vicinity of the treatment plant, shop and
the engine house areas have been tested. The highest
concentrations of indicator chemicals in soil media,, with the
exception of metals, is in the treatment plant area. Nineteen
indicator chemicals were detected at the treatment plant. Penta
was detected at a concentration of 3300 ppm. Dioxin levels
(reported in TCDD equivalencies) were as high as 3.5 ppb. Many
of the other indicator chemicals were detected in concentrations
ranging from 500 to 1400 ppm (Table C-1). Lead and copper were
detected at concentrations of 499 and 255 ppm, respectively.
Concentrations of indicator chemicals in soils from the shop area
are considerably lower than from the treatment plant area.
Nineteen indicator chemicals were detected at concentrations of
10 to 90 ppm (Table C-1). Benzo(b)-fluoranthene was the
exception with a concentration of 350 ppm. Penta was detected at
a concentration of 46 ppm. Copper and lead were present at
concentrations of 243 and 152 ppm, respectively.
Soils from the engine house area contained 17 of the indicator
chemicals. As shown in Table C-1, metals were present in high
concentrations. Lead, copper, cadmium and arsenic were detected
at concentrations of 5300, 619, 144 and 117 ppm, respectively.
Other nonmetallic indicator chemicals were generally detected in
concentrations of six ppm or less. The exception was
acenaphthene, which was detected at a concentration of 500 ppm.
Approximately 14 surface soil samples have been taken outside the
treatment plant, shop and engine house areas. All of the samples
were tested for penta. Samples from four locations (16, 46, 47,
SB-15) contained measurable quantities of penta ranging from 0.6
to 220 ppm. Samples from 11 locations were tested for other
nonmetallic indicator parameters. Samples from four locations
(13, 46, 47 'and SB-14) contained detectable levels of indicator
parameters. Samples from five locations were tested for metals.
Samples from three of these locations (46, 47 and 48) had
elevated concentrations of metals compared to national norms.
- C-5 -
-------
5. Monitoring
Currently, monitoring of site conditions is limited to weekly
visits by a former BWP employee who measures water levels in the
ground water monitoring wells. The site has also been observed
by neighboring businesses who have frequently reported
unauthorized trespass by transients and others.
6. Additional
a. Surface Water
Tests of surface water runoff were limited to Pond 4, Fisher
Ditch and off-site seeps. A related surface water issue is the
interaction of ground water with the surface water in Fisher
Ditch.
Surface water has been tested at five seep locations north of
Fisher Ditch. SW-5 is a seep which surfaces north of Fisher
Ditch, almost due north of the main impoundment. Fourteen
indicator chemicals have been detected at this location.
Typically, concentrations ranged from 0.01 to 0.3 ppm. Penta was
detected at 1.8 ppm.
In June 1986, the surface water in Pond 4 was tested. Surface
water at location 45 exhibited 11 indicator chemicals.
Concentrations ranged from 0.001 to 0.8 ppm for most
constituents. A notable exception was acenaphthene which was
detected at a concentration of 110 ppm.
The water in Fisher Ditch has been analyzed 11 times. Four of
the samples contained indicator chemicals. Penta was detected in
concentrations of 0.05 ppm and less. There is evidence that
ground water from the site interacts with the water in Fisher
Ditch. Although the Phase II RI/FS concluded that ground water
does not recharge Fisher Ditch, the data presented indicate
recharge may be occurring along the western portion of the ditch.
b. Ground Water
Eighteen indicator chemicals have been detected in ground water
samples from the site at concentrations up to 124,000 ppm. Water
from wells adjacent to the impoundments contained the highest
concentrations. The most contaminated portions of the ground
water are associated with the floating and sinking phases of the
wood-preserving chemicals. Concentrations of floating phase
indicator chemicals are between 1300 and 18,000 ppm.
Concentrations of the sinking phase indicator chemicals are
generally between 490 and 14,000 ppm. The exception is
naphthalene which was detected at 124,000 ppm.
- C-6 -
-------
c. Dioxins and furans
As with many wood treating plants, the potential presence of
isomers of dioxins and furans has been a concern at the BWP site,
and sampling and analysis for dioxins and furans has been
conducted. Isomers of dioxins and furans have been detected in
the impoundments, notably in the sludge and oil, and in some of
the surface soils, particularly in the Facilities Area. However,
only the heavier isomers of the dioxins and furans, such as
penta, hexa, hepta and octa, were detected. The most potent
isomer, 2,3,7,8 tetrachlorodibenzodioxin, was not detected in any
medium.
The maximum concentrations found in the various media are
presented in Table C-1, expressed as total dioxin equivalencies
to 2,3,7,8 TCDD. This means that the concentrations of the less
potent isomers were multiplied by certain equivalency factors to
express their relative strength compared to 2,3,7,8 TCDD.
- C-7 -
-------
Table C-
MAXIMUM CONCEWTRATICNS1 OF INDICATOR CHEMICALS IN VARIOUS MEDIA AND LOCA
iflBrej
AT THE BRODERICK MOOD PRODUCTS SITE. ADAMS COUNTY,
Indlcat QC-Parame t ets
PAIIs:
Acenaphthene
Acenaphthylene
Anthracene
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(a)pyrene
Chrysene
Fluoranthene
Fluorene
Napthalene
Pyrene
Phenathrene
2-Methylnaphthalene
Ehenollcs:
Pentachlorophenol
VQCs:
Benzene
Surface Soils fQ-2 ft)
(Oil)
mg/1
1570
ND
12100
ND
ND
260
1680
8700
3590
1170
4960
9000
ND
Main
(Water)
mg/1
0.12
0.022(J)
ND
ND
ND
ND
0-083
0.630
0.062
1.1
0.170
0.340
ND
(Sludge)
mgZkg
17300
380
47800
1000
ND
400
1200
16000
20200
110000
10200
12000
2900
Secondary
(Sludge)
mg/kg
4100
ND
2500
ND
1200(J)
ND
2200
11000
4300
11000
7800
14600
ND
Soils Near
Impoundment
tag/kg
ND
10(B)
10(B)
10(B)
ND
10(B)
10(B)
10(B)
ND
ND
25(B)
25(B)
ND
Pond 4
(Sediment)
m£/k£
470
170
590
190
150
100(B)
690
3200
810
100(B)
1900
420
100(B)
Facilities
Area
mglkg
790
29(J)
770
250
ND
320
1300
500
500
1400
1400
320(J)
Shop
Area
mg/kg
27
2.3(J)
12(J)
17
350(J)
16(J)
23(J)
79(J)
16
26
91
50
8.1
Engine
House
ing /kg
500
ND
.8
2.4
4.9
2.5
2.8
5-9
0-24
0-13
6.0
3-8
0.11
Drip
r
Tracks
iqg/kg
ND
ND
0.089(J)
ND
0.460
0.150(J)
0-320(J)
0.33
ND
ND
0.45
0.13(J)
ND
160
ND
0-69
ND
Dihenzodloxlns/Dlbenznfiirans (ppb):
TCDD (equivalency2) 20 0-002
Metalsi
Arsenic
Cadmium
Copper
Lead
ND 0-004
ND ND
8 0.050
0.73 0.006
11000
8600
220
3300
46
4-5
18
O.ll(J) ND
9.5
ND
ND
0-03
0.023(J) ND
3.5
1.5
ND
ND
0.0007
ND
ND
0.06
1.9
2
16
12
2.3
4
20
29
1.1
0.11
14.7
39
ND
0-26
8-3
5-9
12
4.3
255
499
10
3-0
243
152
117
144
619
5310
5.2
ND
14
14
Notes:
Data complied from ITC, 1986, Tables 2-22 through 2.27, Tables 2.42 through 2.49, Table 3-4, and Appendix B (See Figure C-3 for general
locations). Data qualifiers: B - Mass spectral data Indicate the presence of a compound that meets the Identification criteria; the
quantitative result Is less than detection limit but greater than zero- Actual value, within the limitations of this analytical method, Is
less than value given; J - estimated value; ND - Not detected-
2- Concentrations of all Isomers of TCDD are expressed cumulatively In equivalencies of TCDD
-------
'34
BFI Landfill
Fisher Ditch
8W-2
SW-I
Main Impoundment
N
Secondary \
Impoundment >
\
\
/ Property
/ Boundary
290 0 280 900
\ o /
\ 0 /
LEGEND
O SAMPLE LOCATION (no contamination detected)
• SAMPLE LOCATION (contamination detected)
v;\
\
Figure C-1
SURFACE WATER AND
SEEP SAMPLE LOCATIONS
BRODERICK WOOD PRODUCTS SITE
Adams County, Colorado
From IT, 1986
JACOBS ENGINEERING GROUP INC
-------
BFl Londfill
Fisher Dilch
N
Secondory
Impoundment
IT.g
v :' IT-«
\ • " •
/>
/ /
^^
Properly
Boundary
29O O 25O
ecean-i -e=
SCALE IN FEET
LEGEND
UPPER AQUIFER
SOO
* Contomlnation delected
O No contamination delected
BEDROCK AQUIFER
A Contamination delected
A No contamination detected
•
0 /
D /
/
/
\ \
VY\
\
GROUNCWATER SAMPLES HAVE NOT BEEN OBTAINED FROM WELL tT-lfWELL BB-II
• « ONLY VERr LOW CONCENTRATIONS OF PENTACHLOROPHENOL (0.02 mg/l) «
NAPHTHALENE 1005
-------
B F I Landfill
Fisher Dilch
sw-o
I
^ (jj^iiilw^^
60 • o
20
•l 5\4S
SB-18 ( ;—Pond 1
18
o
48
Main Impoundment
,2°
• SB-14
Secondary \
Impoundment >
\
\
\
\
\
\
\
\
8OO
290
—I
SCALE .IN FCET
LEGEND
O SAMPLE LOCATION (no contamination delected)
• SAMPLE LOCATION (contamination delected)
~~\ COMPOSITE SAMPLE AREA
~~ (contamination delected In all composite sample areas)
A- Shop Area
B - Treatment Plant
C - Engine House Area
FROM-IT, 1968, Flgurit 2-4, 2-11, 2-12
Approximate
Properly
Boundary
\
\
0 /
o /
\
A \
\ A \
V \ \
\
FIGURE C-3
SURFACE SOIL SAMPLE LOCATIONS
BRODERICK WOOD PRODUCTS SITE
Adams County, Colorado
JACOBS ENGINEERING GROUP INC
-------
D. PUBLIC HEALTH AND ENVIRONMENTAL RISKS
Scope of Risk Analysis/ Risk Scenarios
Based on the data gathered thus far, the contamination associated
with the BWP site poses a variety of actual and potential risks
to human health and the environment. Thus far, no risk scenarios
identified with the site have been eliminated from risk analysis,
and the full range of scenarios (from industrial use through
residential use) remain for consideration.
However, as noted previously, the full nature and extent of
contamination have not yet been characterized. This lack of
complete characterization is most obvious for the ground water
exposure pathway, particularly in the area north of the site.
Characterization of this pathway is expected to be accomplished
with the Phase III RI/FS, and will be addressed in a future
record of decision.
As a consequence of the current incomplete level of
characterization, the scope of risk analysis for this record of
decision has generally been limited to those pathways about which
there are sufficient data to support risk analysis and for which
remedies are being considered. These pathways are generally
those associated with on-site risks and direct contact, as well
as those that can be addressed with the source control types of
remedies contemplated by BIC and EPA in the revised and
supplemental Phase II RI/FS reports.
Where appropriate, there will also be some discussion of other
risk pathways.
Risk Pathways
Within the limited scope of this operable unit and the currently
available data, the significant actual and potential exposure
pathways identified for the BWP site include:
1. Ingestion of hazardous substances in surface soil and the
impoundments.
2. Direct dermal contact with hazardous substances in
surface soil and the impoundments.
3. Inhalation of airborne hazardous substances.
4. Ingestion of food crops contaminated with hazardous
substances.
5. Ingestion of contaminated ground water below the site.
- D-1 -
-------
Receptor Populations
Potential and actual populations at risk from contamination at
the BWP site include:
1. On-site workers, including the caretaker and remedial
workers.
2. Trespassers, including children and transients.
3. Future workplace populations, including children in
workplace day-care centers.
4. Future residential populations, including children.
5. Off-site users of ground water from the site.
6. Off-site populations immediately adjacent to the site.
The pathways by which hazardous substances from the site may
reach human and environmental receptors are depicted in Figure
D-1 .
Contaminants, Hazardous Effects
The analysis of risk at the BWP site included selection and
evaluation of certain indicator chemicals which represent the
most'toxic, mobile and persistent hazardous substances associated
with the site. - The indicator chemicals consisted of all those
listed in Table C-1, including:
1. many of the polynuclear aromatic hydrocarbons (PAHs) that
make up cresoste;
2. pentachlorophenol, representing the phenolics group;
3. benzene, representing volatile organics;
4. 2,3,7,8 - tetrachlorodibenzo-p-dioxin, representing the
dioxins and furans; and
5. arsenic, cadmium, copper and lead, representing the
metals.
Ingestion of any of the indicator chemicals has the potential to
cause damage to orcan systems. For example, naphthalene,
acenaphthene, penta, benzene, and copper cause liver and kidney
damage. Lead primarily affects the hematopoietic (blood-forming)
system and central nervous system and has been linked to learning
disabilities in children. Cadmium is a teratogen. Both cadmium
and lead are reproductive toxins.
- D-2 -
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Several indicator chemicals have the potential to cause health
effects if inhaled. Some of the chemicals, including the PAHs,
may be absorbed into the body through the lungs, resulting in
health effects similar to those resulting from ingestion. Some
of these chemicals also have direct effects on the respiratory
system. Inhalation of arsenic compounds and cadmium causes lung
cancer, while benzene vapors and penta irritate the upper
respiratory tract and eyes.
Dermal contact with PAHs, penta, and benzene cause skin
irritation and possibly dermatitis. Naphthalene, penta, benzene,
TCDO, and lead can be dermally absorbed, once again resulting in
health effects similar in some cases to the effects from
ingestion.
Human Health Risk
The following potential or actual human health risks associated
with direct contact with hazardous substances on the BWP site
have been identified:
1. Ingestion of Contaminated Surface Soil
Inadvertent ingestion of hazardous substances in surface
soils may occur if children or other trespassers gain access
to the site. A potential worst case scenario was evaluated
using inadvertent ingestion by children of soils containing
the maximum concentrations of indicator chemicals detected in
soil at the site. To obtain a range of risk, two ingestion
rates were used: 0.1 grams of soil per day and 5.0 grams per
day, occurring once a week for five years.
In estimating the carcinogenic effects of this exposure
scenario, it was determined that the increased cancer risk
ranged from negligible to as high as 6.4 X 10~2, or 6.4
increased cancers in a lifetime per 100 population. The
greatest risks were those associated with ingesting
carcinogenic PAHs at the 5.0 grams per day level.
To estimate noncarcinogenic effects of this scenario, the
estimated chronic daily intake (GDI) of noncarcinogenic
hazardous substances from soil ingestion was compared with
acceptable chronic intakes (AIC). The GDIs for lead exceed
the AIC by factors of three and 157, respectively at the 0.1
and 5.0 grams per day levels. The GDIs for penta and cadmium
exceed the AICs at the 5.0 grams per day level.
Because of their current aesthetic quality, the impoundments
were not included in this ingestion scenario. However, a
future scenario based on no remediation of the impoundments
would likely result in even greater risks if the site were
regraded and the impoundment contents were mixed with other
surface soils.
- D-3 -
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2. Direct Dermal Contact with Hazardous Substances
Direct dermal contact, particularly with the high
concentrations of indicator chemicals in the impoundments,
poses a risk of skin irritation and dermatitis, as well as
other health effects associated with dermal absorption of the
indicator chemicals. Chronic exposure to some PAHs and
dioxins poses a cancer risk. The populations at risk include
on-site workers and site trespassers, including children.
3. Inhalation of Vapors and Contaminated Dust
Inhalation by on-site personnel and trespassers of
volatilized hazardous substances from the impoundments and
soils contaminated with hazardous substances can occur and
pose a health threat to such persons. Because sufficient air
monitoring data are not available, the human health risk
cannot be quantitatively evaluated at this time.
The presence of asbestos in and adjacent to buildings on the
site poses a health risk. Site personnel and trespassers may
be exposed by direct contact to the asbestos insulation or by
inhalation of airborne fibers.
4. .Ingestion of Contaminated Food Crops
Under the present land use, food crops are not grown at the
BWP site. If the land is used for residential or
agricultural purposes in the future, humans may be exposed to
hazardous substances either taken up by food crops grown in
contaminated soil or as a result of contamination of food
crops with contaminated irrigation water. Insufficient
information about ground water contamination is available to
evaluate the human health risk quantitatively.
5. Ingestion of Contaminated Ground Water
Because of the lack of adequate data, ground-water impacts
were not evaluated in detail. However, the use of ground
water as a potable water supply off the site is potentially a
significant pathway for exposure to hazardous substances from
the BWP site. The maximum concentrations of indicator
chemicals in ground-water samples taken on the site exceed
appropriate water quality criteria. Consequently, any future
use of this ground water for human consumption poses a
potential health risk requiring further evaluation during the
Phase III RI/FS.
Environmental Impacts
The following environmental impacts have been identified at the
BWP site:
- D-4 -
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1. Damage to ground water, resulting in loss of a natural
resource and potential-impact on socioeconomic
development.
2. Impact on wildlife as a result of direct contact with
hazardous substances or by ingestion of contaminated
water from the surface impoundments.
3. Impact on wildlife and domestic animals from exposure to
contaminated soils.
4. Other socioeconomic impacts such as decrease in property
value and economic development.
- D-5 -
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LEGEND
SAMPLE SHOWING CONTAMINATED SOIL
CONTAMINATED SOIL
CONTAMINATED SURFACE IMPOUNDMENT
<"-••>
i .> POND 4-SURFACE WATER COLLECTION AREA
POTENTIAL CONTAMINANT MIGRATION PATHWAY
A'
SCHEMATIC CROSS SECTION
Trsolmsnl
Building
Schematic Cross Section (not lo scale)
A
POTENTIAL PATHWAYS
I) Wind deposition ol contaminated cur lac* water on surrounding soil
2) Vololllliatlon ol naiordous substances Ira* contaminated surloce water or soil
SI Inllllrollon ol contaminated surlac* water from sgrlace Impoundments and
ponds Into soil and ground water
41 Subturloc* loltral and vertical migration ol contaminant* via ground water
lo bsdrock and oil-ill* alluvium and bedrocl
ft) Contaminated ground wal*r r*surloc*s as seeps
A'
6) Conlonlnaitd ground
• llh voltr llOfi
ol«r rtcharglng Flintr Ollck and Irantparltd all lilt
71 Surloc* runoll Iron) conlomlnolid toll artai lo Flinor Ollck or oil lit* loll
• ) Alrborn* transport ol otbtitot llbtri
• ) Intlllrollon ol conlomlnoKd woUr pondid In bo»m«nt ol lr*olmont plant
building and ol haiardoui lubiloncci Irom on -ill* conlalntri
K» Vololllliollon of lioiordou* tubiloncct Irani on- ill* contolntrt
FIGURE D-l
Potential Surface and Subsurface
Contaminant Migration Pathways at the
Broderick Wood Products Site
Adams County, Colorado
JACOBS ENGINEERING GROUP INC.
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E. SCOPE AND ROLE OF RESPONSE ACTION
Response Actions as Operable Units
As noted previously, the remedy selected in this document is an
interim remedy or "operable unit." EPA is selecting this remedy
as part of a multi-phase cleanup process at the BWP site.
The current National Contingency Plan (NCP) contemplates
selecting and implementing such "phased" operable units prior to
selection of an appropriate final remedial action for a site.
Such operable units must be cost-effective and consistent with
achieving a permanent remedy at the site.
The Multi-Phase Process at BWP
Phase I of the RI/FS at BWP consisted of studies conducted by a
BIC consultant during 1983-84. While the information gathered
during these studies has provided useful background information,
the Phase I studies and report did not lead to any remedy
selection.
After BIC submitted the Phase I report, EPA and BIC negotiated
over further RI/FS activities to be conducted. These
negotiations resulted in a partial consent decree (PCD), which
required BIC to conduct a Phase II RI/FS to define the extent of
contamination and develop remedies to address the problem.
Additionally, a Phase III RI/FS would be required if EPA
concluded that the Phase II RI/FS did not sufficiently address
the problem.
After reviewing the draft Phase II RI/FS report submitted by BIC
in December 1986, EPA concluded that further (Phase III) RI/FS
studies would be required. The Phase III RI/FS will define the
full nature and extent of contamination associated with the site,
and develop remedies to address that contamination. The main
focus of Phase III will be: the contaminant plume offsite to the
north and in the bedrock; contamination in surface soils at the
site; and "hot spots" of contamination at the site, including
buildings and vessels. After the Phase III RI/FS is completed, a
remedy will be selected to address the remaining contamination.
However, EPA also concluded that the draft Phase II report was
complete insofar as the information in the report was sufficient
to support implementation of certain interim remedies while the
Phase III RI/FS is conducted. EPA was particularly interested in
those remedies relating to source control and the direct contact
pathway. EPA believed that implementation of these remedies
would be consistent with future studies and remedies at the site.
- E-1 -
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Scope of This Operable Unit at BWP
After considering EPA's comments, BIC agreed to revise the draft
Phase II RI/FS report to address or develop interim remedies
relating to the following five "segments" of site cleanup:
1. SITE ACCESS: The revised report considered remedies to
address the fact that access to the site is not adequately
restricted. Access restrictions such as signs, fences and
security guards were evaluated.
2. IMPOUNDMENTS: The main and secondary impoundments remain the
major sources of contamination on the site. The revised
report addressed the impoundment contents (sludge, oil and
water), as well as the visibly contaminated soils directly.
under the impoundments.
3. FACILITY AREA (BUILDINGS, VESSELS, ETC.): This segment of the
revised RI/FS addressed potential demolition and disposal of
contaminated and fire-damaged structures in the Treatment
Facilities and Shop Areas. Also to be addressed in this
segment were potential remedies for the contents of the
vessels, including the "firewater" remaining after the July
1985 fire.
4. SURFACE SOILS: In this segment, remedies for contamination of
surface soils at the site were evaluated. These evaluations
were somewhat constricted by the lack of complete knowledge
about the nature and extent of the contamination.
5. MONITORING: Under this segment, the RI/FS process focused on
methods to measure the effectiveness of the various remedies
being proposed. These methods included such monitoring
techniques as inspections, sampling" of emissions, ground
water monitoring, etc.
After receipt and review of the revised Phase II RI/FS report
submitted by BIC, EPA concluded that certain modifications to the
report were required to support the remedies that EPA believed
were supportable by the studies. EPA tasked its contractor to
perform these modifications, and a supplemental Phase II RI/FS
report was completed in November 1987.
The remedies considered for this first OU at the BWP site are
based on all three of the Phase II RI/FS reports: the draft and
revised Phase II RI/FS reports submitted by BIC, and the
supplemental report developed for EPA.
- E-2 -
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F. EVALUATION OF REMEDIAL ALTERNATIVES
Five Segment Approach
As discussed in chapter E, the remedies evaluated as part of the
first operable unit (OU) at the BWP site during the Phase II
RI/FS were based on the five segments to be addressed in the 00.
These segments are:
site access;
the surface impoundments;
the facility area (buildings, vessels, etc.);
surface soils; and
monitoring
The remedies considered under each of these segments were
designed to address the chief.health and/or environmental risks
associated with each segment. The evaluation process summarized
here will also use this five-segment structure.
Remedial Action Objectives
The overall objective of any remedial action at the BWP site is
to protect human health and welfare, and the environment. Any
remedial actions must also comply with CERCLA (as amended by
SARA), and the National Contingency Plan (NCP) [40 CFR Part 300],
Specific objectives for remedial actions at the site in this OU
involve the following:
1. Addressing the contents of the impoundments as the
greatest concentration of contaminants on site; measures
to address these contaminants would necessarily address
all applicable or relevant and appropriate requirements
that govern such measures.
2. mitigating the following risks or pathways summarized
from Section D:
o Ingestion of hazardous substances in the surface
soils and the impoundments.
o Direct dermal contact with hazardous substances in
surface soils and the impoundments.
o Inhalation of airborne hazardous substances.
o Ingestion of contaminated ground water.
- F-1 -
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Initial Screening
As noted previously, the Phase II RI/FS is documented in the two
BIC reports and the EPA supplemental report. These reports
identified over 40 remedial action alternatives (in addition to
the No Action alternative) for consideration as solutions to the
various risks and pathway scenarios posed by contamination at the
BWP site. Descriptions of the various alternatives are contained
in the three reports, and many of them are summarized later in
this chapter.
All of the 40+ alternatives identified in the reports were first
subjected to an initial screening to eliminate those, which for
reasons of technical infeasibility or lack of implementability,
did not merit further consideration as remedies in this OU. A
related purpose for the initial screening was to reduce the
number of alternatives for a subsequent, more rigorous detailed
evaluation.
In this initial screening process, several of the alternatives
were eliminated from further consideration for a variety of
reasons. For example, several of the alternatives for treating
contaminated water were judged infeasible because of
administrative or regulatory constraints. Also, all of the
alternatives to address surface soil contamination were
eliminated because the full extent of that contamination has not
yet been defined, and because soil cleanup goals for the site
have not yet been established. Soil remediation will be
addressed in the Phase III RI/FS.
Description of Alternatives
Those alternatives that remained after the initial screening are
presented in Table F-1. These alternatives were carried through
the rest of the evaluation process. A summary description of
each of these alternatives (using the five-segment structure)
follows:
I. SITE ACCESS - under this segment, the remedies evaluated
included the following:
A. No Action
The site would remain in its current condition; site
access restrictions would not be modified.
- F-2 -
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B. Posting Notices
Twenty warning signs"displaying the warning: "Danger -
Hazardous Waste - Unauthorized Personnel Keep Out"
would be posted around the site in strategic locations.
Two options were evaluated, signs that are legible at
50 feet, and signs legible at 125 feet.
Selective Fencing
A six-foot chain-link fence would be erected around the
surface impoundments. This would prevent access to an
area defined by the impoundments. Additionally, a
"field farm fence" would be erected around the visibly
contaminated surficial soil areas in the treatment
plant/shop area.
D. Fencing Entire Site
A six-foot chain-link fence topped with three strands
of barbed wire would be erected around the perimeter of
the site. Two 20-foot wide gates would be included for
site access and fire control.
E. Security Guards
Access to the site would be monitored and restricted by
providing guards on a 24 hours per day - 7 days per
week schedule. Provisions for this security would
include a shelter, electrical and telephone hookups and
sanitary facilities.
II. IMPOUNDMENTS/Sludge:
A. No Action
The impoundment sludge would remain in place in the
unlined main and secondary impoundments.
B. Excavate and reclaim
The sludge would be separated into commercially
valuable creosote, water and solids. The creosote
could potentially be sold, the water evaporated or
managed with the impoundment water, and the solids
disposed at an approved landfill. It is estimated that
an 80 percent recovery rate could be attained.
- F-3 -
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Excavate, stabilize and dispose off-site
The sludge in the impoundment vould be stabilized
through the addition and mixing of physical and
chemical stabilizing agents. The sludge vould be mixed
in place, with an equal volume of stabilizing agent.
Once the sludge was solidified/stabilized, the material
vould be excavated and transported to a loading area
for subsequent off-site disposal in an approved
hazardous vaste landfill.
0. Excavate and incinerate off-site
The sludge vould be tested to determine the material
compatibility with the off-site facility. The sludge
vould be solidified as needed for transportation. It
would then be excavated and stockpiled for immediate
bulk transport. The material would be incinerated in
ah off-site permitted facility.
E. Excavate and incinerate on-site
The sludge in the impoundments would be excavated and
incinerated on-site using a mobile.thermal incinerator,
Some stabilization might be required to facilitate
handling and loading the sludge. Three incinerator
processes were evaluated: a rotary kiln, an infrared
kiln, and a circulation bed system. These incinerator
processes are discussed in detail in the revised Phase
II RI/FS report. Residue (ash) from the process would
be transported to a hazardous waste landfill.
II. IMPOUNDMENT/Oil:
A. No Action
The oil would remain on the surface of the main
impoundment and would continue to inhibit evaporation
of the water in that impoundment.
B. Pump from impoundment and treat (capture) with carbon
adsorption
The oil would be skimmed off the surface of the main
. impoundment and pumped into the carbon adsorption
system after treatment of the main impoundment water.
It might be necessary to store the oil temporarily
- F-4 -
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while the water treatment process is proceeding. The
spent carbon would be reclaimed by the commercial
provider of the carbon canister(s).
C. Pump from impoundment and incinerate on-site
The oil would be skimmed off the surface of the main
impoundment and incinerated along with the impoundment
sludge.
II. IMPOUNDMENT/Water:
A. No action
Impoundment water would remain in the main impoundment
on a year-round basis, and in the secondary impoundment
on a seasonal basis.
B. Evaporate in secondary impoundment
The main impoundment water would be pumped onto the
upper crust of the secondary impoundment to depths not
exceeding six inches and allowed to evaporate. It is
assumed that this alternative would be undertaken
during the dry part of the year and that the secondary
impoundment would not contain an appreciable amount of
water. It is also assumed that three applications of
water would be required, based on the volume of water
present and additional precipitation.
C. Treat with carbon adsorption; dispose on-site via
evapo-transpiration
The water from the main impoundment would be treated to
eliminate contaminants in a carbon adsorption system.
The treated water would be discharged to a vegetated
area of the site to be eliminated through evapo-
transpiration. The rate of discharge would be
monitored and controlled so as not to exceed the evapo-
transpiration rate.
D. Pump to new lined pond and evaporate; incinerate liner
A new lined pond would be constructed on the site. The
main impoundment water would be pumped into the pond
for evaporation. The preferred period for evaporation
would be from June through September when evaporation
- F-5 -
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rates are the highest. At the end of use, the pond
would be dismantled and the liner would be incinerated
or disposed of in an appropriately permitted landfill.
E. Use as incineration quench water
The water would be used as quench water in the mobile
incinerator used for the sludge and/or soils.
II. IMPOUNDMENT/Soil:
The RI/FS confirmed the existence of contaminated soil beneath
the impoundments but did not define the extent or degree of that
contamination. Consequently, the first operable unit will be
restricted to addressing visibly contaminated soil. Other
contaminated soils beneath the impoundments will be addressed
during the Phase III RI/FS.
A. No action
The visibly contaminated soil would remain beneath and
around the impoundments.
B. Excavate and dispose off-site
The visibly contaminated soil would be excavated with
backhoe digging equipment and front end loaders. Soil
requiring stabilization due to residual sludge or water
would be solidified by mixing with kiln dust, alpha
Portland cement or possilime to meet the paint filter
test required for transportation and disposal. The
soil could be temporarily stockpiled prior to loading
in trucks for disposal. The soil would be transported
as bulk shipments to an approved hazardous waste
landfill. Truck scales and a decontamination pad would
be constructed on site.
C. Excavate and biodegrade on-site
The visibly contaminated soil beneath and around the
impoundments would be excavated and treated on the site
using an engineered biodegradation system (EBDS). The
EBDS is a unit process for immobilizing and
biologically degrading compounds using soil as the
medium for growing and maintaining the necessary
microorganisms. The major components of this system
consist of treatment and storm water control units.
- F-6 -
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D. Excavate and manage on-site (temporary waste pile)
The visibly contaminated soil beneath and around the
impoundments would be excavated and stockpiled in an
isolated area of the impoundment. The ultimate
disposition of the soils would be determined or
resolved as part of the final solution for the entire
site
Excavate and incinerate on-site
Samples of contaminated soil would be tested to
demonstrate compatibility with the incineration
process. The visibly contaminated soil beneath and
around the impoundments would be excavated and
incinerated on the site using the mobile incinerator
used for the impoundment sludge. It is likely that the
soil would be mixed with the sludge and/or oil prior to
incineration.
Excavate and incinerate off-site
Samples of contaminated soil would be tested to assure
compatibility with facility criteria. The visibly
contaminated soil beneath and around the impoundments
would be excavated. Soils requiring stabilization due
to residual sludge or other liquids would be stabilized
prior to transportation. The soil could be temporarily
stockpiled prior to loading in trucks for disposal.
The soil would be transported as bulk shipments to an
approved hazardous waste incinerator. Truck scales and
a decontamination pad would be constructed on site.
III. FACILITY AREA/Firewater:
Treatment options for the "firewater" would also apply to other
contaminated water found or generated during building/structure
decontamination process.
A. No action
The firewater would remain in its present locations in
the basement of the treatment plant and/or vessel(s) on
the site.
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B. Filter asbestos fibers; filters disposed in hazardous
vaste facility
The firewater would be filtered to remove any asbestos
fibers. The filter would be appropriately packaged and
disposed in a facility licensed to accept asbestos
fibers. Further treatment of the water is discussed
below.
Evaporate in secondary impoundment
Contaminated water would be pumped to the secondary
impoundment in depth not to exceed six inches and
allowed to evaporate. This alternative includes an
assumption that it would take place during a dry time
of year (June through October), and that the secondary
impoundment would not contain an appreciable amount of
water.
D. Treat with carbon adsorption; dispose on-site via
evapo-transpiration
Contaminated water would be pumped through an activated
carbon adsorption unit. The treated water would be
sampled and analyzed periodically to verify the
effectiveness of the process. The treated water would
be discharged to the eastern portion of the site at a
rate not to exceed the evapo-transpiration rate.
E. Pump to new lined pond and evaporate; incinerate liner
A new lined pond would be constructed on the site. The
firewater would be pumped into the pond for
evaporation. The preferred period for evaporation
would be from June through September when evaporation
rates are the highest. At the end of use, the pond
would be dismantled and the liner would be incinerated
or disposed of in an appropriately permitted landfill.
It is likely that the evaporation pond would be the
same one used for the main impoundment water.
F. Use as incineration quench water
The contaminated water would be used as quench water in
the mobile incinerator while incineration of the sludge
and/or soils proceeds.
- F-8 -
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III. FACILITY AREA/Buildings:
A. No action
The existing site structures would be left in place and
evaluated later as part of the final solution.
B. Demolish, decontaminate and dispose of debris in an
approved landfill
The treatment plant and shop buildings on the site
would be demolished (razed). Asbestos and asbestos
contaminated material would be segregated and disposed
of in an appropriate hazardous waste landfill.
Building debris would be cleaned with a high-pressure
water stream and tested for residual contamination.
Debris that is no longer contaminated would be
transported to an industrial landfill. Steel debris
would be salvaged or disposed of as scrap after the
decontamination process. Residual organic wastes would
be treated according to their medium. Sludge-like
material could be treated the same as the impoundment
sludge, and water could be treated like the impoundment
water. Removal activities involving asbestos will
require adherence with state, federal and local
regulations regarding asbestos handling protocol, which
will impact the method of building demolition.
III. FACILITY AREA/Vessels:
As noted in Section C, the contents of vessels have not been
fully charac'terized. In order to select cleanup alternatives for
these vessels and/or their contents, further characterization
will be necessary during the Phase III RI/FS.
A. No action
The vessels would be left in place with their contents,
and would be further addressed during Phase III.
B. Dispose of contents appropriately
The contents of the vessels would be emptied with a
hydraulic sludge pump and treated appropriately
according to medium. Sludge-like materials would be
treated like the impoundment sludge, with an emphasis
on reclaiming product where possible. Contaminated
water would be treated like the impoundment water.
- F-9 -
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Use as temporary storage ~
Usable vessels would be emptied of their contents,
which would be tested and treated appropriately. The
vessels would then be decontaminated with a high
pressure water stream or solvent wash. The vessels
would either remain in place or be moved to an area of
the site where they might be used in future remediation
tasks.
D. Demolish and dispose in a commercial industrial
landfill
Vessels would be emptied of their contents, which would
be tested and treated appropriately. After-decontami-
nation, the vessels would be cut into manageable sizes
and loaded into roll-off boxes and/or dump trucks for
transportation to an industrial or commercial landfill.
E. Demolish and transport to scrap yard
Vessels would be emptied of their contents, which would
be tested and treated appropriately. After decontami-
nation, the vessels would be cut into manageable sizes
and loaded into roll-off boxes and/or dump trucks for
transportation to a scrap yard.
IV. SURFACE SOILS/with Organic Contamination:
The Phase II RI/FS identified areas where surface soils contain
elevated levels of organic contamination. However, the degree
and extent of soil contamination have not been fully evaluated
for the entire site. Additionally, an appropriate action level
for cleanup of any soils other than those that are visibly
contaminated remains to be determined. Consequently, all
remedies addressing contaminated surface soils were eliminated
during the initial screening process, and the only alternative
that remained was "No action at this time."
A. No action at this time
The soils would remain in place and be the subject of
further study during the Phase III RI/FS. There is
insufficient information to support remedy selection at
this time.
- F-10 -
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IV. SURFACE SOILS/with Metals Contamination:
The Phase II RI/FS identified areas where surface soils contain
elevated levels of inorganic contamination. However, the degree
and extent of soil contamination have not been fully evaluated
for the entire site. Additionally, an appropriate action level
for cleanup of soils remains to be determined. Consequently, all
remedies addressing contaminated surface soils were eliminated
during the initial screening process, and the only alternative
that remained was "No action at this time."
A. No action at this time
The soils would remain in place and be the subject of
further study during the Phase III RI/FS. There is
insufficient information to support remedy selection at
this time.
V. MONITORING
The performance of the implemented operable unit would be
monitored both to assure that the remedies are effective and to
comply with any associated ARARs. Specific monitoring activities
cannot be identified until remedy design phase.
A. No action
•
No monitoring"would take place.
B. Monitoring performance of implemented actions
A variety of remedy-specific monitoring procedures
would be implemented, depending on the specific
remedies selected:
Monitoring of site access restrictions would be
conducted via periodic site inspections;
Temporary storage vessels, impoundments, etc. would
be monitored regularly throughout their use.
Air emissions and/or ash residues from any
incineration process would be sampled and tested
regularly to assure compliance with air standards
and the effectiveness of the incineration process.
The effluent from any liquid treatment process
would be sampled and analyzed regularly to assure
the effectiveness of the process.
- F-11 -
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C. Ground water monitoring
Monitoring to determine the nature and extent of ground
water contamination would be conducted to achieve two
purposes: •_ :
- Regularly scheduled monitoring of ground vater
would be used to establish baseline conditions
against which future conditions would be compared
to show the effectiveness of remedies.
- The Phase III RI/FS will include monitoring of
contamination in the ground water as one of its
primary objectives.
Detailed Evaluation Process
The remedial action alternatives that passed the initial
screening process were further refined and evaluated in detail,
as contemplated under Section 300.68(h) of the current NCP and in
Directive Number 9355.0-19 of the Office of Solid Waste and
Emergency Response (OSWER). This detailed analysis of each RAA
was based on a set of nine criteria developed from the NCP and
the new SARA language in CERCLA. These criteria relate directly
to factors mandated in Section 121 of CERCLA, particularly
Section 121(b)(1)(A-G). A major part of this evaluation of
alternatives was in considering the mandate to utilize permanent
solutions 'and alternative treatment technologies to the maximum
extent practicable, as specified in Section 121 of CERCLA.
The nine criteria are listed and described in Table F-2.
ARARs Considerations
The Phase II RI/FS process included an analysis of applicable or
relevant and appropriate requirements (ARARs) to determine which
requirements the various remedies for this OU at the BWP site
would have to meet. In this analysis, most ARARs were related to
specific remedies rather than to contaminants or locations.
In general, many of the remedies that were considered involved
the treatment, storage or disposal of listed and/or character-
istic hazardous wastes. Consequently, the primary ARARs for this
OU are Federal RCRA laws and regulations, or their State counter-
parts. The.State of Colorado has been delegated RCRA authority;
however, the State has yet to implement HSWA requirements.
Therefore, for some remedial actions, federal RCRA requirements
are more stringent and are the proper ARARs to be considered.
- F-12 -
-------
The specific ARARs considered for each remedial action
alternative are listed in Table F-3. Some discussion of those
ARARs follows:
For those remedies relating to Site Access, the applicable
regulations for site security are found in 6 CCR 1007-3 Section
264.14. In particular, this section establishes minimum
requirements for restricting site access to hazardous waste
facilities.
The alternatives which address the contents of. the Impoundments
will generally involve the treatment or disposal of the listed
K001 sludge. The water and oil in the impoundments is not a
listed hazardous waste; however, these liquids contain hazardous
constituents and the remedies were evaluated on the basis of
their ability to treat these liquids as if they were a hazardous
waste.
The impoundment remedies are all subject to specific design and
operating requirements applicable to the particular remedies
being evaluated. For incineration, these requirements are found
at 6 CCR 1007-3 Part 264 Subpart 0. For surface impoundments and
waste piles, design and operating requirements are found in more
stringent federal regulations in 40 CFR 264 Subparts K and L,
respectively.
For the K001 sludge, HSWA Land Disposal Restrictions are
applicable. In the May 17, 1988 Federal Register, draft
regulations proposed the following treatment standards to define
Best Demonstrated Available Technology (BOAT) for disposal of
K001 waste after incineration:
Constituent Total Composition (mq/kg) TCLP (mq/1)
Naphthalene 7.98 na
Pentachlorophenol 36.75 . na
Phenanthrene 7.98 na
Pyrene 7.28 na
Toluene 0.143 na
Xylenes 0.162 na
Copper na 0.71
Lead na 0.53
Zinc na 0.066
For those remedies involving treatment of contaminated water, the
provisions of 6 CCR Section 261.3 would apply to determining
whether the water treated by carbon absorption is still a
hazardous waste after such treatment. If the treated water is a
hazardous waste as defined in the applicable regulations, then
subsequent land treatment of the water would be subject to the
requirements of 6 CCR 1007-3 Part 264 Subpart M.
- F-13 -
-------
In compliance with EPA's Offsite Policy, all alternatives which
include off-site disposal of contaminants and treatment residues
would be required to have such disposal occur at a licensed RCRA
facility.
The treatment and disposal of asbestos is covered by State
Regulation Number 8, which requires notification of the Air
Pollution Control Division prior to undertaking asbestos removal
activities. State Regulation Number 1 regulates fugitive dust
emissions and would be applicable to any demolition process.
There may be other listed wastes in some of the vessels in the
treatment facility area, and RCRA regulations are likely to list
some other materials or wastes relating to the site in the near
future.
Costs Analysis
Consistent with the CERCLA mandate for cost-effective remedies,
all the RAAs were evaluated on the basis of cost-effectiveness.
Costs associated with each of the remedies under consideration
are summarized in Table F-4.
In comparing costs among different remedies, only remedies with
similar results or main features have been compared.
Results of the Detailed Evaluation
The results of the detailed evaluation of each remedy against the
nine criteria are found in Table F-5. The following discussion
highlights the results presented in the table:
For the Site Access remedies, the Posting Notice remedy scored
high, but it was noted that this could not be the sole component
of the Site Access remedy. Fencing the entire site scored
highest among the other remedies, particularly because of its
overall protectiveness, implementability, and low cost.
Among the Impoundment remedies, On-Site Incineration was rated
high for both the sludge and the oil based on its permanence,
protectiveness, reduction of TMV, and relative low cost.
Carbon treatment, the new lined pond and the quench water options
were all rated highly for addressing contaminated water, although
there were some concerns about each of them.
Several RAAs scored high for addressing the impoundment soils,
with on-site incineration and on-site management both showing
favorable qualities because of permanence and implementability,
respectively.
- F-14 -
-------
in the Facilities Area, the RAAs to treat the firewater were
rated similarly to the Impoundment water RAAs. For the RAAs
addressing both buildings and the vessels, no particular remedy
stood out, mostly because of the unknowns associated with this
segment of the site.
For the Surface Soils, the detailed analysis was severely
hampered by the lack of information on the full nature and extent
of the contamination in that medium.
- F-15 -
-------
Table F-l
LISTING OF INTERIM REMEDIAL ALTERNATIVES CONSIDERED FOR THE
BRODERICK HOOD PRODUCTS SITE, ADAMS COUNTY, COLORADO1
SBOlENT/Probli
Al
I. SITE ACCESS:
A. No action
B. Posting notices
C. Selective fencing
D. Fencing entire site
E. Security guards
II. IMPOUNDMENTS:
Sludge A. No action
B. Excavate and reclaim
C. Excavate, stabilize and dispose off-site
D. Excavate and incinerate off-site
E. Excavate and incinerate on-site
Oil A. No action
B. Pump from impoundment and treat (capture) with carbon adsorption
C. Pump from impoundment and incinerate on-site
Water A. No action
B. Evaporate in secondary impoundment
C. Treat with carbon adsorption: dispose on-site via evapo-transpiration
D. Pump to new lined pond and evaporate; incinerate liner
E. Use as incineration quench water
Soil A. No action
B. Excavate and dispose off-site
C. Excavate and biodegrade on-site
D. Excavate and manage on-site (temporary waste pile)
E. Excavate and incinerate on-site
F. Excavate and incinerate off-site
(1) The alternatives listed are those that remained after the initial screening process; these
alternatives were carried through the detailed analysis.
-------
Table F-l (cont'd)
USTDC Of INTERIM REMEDIAL ACTION ALTERNATIVES CONSIDERED FOR TEE
HRCCERICX WOOD PRODUCTS SITE, ADAMS COUNTY, COLORADO1
gPfXTVTVTVnM <*m Alternatives
III. BUILDINGS. VESSELS, ETC.
Plrewster2 A. No action
B. Filter asbestos fibers; filters disposed In hazardous waste facility
C. Evaporate in secondary impoundment
0. Treat with carbon adsorption; dispose on-slte via evapo-transplratiori
E. Pump to new lined pond and evaporate; Incinerate liner
F. Use as incineration quench water
Buildings A. No action
B. Demolish, decontaminate and dispose of debris in an approved landfill
Vessels A. No action
B. Dispose of contents appropriately
C. Use as temporary storage
D. Demolish and dispose in a commercial Industrial landfill
E. Demolish and transport to scrap yard
IV. SURFACE SOILS Contaminated with:
Organics A. No action at this time
Metals A. No action at this time
V. MCNTTCRUC A. No action
B. Monitoring performance of implemented actions
C. Ground-water monitoring
(1) The alternatives listed are those that remained after the Initial screening process; these
alternatives were carried through the detailed analysis.
(2) Treatment options for "firewater" will also apply to other contaminated water found or
generated during building/structure decontamination process.
-------
Table F-2
ALTERNATIVE EVALUATION CRITERIA FOR INTERIM REMEDIES
AT THE BRODERICK WOOD PRODUCTS COMPANY
ADAMS COUNTY, COLORADO
1. Overall protection
This criterion evaluates how the alternative eliminates,
reduces, or controls existing and potential risks to human
health and the environment through treatment, engineering
contols, and/or institutional controls.
2. Compliance with ARARs
This criterion considers the ability of each RAA to attain
chemical-specific, location-specific, and action-specific
applicable or relevant and appropriate requirements (ARARs);
also considered are other criteria, advisories, and
guidances. If a waiver is to be invoked, the justification
for that waiver will be discussed.
3. Permanence
Under this criterion, the evaluation compares the magnitude .
of total residual risk in terms of untreated waste and
treatment residuals. This criterion also covers the adequacy
and suitability of engineering and institutional controls
used to manage untreated waste and treatment residuals. The
criterion also considers the reliability of the alternative
over time, including the potential for failure and the
resulting potential risk.
4. Reduction of TMV (toxicity, mobility, or volume)
This criterion includes an evaluation of the treatment
process(es) and the kinds and amounts of waste material to be
treated. The evaluation considers whether or not treatment
is a principal element in the alternative, and how the
treatment will reduce or destroy the waste. Other
considerations include the degree (percentage) of treatment,
degree of irreversibility and the kinds and amounts of
residuals.
page 1 of 3
-------
.Table F-2 (cont'd)
ALTERNATIVE EVALUATION CRITERIA FOR INTERIM REMEDIES
AT THE BRODERICK WOOD PRODUCTS COMPANY
ADAMS COUNTY, COLORADO
5. Short-term effectiveness
Considerations under this criterion include: potential
impacts on the community during implementation of the
alternative; potential impacts on and protective measures for
workers during implementation; potential environmental
impacts and mitigation measures; and time until protection is
achieved.
6. Implementability
This criterion includes the following considerations:
a. Technical Feasibility:
Reliability of the technology
Difficulties and unknowns associated with technology
Ease of undertaking additional action, if necessary
Consistency with future remedies at the site
Reliability and effectiveness of remedy monitoring
b. Administrative Feasibility:
Ability and time required to obtain permits/approvals
Required coordination with other agencies and
associated time requirements
c. Availability of services and materials
Treatment, storage and disposal capacity
Existence of multiple vendors
Availability of needed equipment and specialists
Timing of technology availability
7. Cost
This includes capital costs, operation and maintenance, and
present vorth analysis. When comparing different
alternatives for costs, only alternatives with similar
results will be compared.
page 2 of 3
-------
Table F-2 (cont'd)
ALTERNATIVE EVALUATION CRITERIA FOR INTERIM REMEDIES
AT THE BRODERICK WOOD PRODUCTS COMPANY
ADAMS COUNTY, COLORADO
8. State acceptance
This criterion addresses those features of each alternative
that the State supports, those features about which the State
has reservations, and those elements which the State strongly
opposes,
9. Community acceptance
This criterion addresses those features of each alternative
that the community supports, those features about which the
community has reservations, and those elements which the
community strongly opposes.
page 3 of 3
-------
— , Table F-3
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS FOR IKTERIM REMEDIAL ALTERNATIVES
ERODERICX WOOD PRODUCTS SITE, ADAMS COUNTY, COLORADO1
AT tprnattvg
I. SITE ACCESS:
A. No action
B. Posting notices
C. Selective fencing
D. Fencing entire site
E. Security guards
Appllpahlp nr Rt»1 gvant and Appropriate
In general) ARARs are those state regulations found at 6
OCR 1007-3 Section 264.14. These regulations and their
federal counterparts (40 CFR 264.14) require either 24-
hour surveillance of the facility, or access restrictions
such as fences, gates, signs, etc.
Would not meet ARARs noted above.
Signs mist be In English and any other predominant
language; oust be visible from >25 feet.
Selective fencing would meet ARARs if extent of
contamination could be well defined.
An option that would be consistent with the regulation,
particularly if contamination is widespread.
One of the options contained in the regulations.
II. IMPOUNDMENTS/Sludge
A. No action
B. Excavate and reclaim
C. Excavate, stabilize
and dispose off-site
The sludge is listed as a.waste (K001) under RCRA
regulations, and Is subject to land disposal
restrictions.
Would not comply with ARARs. Statutory requirement
(Section 3005(j) of HSWA) requires all surface
Impoundments to be retrofitted to meet Section 3005(o)
standards by November 8, 1988.
t,
Product from reclaiming process would not be subject to
RCRA regulations. RCRA land disposal restrictions would
apply to residues from reprocessing the K001 sludge as of
August 1988. Any residues to be disposed in a landfill
would have to meet Best Demonstrated Available Technology
(BDAT) standards, and the residues would likely contain
excessive levels of penta and/or dioxlns. If the sludge
or residues need to be stored more than 90 days In an
area other than the impoundments prior to reclaiming or
disposal, the State and Federal regulations on surface
Impoundments (6 OCR 1007-3, 264 Subpart K and 40 CFR 264
Subpart K, 264.220-249, respectively) would be
applicable. State regulations at 6 OCR 1007-3, Part 264,
Subparts I and J would apply to the use of any containers
and tanks during the reclaiming process.
RCRA Land Disposal restrictions will apply to sludge as
of August 1988. Any sludge to be disposed in a landfill
would have to meet Best Demonstrated Available Technology
(BDAT) standards; the excessive levels of penta and/or
dioxins in the sludge will make it difficult to meet
BDAT. If the sludge needs to be stored on-site in a new
Impoundment prior to transport, the State and Federal
regulations on surface Impoundments (6 CCR 1007-3, 264
Subpart K and 40 CFR 264 Subpart K, 264.220-249,
respectively) would be applicable. RCRA manifest
requirements (40 CFR 262, Subparts B, C) would apply to
transporting the waste.
page 1 of 5
-------
Table F-3 (confMT
APPLICABLE OR RELE7AOT AND APPROPRIATE REQUIREMENTS FOR INTERIM REMEDIAL ALTERNATIVES
HRODERICT WOOD PRODUCTS SITE, ADAMS COUNTT, COLCRADO1
Al tor-native
II. IMPOWDMEtrrS/SIudge (cont'd)
D. Excavate and incinerate
off-site
E. Excavate and incinerate
on-site
Aoollrahlg nr RP! gyant a TV) AnDFODcLate Ratruire
State and Federal regulations on incineration of RCRA/
hazardous wastes are found at 6 CCR 1007-3, 264 Subpart 0
and 40 CFR 264 Subpart 0 (264.340-351), respectively and
40 CFR 270.62. The sludge would have to be taken to a
licensed hazardous waste treatment facility. RCRA land
disposal restrictions would apply to disposal of treat-
ment residues. RCRA manifest requirements (40 CFR 262.
Subparts B, C) would apply to transporting the waste.
State and Federal regulations on incineration of RCRA/
hazardous wastes are found at 6 CCR 1007-3. 264 Subpart 0
and 40 CFR 264 Subpart 0 (264.340-351), respectively, and
40 CFR 270.62. RCRA land disposal restrictions would
apply to disposal of treatment residues, which will need
to meet BOAT levels. The substantive requirements of
State Air Pollution Control Regulations will also apply
to operating and controlling the incinerator.
II. IMPOUNDMENTS/Oil
A. No action
B. PI imp from impoundment and
treat (capture) with
carbon adsorption
C. Pump from impoundment and
incinerate on-site
The oil in the main impoundment contains hazardous
constituents. Although it is not a listed waste, the
impoundment water will be treated as if it were a
hazardous waste and EPA RCRA Land Disposal restrictions
would be considered relevant and appropriate because of
the penta and dioxin content.
Would not meet ARARs.
RCRA Land Disposal requirements would apply to disposal
of the carbon filter: the contents of the filter
cylinder would have to meet BOAT levels before disposal.
Applicable State and Federal regulations on incineration
of RCRA/hazardous wastes are found at 6 CCR 1007-3, 264
Subpart 0 and 40 CFR 264 Subpart 0 (264.340-351),
respectively. RCRA land disposal restrictions would be
relevant and appropriate to disposal of treatment
residues, if any remain from the incineration process.
II. IMPOUNDMENTS/Hati
A. No action
B. Evaporate in secondary
impoundment
C. Treat with carbon adsorp-
tion: dispose on-site via
evapo-transplratIon
The water in the main impoundment is in immediate contact
with the bottom sludge, which is a listed hazardous waste
(ROOD under RCRA. Additionally, the water contains
hazardous constituents. Consequently, although it is not
a listed waste, the impoundment water will be treated as
if it were a hazardous waste.
Would not meet ARARs.
The applicable requirements are those found in State and
federal regulations on surface impoundments (6 CCR 1007-
3, Subpart K and 40 CFR, Subpart K, 264.220-249,
respectively).
State regulations for disposing the water on-site would
require either treating the water to non-detectable
levels for hazardous constituents or compliance with Land
Treatment regulations found in 6 CCR 100/-3, Part 264,
Subpart M. State regulations at 261.3 would apply to
determining whether the treated water is still a
hazardous waste.
page 2 of 5
-------
Table F-3 (confd)
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS FOR INTERIM REMEDIAL ALTERNATIVES
BRODERId WOOD PRODUCTS SITE, ADAMS COUNTY, COLORADO1
Alt ernat tve
II. IMPOUNDMENTS/Water (confd)
D. Pump to new lined pond
and evaporate; Incinerate
liner
E. Use as incineration
quench water
or Relevant and. AnoroDriate
Lranents
Applicable State and Federal regulations on surface
impoundments, especially design considerations, are found
at 6 CCR 1007-3 Part 264, Subpart K and 40 CFR Part 264,
Subpart K (264.220-249), respectively. State and Federal
regulations on incineration of RCRA/hazardous wastes are
found at 6 CCR 1007-3, 264 Subpart 0 and 40 CFR 264
Subpart 0 (264.340-351), respectively and 40 CFR 270.62.
Applicable State and Federal regulations on Incineration
of RCRA/hazardous wastes are found at 6 CCR 1007-3, Part
264, Subpart 0 and 40 CFR Subpart 0 (264.340-351),
respectively. RCRA land ban restrictions would be
relevant and appropriate to disposal of treatment
residues, if any remain from the incineration process.
II. IMPOUNDMENTS/Soil
A. No action
B. Excavate and dispose
off-site
C. Excavate and biodegrade
on-site
D. Excavate and manage
on-site (temporary
waste pile)
D. Excavate and incinerate
off-site
E. Excavate and incinerate
on-site
The soils under the impoundments contains hazardous
constituents and will be treated as if they were a
hazardous waste.
Would not meet ARARs.
The RCRA Land Disposal regulations and off-site policy
would govern this alternative.
Applicable requirements would be State land treatment
regulations found at 6 CCR 1007-3, Part 264, Subpart M.
Additionally, Subparts F and C would also apply.
Two sets of regulations apply to this alternative: state
regulations at 264 Subpart L (264.250-269) include
requirements for either a single liner with ground water
monitoring or a double liner and leak detection without
ground water monitoring. Under parallel federal
regulations (264.250-269), requirements are for a single
liner and leachate collection system, 100 year storm
protection, among other things.
Applicable State and Federal regulations on Incineration
of RCRA/hazardous wastes are found at 6 CCR 1007-3, 264
Subpart 0 and 40 CFR 264 Subpart 0 (264.340-351),
respectively, and 40 CFR 270.62. The soil would have to
be taken to a licensed hazardous waste treatment
facility. RCRA land disposal restrictions would apply to
disposal of treatment residues. RCRA manifest
requirements (40 CFR 262, Subparts B, C) would apply to
transporting the waste.
Applicable State and Federal regulations on incineration
of hazardous wastes are found at 6 CCR 1007-3, 264
Subpart 0 and 40 CFR 264 Subpart 0 (264.340-351),
respectively, and 40 CFR 270.62. RCRA land disposal
restrictions would be relevant and appropriate to
disposal of treatment residues, which will need to meet
BOAT levels. The substantive requirements of State Air
Pollution Control Regulations will also apply to
operating and controlling the incinerator.
page 3 of 5
-------
Table F-3 (conf d)
APPLICABLE CR RELEVANT AND APPROPRIATE REQUIREMENTS FCR INTERIM REMEDIAL ALTERNATIVES
HRODERIO: WOOD PRODUCTS SITE. ADAMS OOUNTT, COLORADO1
Alternative
III. FAdLTTT AREA/Flreuati
A. No action
B. Filter asbestos fibers;
filters disposed in
hazardous waste facility
C. Evaporate in secondary
impoundment
D. Treat with carbon adsorp-
tion: dispose on-site via
evapo-transpiration
E. Pump to new lined pond
and evaporate; incinerate
liner
F. Use as incineration
quench water
AllraKlo nr RfjVgvaTit and Aroriate
The firewater has been in contact with hazardous
constituents and contains hazardous constituents and will
be treated as if it were a hazardous waste.
Would not meet ARARs.
State Air Regulations for handling the asbestos-laden
will apply. These requirements are found at Air Quality
Control Commission Regulation Number 8.
The applicable requirements are those found In State and
federal regulations on surface Impoundments (6 OCR 1007-
3. Subpart K and 40 CFR, Subpart K, 264. 220-249,
respectively).
State regulations for disposing the water on-site would
be applicable and require either treating the water to
non-detectable levels for hazardous constituents or
compliance with Land Treatment regulations found In 6 CCR
1007-3, Part 264, Subpart M. State regulations at 261.3
would apply to determining whether the treated water Is
still a hazardous waste.
Applicable State and Federal regulations on surface
Impoundments, especially design considerations, are fou
at 6 CCR 1007-3 Part 264, Subpart K and 40 CFR Part 264
Subpart K (264.220-249), respectively. State and Federa
regulations on incineration of RCRA/hazardous wastes are
found at 6 CCR 1007-3, 264 Subpart 0 and 40 CFR 264
Subpart 0 (264.340-351), respectively and 40 CFR 270.62.
indj
al
Applicable State and Federal regulations on Incineration
of RCRA/hazardous wastes are found at 6 CCR 1007-3, Part
264, Subpart 0 and 40 CFR Subpart 0 (264.340-351),
respectively. RCRA land ban restrictions would be
relevant and appropriate to disposal of treatment
residues, if any remain from the incineration process.
III. FACILITY AREA/BuUdlngs
A. No action
B. Demolish, decontaminate
and dispose of debris in
an approved landfill
Would not meet ARARs.
State Regulations on handling and disposing of asbestos
will apply. Additionally, Colorado Air Quality Control
Regulation Number 1 will apply to controlling fugitive
dust during the demolition process. The State considers
any discarded chemical product to be F-llsted waste, and
such wastes dwould have to be removed from the debris
prior to off-site disposal.
III. FACIMTY AREA/Vessels
A. No action
B. Dispose of contents
appropriately
Would not meet ARARs.
The empty container rule at 40 CFR 261.7(b)(l) will
apply to determinations of when a container Is consider
empty. Some of the contents may be F-llsted wastes,.to
which "fast track" land disposal restrictions would appl>
after November 8, 1988. Such restrictions would require
that disposed wastes or residues meet BDAT levels.
I
page 4 of 5
-------
Table F-3 (cont'd)
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS FOR INTERIM REMEDIAL ALTERNATIVES
RODERICK HOOD PRODUCTS SITE, ADAMS COUNTT, COLORADO1
AT tprnattvp.
III. FACTUTY AREA7Vessels (cont'd)
C. Use as temporary storage
D. Demolish and dispose In
a commercial industrial
landfill
E. Demolish and transport to
scrap yard
Applicable or Rpl pvant anrf Appropriate Boqii
-------
SKXENT/
Problem
I. SITE ACCESS
Table
COMPARISONS OF COSTS OF KEY ALTERNATIVES FOR OPERABLE IKTT AT BWP
Cost*
Alternative
Unit Iotal_I$lQQQl Eelerence?
Comments
A. No Action
B. Posting Notices stating: "Danger - Hazardous Waste - Unauthorized Personnel Keep Out"
signs legible at 50*
signs legible at 125'
C. Selective fencing
3500 feet
520/ea
>125/ea
$10/ft
50. 4 C
?2.5 A, pg. 4-22
$35
A, pg. 4-29
D. Fence entire site
8750 feet
2 gates 20* each
Total
$8.75/ft
§18.75/ft
$76-6
^^
$77.4
B, pg. 63
E. Security guards
24 hour surveillance
$9/hr
$197
A, pg. 4-32
Assumes 24 hour/day surveillance for two years-
II. IMPOlftDMENTS/
Sludge (4000 yd3)
A. No Action
Sludge volume estimated at 3600 yd3 by ITC;
figure rounded to 4000 by Keystone
B. Excavate and reclaim
Remove, centrifuge 4000 yd3
Residuals to landfill
Total
5325/yd3
?369/yd3
$1300
§295
§1595
A, pg. 4-37
Backfill & cap noted by Keystone not Included
here- Residuals assumed to be 20* or 800ydJ-
page 1 of 8
-------
Table F-4 (cont'd)
COMPARISONS OF COSTS OF KEY ALTERNATIVES FOR OPERABLE UNIT AT BWP
II.
SEGMENT/
Prohlon Alternative
IMPOUNDMENTS/ (cont'd)
Sludge (4000 yd3) (confd)
Unit
TataLJJSlOQQl Beference2.
C- Excavate, stabilize and dispose off-site
Stabilization material.
Mix and remove 8000 vdj
Transport to landfill
Total
$125/yd3,
$62.5/yd3
$369/yd3
na
A, pg. 4-40
Comments
Sludge volume estimated at 3600 yd3 by ITC;
figure rounded to 4000 by Keystone.
Assumes 4000 yd3 stabilization material-
Backfill & cap noted by Keystone not Included
here.
D. Excavate and Incinerate off-site
Stabilization material.
Mix and remove 8000 ydj
Transport to Incinerator
Incinerate
Total
;125/yd3
Hffl3
?312/yd
na
$500
$500
51250
$2500
54750
A, pg. 4-43
Backfill & cap noted by Keystone not Included
here*
E-l- Excavate and Incinerate on-slte (Keystone)
Sludge removal $31 /yd3
Engineering
Incinerator contractor cost 281/ton
$125
$138
1125
I 388
A, pg. 4-48
Backfill & cap noted by Keystone not Included
here •
Keystone used 1-2 tons/ydJ; this figure Is
based on 1.0 ton/yd •
E-2- Excavate and Incinerate on-slte (Jacobs)
12/yd3
Sludge removal
Incinerate on-slte
Dispose of 440 Tons of ash
Total
54977yd3
>369/ton
$48
$1989
,$162
$2199
D Backfill and cap noted by Keystone not Included
D here. Cost Includes test burn. Assumes 0-11
A, pg 4-40; D tons of ash/ton of sludge-
Oil (approximately 3000 gallons)
A. No Action
page 2 of 8
-------
Table F-A
COMPARISONS OF COSTS OF KEY ALTERNATIVES FOR OPERABLE UNIT AT BWP
SEQ4ENT/
Erablen
CostL
Alternative Unit Iata_L_L$lQQQl Reference?
II. IMPOUNDMENTS/ (cont'd)
Oil (cont'd)
B. Pimp firm iiopoundment and treat (capture) with carbon adsorption
$2.39/gal $7.2 D
C- Pimp fro* Impoundment and Incinerate on-slte
$3.03/gal $9-1 D
Water (approximately 560,000 gallons In main impoundment)
A. No Action 0
B. Evaporate In secondary Impoundment
Pumping costs $0-023/gal $13
B, pg. 69
Comnents
Keystone, estimate of 1.5 M gallons may be much
greater than actual; this evaluation uses
560,000 gallons, based on Jacobs estimate.
C- Treat with carbon adsorption; dispose on-slte via evapo-transplratlon
Carbon Treatment $0.033/gal $18-6
Evapo-transplratlon process $0.0185/gal $1(LA
Total $29.0
B. pg. 70; C Carbon Treatment costs prorated based on volume
D from total of $20K. Assumes a system with one
or two sprinkler heads> All pumping costs
Included here-
D. Pump to new lined pond and evaporate; incinerate liner
Build new pond (1-5 acres) $191 A, pg. 4-69
Pump water to pond $0-237/gal $133 A, pg. 4-69 .
Incinerate liner $5 D Assumes liner weighs 2-5 lb/yd*
Total $329
E- Use as Incineration quench water
Pump to Incinerator $0-0063/gal
$3.5
Assumes Incinerator equipped with holding tank.
page 3 of 8
-------
II.
SEQUENT/
Prahlea Alternative
IMPOUNDMENTS/ (confd)
Table F-4 (cont'd)
OCHPARISGNS OF COSTS OF KEY ALTERNATIVES TOR OPERABLE UNIT AT BMP
Cost1
Unit
Iutai_L$lQQQl Reference?
Ccnments
Soils under the Impoundments (volume estimated as large as 30,700 yd-*)
A. No Action $0
Volume Is estimate of naxlmumt actual volume
may be much less-
B- Excavate and dispose off-site
Excavate
Transport to facility
Disposal
Total
$12.5/yd3 $38*.
$156.2/yd3 $4796
212-5/yd3 $6524
$11704
Backfill & cap noted by Keystone not
here- Assumes 31,000 ydj of soil.
Includec
C- Excavate and blodegrade on-slte
A, pg. 4-56
Excavate
Blodegrade
Total
$29/yd3 .
16.35/yd3
5384
5502
5886
Backfill & cap noted by Keystone not Include
here- Assumes 30,700 ydj of soil.
D-l- Excavate and Manageon-slte (tenporary waste pile) (Keystone estimate)
Excavate to lined area $31.25/yd3 $959
A, pg. 4-59 Backfill & cap noted by Keystone not Includec
here
D-2. Excavate and Manage on-slte (tenporary waste pile) (Jacobs estimate)
Excavate half 2ndry Impndmt
Construct liner
2ndary soils to liner
Main soils to liner
Cover
Total
$10.5/yd3
na ,
SlO-5/yd3
$10-5/yd3
5108
>157
>215
108
>745
E-l. Excavate and Incinerate on-slte (Keystone)
B, D
B, D
B, D
B, D
A, pg. 4-62
Assumes 10,234 yd3 under main Impoundment,
20,466 ydj under secondary Impoundment. Line
area would be 1.9 acres In 2ndary Impoundment;
Excavate
Incinerate
Total
>12.5/yd3 $384
?342/yd3 §10498
$10882
Backfill & cap noted by Keystone not Include*
here- Assumes 31,000 ydj of soil to be :
Incinerated. ':
page 4 of 8
-------
SEGMENT/
Pcoblen
Table F-4
COMPARISONS OF COSTS OF KEY ALTERNATIVES FOR OPERABLE UNIT AT BMP
Cost!
Alternative
Unit
Total f$10QQ) Reference?
Comments
IT. IMPOUNDMENTS/ (confd)
Soils under the Impoundments (volume estimated as large as 30.700 yd3) (cont'd) Volume Is estimate of maximum; actual volume
may be much less-
E-2. Excavate and Incinerate on-slte (Jacobs) D
Excavate .
Incinerate 2500 ydj
Total
F. Excavate and Incinerate off-site
Excavate
Transport
Disposal (incineration)
Total
110.5/yd3
1490/yd3
e
U2.5/yd3
H56/yd3 .
1312- 5/yd3
A $52
$1225
$1277
$384
$4797
$9594
$14775
A, pg. 4-65
Backfill & cap noted by Keystone not Included
here- Assumes only 2500 yd to be incinerated-
Disposal of residue not Included.
Backfill & cap noted by Keystone not Included
here. Assumes 30.700 ydj of soil.
Ill- FACILITY AREA (BUILDINGS, VESSELS, ETC.)
Firewater: Cost estimates are all based on volume estimate of 40.000 from Keystone-
A- No Action
B. Filter asbestos fibers; dispose filters in hazardous waste landfill
Filter 40.000 gal $0-21/gal $8-4 A, pg- 4-73 Disposal of filter not Included
C- Evaporate water In secondary Impoundment
pump water to Impoundment $0-13/gal
$0.5
D. Treat with carbon adsorption; dispose on-slte via evapo-transplratlon
Carbon Treatment $0.033/gal
Evapo-transpiratlon process $0-0185/gal
Total
51-33 D. B. pg. 73 Carbon Treatment costs prorated based on volume
50.745 D from total of $20K- Assumes a system with one
$2-075 or two sprinkler heads• All pumping costs
Included here-
page 5 of 8
-------
Table F-4 (cont 'd)
COMPARISONS OF COOTS OF 1CET ALTERNATIVES FOR OPERABLE UNIT AT BWP
SEGMENT/
Prnblea Alternative Unit Iulai_t$lQQQl Reference?
III. FACILITY AREA (BUILDINGS, VESSELS, ETC.) (cont 'd)
Firewater (cont'd)
E. Pump to new lined pond and evaporate i Incinerate liner
Build pond, pump water to It Sl-28/gal $51 'A, pg. 4- 69 Assumes separate pond from Impoundment water
Incinerate liner $490/ton $0-4 pond- Cost would decrease significantly If
Total $51-4 combined with Impoundment water. Assumes liner
weighs 0.75 tons.
F. Use as incineration quench water
Pump to Incinerator $0-0l3/gal $0-5 D Assumes incinerator equipped with holding tank.
Buildings: The extent of remediation for this problem needs to be defined In greater detail regarding the degree to which the
debris can be decontaminated-
A. No Action at this time 0
B- Demolish, decontaminate and dispose of debris in an approved landfill
$458 A, pg- 4-81 Includes asbestos, debris and associated
contamination and sludge removal and disposal.
Vessels: The extent of remediation for this problem needs to be defined In greater detail regarding the contents of the vessels
and the degree to which the debris can be decontaminated.
A. No Action at this time 0
B. Dispose of contents appropriately unknown
C. Use as temporary storage $219 A, pg 4-85
D. Demolish and dispose in a oonnerclal industrial landfill
$325 A, pg 4-87
page 6 of 8
-------
SEGMENT/
Eroblen
Table F-*. (cc
COMPARISONS OF OCCTS OF KEY ALTERNATIVES FOR OPERABLE UNIT AT BWP
Cost1
Alternative Unit Iolal_£$10QQl Reference?
III. FACILITY AREA (BUILDINGS, VESSELS, ETC.) (confd)
Vessels (cont'd):
E. Demolish and transport to scrap yard $294 A, pg 4-89
Ccmnents
IV. SURFACE SOILS contaminated with:
Organlcs A- No Action
Metals A. No Action
$0
$0
B,
B,
Not enough Information to select remedy; will
be determined during Phase III RI/FS
Not enough Information to select remedy; will
be determined during Phase III RI/FS
page 7 of 8
-------
SEGMENT/
Prablen
Table F-4 (cont'd)
COMPARISONS OF COSTS OF KEY ALTERNATIVES FOR OPERABLE WIT AT BMP
Cost!
Alternative
Unit
Total ($10001 Refcrenre2
V- MONITORING: In general, costs of monitoring operable unit will be determined In greater detail during design stage.
Site Access
periodic Inspection of perimeter/signs unknown
Impoundments
Incineration: stack testing,
Staging areas: leachate monitoring
sampling treated water
ground water monitoring
unknown
unknown
Facility Area
Sampling of treated firewater
Further characterization of the buildings
and vessels-
unknown
unknown
Surface Soils
Will be Investigated further during Phase III RI/FS
Testing will accord with Colorado
Regulations
Hill be main focus of Phase III RI/FS.
Will be conducted In Phase III RI/FS.
Notes:
1 - All costs Include a 25" contingency fee-
2 - References:
A - "Revised Phase II RI/FS" by Keystone, July 1987
B - "Supplemental RI/FS Information" by Jacobs, November 1987
C - Jacobs communication to EPA, December 15, 1987
D - Jacobs Letter Report dated June 15, 1988
page 8 of 8
-------
Table F-5
Alternattve/
. Criterion
EVALUATION OF INTERIM REMEDIAL ACTION ALTERNATIVES
FOR THE BRODERICK WOOD PRODUCTS COMPANY
ADAMS COUNTY, COLORADO
Fvalnatirm
I.
A. No action
1. Overall protection
2. Compliance with ARARs
3. Permanence
it. Reduction of TMV
5. Short-term effectiveness
6. Implementabillty
7. Cost
8. State acceptance
9. Community acceptance
B. Basting notices
1. Overall protection
2. Compliance with ARARs
3. Permanence
it. Reduction of TMV
5. Short-term effectiveness
6. Implementability
7. Cost
8. State acceptance
9. Community acceptance
C. Selective fencing
1. Overall protection
2. Compliance with ARARs
Would not be protective. Unauthorized trespassers and
others would continue to be exposed to contamination.
Would not comply.
Not applicable.
No reduction of TMV.
Not effective in short term.
Not applicable.
No cost.
State would not accept.
Community not likely to accept.
Would alert public of potential danger from
contaminationi but not sufficient alone. Would not
control site access.
Signs legible at 50 feet will exceed regulatory
requirement, which says legible at 25 feet. Signs may
need to be in Spanish as well as English. This
alternative will comply with ARARs, but will not be
sufficient by Itself.
Not a permanent remedy.
Helps reduce potential for toxicity to Impact people by
warning them to stay away. Would not reduce actual TMV
associated with the site.
Effective for short term.
Easily Implementable.
Very low cost: $400.
Acceptable to State, provided not the sole remedy for
this problem area.
No negative response from community.
Would minimize contact only with known areas of
contamination: may not address other areas not yet known.
Would not comply with ARARs unless extent of
contamination was well defined.
page 1 of 19
-------
Table F-5 (conf d)
EVALUATION OF INTERIM REMEDIAL ACTION ALTERNATIVES
FOR THE BRODERICK WOOD PRODUCTS COMPANY
ADAMS COUNTY, COLORADO
Altprnat IVP/
C.r\ t priori
I.
(cont'd)
C. Selective fencing (cont'd)
3. Permanence
4. Reduction of TMV
5. Short-term effectiveness
6. Implementablllty
7. Cost
8. State acceptance
9. Community acceptance
D. Fencing entire alte
1. Overall protection
2. Compliance with ARARs
3. Permanence
it. Reduction of TMV
5. Short-term effectiveness
6. Implementablllty
7. Cost
8. State acceptance
9. Community acceptance
FValttatlrm
Not a permanent remedy.
Helps reduce potential for toxlclty by restricting public
access to contamination. Mould not reduce actual TMV
associated with the site.
Would be effective for those areas fenced; not protective
for unknown areas of contamination.
Relatively easy to Implement. May not be consistent with
future remedies which could require fences to be moved.
Lesser short term expense than fencing entire site;
however, costs may Increase significantly If fences need
to be moved for future remedies or If other contaminated
areas are found.
State favors fencing entire site.
No negative reaction.
Very protective site access control measure; would limit
access to all areas of contamination, including areas not
yet fully characterized.
Would comply fully with ARARs.
Not a permanent remedy.
Helps reduce potential for toxiclty by restricting public
acces to contamination. Would not reduce actual TMV
associated with the site.
Very effective site access option.
Relatively easy to Implement. Likely to be consistent
with future remedies which may require access to various
parts of the site.
More costly than selective fencing In short term;
however, may be less costly in long term, particularly if
remedies or future studies (Phase III) were to show need
to move or expand fencing option.
The State prefers this option.
Most likely to be acceptable to community.
agreed to this option.
The PRP has
page 2 of 19
-------
Table F-5 (cont'd)
EVALUATION OF INTERIM REMEDIAL ACTION ALTERNATIVES
FOR THE BRODERICK WOOD PRODUCTS COMPANY
ADAMS COUNTY, COLORADO
Altprnativg/
I. SITE ACCESS (cont'd)
E. Security guards
1. Overall protection
2. Compliance with ARARs
3. Permanence
4. Reduction of TMV
5. Short-term effectiveness
6. Implementability
7. Cost
8. State acceptance
9. Community acceptance
Evaluation
Most protective of site access remedies. Would provide
greatest assurance that no unauthorized persons vrould
gain access to the site and be exposed to the
contamlnat Ion.
Would comply with ARARs.
Not a permanent remedy.
Helps reduce potential for toxlclty by restricting public
access to contamination. Would not reduce actual TMV
associated with the site.
Would be very effective In short term. However, guards
would need hazard/safety training to avoid exposure to
contamination.
Implementable, but not as easily implemented as other
site access remedies.
Rather high cost for.this problem area: almost $200,000
State would accept as remedy.
Community would likely support this remedy.
II. IMECLHttlHirS/ Sludge
A. No action
1. Overall protection
2. Compliance with ARARs
3. Permanence
I*. Reduction of TMV
5. Short-term effectiveness
6. Implementability
7. Cost
8. State acceptance
9. Community acceptance
B. Excavate and reclaim
1. Overall protection
Not protective. Sludge would remain in impoundments as
the largest concentration of contamination on the site.
Would not comply with ARARs.
Not applicable.
Would not reduce TMV.
Not effective In short term.
Not applicable.
No immediate cost.
State would not accept.
Community not likely to accept.
preferred by the PRP.
No action at this time
There could be some difficulty in separating penta and
dioxins from creosote. There remains some doubt about
the level of contaminants in the product and how
protective this alternative would be.
page 3 of 19
-------
Table F-5 (cont'd)
EVALUATION OF INTERIM REMEDIAL ACTION ALTERNATIVES
FOR THE BRODERICr WOOD PRODUCTS COMPANY
ADAMS COUNTY, COLORADO
Al
II. mEGUHDHHIIS/Sludge (cont'd)
B. Excavate and reclaim (cont'd)
2. Compliance with ARARs
3. Permanence
A. Reduction of TMV
5. Short-term effectiveness
6. Implementability
7. Cost
8. State acceptance
9. Community acceptance
Compliance with ARARs questionable; penta and dioxlns In
sludge and residues could make it impossible to reuse
creosote or comply with new RCRA Land Disposal
Regulations.
Would permanently address much of sludge. However,
dioxins would remain in recovered creosote and residues.
Residues proposed for disposal rather than destruction.
Would greatly reduce TMV of sludge. However, penta and
dioxins would remain in recovered creosote and residues.
Some risk associated with disturbing, handling sludge.
Technically implementable and feasible. No certainty
that product is saleable.
$1.6 million.
State would accept if all ARARs could be attained with
certainty.
No negative reaction
C. Excavate, stabilize and dispose off-site
1. Overall protection
2. Compliance with ARARs
3. Permanence
A. Reduction of TMV
5. Short-term effectiveness
6. Implementability
7. Cost
8. State acceptance
9. Community acceptance
Not as protective as remedies that include destruction of
contaminants.
Presence of penta. dioxins, and other contaminants in
sludge and oil would make it difficult to comply with
RCRA Land Disposal restrictions.
Would require long term monitoring and/or management at
the disposal site.
Would reduce mobility, not volume or toxicity. Does not
include treatment or destruction of contamination as a
principal element.
Some risk associated with disturbing, handling and
transporting sludge.
Not difficult to implement.
$A.O million: more costly than other, more permanent
alternatives.
State would not accept unless ARARs could be met.
Conmunity reaction unknown.
D. Excavate and incinerate off-site
1. Overall protection Very protective remedy.
page A of 19
-------
Table F-5 (cont'd)
Altprnatlve/
Critprton
II.
EVALUATION OF INTERIM REMEDIAL ACTION ALTERATIVES
FOR THE BRODERICX WOOD PRODUCTS OOMPANT
ADAMS COUNTY, COLORADO
(cont'd)
D. Excavate and Incinerate off -site (cont'd)
2. Compliance with ARARs
3. Permanence
A. Reduction of TMV
5. Short-term effectiveness
6. Implementablllty
7. Cost
8. State acceptance
9. Community acceptance
Compliance with ARARs fully attainable.
A permanent remedy that would leave little long-term
risk.
Significant reduction In TMV. The remedy would employ
destruction of contaminants as a principal element.
Potential risks associated with transportation of
material to off-site incinerator.
Reliable! demonstrated technology.
$4.8 million. Cost greater than on-site incineration due
to transportation of materials to Incinerator.
State would accept if all ARARs complied with.
Local community likely to accept.
F. Excavate and Incinerate on-site
1. Overall protection
2. Compliance with ARARs
3. Permanence
A. Reduction of TMV
5'. Short-term effectiveness
6. Implementability
7. Cost
8. State acceptance
9. Community acceptance
Very protective.
Compliance with ARARs fully attainable.
A permanent remedy that would leave little long-term
risk.
Significant reduction in TMV. This remedy employs
destruction of contaminants as principal element.
Treatment (destruction) efficiency in greater than 99".
Some short-term risks associated with disturbing and
handling sludge. Minimal risk associated with air
emissions.
Reliable> demonstrated, technically feasible remedy.
At $1.4 to 2.2 million, the cost of this RAA is much less
than off-site incineration.
State will accept provided ARARs met.
No adverse reaction from community.
II.
A. No action
1. Overall protection
2. Compliance with ARARs
Not protective: oil would remain on-site as potential
hazard.
Would not comply with ARARs.
page 5 of 19
-------
Table F-5 (confd)
Altpj-nativt»/
II.
EVALUATION Of INTERIM REMEDIAL ACTION ALTERNATIVES
FOR TEE BRODERICK WOOD PRODUCTS COMPACT
ADAMS COUNT?, COLORADO
(confd)
A. Mo action (cont'd)
3. Permanence
4. Reduction of TMV
5. Short-term effectiveness
6. Implementabillty
7. Cost
8. State acceptance
9. Community acceptance
Not a permanent remedy.
Would not reduce TMV.
Not applicable.
Not applicable.
No direct costs.
State vjould prefer a remedy.
Community would prefer a remedy.
B. Pump from Impoundment and treat (capture) with carbon adsorption
1. Overall protection
2. Compliance with ARARs
3. Permanence
<». Reduction of TMV
5. Short-term effectiveness
6. Implementabillty
7. Cost
8. State acceptance
9. Ccomunlty acceptance
Very protective. A major source of contamination at the
site would be remedied with this RAA.
Would comply with ARARs.
A remedy that would permanently reduce the long-term risk
associated with this problem.
Recovery process for carbon filter would effectively
reduce TMV of oil. Treatment Is a principal element of
this RAA.
Would be very effective In the short term: some short
term risks associated with disturbing and handling the
oil.
Very easy to implement, particularly If carbon adsorption
Implemented for water treatment. However, it may be
preferable either to keep the carbon filter process
exclusively for water treatment, or to treat the oil
last, after the water has been treated.
Low cost ($7,200), particularly If carbon adsorption
Implemented for water treatment.
State would accept this RAA, provided all ARARs attained.
No negative reaction.
C. Pump from Impoundment and incinerate on-slte
1. Overall protection
2. Compliance with ARARs
3. Permanence
Very protective. A major source of contamination at the
site would be remedied with this RAA.
Would comply with ARARs.
A remedy that vjould permanently reduce the long-term risk
associated with this problem.
page 6 of 19
-------
II.
Table F-5- (conf d)
EVALUATION OP INTERIM REMEDIAL ACTION ALTERNATIVES
FOR THE BRODERICK WOOD PRODUCTS OOHFANT
ADAMS COUNTY, COLORADO
Prralnaf Inn
(confd)
C. PlBBp front Impoundment and incinerate on-slte (cont'd)
A. Reduction of TMV
5. Short-term effectiveness
6. Implementablllty
7. Cost
8. State acceptance
9. Community acceptance
This RAA Includes treatment of contamination (destruction
efficiency greater than 99") as a principal element. TMV
would be effectively reduced.
Would be very effective In the short term; some short
term risks associated with disturbing and handling the
oil.
Very easy to Implement If Incineration Implemented for
sludge. This method may be preferable to using carbon
treatment so that carbon can be used longer for
contaminated water.
Low cost ($9,100), If incineration Implemented for
sludge.
State would accept this RAA, provided all ARARs attained.
No negative reaction.
II. IMPOUNDMENTS/Hater
A. No action
1. Overall protection
2. Compliance with ARARs
3. Permanence
A. Reduction of TMV
5. Short-term effectiveness
6. Implementablllty*
7. Cost
8. State acceptance
9. Community acceptance
Not protective: water would remain on-site as potential
hazard and would Interfere with potential remedies for
other contents of the impoundments.
Would not comply with ARARs.
Not a permanent remedy.
Would not reduce TMV.
Not applicable.
Not applicable.
No direct costs.
State would prefer a remedy.
Community would prefer a remedy.
B. Evaporate In secondary Impoundment
1. Overall protection
2. Compliance with ARARs
Overall protection would be achieved only after treatment
of sludge in impoundment. Small potential for water to
aggravate ground water contamination problems if pond
surface not sealed.
Secondary impoundment not lined, would not meet ARARs
page 7 of 19
-------
Table F-5 (conf d)
EVALUATION OF INTERIM REMEDIAL ACTION ALTERNATIVES
FCR THE BRODERICT WOOD PKOUUCIS OCMPANT
ADAMS COJNT7, COLCRADO
Al
Criterion
II. HffiflMIMEHIS/Hater (cont'd)
B. Evaporate la secondary impoundment (cont'd)
3. Penanence
4. Reduction of TMV
5. Short-term effectiveness
6. Implementability
7. Cost
8. State acceptance
9. Community acceptance
Does not provide permanent remedy by itself; subsequent
treatment of sludge would be permanent for contaminants
in water.
Does not directly treat TMV of contaminants: contaminants
would remain in Secondary impoundment and be treated with
sludge.
Small potential for water to aggravate ground water
contamination; abnormal weather could cause some
uncertainty about how long remedy would take.
Remedy easy to Implement. Some potential for abnormal
weather events to lengthen time of remedy.
Low cost remedy for Impoundment water ($13,000).
State would concur only if ARARs could be achieved.
Unknown.
C. Treat with carbon adsorption; dispose cm-alte via evapo-transpiration
1. Overall protection
2. Compliance with ARARs
3. Permanence
5.
6.
7.
8.
Reduction of TMV
Short-term effectiveness
Implementability
Cost
State acceptance
9. Community acceptance
Very protective.
Would comply with ARARs If treatment reduced hazardous
constituents to non-detectable levels. If non-detect
levels not achievable, may need to waive ARARs and treat
below SDWA MCLs.
A permanent remedy; hazardous contaminants captured on
carbon filter will be destroyed in filter regeneration
process.
Would significantly reduce TMV.
Very effective in short term.
Treatment process is a reliable, demonstrated technology.
Discharge and evapo-transpiration process will require
close monitoring. Would also allow the greatest
flexibility for scheduling disposal of impoundment water
and treatment of other contaminated water (decon water)
generated during other/future remedies.
A low cost option ($29,000).
State will accept provided ARARs met (treat to non-
detect), and provided ET rate managed closely.
No negative reaction, provided ET rate managed closely to
prevent "mounding" of ground water.
page 8 of 19
-------
Table F-5 (cont'd)
EVALUATION OF INTERIM REMEDIAL ACTICN ALTERNATIVES
FOR THE BRODERICK WOOD PRODUCTS COMPANY
ADAMS COUNTY, COLORADO
Altprnative/
CrltPt-lnn
II. PgOmnMFKTS/Hater (confd)
D. Pu«p to new lined pond and evaporate; incinerate liner
1. Overall protection
2. Compliance with ARARs
3. Permanence
A. Reduction of TMV
5. Short-term effectiveness
6. Implementability
7. Cost
8. State acceptance
9. Coonunity acceptance
Very protective alternative.
Compliance attainable.
A permanent remedy. Would eliminate total risk
associated with this contamination.
Treatment and destruction of contaminants would be
principal element of alternative.
Would be effective in short term. Would require
significant movement of soils in constructing the new
impoundment.
Technology not difficult to implement. New pond may be
useful as part of storage/treatment options for other
(future) contaminated water.
Most costly of water treatment options. $329,000.
State would accept if all ARARs achievable.
Community would accept.
E. Use as incineration quench water
1. Overall protection
2. Compliance with ARARs
3. Permanence
A. Reduction of TMV
5. Short-term effectiveness
6. Implementability
7. Cost
8. State acceptance
9. Community acceptance
Would be protective provided there were not high levels
of organic constituents in water. Some potential for
organlcs to volatilize and escape via air pathway.
Compliance with ARARs achievable.
Would be a permanent remedy, provided method to capture
volatilized organics in water could be implemented.
Treatment (destruction) of some contaminants would be a
principal element of this RAA.
Would be effective in the short term.
Technically feasible. Could be coordinated with
incineration of sludge and/or soil, if schedules could be
coordinated.
Very little cost ($3,500): may need water storage pond to
hold water during incineration process.
Would accept provided ARARs attainable.
Unknown.
page 9 of 19
-------
Table F-5 (confd)
EVALUATION OF INTERIM REMEDIAL ACTION ALTERNATIVES
FOR THE BRODERId WOOD FROUUCJU CCKPANY
ADAMS COJNTT, COLORADO
II .
Alternat ive/
Crl tprlnn
A. Ho action
I. Overall protection
2. Compliance with ARARs
3. Permanence
4. Reduction of TMV
5. Short-term effectiveness
6. Implementability
7. Cost
8. State acceptance
9. Community acceptance
B. Excavate and dispose off-site
1. Overall protection
2. Compliance with ARARs
3. Permanence
4. Reduction of TMV
5. Short-term effectiveness
6. Implementability
7. Cost
8. State acceptance
9. Community acceptance
C. Excavate and blodegrade on-site
1. Overall protection
2. Compliance with ARARs
3. Permanence
Not protective; soil would remain on-site as potential
hazard In contact with ground water regime.
Would not comply with ARARs.
Not a permanent remedy.
Would not reduce TMV.
Not applicable.
Not applicable.
No direct costs.
State would prefer a remedy.
Community would prefer a remedy.
Very protective of human health and environment.
Compliance attainable, unless dioxins are present In
levels greater than BEAT would allow for disposal.
Threat to site would be permanently addressed; however,
disposal site would require long-term management and
monitoring.
TMV of contaminants would be eliminated at the site.
There would be some reduction of mobility due to disposal
process; no reduction of toxlclty or volume.
Potential risks associated with disturbing, handling and
transporting material to disposal facility. Relatively
short time to complete remedy.
Technically reliable and a demonstrated, feasible remedy.
Very costly. $11.7 million.
State would accept provided all ARARs met.
Local acceptance likely.
Uncertain as to whether the level of treatment would be
adequate for future uses of the site.
Compliance with Land Treatment ARARs attainable.
Some potential for failure, i.e., remedy may not be able
to meet cleanup goals. Would permanently address some
contamination.
page 10 of 19
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Table F-5 (cont'd)
EVALUATION OP INTERIM REMEDIAL ACTION ALTERNATIVES
FOR THE BRODERICK HOOT PKDDOCTS (XMFANT
ADAMS COUNTY, COLORADO
Al tt»rnat tve/
Criterion
Evaluation
II. IMESMaiEHIS/Soil (conf d)
C. Excavate and blodegrade oo-01te (cont'd)
A. Reduction of TMV
5. Short-term effectiveness
6. Implementability
7. Cost
8. State acceptance
9. Community acceptance
Would reduce TMV of contaminants at the site, and reduce
direct contact risks. However, degree of TMV reduction
not certain, particularly If dloxlns are present.
Potential risks from disturbing and handling soils.
Would require about one year to complete remedy.
Technical feasibility has not been demonstrated with
sufficient degree of reliability, particularly to meet
stringent cleanup goals.
Relatively Inexpensive. $886,000.
State would accept if all ARARs achievable.
Unknown.
D. Excavate and manage on-site (temporary waste pile)
1. Overall protection
2. Compliance with ARARs
3. Permanence
A. Reduction of TMV
5. Short-term effectiveness
6. Implementabi.il ty
7. Cost
8. State acceptance
9. Community acceptance
Would reduce potential for contaminants to migrate during
period of storage, but not a permanent solution.
Compliance attainable.
Not a permanent remedy. Permanent remedy would have to
be developed during future studies.
Would reduce mobility during period of storage. Would
not reduce toxicity or volume.
Would be very effective in the short term reduction of
mobility.
Reliable, easily implemented remedy. Monitoring would be
required during storage period. Would be consistent with
future remedies by revealing subsurface contamination.
Relatively Inexpensive. $959,000.
State would concur, provided ARARs met.
No negative reaction from community.
E. Excavate and Incinerate on-slte
1. Overall protection
2. Compliance with ARARs
3. Permanenc e
Reduction of TMV
Very protective. Would destroy contamination source, and
eliminate risks from these soils.
Compliance attainable.
A permanent remedy. No long-term management or
monitoring required.
Destruction of contaminants would be principal element of
remedy. There would be greater than 99* reduction In
TMV. Residuals would be ash.
page 11 of 19
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Table F-5 (conf d)
EVALUATION OF INTERIM REMEDIAL ACTION ALTERNATIVES
FOR THE BRODERICK WOOD PRODUCTS COMPANY
ADAMS COUNTY, COLORADO
Alternative/
Criterion
II. mEOKttiBnS/SoLl (conf d)
E. Excavate and Incinerate on-alte (cont'd)
5. Short-term effectiveness
8.
9.
Implementabllity
Cost
State acceptance
Community acceptance
Close monitoring of Incinerator operation would be
required. Potential risks from disturbing and handling
soils. Relatively short time until permanent remedy
achieved. Minor air quality Impacts.
Uncertain until volume of soils is determined. Larger
volume (>2,500 ydj) of soils not feasible if small
incinerator selected for sludge Incineration.
Not certain. Range of costs from $1.3 million to $10.9
million, depending on volume of soil to be incinerated.
Acceptable to state, provided ARARs achieved.
No negative reaction.
F. Excavate and Incinerate off-site
1. Overall protection
2. Compliance with ARARs
3. Permanence
4. Reduction of TMV
5. Short-term effectiveness
6. Implementability
7. Cost
8. State acceptance
9. Community acceptance
Very protective. Would destroy contamination source, and
eliminate risks from these soils.
Compliance attainable.
A permanent remedy. No long-term management or
monitoring required.
Destruction of contaminants would be principal element of
remedy. There would be close to 100" reduction in TMV.
Close monitoring of incinerator operation would be
required. Potential risks from disturbing, handling and
transporting soils. Relatively short time until
permanent remedy achieved. Minor air quality impacts at
Incinerator site.
Technically feasible. A known, reliable remedy.
Most expensive permanent soils remedy. $14.8 million to
Incinerate up to 31.000 yd^.
Acceptable to state, provided ARARs achieved.
No negative local reaction.
III. ZACILIlLAREA/Flrewater
A. No action
1. Overall protection
2. Compliance with ARARs
3. Permanence
Not protective: water would remain on-site as potential
hazard, and would interfere with other potential remedies*
for the facilities area.
Would not comply with ARARs.
Not a permanent remedy.
page 12 of 19
-------
Table F-5 (cont'd)
EVALUATION Of INTERIM REMEDIAL ACTION ALTERNATIVES
FOR THE BRODERICK HOOD PRODUCTS COMPANT
ADAMS COUNTY, COLORADO
>KJtFMT
/Pmhli
Alternative/
Criterion
III. ZACILrELABEA/Flrewater (cont'd)
A. No action (cont'd)
4. Reduction of TMV
5. Short-term effectiveness
6. Implementablllty
7. Cost
8. State acceptance
9. Community acceptance
B. Filter asbestos fibers
1. Overall protection
2. Compliance with ARARs
3. Permanence
A. Reduction of TMV
5. Short-term effectiveness
6. Implementability
7. Cost
8. State acceptance
9. Community acceptance
C. Evaporate water In secondary
1. Overall protection
2. Compliance with ARARs
3. Permanence
A. Reduction of TMV
5. Short-term effectiveness
Would not reduce TMV.
Not applicable.
Not applicable.
No direct costs.
State would prefer a remedy.
Community would prefer a remedy.
Necessary to remove asbestos as source. Would eliminate
risk from asbestos in water.
Compliance attainable. Filters would' be treated
(disposed) as hazardous waste in licensed landfill.
A permanent remedy.
Would eliminate TMV of asbestos in water.
Very effective in short term. Little time to Implement.
Easy to Implement. Known, reliable technology.
Low cost. $8,AGO
Acceptable to state
No negative reaction.
Overall protection would be achieved only after treatment
of sludge in impoundment. Small potential for water to
aggravate ground water contamination problems if pond
surface not sealed.
Secondary impoundment not lined, would not meet ARARs
Does not provide permanent remedy by Itself; subsequent
treatment of sludge would be permanent for contaminants
in water.
Does not directly treat TMV of contaminants: contaminants
would remain in Secondary impoundment and be treated with
sludge.
Small potential for water to aggravate ground water
contamination: abnormal weather could cause some
uncertainty about how long remedy would take.
page 13 of 19
-------
Table F-5 (conf d)
EVALUATION OP INTERIM REMEDIAL ACTION ALTERNATIVES
FOR THE BRODERICK WOOD PRODUCTS COMPANY
ADAMS COUNTY, COLORADO
Al t Pi-rat ive/
Critprlrm Pvalimt irm
III. F*rTT.TTT AHPA/Ptrg«atgr (confd)
C. Evaporate water In secondary Impoundment
6. Implementability Remedy easy to implement. Some potential for abnormal
weather events to lengthen time of remedy.
7. Cost Low cost remedy ($500).
8. State acceptance State would concur only if ARARs could be achieved.
9. Community acceptance Unknown.
D. Treat with carbon adsorption; dispose on-slte via evapo-transpLratlon
1. Overall protection Very protective. Would eliminate this contamination
source.
2. Compliance with ARARs Would comply with ARARs if treatment reduced hazardous
constituents to non-detectable levels. If non-detectable
levels not achievable, may need to waive ARARs and treat
below SDWA MCLs.
3. Permanence A permanent remedy; hazardous contaminants captured on
carbon filter will be destroyed in filter regeneration
process.
-------
Table F-5 (conf d)
•III.
EVALUATION OF INTERIM REMEDIAL ACTION ALTERNATIVES
FOR THE BRODERICK HOOD PRODUCTS COMPANY
ADAMS COUNTY, COLORADO
Alternative/
Criteflon
PvaliiaMrm
ABEAy Firewater (cont'd)
D. Pup to new lined pond and evaporate; Incinerate liner (cont'd)
5. Short-term effectiveness
6. Implementability
7. Cost
8. State acceptance
9. Contrainlty acceptance
Would be effective in short term. Mould require
significant movement of soils in constructing the new
impoundment.
Technology not difficult to Implement. New pond may be
useful as part of storage/treatment options for other
(future) contaminated water.
Most costly of firewater treatment options. $51,400.
State would accept if all ARARs achievable.
Coumunlty would accept.
F. Use aa incineration quench water
1. Overall protection
2. Compliance with ARARs
3. Permanence
A. Reduction of TMV
5. Short-term effectiveness
6. Implementability
7. Cost
8. State acceptance
9. Community acceptance
Would be protective provided there were not high levels
of organic constituents in water. Some potential for
organics to volatilize and escape via air pathway.
Compliance with ARARs achievable.
Would be a permanent remedy, provided method to capture
volatilized organics in water could be Implemented.
Treatment (destruction) of some contaminants would be a
principal element of this RAA.
Would be effective in the short term.
Technically feasible. Could be coordinated with
incineration of sludge and/or soil.
Very little cost ($3,500); may need water storage pond to
hold water during incineration process.
Would accept provided ARARs attainable.
Unknown.
Ill. FJCILIILAElA/Structures:
A. No action
1. Overall protection
2. Compliance with ARARs
As Indicated below, EPA has concluded that not enough
information exists to support selection of a remedy to
address the buildings in the facility area. EPA believes
that such information could be gathered in a relatively
short period of time after this Record of Decision, and
be documented in either the Phase III RI/FS or a separate
study to support a removal action.
Full extent of risks have not yet been defined.
ARARs have not yet been determined.
page 15 of 19
-------
Table F-5 (cont'd)
EVALUATION OP INTERIM REMEDIAL ACTION ALTERNATIVES
FOR THE BRODERICK WOOD PRODUCTS COMPANY
ADAMS COUNTY, COLORADO
Alternative/
III. zacnUL-ABZA/Structurrs (cont'd)
A. No action (cont'd)
3. Permanence
4. Reduction of TMV
5. Short-term effectiveness
6. Implementabillty
7. Cost
8. State acceptance
9. Community acceptance
Not a permanent remedy.
No reduction of TMV.
Not effective.
Not applicable.
No direct costs.
State would not accept.
Community would prefer a remedy.
B. DemolLsh, decontaminate and dispose of debris in an approved landfill
1. Overall protection
2. Compliance with ARARs
3. Permanence
<». Reduction of TMV
5. Short-term effectiveness
6. Implementabllity
7. Cost
8. State acceptance
9. Community acceptance
Full nature and extent of contamination and risks have
not yet been defined. Unable to define how well this
remedy might address those risks.
ARARs have not yet been determined.
Potentially a permanent remedy.
Potentially a great reduction of TMV.
Potentially very effective.
Not yet determined; dependent on contents.
Not yet fully defined. The cost of this RAA has been
augmented up to 250" because of damage from the July 1985
fire. Estimates range from $260,000 to 5800,000.
State would prefer a remedy, once the nature and extent
of contamination is better defined, and compliance with
ARARs can be assured.
Community would prefer a remedy.
Ill.
A. No action
1. Overall protection
2. Compliance with ARARs
EPA has also concluded that not enough information exists
at this time to support selection of a remedy to address
the vessels and their contents. EPA believes that such
information could be gathered in a relatively short
period of time after this Record of Decision, documented
in either the Phase III RI/FS or a separate study to
support a removal action.
Full extent of risks have hot yet been defined.
ARARs have not yet been determined-
page 16 of 19
-------
Table F-5 (confd)
EVALUATION OF INTERIM REMEDIAL ACTION ALTERHATTVES
FOR THE BRODERICX HOOD PRODUCTS COMPANY
ADAMS COUNTY, COLORADO
Al tprnat1ve/
Critprlrm
III. ZACILITJLABEA/Vessels (cont'd)
A. No action (cont'd)
3. Permanence
A. Reduction of TMV
5. Short-term effectiveness
6. Implementabillty
7. Cost
8. State acceptance
B.
Evaluation
Not a permanent remedy.
No reduction of TMV.
Not effective.
Not applicable.
No direct costs.
State would prefer a remedy. once nature and extent of
contamination better defined.
9. Community acceptance
Community would prefer a remedy.
Dispose of contents appropriately
1. Overall protection
2. Compliance with ARARs
3. Permanence
A. Reduction of TMV
5. Short-term effectiveness
6. Implementabillty
7. Cost
8. State acceptance
9. Community acceptance
Full nature and extent of contamination and risks have
not yet been defined. Unable to define how well this
remedy might address those risks.
ARARs have not yet been determined.
Potentially a permanent remedy.
Potentially a great reduction of TMV.
Potentially very effective.
Not yet determined; dependent on contents.
Not defined.
State would prefer a remedy, once the nature and extent
of contamination is better defined, and compliance with
ARARs can be assured.
Community would prefer a remedy.
C. Use for temporary storage of liquids
1. Overall protection
2. Compliance with ARARs
3. Permanence
4. Reduction of TMV
Short-term effectiveness
5.
6.
7.
Implementability
Cost
Probably would not contribute directly to protectIveness.
Could potentially contribute to other remedies.
Compliance with ARARs attainable.
Not applicable.
Not applicable.
Not applicable.
Easily implementable; would likely contribute to other
remedies.
Estimated at $219,000.
page 17 of 19
-------
: "'* Ta6Ie~T-S- (cent *d')~~
EVALUATION Of INTERIM REMEDIAL ACTION ALTERNATIVES
FOR THE BRODERICX HOOD PRODUCTS COMPANY
ADAMS COUNTY, COLORADO
Alternative/
tori on
III. ZAaLUL-ARZA/Vessels (confd)
C. Use for temporary storage of liquids (cont'd)
. 8. State acceptance Acceptable to the State, provided ARARs are achieved.
9. Community acceptance No negative reaction.
cial Industrial Landfill
Potentially very protective, provided ARARs are met.
Compliance attainable.
Potentially a permanent remedy.
Could significantly reduce TMV.
Implementation would be short term.
Easily Implementable.
Estimated at $325,000.
State would accept provided ARARs are met.
No negative reaction.
I
yard
Potentially very protective! provided ARARs are met.
Compliance attainable.
Potentially a permanent remedy.
Could significantly reduce TMV.
Implementation would be short term.
Easily Implementable.
Estimated at $325,000.
State would accept provided ARARs are met.
No negative reaction.
D. Demolish and dispose In a
1. Overall protection
2. Compliance with ARARs
3. Permanence
4. Reduction of TMV
5. Short-term effectiveness
6. Implementabillty
7. Cost
8. State acceptance
9. Community acceptance
•E. Demolish and transport to scrap
1. Overall protection
2. Compliance with ARARs
3. Permanence
A. Reduction of TMV
5. Short-term effectiveness
6. Implementabillty
7. Cost
8. State acceptance
9. Community acceptance
IV. SUBZaCE_SQILS/vrith Organic Contamination
A. No action
EPA has concluded that the current level of information
about surface soils contaminated by organlcs is not
sufficient to support selection of a remedy at this time.
It Is EPA's intent that the Phase III RI/FS will addressl
the unknowns relating to surface soils. Consequently, a\
full evaluation of surface soil remedies was not
conducted for this ROD.
page 18 of 19
-------
Table F-5 (cont'd)
EVALUAnCN OF INTERIM REMEDIAL ACTION ALTERNATIVES
FOR THE BRODERICK WOOD PRODUCTS CCMPANT
ADAMS COUNTY, COLORADO
Al ternflt tve/
Criterion Evaluation
IV. SURFACE fiOTLS/wlth Metals Contamination
A. No action EPA has concluded that the current level of information
about surface soils contaminated by metals is not
sufficient to support selection of a remedy at this time.
It is EPA's intent that the Phase III RI/FS will address
the unknowns relating to surface soils. Consequently) a
full evaluation of surface soil remedies was not
conducted for this ROD.
V. HmTQBHC Because the actual monitoring activities to be conducted
under the OU will not be determined until the design
phase of remedy implementation, EPA has not conducted a
detailed analysis of the monitoring RAAs. In many
instances, monitoring is included in the remedies
discussed above.
A. No action
B. Monitoring performance of implemented actions
C. Ground-water monitoring
page 19 of 19
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G. COMMUNITY INVOLVEMENT
1. EPA'S COMMUNITY INVOLVEMENT PROGRAM FOR THE BWP SITE
In compliance with the requirements of CERCLA and the NCP, EPA
and the State of Colorado have conducted a program to keep nearby
residents and other individuals with an interest in the BWP site
informed about the ongoing studies and proposed remedies. This
program has included the following:
a. Developing a list of all nearby residents and other
persons interested in activities at the site.
b. Working with municipal and other local agencies to keep
government officials informed about site issues and
activities.
. c. Establishing repositories of key information relating to
the site, including RI/FS reports, the proposed plan,
comments, responses and other documents so that the
public would have ready access to the information.
d. Preparing and distributing news releases of significant
events during the ongoing activities at the site.
e. Meeting with nearby residents, neighbors and local
officials to discuss any concerns that they may have.
f. Mailing two Fact Sheets to all individuals on the mailing
list. The first Fact Sheet, in January 1987, described
the site and ongoing RI/FS activities. The second Fact
Sheet, in December 1987, announced EPA's proposed plan
for an interim remedy at the BWP site.
g. Announcing the proposed plan in a local newspaper so that
persons not on the mailing list might be informed.
h. . Conducting a public comment period on the proposed plan.
The comment period was from February 10 through March 4,
1988. A public meeting was held near the site on
February 22, 1988.
i. Responding to the comments received during the public
comment period and at the public meeting.
j. Conducting a domestic well sampling program to determine
whether any site-related contaminants had reached any of
the off-site wells.
- G-1 -
-------
2. COMMUNITY CONCERNS AT THE BWP SITE
The level of interest in the community about the BWP site has
been relatively low. This has been due primarily to the
industrial character of much of the surrounding properties and
the relatively sparse residential population nearby.'
Approximately 25 people attended the public meeting during the
comment period on the proposed plan. Written comments on the
proposed plan were received from only a few individuals and/or
companies. These comments showed that community concerns were
generally related to the following major topics:
a. Much concern has been voiced by owners of property
immediately adjacent to the BWP site because of their
concern about impacts from the site. Of particular note
was the concern that either current site conditions or
some component of the preferred remedy would exacerbate
the potential for ground water or other contamination to
move off-site to the north. These concerns were related
to, among other things, the preferred remedy to dispose
of treated water on-site through evapo-transpiration.
b. Another significant concern was that contamination that.
may have already moved off-site should be addressed as
soon as possible, and that the interim remedies being
considered should not interfere with Phase III studies
and remedy implementation.
c. There were also some concerns about the impact of Fisher
Ditch on the site, both as a impediment and as an aid to
off-site migration of contaminants.
d. BIC and its consultants have offered voluminous technical
comments on the preferred remedy. Their basic objection
to the remedy was that it was premature to select
incineration for addressing either the sludge or the
soils. BIC's comments are documented more thoroughly in
the Administrative Record and will not be discussed in
detail in this portion of the ROD.
Other community concerns relating to the ongoing Phase III RI/FS,
the details of remedy implementation, remedy costs and monitoring
are discussed in detail in the attached Community Involvement
Responsiveness Summary.
EPA RESPONSE TO COMMUNITY CONCERNS
EPA's responses to individual concerns and issues raised during
the public comment period are presented in the attached Community
Involvement Responsiveness Summary. Of particular note are the
following:
- G-2 -
-------
a. EPA's proposed remedy was designed to decrease the
potential impact of the BWP site on the adjacent
properties. Built into the water disposition remedy, for
example, is the mechanism that water will be applied at
less than the evapo-transpiration rate for the site.
b. EPA shares the community's concern that Phase III of the
RI/FS should proceed without interference from the
proposed plan, and has selected remedies that will meet
this criterion. None of the remedy components should
interfere with Phase I.I I.
EPA recognizes that the off-site contamination to be
characterized in the Phase III RI/FS will likely be of
greater impact than the contamination being addressed by
this OU, and it is EPA's intent to have the Phase III
RI/FS proceed as expeditiously as possible. However, EPA
believes that it is prudent to remedy some of these very
concentrated sources of contamination as soon as
possible.
c. EPA concurs that the relationship of Fisher Ditch with
the site's ground water regime has yet to fully
characterized, and intends for this to be addressed in
the Phase III RI/FS.
d. EPA's responses to BIC's comments on the preferred remedy
are presented in detail in the Administrative Record and
summarized in Chapter-J, Rationale for the Selected
Remedy.
Other EPA responses to public comments are presented in the
attached Community Involvement Responsiveness Summary report.
- G-3 -
-------
H. CHANGES SINCE THE PROPOSED PLAN
1. THE PROPOSED PLAN
On February 10, 1988, EPA published and solicited comment on its
proposed plan and preferred remedy for interim cleanup of the
contamination at the BWP site. The preferred remedial
alternative included:
erecting a security fence around the entire site;
- posting warning signs around the perimeter;
excavating and incinerating the impoundment sludge and
oil;
treating the contaminated water in the main impoundment
with carbon adsorption and disposing of it on-site;
excavating and either incinerating or stockpiling the
visibly contaminated soils under the impoundments;
filtering the "firewater" to remove asbestos fibers,
treating the filtered water in the carbon adsorption unit
and disposing of the treated water on-site;
demolishing the treatment plant and shop buildings; and
- monitoring the performance of the remedies.
2. CHANGES SINCE THE PROPOSED PLAN
There have been a few changes since EPA's publishing of the
Proposed Plan. Most of the changes have resulted from new
information received by EPA since the plan was published. The
changes include the following:
a. EPA has decided to address all contaminated water at the
site, including both the water in the main impoundment
and the firewater, by combining the preferred carbon
adsorption treatment option with a new disposal method.
The new disposal method will be using the treated water
as incineration quench water. EPA is retaining as its
second option the treatment of the water with carbon
adsorption, followed by on-site evapo-transpiration.
- H-l -
-------
b. EPA has refined its decision on the volume of visibly
contaminated soils beneath the main and secondary
impoundments. The cutoff volume for incineration of
these soils will be 2,500 yd^. if the volume of visibly
contaminated soils is determined to be larger than this,
the entire volume of soils will be stored temporarily on-
site in a RCRA waste pile, while the Phase III RI/FS
proceeds.
c. EPA has concluded that not enough information is
available to support selection of a remedy in the
Facilities Area, particularly for the buildings and
vessels. EPA believes that such information could be
gathered in a relatively short period of time after this
Record of Decision, and a removal-type of remedy could be
implemented at that time.
d. There have also been a few minor changes in the cost of
the preferred remedy, as EPA has refined the cost
information for some of the components.
3. RECENT INFORMATION
After the close of the public comment period, BIC submitted new
data and information concerning the bioreclamation remedial
alternative and asked EPA to consider this remedy for addressing
the impoundment contents. In the Phase II RI/FS, BIC had
presented bioreclamation as an alternative for soils, but not for
impoundment sludge.
EPA has reviewed this information and has concluded that there is
insufficient cause at this time to make significant changes in
the selected remedy based on the new data. EPA concurs that
bioreclamation is a viable alternative for soils, and expects
this RAA to be a major focus of the Phase III RI/FS. However,
EPA has concluded that this new information is not sufficient to
support a change in the remedy for the impoundment sludge. Most
of the information submitted by BIC concerns bioreclamation of
contaminated soils rather than sludge. Selection of bioreclama-
tion for sludge would have required much more extensive
feasibility study work and data showing its effectiveness for
such a heavy concentration of contaminants.
- H-2 -
-------
I. DESCRIPTIOK OF THE SELECTED REMEDY
Based on the currently available RI/FS information, EPA has
concluded that several remedial action alternatives (RAAs) are
necessary to protect human health, welfare, and the environment,
and should be implemented as an "operable unit" at the BWP site.
All of the remedies fall within the scope of the source control
and direct contact measures contemplated by the revised and
supplemental RI/FS reports.
Consistent with the earlier parts of this document, the selected
remedies will be presented using the five segment process
discussed previously. A summary table of the selected remedies
and their associated costs is presented in Table 1-1.
1. SITE ACCESS .
EPA has concluded that access to the site should be restricted by
a full security fence around the entire site. The fence should
be a six-feet high chain link security type fence with three
strands of barbed wire on top.
EPA is also selecting the posting of 20 signs with the warning
"Danger - Hazardous Waste - Unauthorized Personnel Keep Out" to
provide an additional deterrent to site entry. The signs will be
legible from 50 feet, and will be in English.
The cost of the fence and warning signs is estimated at $77,800.
2. IMPOUNDMENTS
EPA has concluded that the contents of the main and secondary
impoundments should be removed and treated to mitigate their
potential to contribute further contamination to the site or off-
site environment.
a. Main and Secondary Impoundment Sludge
The remedy that EPA is selecting to address the approximately
4000 yd^ of sludge in the main and secondary impoundments is to
remove the sludge from the impoundments and incinerate them in an
on-site mobile thermal incinerator. The residue (ash) from this
process will be tested to assure that it meets BOAT levels and
then shipped to a permitted hazardous waste landfill.
- I-l -
-------
For the residue from incineration of K001 wastes to meet BOAT,
the maximum for any single grab sample must not exceed:
Constituent Total Composition (mq/kq) TCLP (mq/1)
Naphthalene 7.98 ha
Pentachlorophenol 36.75 na
Phenanthrene 7.98 na
Pyrene 7.28 na
Toluene 0.143 na
Xylenes 0.162 na
Copper na 0.71
Lead na 0.53
Zinc . na 0.066
The ability of the incineration ash to meet these levels will be
confirmed during a test burn of the sludge. It is possible that
some stabilization of the ash will be required if the levels are
not achievable without stabilization.
The remedy will be designed to achieve compliance with all
applicable or relevent and appropriate state and federal
regulations, particularly those pertaining to operation of
incinerators. Although a permit will not be required, the remedy
will have to meet the substantive requirements of the
regulations.
The implementation of this remedy will also be closely
coordinated with the appropriate federal and state air pollution
control authorities to assure that applicable air pollution
controls and monitoring measures are implemented during the
incineration process. This will include whatever stack testing
and quality assurance procedures are appropriate for the
incineration process.
Cost estimates for this remedy are variable, depending on the
source, and range from $1.4 to $2.2 million.
b. Main Impoundment Oil
EPA is selecting on-site incineration as the remedy to address
the approximately 3000 gallons of oil on the surface of the main
impoundment. The oil would be mixed with and incinerated with
the main and secondary impoundment sludge. Residu.es from this
process would be mixed in with the sludge residues and would be
handled the same as the ash from the sludge.
The cost of incinerating the oil would be approximately $9,100.
- 1-2 -
-------
c. Main Impoundment Water
EPA's preferred remedy for the contaminated water in the main
impoundment is to treat the water in a carbon adsorption
filtration unit and then use the water as quench water for the
incineration process. The used carbon filters would be
regenerated or disposed in an approved landfill. It is possible
that a small storage pond may have to be built as part of the
treatment plant.
It is anticipated that the treated water will have little or no
contamination in it when it is added as quench water. If there
is any contamination, it would mix with the residues of the
sludge and be handled accordingly.
EPA is keeping the option of treating the water with a carbon
adsorption unit and discharging it on the site through an above-
ground sprinkler system. As part of this remedy the rate of
application would not exceed the evapo-transpiration rate.
If the on-site discharge remedy is to be implemented, a pilot
test will be conducted beforehand to determine whether the
contaminants in the water would be reduced to non-hazardous
levels. The goal would be to reduce the hazardous constituents
in the water to non-detectable levels to comply with State ARARs.
If non-detectable levels could not be met, EPA would waive the
ARARs and treat to Maximum Concentration Limits (MCLs) under the
Safe Drinking Water Act. The basis for this waiver would be that
this is an interim remedy. More discussion of this issue is
contained in Chapter J.
The quench water remedy would cost about $22,000 (including the
carbon treatment), while the on-site discharge option would cost
about $29,000 (including the carbon treatment).
d. Visibly contaminated soils beneath the impoundments
EPA has concluded that the visibly contaminated soils beneath the
main and secondary impoundments should be removed from contact
with the ground water regime, and is selecting two different
remedies to address this contamination. Only one of the remedies
will be implemented. The choice of which option to implement
will be based on information to be gathered during the design
stage of the remedy.
The key piece of information that needs to be gathered is the
actual volume of the visibly contaminated soil. As noted earlier
in this document, there are currently insufficient data to
determine the volume of the visibly contaminated soils beneath
the impoundments. The volume has been estimated to be as large
as 31,000 yd3.
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EPA is therefore including a decision tree in the selection of a
remedy for these soils. The two options, and the conditions on
which they are based, are:
1. If the volume of the visibly contaminated soils does not
exceed 2,500 yd3:
The soils would be excavated and incinerated on-site, using
•the same small-quantity mobile unit being used for the
impoundment sludge and oil. The ash from the process would
be tested and either disposed on-site or shipped to a
hazardous waste landfill.
The cost of the incineration option is estimated at $1.3
million.
2. If the volume of the visibly contaminated soils does exceed
2,500 yd3:
The soils will be excavated and managed on-site in a
temporary waste pile, stockpiling them on a temporary liner
in the secondary impoundments. In compliance with State
ARARs, this liner will be a single liner with a leachate
collection system. There will be a flexible synthetic
membrane cover over the pile.
The cost of this second option has been estimated to range
from $745,000 to $959,000. These costs would be reduced
significantly if the volume were significantly less than the
highest estimate of 30,700 yd3.
The actual volume of visibly contaminated soil will be estimated
during remedial design with information from soil borings and
will be determined with certainty when the overburden is removed
during remedial activities. The depression left by removal of
the soils would not be backfilled (except where the stockpile is
located) to allow access to other (less than visibly
contaminated) soils under the impoundments.
3. FACILITY AREA (BUILDINGS, VESSELS, ETC.)
a. Firewater
EPA has concluded that the "firewater" problem should be remedied
as part of this first operable unit at the BWP site. The
remedies selected and described below will also apply to any
other contaminated water that may be produced or generated during
the building demolition and decontamination process.
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The "firewater" will be filtered to remove any asbestos fibers.
The filter will be disposed of-in a landfill licensed for such
disposal.
The filtered water will then be treated using the same activated
carbon adsorption filter system used for the impoundment water.
The treated water will also be disposed of in the same manner as
the treated impoundment water discussed above: it will either be
used as quench water for the mobile incinerator or discharged on-
site to a vegetated portion of the site for evapo-transpiration.
The rate of application will be regulated not to exceed the
natural evapo-transpiration capacity of the area.
The cost of the asbestos filtration portion of this RAA will be
about $8,400. The cost of either carbon treatment/disposal
option would be an additional $2,000.
b. Buildings
EPA has concluded that not enough information exists to support
selection of a remedy to address the buildings in the facility
area. EPA believes that such information could be gathered in a
relatively short period of time after this Record of Decision,
documented in either the Phase III RI/FS or a separate study to
support a removal action.
c. Vessels
i
EPA has also concluded that not enough information exists at this
time to support selection of a remedy to address the vessels and
their contents. EPA believes that such information could be
gathered in a relatively short period of time after this Record
of Decision, documented in either the Phase III RI/FS or a
separate study to support a removal action.
4. SURFACE SOILS/with Organics or Metals Contamination
EPA has concluded that the current level of information about
surface soils contaminated by either organics or metals is not
sufficient to support selection of a remedy at this time. It is
EPA's intent that the Phase III RI/FS will address the unknowns
relating to surface soils.
In the interim, EPA believes that the security fencing selected
as part of the first operable unit will effectively limit the
potential for human exposure to surface contamination.
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5. MONITORING
EPA has concluded that environmental monitoring will be necessary
during implementation of the selected remedies to ensure the RAAs
successfully reduce or eliminate threats or potential threats to
human health and the environment posed by the BWP site. The
major purposes of the monitoring program will be to:
a. assure the effectiveness of each specific remedy
implemented. For example, there will regular testing of
treatment process discharges, such as incinerator stack
: emissions, and carbon adsorption treatment plant
effluent. There will also be regular inspections and
monitoring of any impoundments, waste piles, etc. that
are implemented as part of the operable unit.
b. evaluate the overall effect of the operable unit on
contaminant migration associated with ground water. The
most significant parts of this program will be the
continuing monitoring of ground water to the north and
the monitoring for ground water mounding where treated
water would be discharged on-site.
The actual details of the monitoring program will be developed
during the design stage of remedy, implementation, and will be
based on the specific remedial actions taken. The monitoring
program is likely to be developed in conjunction with the Phase
III RI/FS. The most significant part of the Phase III study will
be the ground water monitoring program to determine the extent of
contaminant migration both on and off the site.
In many instances, the costs associated with monitoring a
specific remedy have been included in the cost of the remedy.
However, in other cases, the costs associated with a monitoring
program are dependent on the specific actions included in the
operable unit. Until those factors are determined, costs cannot
be estimated.
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Table 1-1
SUMMARY OF BWP INTERIM REMEDIES SELECTED BY EPA
SEGMENT/
SITE ACCESS
BumoH
Install Security Fence around entire site boundary.
(chain link, 6' tall, topped with 3 strands .of
barbed wire)
Post 20 signs stating "Danger - Hazardous Waste -
Unauthorized Personnel Keep Out" (legible at 50 feet)
anot»
Low
77,400
400
77,400
400
IMPOUNDMENTS/
Sludge
Oil
Water
Soil
Excavate and incinerate on-slte; dispose of ash
at hazardous waste landfill.
Incinerate on-site; residues will be mixed with
residue (ash) from sludge Incineration.
Treat with carbon adsorption process and use as
Incinerator quench water; or
Treat with carbon adsorption process and dispose
on-slte via evapo-transpiration.
Incinerate up to 2500 yd^ on-site: dispose of ash
residues at a hazardous waste landfill.
Manage on-site in a temporary waste pile.
1,400,000 2,200,000
9,000
22,000
9,000
29,000
1,277,000
745,000
FACILITY AREA/
Firewater
Buildings
Vessels
Filter asbestos fibers; and
Treat with carbon adsorption process and use as
incinerator quench water; or
Treat with carbon adsorption process and dispose
on-site via evapo-transpiration.
No Action at this time; address before or during
Phase III RI/FS.
No Action at this time; address before or during
Phase III RI/FS.
8,400
2,000
0
0
8,400
-
2,000
0
0
SURFACE SOILS/
Organlcs No Action at this time; address with Phase III RI/FS.
Metals No Action at this time; address with Phase III RI/FS.
0
0
0
0
MONITORING: No specific actions or associated costs are listed here. In many
instances, the monitoring and costs are included in the
remedies listed above.
2,264,000 3,603,200
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RATIONALE FOR THE SELECTED REMEDY
In this chapter, the technical rationale for the selected remedy
will be presented, followed by a discussion of the statutory
determinations.
1. TECHNICAL RATIONALE
For this section of the discussion, the information will be
presented under the same five-segment structure used previously.
a. SITE ACCESS
EPA believes that the selected remedy will provide protection
to human health and the environment while the Phase III RI/FS
works on a more complete remedy. This RAA would effectively
restrict site access for humans and wildlife. While a number
of areas with high contaminant levels in the soils (visibly
contaminated soils or "hot spots") have been identified
throughout the site, a significant portion of the BWP site
remains generally uncharacterized. The potential increased
cancer risk from human exposure to soils in uncharacterized
areas and "hot spots" would be mitigated through this interim
action by deterring inadvertent exposure to these areas.
This RAA will provide substantially greater protection from
exposure to contaminants than other less costly RAAs.
EPA has also concluded that this RAA would be the only
alternative that would both comply fully with ARARs and be
consistent with future remedies. This remedy will not
interfere with the implementation of the first or future
operable units. A security fence around the perimeter of the
site would not have to be removed or altered during remedial
activities and would continue to serve its designed function
through completion of the Phase III RI/FS and the final
remedial action.
b. IMPOUNDMENTS
EPA has concluded that the main and secondary impoundments
constitute the major source and concentration of
contamination at the site, and should be remedied to address
these high concentrations of contaminants.
*
(1) Main and Secondary Impoundment Sludge
Removal and thermal treatment of the impoundment sludge
would be a reliable, proven technology for source control
and migration management of the major source of
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contamination at the site, and would be a permanent
remedy. It will remove the contamination from contact
with the ground water regime and terminate any additional
contribution of contamination to the ground water. It is
also the most effective way to address the dioxins that
are present in the sludge in that those contaminants
would be permanently destroyed.
It is the most cost-effective remedy that would assure
compliance with ARARs, particulary with Best Demonstrated
Available Technology treatment standards for this type of
waste. The sludge has a high BTU (approximately 10,000)
value and would help keep energy costs down by generating
heat during the incineration process.
The selected alternative will be consistent with future
remedies in that it will allow removal of visibly
contaminated soils as part of the same operable unit. It
would also provide the means to conduct a pilot study of
on-site soil incineration during the Phase III RI/FS.
As noted previously, BIC recently (after the end of the
public comment period) submitted some new data on the
viability of bioreclamation of contaminated soils and
suggested that this technology could be applied to the
impoundment sludge. EPA reviewed these data and
concluded that there was insufficient cause to change the
remedy for the sludge. The application of the technology
to sludge would involve mixing the sludge with less
contaminated soils, thereby diluting the contamination to
levels in which the microorganisms would be effective.
EPA is concerned that this technology has not been
proven, and has particular concerns about the fate of the
dioxins in the sludge during this process.
(2) Main Impoundment Oil
The selected thermal treatment remedy would assure
permanent destruction of the contaminants in the oil,
particularly the dioxins. The principal reasons for
selecting this remedy over the slightly less costly
carbon treatment remedy were the assured destruction of
dioxins and the enhanced usability of the carbon system.
Using the carbon system for only contaminated water and
not for contaminated oils will extend the life the
treatment system.
The oil has a high heat value <17,000 BTU) and would also
be used as a source of energy during incineration.
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As with the impoundment sludge, this remedy would be the
most effective way to address the dioxins that are
present in the oil in that those contaminants would be
permanently destroyed.
(3) Main Impoundment Water
The selected carbon treatment/quench water remedy is a
technically feasible and cost-effective approach to
elimination of the hazardous substances in this medium.
This RAA would be consistent with future remedies in that
it would greatly enhance the ability to address other
contaminated water generated on the site in the future by
providing a ready means to treat and dispose of the water
in a manner that is protective of human health and the
environment. This will likely be most applicable to
water produced during future decontamination of the
buildings and vessels.
(4) Visibly contaminated soils beneath the impoundments
EPA has selected both a thermal treatment remedy (for a
volume of 2500 yd^ or less) and a temporary storage
remedy (for a volume greater than 2500 yd^) for the
impoundment soils to assure that the heavily contaminated
soils are removed as soon as possible from contact with
the ground water regime in the most cost-effective manner
and to provide consistency with future remedies.
EPA believes that bioremediation and other related
technologies show promise as an effective remedy for
soils contamination. However, EPA also believes that
significant work in developing these soils remedies needs
to be performed during the Phase III RI/FS. No large-
scale soils.remedies (including incineration or
bioremediation) have yet been supported by any pilot
study at this site. Those pilot studies are anticipated
to be part of the Phase III RI/FS. EPA did not want to
unduly influence these future remedy considerations by
selecting a large-scale soils treatment process before
the pilot study process was completed.
Consequently, EPA is limiting the incineration option of
this remedy to only the small volume of soils that would
be compatible with the small-scale sludge incinerator.
Any commitment at this time to large-scale incineration
or biodegradation would establish an on-site plant that
would artificially influence the Phase III engineering
sensitivity analysis.
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The implementation of the temporary waste pile would be
based on the fact that volume of material would be too
great (more than 2,500 yd3) to remediate in the small-
scale incinerator selected for the sludge and oil.
However, the removal of the soils from contact with the
ground water regime would terminate any migration of
contaminants from these soils into the ground water.
This remedy would also allow for pilot studies on the
stockpiled visibly contaminated soils during the Phase
III RI/FS.
With either thermal treatment or temporary storage of
visibly contaminated soils, other (less than visibly)
contaminated soils under the impoundments would be
exposed for further investigation during the -Phase III
RI/FS. Hence, either of these remedies would be
consistent with future remedies.
C. FACILITY AREA (BUILDINGS, VESSELS, ETC.)
(1) Firewater
EPA believes that removal and treatment of the firewater
will permanently address a major source of contamination
in the Facilities Area. This remedy will also be
consistent with future remedies in that the presence of
this water has been a major impediment to addressing the
other sources in this area.
(2) Buildings
As noted previously, EPA has concluded that not enough
information exists to support selection of a -remedy to
address the buildings in the facility area. EPA believes
that such information could be gathered in a relatively
short period of time after this Record of Decision,
documented in a either the Phase III RI/FS or a separate
study to support a removal action.
(3) Vessels
EPA has also concluded that not enough information exists
at this time to support selection of a remedy to address
the vessels and their contents. In particular, EPA is
concerned that the contents of the vessels need to be
characterized better to allow adequate evaluation of
treatment remedies. As-with the buildings, EPA believes
that such information for the vessels could be gathered
in a relatively short period of time after this Record of
Decision, documented in a either the Phase III RI/FS or a
separate study to support a removal action.
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d. SURFACE SOILS/vith Organics or Metals Contamination
As noted previously, EPA believes that selection of a remedy
for the surface soils is not supportable at this time. The
full extent of contamination associated with surface soils
throughout the site is unknown. Cleanup goals for surface
soils at the site have not yet been established. No reliably
effective remedy has been identified to meet cleanup goals.
It is EPA's intent that the Phase III RI/FS will address
these three key issues relating to surface soils.
In the interim, EPA believes that the security fencing
selected as part of the first operable unit will effectively
limit the potential for human exposure to surface
contamination.
e. MONITORING
As noted previously, EPA has concluded that environmental
monitoring will be necessary during implementation of the
selected remedies to assure that the RAAs successfully reduce
or eliminate threats or potential threats to human health and
the environment posed by the BWP site. The major purposes of
the monitoring program will be to:
a. assure the effectiveness of "each specific remedy
implemented, and
b. evaluate the overall effect of the operable unit on
contaminant migration associated with ground water.
2. STATUTORY DETERMINATIONS
Section 12l(b) of CERCLA requires that any selected remedy be
protective of human health and the environment, be cost-
effective, and utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the
maximum extent practicable. In addition, under Section 121(d) of
CERCLA, remedial actions that leave any hazardous substance,
pollutant, or contaminant on-site must meet, upon completion of
the remedial action, a level or standard of control that at least
attains standards, requirements, criteria, or limitations that
are legally applicable to the hazardous substance, pollutant, or
contaminant concerned, or are relevant and appropriate under the
circumstances of the release or threatened release. A remedial
action that does not attain such a standard or level of control
may be selected only if a statutory waiver is available and
determined to be appropriate.
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TPA~ha-s~concluded that the selected remedy is consistent with
these requirements of CERCLA as well as with the requirements of
the NCP. The basis for this conclusion is found in Chapter F and
the accompanying tables (Tables F-l through F-5). Of particular
note is the information in Tables F-5, which evaluates the
various remedies against nine criteria that parallel the
statutory considerations listed above and discussed in greater
detail below. The following section provides a narrative
description of how the selected remedy meets the specific
statutory requirements:
a. PROTECTIVENESS
EPA's selected remedy, the operable unit at the BWP site, is
protective of human health and the environment. To begin
with, fencing the entire site, along with posting warning
signs, is the most effective option for restricting access to
both known and uncharacterized areas of contamination.
For the primary source of contamination, the impoundment
sludge, oils and soils, excavation and on-site incineration
will provide the greatest degree of protection available for
human health and the environment. This protection is
achieved because the selected remedy eliminates the primary
contamination source from the site,, thereby minimizing future
releases of contamination from the site and precluding human
or animal contact with these contamination sources.
EPA's preferred option for addressing the contaminated
impoundment water and firewater is also protective of human '
health and the environment. Even if EPA's backup remedies
for these contaminated waters are determined to be most
appropriate during the remedial design phase, there will
still be maximum long-te.rm protection of human health and the
environment. For example, even the backup remedies will
assure that discharged water meets MCLs.
All of the selected remedial options for these contamination
sources utilize treatment technologies which will eliminate
the contamination source from the site. Finally,
implementation of all components of the selected remedy poses
no unacceptable short-term risks to human health or the
environment.
b. COST EFFECTIVENESS
The selected remedy is a cost effective option for the
operable unit at the BWP site. This determination is based
on the cost and overall effectiveness of the selected remedy
when viewed in light of the cost and overall effectiveness of
other alternatives.
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For the purpose of evaluating cost effectiveness, the primary
component of the selected remedy is on-site incineration of
contamination sources. Incineration will provide a permanent
remedy to the problems posed by the primary sources of
contamination by significantly reducing the toxicity,
mobility, and volume of contamination while providing
technologically reliable, long-term protection of human
health and the environment. Based on information currently
available to EPA, no other remedy addressing the primary
source of contamination would achieve the same degree of
reliable, permanent, overall protection for a lower cost.
The other components of the selected remedy, including the
selected options for restricting site access, and treatment
of firewater, impoundment water and oils, are also cost
effective. For the remedial options chosen for these
components of the remedy, the costs are not significantly
greater and in some cases are less expensive than the other,
less-effective alternatives which were considered (excepting
the no-action alternatives). Once again, these components of
the remedy provide a high degree of protection at the site,
utilizing technologically reliable, permanent remedies which
significantly reduce the toxicity, mobility, and volume of
contamination on-site.
C. UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE
TREATMENT TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE
The selected remedy satisfies the statutory preference for
utilization of a permanent solution for the sources of
contamination addressed in this operable unit. Incineration
of contamination sources will significantly and permanently
reduce the toxicity, mobility, and volume of the incinerated
"contaminants. There are no technological barriers to the
implementation of the incineration component of the remedy,
and once the incineration process is complete, there will be
little need for long-term maintenance for this aspect of the
selected remedy. The only such maintenance will be
associated with the disposal of the residues of the
incineration process.
Feasible implementation, significant reduction of TMV, and
minimal long-term maintenance are also characteristics of the
other components of the selected remedy. Potential remedial
options described in the selected remedy for the firewater,
impoundment water and oil were selected to achieve the goal
of significantly reducing the toxicity, mobility, and volume
of the contaminants. Implementability is a key component of
the "decision tree" established in the selected remedy, with
the options to be chosen during the remedial design phase
after it is determined which options can in fact be
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implemented while at the same time meeting the other
selection criteria. Furthermore, all of the selected
remedial options require little long-term maintenance.
d. COMPLIANCE WITH ARARs
The selected remedy will comply with all of the ARARs
identified for the particular remedial action alternatives
which are the components of this operable unit except in one
instance in which a backup remedy may not meet ARARs. In
that instance in which the remedy may not comply with ARARs,
EPA waives the ARAR pursuant to CERCLA section l2Kd)(4)(A).
This section will describe how the selected remedy complies
with ARARs and give the rationale for invoking the statutory
waiver.
(1 ) Site Access
Fencing the entire site complies with the applicable
provisions of 6CCR 1004-3 section 264.14. Specifically,
section 264.14(b)(2)(i) describes fencing as one of the
acceptable alternatives for providing site security at a
hazardous waste facility.
(2) K001 Sludge and Impoundment Oils
HSWA requires BOAT treatment of K001 sludge prior to Land
Disposal. Incineration will achieve BOAT numbers for the
sludge as prescribed in the.May 17, 1988 Federal Register
and listed elsewhere in this document. Disposal of the
ash residues at a licensed hazardous waste landfill is
likewise in compliance with HSWA requirements.
(3) Incineration Design and Operation
As noted in the selected remedy description, design and
operation of the on-site incinerator will be subject to
the requirements set forth in 6 CCR 1007-3 part 264
subpart 0.
(4) Treatment and Disposal of Contaminated Water
EPA's first choice for disposal of the contaminated water
after treatment by carbon adsorption is to use it as
incineration quench water. This option would meet all
ARARs in that the water would be evaporated rathnr than
disposed.
If the quench water option is not viable, for instance
because of too much quench water, the on-site disposal
may be exercised as a second choice. It is possible that
carbon adsorption treatment of the contaminated water
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would achieve non-detectable levels of hazardous
constituents. If this is the case, the>treated water
would no longer be considered hazardous under.the State
of Colorado's interpretation of 6 CCR section 261.3.
Since the water would no longer be considered a hazardous
waste, on-site evapo-transpiration would not be subject
to any ARARs.
If non-detectable levels are not achieved subsequent to
carbon adsorption, the State of Colorado would consider
on-site evapo-transpiration as subject to the land
treatment requirements of 6 CCR 1007-3 part 264 subpart
M. However, EPA will waive the applicable land treatment
requirements for this alternative. The basis for this
waiver would be that this is an interim remedy, and that
any small amount of contamination deposited on the soil
would be addressed when the Phase III RI/FS develops
remedies for the soils. In any case, as noted
previously, the treatment process would still provide a
sufficient level of protection in that the treated water
would still meet MCLs for drinking water.
(5) Impoundment Soils
Incineration of the impoundment soils should meet ARARs
as described for the K001 sludge and impoundment oils.
If a waste pile is used to manage the impoundment soils
prior to RD/RA which will follow the Phase III RI/FS, the
waste pile will be designed consistent with the criteria
established in 6 CCR 1007-3 part 264 subpart L.
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