United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R08-89/025
September 1989
3EPA
Superfund
Record of Decision
Monticello Vicinity Properties, UT
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R08-89/025
3. Recipient' Accession No.
4. Title and Subtitle
.SUPERFUND RECORD OF DECISION
Monticello Vicinity Properties, UT
First Remedial Action - Final
5. Report Data
09/29/89
7. Author(s)
8. Performing Organization Rept No.
9. Performing Organization Name and Address
10. Pro|ectrrask/Work Unit No.
11. ContracqC) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street-, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Note*
16. Abstract (Limit: 200 words)
The Monticello Vicinity Properties site, also known as the Monticello Radiation
Contaminated Properties, is a federally-owned abandoned vanadium and uranium mill area
in the city of Monticello, San Juan County, Utah. Land use in the area is residential,
however, there is limited commercial use as well. Milling of vanadium and uranium
occurred from 1944 to 1960. Throughout the operating period, mill tailings were used
in the city of Monticello for construction purposes including fill for open lands;
backfill around water, sewer, and electrical lines; sub-base for driveways, sidewalks,
and concrete slabs; backfill against basement foundations; and as sand mix in concrete,
plaster, and mortar. Currently, the site consists of a dismantled vanadium and uranium
mill, and stabilized mill tailings piles. The Monticello Radiation Contaminated
Properties were accepted into the Department of Energy's Surplus Facilities Management
Program in 1980 for remedial action. The Vicinity Properties were formally included on
the NPL in 1986 and, therefore, must comply with requirements of CERCLA. In October
1989 the Millsite itself was also listed on the NPL. DOE established an official list
of Vicinity Properties designated for remedial action based on radiological surveys
conducted from 1971 to 1984. As of March 1989, 91 properties had been identified to be
included in the Monticello Vicinity Properties. Of these 91 properties, 53 remedial
actions have been completed and 12 additional properties (See Attached Sheet)
UT
17. Document Analysis a. Descriptors
Record of Decision - Monticello Vicinity Properties,
First Remedial Action - Final
Contaminated Media: construction material and debris contaminated with uranium
(mill tailings)
Key Contaminants: radium-226 and radon-226 in uranium mill tailings
b. Identifiers/Open-Ended Terms
c. COSATI Held/Group
18. AvailabiBty Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
30
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPI1UNAL rvnM 2/2 (4-f f
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/RO8-89/025
Monticello Vicinity Properties, UT
First Remedial Action - Final
6. Abstract (continued)
are slated for remedial action in 1989. Approximately 100,000 cubic yards (135,000 tons)
of contaminated construction debris and wind blown deposited contamination is estimated to
be within the Vicinity Properties. The primary contaminants of concern in construction
material and debris are thorium-230, radium-226, and radon-222 contained in the vanadium
and uranium mill tailings.
The selected remedial action for this site -includes excavation and removal of residual
radioactive material from affected properties and restoration/reconstruction using clean
materials, or modification of existing structures to isolate radiation sources from
inhabitants; filling and regrading excavated areas; and disposal and temporary storage of
all contaminated material at the Monticello Millsite. The millsite is addressed
separately under a 1988 Federal Facilities Inter-agency Agreement. The estimated present
worth cost of this remedial action is $65,000 per Vicinity Property for 91 "included1
properties, or $5,915,000.
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DECLARATION
FOR THE
RECORD OR DECISION
SITE NAME AND LOCATION
Monticello Vicinity Properties Project
Department of Energy Facility - Surplus Facilities Management
Program
Monticello, San Juan County, Utah
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Monticello Vicinity Properties NPL site.
The Environmental Protection Agency (EPA), the State of Utah (the
State) and the U.S. Department of Energy (DOE) have agreed to v
conduct the remedial action(s) at the site pursuant to the
Federa-1 Facilities Agreement of December 1988 under Section 120
of the Comprehensive Environmental Response, Compensation and
Liability Act of 1980, as amended by the Superfund Amendments and
Reauthorization Act of 1986 (CERCLA), and the National
Contingency Plan. As part of this Agreement, EPA the State have
reviewed DOE'S project documentation. On May 24, 1989, the State
and EPA concluded that DOE had complied with the CERCLA
requirements by performing the functional equivalent of a
Remedial Investigation/Feasibility Study at the Monticello
Vicinity Properties.
This decision document is based upon the administrative record
for the Monticello Vicinity Properties. The attached Record of
Decision Summary identifies the items comprising the
administrative record upon which the selection of the remedial
action was based. The State concurs on the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Record of Decision, may present an imminent and
substantial endangerment to public health, velfare, or the
environment.
DESCRIPTION OF THE SELECTED REMEDY
In consultation with EPA and the State, DOE developed a remedial
action plan to stabilize and control uranium mill tailings and
related contaminated material at the Monticello Vicinity
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Properties In a long-term manner that complies with EPA's
Standards for Remedial Action at Inactive Uranium Processing
Sites (40 CFR Part 192).
Concern regarding the potential health hazards that result from
exposure to radiation emanating from uranium mill tailings and
from contaminated structures in the vicinity of such sites
("vicinity properties" or "off-site properties") prompted the
U.S. Congress to enact legislation that authorized DOE to
undertake remedial action to prevent or minimize
this type of environmental hazard. The Uranium Hill Tailings
Radiation Control Act of 1978 authorized remedial action at
certain inactive uranium milling sites that were not owned by the
Federal government. Since the Monticello mill site is owned by
the Federal government, it was included instead in the Department
of Energy's Surplus Facilities Management Program in 1980 for
remedial action. Subsequently, the Monticello Vicinity
Properties Project was initiated.
The purpose of the Monticello Vicinity Properties Project is to v
reduce the public's exposure to radiation either by removing
contaminated material from properties or by modifying existing
structures to isolate radiation sources. The "Standards for
Remedial Action at Inactive Uranium Processing Sites" identified
in 40 CFR 192 and the Hot Spot Criteria established by
radiological protection guidelines in the U.S. Department of
Energy Guidelines for Residual Radioactive Material at Formerly
Utilized Sites Remedial Action Program and Remote Surplus
Facilities Management Program Sites (Revision 2, March 1987),
will be the basis for remedial action under the proposed plan.
Because mill tailings from the Monticello millsite were used in
the city of Monticello for construction of residential buildings,
the cleanup activities for the Monticello Vicinity Properties
will require excavation of contaminated materials and, in some
cases, demolition of sidewalks, patios, sheds, and other
improvements. All excavations will be refilled with clean
fill and regraded; all affected structures and other
improvements will be reconstructed. All contaminated material
will be removed to the Monticello millsite and temporarily stored
on the East Tailings Pile. The millsite is addressed separately
under the 1988 Federal Facilities Agreement. If Resource
Conservation and Recovery Act (RCRA) hazardous wastes are found,
disposal plans will be prepared for that specific hazardous waste
and approved by EPA in consultation with the State. All remedial
actions shall meet applicable or relevant and appropriate
requirements of Federal law and those State laws more stringent
than Federal laws in accordance with Section 121 of CERCLA.
After remediation is completed, DOE will prepare a completion
report for each property certifying that the property has been
cleaned up in compliance with the standards discussed above.
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Verification of the site remediation vill be performed by an
independent contractor as an additional assurance that standards
have been met.
The proposed cleanup activities must be accomplished before
remedial action at the Monticello millsite is complete, since the
contaminated material from the vicinity properties vill be
addressed along with the tailihgs and other contaminated material
remaining at the millsite. This Record of Decision covers all
properties that vere contaminated, including those that have been
remediated, those that are currently included but have not been
remediated, and all future properties that might be included for
remediation.
The purpose of the Monticello Vicinity Properties Record of
Decision document is to shov that selection of the preferred
alternative, which is currently being used to complete remedial
actions in Monticello, was an appropriate selection and to
satisfy the requirements of the Federal Facilities Agreement and\
the Comprehensive Environmental Response, Compensation, and
Liability Act as amended.
STATUTORY DETERMINATIONS
Based on the standards established pursuant to CERCLA; the
National Contingency Plan; and the Standards for Remedial Action
at Inactive Uranium Processing Sites, we have determined that the
selected remedy for the Monticello Vicinity Properties Project is
protective of human health and the environment, attains
applicable or relevant and appropriate requirements to this
remedial action, and is cost-effective considering current
technology.
This remedy utilizes permanent solutions (removal of all
radioactive tailings and other contaminated material) to the
maximum extent practicable for this site. This remedy does not
satisfy the statutory preference for treatment as a principal
element of the remedy, because treatment of the principal
potential risks from the site was not found to be practicable.
Pursuant to CERCLA, EPA will review the response action no less
often than each five (5) years for portions of the remedial
action involving waste being left on-site, as required by the
Federal Facilities Agreement, after the initiation of the final
response to assure that human health and the environment are
being protected by the remedial action being implemented.
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Date
Kegic^XAdmin^trator (Region vin)
U.S. Environmental Protection Agency
Date
U.S. Department of Energy
Concurring in this determination:
Date
State of Utah
Department of Health
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MONTICELLO VICINITY PROPERTIES
RECORD OF DECISION SUMMARY
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1.0 SITE NAME, LOCATION, AND DESCRIPTION
The city of Monticello is located in San Juan County, which
occupies the southeastern corner of Utah (Figure 1). The city
lies in the Paradox Basin just east of the Abajo Mountains and
north of Montezuma Creek. The.major highway in the Monticello
area is U.S. Highway 191, which runs generally in a
north-south direction, connecting Monticello with Moab 56 miles
to the north and with Blanding 22 miles to the south.
The town of Monticello is located at an average elevation of
7,000 ft. above sea level. Land use within the majority of
Monticello Vicinity Properties is for residential housing.
Adjacent land usage includes heavy and light commercial use and a
"controlled" zoning district allowing a mix of agricultural,
residential, industrial, and commercial use. Natural resource
use in the immediate area includes domestic water supply systems,
with the city being supplied by springs near the Aba jo Mountains.-v
Local groundwater usage includes rural drinking water and
farmland irrigation. Surface water usage is primarily for
irrigation. No mineral exploration exists within the immediate
vicinity of the properties.
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
The original Monticello mill was financed by the United States
Government through its agent, the Defense Plant Corporation, to
provide an additional source of vanadium needed during World War
II. The Vanadium Corporation of America operated the mill for
the Government until 1944, and privately under a lease from the
Government from 1944 to 1946. The U.S. Atomic Energy
Commission reactivated the mill in 1948 and engaged the Galigher
Company to rebuild it. The mill was operated for the U.S. Atomic
Energy Commission from 1949 to 1956 by The Galigher Company, and
from 1956 through 1959 by the National-Lead Company, under
cost-type contracts to produce both uranium and vanadium. During
the years following U.S. Atomic Energy Commission takeover of the
mill, uranium was the primary product.
Mill operations were terminated on January 1, i960, and the plant
was dismantled by the end of 1964. The mill tailings piles were
stabilized over the period 1961 to 1962. Removal of contaminated
soils from associated ore-buying stations was undertaken between
May 1974 and August 1975. The mill foundations were also
demolished and bulldozed into adjacent pits during this same
period of time. It is estimated that during its years of
operation, the mill processed approximately 900,000 tons of ore.
Throughout the operating period, mill tailings from the
Monticello millsite were used in the city of Monticello .for
construction. These tailings were used as fill for open lands;
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backfill around water, sewer, and electrical lines; sub-base for
driveways, sidewalks, and concrete slabs; backfill against
basement foundations; and as sand mix in concrete, plaster, and
mortar. The total tonnage of uranium mill tailings removed from
the millsite for. construction purposes, although never
documented, is believed to be approximately 135,000 tons. This
retrieval of contaminated tailings from the Monticello millsite
was controlled by August 1975 as a fence was erected around the
site to prevent unauthorized access and the ore-buying stations
were gleaned up. Figure 2 outlines the Monticello Vicinity
Properties project area and shows the adjacent millsite location.
Concern regarding the potential health hazards that result from
exposure to wind and water borne contamination and radiation
emanating from uranium mill tailings and from contaminated
structures in the vicinity of such sites ("vicinity properties"
or "off-site properties") prompted the U.S. Congress to enact
legislation, which authorized the Department of Energy to
undertake remedial'action to prevent or minimize this type of
environmental hazard. The Uranium Mill Tailings Radiation
Control Act of 1978 authorized DOE to undertake remedial action
at certain inactive uranium milling sites never owned by the
Federal government. Since the Monticello millsite is a Federally
owned facility, it was not elegible for remediation under the
Uranium Mill Tailings Radiation Control Act and was instead
accepted into the Department's Surplus Facilities Management
Program in 1980 for remedial action. Subsequently, the
Monticello Vicinity Properties Project was initiated.
DOE established an official list of Vicinity Properties
designated for remedial action under its Surplus Facilities
Management Program on the basis of radiologic surveys. Radiologic
surveys conducted throughout the city of Monticello to identify
the existence, nature, and magnitude of radiation exposure from
mill tailings originating from the Monticello millsite included:
1. In 1971 and 1980, EPA-subsidized mobile scanning surveys
(U.S. Environmental Protection Agency, 1972; Bendix Field
Engineering Corp., 1982) were performed by DOE contractors.
These surveys identified 98 anomalous properties.
2. In 1982, Bendix Field Engineering Corporation, under
contract to DOE, investigated a total of 114 properties,
including the 98 properties identified above plus an additional
16 properties, which were surveyed at the request of landowners.
3. Oak Ridge National Laboratory performed a survey in 1983,
which added 36 more properties to the investigation.
4. In June 1984, a radiation survey of buildings in Monticello
was conducted by EPA Region VIII personnel together with
personnel from the State of Utah and DOE. As a result of the
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Son Juon County
Figure 1. Monticello. Utah. Regional Location Map
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Figure 2. Monticello Vicinity Properties Project Area
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surveys, 10 additional buildings were identified for further
investigations.
In October 1984, the Monticello Vicinity Properties were proposed
for inclusion (as "Monticello Radioactively Contaminated
Properties") on the National Priorities List pursuant to CERCLA
and were formally included on the National Priorities List on
June 10, 1986. As a result, cleanup activities at the Vicinity
Properties must satisfy requirements of CERCLA.
Through' its Grand Junction Projects Office, the Department of
Energy began cleanup of properties that exceeded levels for
inclusion in the program in the summer of 1984 in accordance with
EPA's Standards for Remedial Action at Inactive Uranium
Processing Sites. DOE has accepted responsibility for properties
contaminated with tailings from the Monticello millsite. DOE has
also conducted cleanup action, which was funded by EPA in 1984 at
two properties not included in DOE's Surplus Facilities
Management Program, under an interagency agreement. \
As of March 1989, 204 properties have been identified as
anomalous properties with 91 identified by DOE to be included in
the Monticello Vicinity Properties Project. Of these 91
"included" properties, the Department of Energy has completed 53
remedial actions and has scheduled 12 additional properties for
remedial action in 1989. There are probably other contaminated
properties in addition to the 204 screened properties mentioned
above. As other contaminated properties are identified, they
will be considered for addition to the Monticello Vicinity
Properties Project according to the process set forth in Section'
XIII of the Federal Facilities Agreement. The 204 screened
properties include some where owners have refused surveys and/or
remedial action and some where the cleanup responsibility is
still being disputed. EPA and the State of Utah will develop a
plan for resolving owner refusals on specific properties. If DOE
disputes responsibility for response activities at any given
property, the procedure found in Part XIII of the Federal
Facility Agreement will be used to determine who shall be
responsible for cleanup.
EPA, the State, and DOE have agreed to conduct the response
action(s) at the site pursuant to the Federal Facilities
Agreement of December 1988 under Section 120 of the CERCLA, as
amended. As part of this Agreement, EPA and the State have
reviewed the DOE documentation and have agreed that DOE has
complied with CERCLA requirements by performing the functional
equivalent of a Remedial Investigation/Feasibility Study for
Monticello Vicinity Properties currently addressed by DOE.
Property investigations had begun and some remediations had
concluded before the site was listed on the National Priorities
List and prior to the passage of the Superfund Amendments and
Reauthorization Act of 1986. Therefore, EPA and the State agreed
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to evaluate all completed, ongoing, and future work for
equivalency to CEBCLA. The Record of Decision is a primary
document, which is specifically referred to in the Federal
Facilities Agreement at Section XII.C.i.l.
DOE submitted to EPA a document titled Monticello Vicinity
Properties Equivalency of Documentation, dated April 1989, which
EPA subsequently approved on May 24, 1989, concluding that the
documentation was functionally equivalent to the Remedial
Investigation/Feasibility Study for the Monticello Vicinity
Properties.
3.0 COMMUNITY RELATIONS HISTORY
A proposed plan was developed for the Monticello Vicinity
Properties Project in June 1989. The Proposed Plan is a public
participation decision document and, as such, there was
opportunity for the public to comment to DOE, EPA, and the State.
Public comment on the Proposed Plan (for 30 days) began June 30, \
1989 and extended through July 30, 1989. A summary of responses
to the questions raised during the public comment period is
attached as Appendix A. All written comments were sent to:
Mr. Pete Mygatt, Public Affairs Specialist
U.S. Department of Energy
P.O. Box 2567
Grand Junction, Colorado 81502
(303) 248-6015 (collect calls were accepted)
An index to the Administrative Record is attached as Appendix B.
Verbal comments were made at a public hearing between 7 p.m. and
10 p.m. on July 6, 1989, at the San Juan County Courthouse in
Monticello, Utah. Documentation developed by DOE for the
Monticello Vicinity Properties can be reviewed at the
Administrative Record Repository:
San Juan Public Library
80 North Main Street
Monticello, Utah 84535
(801 ) 587-2281
Overall public acceptance of the work plan for the remedial
action of the Monticello Vicinity Properties has been very good.
Questions and comments received from the audience during the
public meeting held on July 6, 1989, related primarily to the
steps of the remedial action process for individual properties,
overall costs of the program, and warranty questions for
properties that had already been remediated.
The only new area of concern voiced by the public related to
enforcement of cleanup under the program. EPA responded to the
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concern by indicating that the program was not one of voluntary
participation and that, by law, EPA was required to ensure the
properties identified on the National Priorities List were
cleaned up. The exact methods of enforcement, in cases where
owners refuse to allow access to the property or to participate
in the cleanup, remain to be determined.
4.0 SUMMARY OF SITE CHARACTERISTICS AND SITE RISKS
Mill-operations were terminated on January 1, i960, at the
Monticello millsite, and the plant was dismantled by the end of
1964. The mill tailings piles were initially stabilized with 6
to 18 inches of cover and revegetated during the period of 1961
to 1962.
Throughout the operating period, tailings from the Monticello
millsite were wind-blown into the city of Monticello or used in
the city of Monticello for construction. These tailings were
used as fill for open lands; as backfill around water, sewer, and\
electrical lines; as sub-base for driveways, sidewalks, and
concrete slabs; as backfill against basement foundations; and
as sand mix in concrete, plaster and mortar. The total tonnage
of uranium mill tailings removed from the millsite for
construction was not documented. However, contaminated material
from vicinity properties (in the Monticello area currently being
remediated) is estimated at 100,000 cubic yards (135,000 tons).
This includes wind blown deposited contamination.
Specific properties were investigated and an environmental
evaluation completed by 1985 (before passage of the Superfund
Amendments and Reauthorizatioh Act). These investigations and
environmental evaluations are found in two documents, Results of
the Survey Activities and Mobile Gamma Scanning in Monticello,
Utah, July 1984, Oak Ridge National Laboratory (ORNL/TM 9738) and
Environmental Evaluation on Proposed Cleanup Activities at
Vicinity Properties near the Inactive Uranium Millsite,
Monticello, Utah, August 1985, Bendix Field Engineering
Corporation. These documents are contained in the Monticello
Vicinity Properties Equivalency of Documentation, April 1989,
U.S. Dapartment of Energy.
Summary of Site Risks
The following summarizes the predicted health effects that may
occur to the general public due to contaminated material existing
at vicinity properties. Calculations are based on exposure rates
affecting persons at the fifteen properties initially authorized
for cleanup. Details of the health risks are found in the
Monticello Vicinity Properties Equivalency of Documentation
(compiled April 1989, for the Monticello Remedial Action Project
Administrative Record), specifically within the Environmental
Evaluation on Proposed Cleanup Activities at Vicinity Properties
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Near the Inactive Uranium Millsite, Monticello, Utah, Appendix B,
DOE-GJ-35, Bendix Field Engineering Corporation, August 1985.
The principal environmental radiological impacts and associated
effects on human health are attributed to thorium-230,
radium-226, radon-222, and daughters of radon-222 contained in
the uranium-mill tailings. Although these radionuclides occur in
nature, their concentrations in tailings material are several
orders of magnitude greater than their average concentrations in
the earth's crust.
The major potential environmental routes of exposure to man are
listed below:
o Inhalation of radon-222 and daughter products that result
from the continuous radioactive decay of radium-226. The
greatest hazard to human health results from the inhalation of
radon-222 daughters, which emit alpha radiation that affects the
lungs. \
o External vhole-body garrma exposure directly from
radionuclides in the tailings.
o Inhalation and ingestion of windblcvn tailings dust. The
primary health hazard results from the alpha emitters thorium-230
and radium-225, both of which affect the bones and lungs.
o Ingestion of groundwater and surface water contaminated with
radioactive elements, primarily radium-226.
o Ingestion of food potentially contaminated through uptake
and concentration of radioactive elements by plants and animals.
A summary of radiation doses from all potential exposure pathways
is presented in Table 1. The potential ingestion pathways of
food, groundwater, and surface water were determined to be
insignificant exposure routes. The number of potential health
effects (defined as radiation-induced cancer deaths) expected
from the whole-body radiation dose listed in Table 1 is
approximately 0.02. The number of potential health effects
expected from the lung-radiation dose is approximately 0.06.
(Table 1 is presented on the next page)
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Table 1. Predictions of Radiation Doses from Exposure Pathways
r Dose (mrem)
Pathway Whole Body Lung
Exposure to Radon and Radon Daughters 400
Exposure to External Gamma Radiation 438
Inhalation of Airborne Radioparticulates 0.033 . 2.5
Ingestion of Water 0 0
Ingestion of Food 0 . 0
Totals (rounded) 438 403
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Record of Decision, may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
5.0 DOCUMENTATION OF SIGNIFICANT CHANGES
Section 117(b) of CERCLA requires documentation of any
significant changes from the preferred alternative as originally
presented in the Proposed Plan. Since the preferred alternative
has not changed for this Record of Decision, no further
documentation is required. For comparison of the preferred
alternative in the Plan for the cleanup activities at vicinity
properties, Monticello, Utah, with the selected remedy, see
Section 7.0.
6.0 DESCRIPTION OF ALTERNATIVES
Two basic alternatives for remedial action for Vicinity
Properties exist.
o Removal of identified residual radioactive material and
restoration with clean materials, or modification of existing
structures to isolate radiation sources from inhabitants, is the
preferred alternative. Cleanup activities will require
excavation of contaminated materials, and in some cases,
demolition of sidewalks, sheds, patios, and other improvements.
All excavations will be refilled with clean fill and regraded;
all affected structures and other improvements will be
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reconstructed. The.contaminated materials relocated temporarily
to the East Tailings Pile at the millsite would be disposed of
with millsite tailings in .a.permanent repository, covered by a
separate action under CERCLA.
o No Action.'
No other alternatives, such as stabilization in-place or
treatment are considered practical or effective at reducing the
risk to human health.
Applicable or Relevant and Appropriate Requirements (ARARs):
The ARARs for the Monticello Vicinity Properties are the
standards on which cleanup activities are based. In March 1983,
EPA published its Standards for Remedial Action at Inactive
Uranium Processing Sites (40 CFR 192). These Environmental
Protection Agency standards established requirements for the
control of tailings piles, cleanup of buildings, cleanup of open
lands, and supplemental standards. DOE has adopted the
concentration limits and associated requirements of these EPA
standards into the DOE guidelines for residual radioactive
material. As a result, the Standards for Remedial Action at
Inactive Uranium Processing Sites, while not applicable, have
been found to be relevant and appropriate to the Monticello
Vicinity Properties remedial actions. DOE has also adopted the
"hot-spot" criteria established in its cvn guidelines, U.S.
Department of Energy Guidelines for Residual Radioactive Material
at Formerly Utilized Sites Remedial Action Program and Remote
Surplus Facilities Management Program Sites (Revision 2, March
1987). The EPA standards at 40 CFR 192 and the Department of
Energy "Hot Spot" criteria are attached as Appendix C.
Other Applicable or Relevant and Appropriate Requirements that
also apply are presented in DOE letter dated May 31, 1989,
Transmittal of Detailed Analysis of Federal and State Potentially
Applicable or Relevant and Appropriate Requirements for the
Monticello Vicinity Properties, (MVP), and the State of Utah
letter to EPA dated June 21, 1989 (aSHW-5705-i) include:
o U.S. Occupational Safety and Health Act of 1976, as amended
o Utah Occupational Safety and Health Standards
o Utah Bureau of Water Pollution Control Standards
o Utah Air Conservation Rules
o Utah Bureau of Radiation Control Standards
o Utah Bureau of Hazardous Waste Standards (except State RCRA
criteria)
7.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
Nine evaluation criteria have been developed by EPA to address
CERCLA requirements and considerations, and to address the
additional technical and policy considerations that have proven
8
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to be important'for remedial alternative selection. A summary of
the preferred alternative performance against these nine criteria
and how it compares to the no-action alternative is presented
below.
Criterion Mo. l'' - Overall Protection of Human Health and the
environment
Approximately 85 percent of the radioactivity originally
conta.ir.ed in uranium ore remains in the tailings after removal of
the uranium, because radium and thorium, principal contributors
to radioactive emissions, are not normally removed from uranium
ores during milling. The principal environmental radiologic
impact and associated effects on human health are attributed to
the thorium-230, radium-226, radon-228, and daughters of
radon-222 contained in the uranium mill tailings. Although these
radionuclides occur in nature, their concentrations in tailings
material are several orders of magnitude greater than their
average concentrations in the earth's crust. ^
The major, potential environmental routes of exposure to humans
are ii%sted below:
o Inhalation of radon-222 and daughter products that result
from the continuous radioactive decay of radiurn-226. Hadon is a
gas that diffuses from the tailings. The greatest hazard to
human health results from the inhalation of radon-222 daughters
that emit alpha radiation affecting the lungs.
o External whole-body gamma exposure directly from
radionuclides in the tailings.
o Inhalation and ingesticn of wind-blcvn tailings dust. The
primary health hazard results from the alpha emitters
uranium-238, thorium-230 and radium-226, which affect the bor.es
and lungs.
o Ingestion of groundwater and surface vater contaminated with
radioactive elements, primarily radium-226.
o Ingestion of food potentially contaminated through uptake
and concentration of radioactive elements by plants and animals.
The removal of contaminated soils and materials from the Vicinity
Properties will eliminate these health risks. The no-action
alternative would continue to expose the Monticello community to
these health risks.
Criterion No. 2 - Compliance with Applicable or Relevant and
Appropriate Kequirements
The preferred alternative will comply with Federal and State
9
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standards and regulations that are applicable or relevant and
appropriate for the Monticello Vicinity Properties. The
no-action alternative, hcvever, will not comply with the EPA
Standards for Remedial Action at Inactive Uranium Processing
Sites.
Criterion No. 3 - Long-term Effectiveness and Permanence
Removal of contamination offers long-term protection of public
health from the radioactive tailings. Since the final disposal
of the contaminated materials will be with the millsite tailings,
the preferred alternative is also a permanent solution. The
no-action alternative obviously provides neither long-term
effectiveness nor permanence.
Criterion Ko. 4 - Reduction of Toxicity, Mobility, or Volume
Since no treatment technology is used in the removal of
contaminated materials, there is no reduction in toxicity,
mobility, or volume of radioactive materials. Hcvever, the
placement of these materials and the millsite tailings in a final
repository will reduce radioactive exposure and restrict mobility
of contaminants which will prevent future environmental
exposures. The no-action alternative would cause no reduction of
toxicity, mobility, or volume.
Criterion Mo. 5 - Short-term Effectiveness
This criterion addresses the period of time r.eeded to achieve
protection, and any adverse impacts on human health and the
environment that may be posed during the construction and
implementation period until cleanup goals are achieved. Based on
risk analysis, the expected exposure of an individual working on
Vicinity Properties over the next 3 years is insignificant when
compared to the radiation dose the individual receives from
natural background radiation. The no action alternative would
not increase exposure over background levels.
Criterion Ko. 6 - Implementability
The preferred alternative of removing the contaminated materials
from Vicinity Properties is both administratively and technically
feasible. Considering that 53 properties have already been
remediated, it is, therefore, recognized that the preferred
alternative is implementable. The no-action alternative could
also be implemented.
Criterion No. 7 - Costs
To date, the average cost of remedial action has been
approximately $65,000 per Vicinity Property. It can be assumed
that the remaining properties still requiring remediation will
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have similar average costs. The no-action alternative would
obviously not incur these costs.
Criterion No' 8 - State Acceptance
The State of Utah is currently an active Participant in the
Monticello Vicinity Properties Project and supports the preferred
alternative. Likewise, The State opposes the no-action
alternative.
Criterion No. 9 - Community Acceptance
Community acceptance of the preferred alternative is assessed in
the Record of Decision Responsiveness Summary following a review
of the public comments received on the Proposed Plan. The
Responsiveness Summary, which includes community relations
activities, is attached as Appendix A.
Based on past community relations and the fact that 53 properties
have already been remediatad, it can be assumed that there is
basic general support for the preferred plan. The no-action
alternative may be expected to have little support in the
community because potential health risks would"not be
eliminated. However, it is recognized that some local residents
do not believe remedial action is necessary.
8.0 SELECTED REMEDY AND STATUTORY DETERMINATIONS
At this time, the preferred alternative, removal and relocation
of uranium mill tailings, provides the best balance of
trade-offs, with respect to the EPA standards at 40 CFR 192 and
"Hot Spot" criteria used to evaluate remedies. The preferred
action consists of removal of identified residual radioactive
material and restoration with clean materials, or modification of
existing structures to isolate radiation sources from
inhabitants. Cleanup activities will require excavation of
contaminated materials, and in some cases, demolition of
sidewalks, sheds, patios, and other improvements. All
excavations will be refilled with clean fill and recraded; all
affected structures and other improvements will be
reconstructed. The contaminated materials relocated temporarily
to the East Tailings Pile at the millsite would be disposed of
with millsite tailings in a permanent repository, covered by a
separate action under CERCLA and the 1338 Federal Facilities
Agreement.
Therefore, based on the information available at this time, the
Department of Energy, the Environmental Protection Agency, and
the State of Utah believe the preferred alternative would be
1 1
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protective of human health and the environment, would meet
Federal and State standards, would be cost effective, and would
provide a permanent solution for the Monticello Vicinity
Properties.
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APPENDIX A
RESPONSIVENESS SUMMARY
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Appendix A
RESPONSIVENESS SUMMARY
MONTICELLO VICINITY PROPERTIES (MVP) SUPERFUND SITE
1.0
This Responsiveness Summary responds (o questions raised during the public comment period
for the U.S. Department of Energy's Monticello Vicinity Properties Superfund Site remedial
action project. The Monticeflo Vicinity Properties draft final proposed plan was available for
public review from June 30, 1989 through July 30, 1989.
No written comments pertaining to the proposed plan for remedial action were received during
the public comment period. During the public meeting held in Monticello, Utah, on July 8,
1989. questions and comments concentrated on the steps of the remedial action process for
individual properties, overall costs of the program, and warranty questions for properties
already remediated.
General public concerns refated primarily !o the issues of dust and noise suppression during
remediation, truck traffic to and from the temporary repository (Monticello Mill site) for
excavated material, and road wear caused by the remediation trucks. These gsneral public
concerns were previously and fully addressed in the proposed work plan.
The only ne"w area of public concern related to enforcement of cleanup under the project. The
Environmental Protection Agency has indicated that (he program is not one of voluntary
participation and that, by law, the Environmental Protection Agency is required to ensure the
properties identified on the National Priority List are cleaned up.
2.Q BACKGROUND CN COMMUNITY INVOLVEMENT
Community relations activities by the U.S. Department of Energy's Grand Junction Projects
Office have been ongoing since 1 930. A comprehensive list of community relations activities is
included as an attachment to this Responsiveness Summary. Contact has been predominantly
through periodic briefings of city and county officials, Slate of Utah representatives and
individual property owners. Periodic press releases and fact sheets have been issued and severs!
public meetings have been csnduc.'ed. As a result of this ongoing communication, community
interest in the cleanup of the Monticelfo Vicinity Properties has been very low.
The low public concern can be accounted for by several factors:
Local citizens have lived and worked with the uranium mining and milling
industry since the early 19<*0'S. Many made their livelihood from those
industries.
Most citizens do not view the mill tailings as a serious health hazard.
The majority of the community is unconcerned about the presence of
contamination on the vicinity properties. In some instances, owners have
to be convinced (hat access (o perform remedial action will benefit them
in the long run.
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Remedial action al the vicinity properties has been in progress since 1984
with 53 out of the currently identified 91 properties having already been
completed as of March 1939. Monticetlo residents are accustomed to seeing the
work in progress and are familiar with the process that is being used.
3.Q SUMMARY CF ftOMMErVTS RECEIVED AND AGENCY RESPONSES
Work Warranties
Comments raised during the public comment period on the proposed work plan for the
Monticello Vicinity Properties were predominantly questions regarding warranty of work
previously completed. These questions were not related to the work plan itself and were dealt
with on an individual basis with the property owners.
Poad Maintenance
A representative of the Monticello city council inquired about possible assistance from the
Department of Energy in upgrading a road leading to the temporary repository. The inquiry did \
not relate directly to the vicinity properties work plan and will be pursued as a separate
matter.
Dust Control
A citizen expressed concern about dust from work in progress at neighboring properties during
this construction year as Monticello is experiencing drought conditions. The Department of
Energy responded that dust control both at the individual property work site and at the
temporary repository would be carefully maintained as standard operating procedure and that,
if citizens had any problems, they should call either the project office in Monticello or the
Department of Energy Grand Junction Projects Office in Grand Junction, Colorado.
Truck Tarofno
A citizen expressed concern that occasionally trucks traveling to the temporary repository were
not tarped. The Department of Energy responded that proper diapering and tarping is required
of the construction subcontractors and any observed cases of non-tarping were to be reported to
the Mcnticallo construction office or to the Department of Energy Grand Junction Projects Cffice
in Grand Junction, Colorado.
Several citizens inquired as to what the procedure would be in the case of a property owner not
allowing access for survey or not wanting the remediation done. The Environmental Protection
Agency responded that since this is a National Priority List site, the Environmental Protection
Agency has the ultimate authority to enforce access for assessment and/or remediation
activities. Specific enforcement methods have yet to be determined.
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Prior to the Environmental Protection Agency exercising its enforcement authority for
property assessment or remediation, the Department of Energy shall use the maximum extent of
its authority, exclusive of CERCLA section 104 authorities, to obtain agreement from the
landowner allowing for access. In the event the landowner refuses, then DOE shall request EPA
following consultation with the Slate of Utah to exercise its authority or initiate its own contact
with the landowner for purposes of gaining access to said property.
A.Q REMAINING CONCERNS
All written and oral public concerns were addressed by either the work plan or at the public
meetings; There are no remaining concerns left unaddressed.
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ATTACHMENT TO APPENDIX A
COMMUNITY RELATION'S ACTIVTTIES
FOR THE MONTICEtLO VICINITY PROPERTIES (MVP)
SUPERFUND SITE
'.
Community relations activities conducted on behalf of the Monticello Vicinity Properties (MVP)
Superfund Site to date have included:
Conducted Site visits and meetings between the DOE and the Remedial Action
Contractor (RAC) and the Monticello City Manager, San Juan County
Commissioners, Slate of Utah representatives and individual property owners.
(1930)
issued news releases on the beginning of the vicinity property cleanup program
and the results of generalized radiologic assessments and survey activities.
(1930)
DOE provided general information briefings to the local news media. Utah Slate
Bureau of Radiation and Occupational Health and the S.E. Utah District Health
Department.
Issued a fact sheet on the Monticello Uranium Mill tailings. (1932)
Maintained close contact with Governor, State Division of Environmental Health,
and State Department of Natural Resources and Energy. (1S32)
Participated in San Juan County Board of Commissioners meeting to provide
an update on the DCE's Surplus Facilities Management Program (SFMP) plan
for Moniicello cleanup. (1932)
Maintained ongoing communications with city and county officials. (1933)
Met with State officials and the San Juan County Scard of Commissioners to
discuss continuation of the Monticello Mill site (MRA?) and Vicinity Properties
(MVP) programs and to outline program milestones. (1984)
Issued a press release on planned decontamination activities for 45 properties.
(1984)
Achieved ma/or news coverage of the Vicinity Properties program through an
extensive newspaper feature on the cleanup of the Randall property. (1935)
' Sent a list of the 48 Vicinity Properties authorized for cleanup by the DCE's
Formerly Utilized Sites Remedial Action Program (FUSRAP) to the Utah State
Hazardous Waste Coordinator. (1385)
Worked with the San Juan Record on a major article summarizing cleanup
activities during 1985, including the Superfund cleanup program. (1986)
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Conducted community interviews with local officials and affected residents.
(1986)
Prepared a draft community relations plan. (May 1987)
Maintained ongoing discussions between the Environmental Protection Agency
(EPA), the Department of Energy (DOE), the State of Utah, San Juan County
and the City of Monticello during (he negotiation of the Federal Facilities
Agreement. (1933)
Issued a press release announcing a public meeting to discuss the Federal
Facilities Agreement (FFA). A public comment period from February 9 through
February 20, 1939 was provided. (January 27, 1989)
Conducted a Health and Safety training workshop for those involved in the
Monticelfo vicinity properties cleanup. Included in the training were
representatives from the State of Utah and the City of Monticelfo. (March 1939)
V
Established an information repository and the Administrative Record at the San
Juan County Library. (June 23, 1939)
Issued a press release on the public meeting on the Proposed Work Plan for the
Monticeifo Vicinity Properties. (June 23, 1989)
Published two Notices of Opportunity to Comment in the local newspaper.
A public comment period from June 30, 1989 through July 30, 1989 was
provided. (June 23 and July 5, 1989)
Conducted a public meeting in Monticello on July 6, 1S89 to describe the
work plan contents and to respond to questions. Eight people attended including
a representative from the City Council and a representative from the San Juan
County Sanitation District. A compilation of the questions and answers is
available as pan of the Administrative Record at the San Juan County Library.
(July 6, 1989)
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APPENDIX 3
ADMINISTRATIVE RECORD INDEX
JUNE 1989
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APPENDIX C
ENVIRONMENTAL PROTECTION AGENCY STANDARDS
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APPENDIX C
E.WIRONKENTAL PROTECTION AGENCY STANDARDS
In December 1982, the Environmental Protection Agency Issued a Final
Environmental Impact Statement, which evaluated standards for cleanup and Ion;
term control of uranium mill tailings at Inactive millsites that qualify for
remedial action under the Uranium Mill Tailings Radiation Control Act of 1973
(PL 95-604).
The standards were issued to reduce and control the hazards associated with
uranium mill tailings. This includes remedial action to clean up tailings
that have spread from the original site or have been removed for use
elsewhere. Although the Monticello Millsite is located on federal government
property and not subject to Uranium Mill Tailing? Radiation Control Act,
the standards promulgated to Implement that legislation are appropriate for
remediation of the vicinity properties.
Extent of contamination is based on the criteria set by Environmental
Protection Agency Standards as follows: \
192.12 Standards
Remedial action shall be conducted so as to provide reasonable assurance that,
as a result of residual radioactive materials from any designated processing
site.
(a) the concentration of radium-22S in land averaged over any area of ICO
square setsrs shall not exceed the background level of 2?Ci/g by sore
than
(1) 5 pCi/g, averaged over the first IS ca of soil below the
surface, and
(2! 15 ?Ci/f. averaged over 15 en thick layers of soil more than 15 cm
below the surface.
(b) in an occupied or habitable building
(1) the objective of remedial action shall be. and reasonable effort
shall be aade to achieve, an annual average (or equivalent) radon
dte.iy product concentration (including background) not to exceed
0.02 WL. In any case, the radon decay product concentration
(including background) shall not exceed 0.03 WL. and
(2) the level of gamma radiation shall not exceed the background level
by more than 20 microroentgens per hour.
132.:i Criteria for Applying Suep'.eaental Standards
The implementing agencies may apply standards in lieu of the standards of
Subparts A or 0 if certain circumstances exist, as defined in 192.21.
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192.22 Suooltatntal Standards
"Federal agencies Implementing Subparts A and B nay in lieu thereof proceed
pursuant to this section with respect to generic or individual situations
sieeting the eligibility requirements of 192.21."
(a) "...the implementing agencies shall select and perform remedial actions
that cose as close to meeting the otherwise applicable standards as is
reasonable under the circumstances."
fcb) "...remedial actions shall, in addition to satisfying the standards of
Subparts A and B. reduce other residual radioactivity to levels that are
as low as is reasonably achievable."
(c) "The implementing agencies nay make general determinations concerning
remedial actions under this Section that will apply to all locations with
specified characteristics, or they may make a determination for a
specific location, the Department of Energy shall inform any private
owners and occupants of the affected location ind solicit their comments.
The Department of Energy shall provide any such comments to the other -^
implementing agencies [and] shall also periodically inform the
Environmental Protection Agency of both general and individual
determination under the provisions of this section."
HOT SPOT CRITERIA
As of 19 October 1987. the Department of Energy started applying the hot-spot
guideline for clean-up of vicinity properties as outlined by the U.S.
Department of Energy Guidelines for Residual Radioactive Material at Formerly
Utilized Sites Remedial Action Program and Remote Surplus Facilities
.Yanagenent Program Sites ["evasion 2 March 1287]. These guidelines rend as
fallows:
1. The method for doterainin; Hot Spot Limits, which is based on the 100
mrem/year Dose Liait. as described in the Formerly. Utilized Surplus Remedial
Action Program procedures manual, shall still be applicable for determining
allowable concentrations of radior.uclidcs under i'nhomoseneous soil
contamination conditions. However, the following approach, more appropriate
for field applications, may be used in place of the Dose Limit method and is
recommended for general applications.
2. For the alternative approach, the basic Hot Spot Limits will be calculated
for each specific site as follows:
Shg Sg " (100 a2/A)1/2
where. Shg » the Hot Spot Limit (pCi/gram)
Sg « the Authorized Limit for a speeifie site
(N'ots: See 192.12 Standards, for limits Xonticello
background averages 2 pCi/gram)
A * the area of the hot spot in square meters
(100/A)1-'2 is the hot spot multiplication factor.
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3. The Units shall be applied In the field over ranees of area with the
factors being constant over a given area. The ranees and factors to be used
arc Indicated S»low:
Range Factor (Multiple of Authorized LimiO
<1 a2 '. 10*
1 - <3 »2 6
3 - <10 a2 3
10 - 23 m2 ' 2
Areas less than one square meter are to be averaged over the one square
meter and that average shall not exceed ten tlaes the Authorized Limit.
4. The average Authorized Limit is considered adequate to protect the public
for areas larger than 25 square neters; hence, no special Hot Spot Limits are
required for areas larger than 25 square meters.
5. Averaging of hot spots less than or equal to 25 square meters shall be
done only over the local hot spot area.
\
6. Every reasonable effort shall be made to identify and remove any source,
which has a concentration of a radionuclide exceeding 30 times the Authorized
Limit irrespective .of area.
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