United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/ROfl-89/026
September 1989 ?,
SEPA
Superfund
Record of Decision
Woodbury Chemical, CO
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R08-89/026
1 ftodptonr* AccMckm He.
4. Tlflo md SuMM
SUPERFUND RECORD OF DECISION
Woodbury Chemical, CO
Second Remedial Action - Final
i. Report DM*
09/29/89
7. Autfior(i)
i. Performing Orgmixrion Ropt No.
». Piffonnlng OrgtlnlnBon Nom» «nd »ddmi
ia Pro|»etfTi«k/Woi* Ui* No.
11. Comncl(C) or GnnUG) No.
(C)
12. Sponsoring Orgmtodon NM* end Ad*iu
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
IX Type o< Report ft Period Covered
800/000
14.
IS. Supplementary Noleo
18. Abstract (Umrfc 200 wonte)
The Woodbury Chemical site is in Commerce City, a northern suburb of Denver, Colorado,
and neighbors a primarily industrial area which includes automobile salvage yards and a
petroleum refinery. From the 1950s to 1971, the Woodbury Chemical Company operated a
pesticide formulation facility which was destroyed by fire in 1965 but was subsequently
rebuilt. Contaminated rubble and debris from the fire were disposed of on a 2.2-acre
vacant lot east of the Woodbury facility. During a 1985 remedial investigation of the
2.2-acre lot, EPA identified high levels of pesticides and metals in surface and
subsurface soils. Although EPA issued a Record of Decision (ROD) later that year, site
cleanup was delayed due to the discovery of significant additional contamination at the
Woodbury facility and adjacent properties to the west and north of the facility. As a
result of the discovery of additional contamination, EPA determined it would be more
cost effective to simultaneously implement the cleanup activities at the 2.2-acre lot,
the Woodbury chemical facility, and adjacent properties. The selected remedial action
addressed in this ROD incorporates and builds upon the 1985 ROD. The primary
contaminants of concern affecting the soil are VOCs including PCE and TCE; other
organics including pesticides; and metals including arsenic. (See Attached Sheet)
17. Oocunwit Anrtyeto a. OnnMun
Record of Decision - Woodbury Chemical, CO
Second Remedial Action - Final
Contaminated Medium: soil
Key Contaminants: VOCs (PCE, TCE), other organics (pesticides), metals (arsenic)
^ !L AvriUbilty SUMmM
111 aMurHyCtewflN>Riport)
None
20. 9MurttyCtaM(TM*Pig*)
None
21. No. at P*OM
47
22. PHe*
(SM ANSI-Z39.18)
So Jrwtructfon* on A*«m»
TJPnOHSE TORM 272 (4-77)
(Fonmrly NT1S-3S)
DoportRMiM ol Convrwf cv
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A GPO: 1983 0 - 381-526(8393) OPTIONAL FORM 272 BACK
(4-77)
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EPA/ROD/R08-89/026
SUPERFUND RECORD OF DECISION
Woodbury Chemical, CO
Second Remedial Action - Final
16. Abstract (continued)
The selected remedial action for this site includes excavation and offsite incineration
of 850 cubic yards of highly-contaminated soil followed by offsite disposal; excavation
and offsite disposal of 11,520 cubic yards of less-contaminated soil at a RCRA-permitted
landfill; and backfilling and revegetation of the excavated area. The estimated present
worth cost for this remedial action is $6,962,600 which includes annual OSM costs of
$31,400.
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RECORD OF DECISION
WOODBURY CHEMICAL COMPANY SUPERFUND SITE
DECLARATION STATEMENT
SITE NAME AND LOCATION
Woodbury Chemical Company Site
Commerce City, Colorado
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Woodbury Chemical Company Site in Commerce City, Colorado.
Developed in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act of
1986 (SARA) and the National Contingency Plan (NCP; 40 CFR Part
300), this document incorporates and builds upon the Record of
Decision (ROD) issued for this site in July 1985.
This decision document explains the factual and legal basis for
selecting the remedy for this site. The information supporting
this remedial action decision is contained in the administrative
record for this site and is summarized in the attached decision
summary. This decision is based on the administrative record for
this site.
The State of Colorado concurs with 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 ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
EPA anticipates that the selected remedy described in this ROD
represents the final, and only, remedial action for the Woodbury
site. The remedial action addresses environmental concerns
presented by soils contaminated with pesticides, volatile organic
chemicals, and metals, and will eliminate the principal threat of
contaminated soil to ground water, on-site workers, and the
surrounding residents.
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Th« major components of the selected remedy include:
o Excavation and treatment, via off-site incineration, of
approximately 2050 cubic yards of soil heavily
contaminated with pesticides and disposal of the
incinerated soil in a RCRA Subtitle C landfill;
o Excavation of approximately 10,635 cubic yards of soil
with low levels of pesticide contamination, volatile
organic chemicals, and metals, and transport to an off-
site RCRA Subtitle C landfill for disposal; and
o Backfilling of excavated areas with clean soil and
revegetation.
The selected remedy will protect ground water resources and
eliminate direct contact risks through the removal and subsequent
destruction or disposal of contaminated soils. Incineration will
be used to destroy highly contaminated soils; thus, ensuring the
long-term protection of the public and the environment through
destruction or containment of toxic chemicals.
Due to the identification of substantial contamination cf the
ground water aquifer upgradient to the Woodbury site, it is
recommended that further investigation be conducted to isolate
the source of this contamination. Since any potential ground
water contamination resulting from the Woodbury site will be
eliminated upon implementation of the selected remedy, it is not
anticipated that the recommended investigation or any remediation
of the source of upgradient contamination to comprise additional
action(s) for the Woodbury site.
DECLARATION OF STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, and complies with Federal and State requirements
that are legally applicable or relevant and appropriate to the
remedial action, and is cost effective. This remedy utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable for this site, and it satisfies the
statutory preference for remedies that employ treatment that
reduce toxicity, mobility, or volume as their principal element.
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Because this remedy will not result in hazardous substances
remaining on-site above health-based levels, the five year review
will not apply to this action. y review
James J£^?fierer, Regional Administrator
Environmental Protection Agency, Region Vlll
Date
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RECORD OF DECISION - ATTACHMENT A
WOODBURY CHEMICAL COMPANY SUPERFUND SITE
DECISION SUMMARY
TABLE OF CONTENTS
CHAPTER PAGE
I. Site Name, Location and Description i
II. Site History and Enforcement Activities 3
III. Highlights of Community Participation 6
IV. Scope and Role of Operable Unit Response
Action
V. Site Characteristics 8
VI. Summary of Site Risks 9
VII. Description of Alternatives 12
VIII. Summary of Comparative Analysis of 16
Alternatives
:x. The Selected Remedy 34
X. Statutory Determinations 35
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RECORD OF DECISION - ATTACHMENT A
WOODBURY CHEMICAL COMPANY SUPERFUND SITE
DECISION SUMMARY
I. Site Name, Location, and Description
The Woodbury Chemical Company Superfund Site is located in
Commerce City, a northern suburb of Denver, Colorado (Figure 1).
The primary concerns for potential harm to human health and the
environment presented by the site are exposure to contaminated
soils and sediments, and potential ingestion of drinking water
from the contaminated ground water aquifer below the site.
Contaminants in the soil and sediment include pesticides, metals,
and organics. Contamination of the ground water is primarily
volatile organics.
The site is surrounded by light and heavy industry including
automobile salvage yards and a petroleum refinery. The site is
approximately bounded on the north by the Colorado and Eastern
Railroad, the Union Pacific Railroad track to the west, and the
Adams-and-Denver County line (54th Avenue) to the south. The
eastern boundary is approximated by an extension of Harrison
Street in a northerly direction.
The nearest residential area to the Woodbury site is a mobile
home park approximately one-third mile to the southwest. The
residential and commercial population within a one-mile radius of
the site numbers approximately 3,000 persons. The majority of
this population lives in the residential areas to the southwest
of the site.
The eastern portion of the Woodbury site, owned by the Colorado
and Eastern Railroad Company (CERC), is a relatively flat, vacant
lot approximately 600 feet long by 175 feet wide (2.2 acres).
This area contains a number of rubble piles approximately two
feet high that are composed of contaminated debris from the 1965
Woodbury Chemical Company fire. Several drainage channels cross
this lot and conduct intermittent stormwater runoff onto the
remainder of the site to the north and west. Vegetation,
primarily grasses and weeds, covers the lot, except in areas on
rubble piles and in the drainage channels. Used tires and other
debris litter the southern border of the lot adjacent to 54th
Avenue.
The middle portion of the site consists of the original Woodbury
property, currently owned by the McKesson Corporation (McKesson),
which is approximately 360 ftet by 165 feet. The main building,
a one-story masonry block building approximately 210 feet by 50
feet, is situated near the northeast corner of the property. A
second, one-story, corrugated-metal building, approximately 60
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R«Unllon
Pond
EXPLANATION
Figure I - SITE PUN STUDT AREA
Wondbtiry Chnnlcal Conpnny Site
Connerce CHy, Colorado
Source: lirnft Fenslblllty Study; IIIJ\, 1989.
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ATTACHMENT A
DECISION SUMMARY
feet by 60 feet is located near the southwest corner of the
property. The area south and east of the two buildings is paved,
except for areas in the northeast and southwest corners. Three
empty bulJc-storage tanks, of which previous contents are unknown,
remain on the west side of the McKesson property. In previous
years, -as many as three tanks were situated on the east side of
the main building and eight tanks on the west side.
The western portion of the site, also owned by CERC, encompasses
a relatively flat, vacant lot with dimensions of approximately
1000 feet by 200 feet. This portion of the CERC property
contains several debris piles and is littered with a substantial
amount of scattered debris, including furniture and household
refuse, automobile parts, scrap lumber, brush, tree stumps,
broken concrete, and 55-gallon drums. Vegetation consists of
low-lying ground cover, primarily weeds.
A drainage ditch runs northeast to southwest across the northern
and central portions of the site. When water is present in the
ditch, the direction of flow is from east to west. The ditch is
approximately six feet deep at the northern boundary of the
Woodbury site and is approximately 15 feet deep near the
southwest corner of the site. A berm of soil, generally about
five feet high, runs along the south side of the drainage ditch.
The Woodbury site is underlain by the Piney Creek alluvium, which
consists of highly calcareous, well-stratified clay, silt, and
sand containing thin gravel lenses. Active ground water flow
beneath the site occurs within the unconfined alluvial aquifer,
which is' underlain by Denver Formation bedrock. Water level
measurements indicate that the depth to ground water varies from
24 feet to 27 feet across the site. Ground water flow is
northwest towards the South Platte River.
Water users within the study area are served by the South Adams
County Water and Sanitation District (SACWSD) or the Denver Water
Department (DWD). No wells exist on the site and there is no
evidence that wells exist in the ground water aquifer
downgradient to the site or that the aquifer is being used for
drinking water.
II. Site History and Enforcement Activities .
The Woodbury Chemical Company operated a pesticide formulation
facility from the late 1950s to 1971 at 5400 Monroe Street in
Commerce City, Colorado. On May 10, 1965, the main building of
the Woodbury Chemical Company was destroyed by fire. Shortly
3
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ATTACHMENT A
DECISION SUMMARY
thereafter, the Woodbury Chemical Company constructed a new
building at the. original building location. Contaminated rubble
and debris from the Woodbury fire were deposited in various
locations at the site including the vacant 2.2-acre lot directly
east of the Woodbury facility.
The Woodbury site was added to the National Priorities List (NPL)
of hazardous waste sites in September 1983. In a September 1983
emergency-removal action, EPA installed a chain-link fence around
the vacant lot to limit access to the site and reduce the
potential for public exposure to contamination.
EPA completed a remedial investigation and feasibility study
(RI/FS) for the First Study Area, which consists of the vacant
2.2-acre lot, in February 1985. High levels of pesticides
(including aldrin, chlordane, DDT, and toxaphene) and metals were
found in the rubble piles on the soil surface with lower
concentrations found in the underlying contaminated soil areas.
EPA issued a Record of Decision (ROD) in July 1985, which
selected a complete cleanup remedy for contamination at the
2.2-acre lot. The remedy involved excavation and off-site
transport, off-site incineration, and off-site ash disposal of
highly contaminated rubble at a total pesticide concentration
above 100 parts per million (ppm) and off-site transport and off-
site disposal of the remaining contaminated soils to a cleanup
level of 3 ppm total pesticide concentrations. The excavated
areas were to be backfilled with clean, impermeable fill
material, regraded, and revegetated.
During pre-design studies, EPA discovered significant additional
contamination west of the 2.2-acre lot. The area of additional
contamination included the original Woodbury Chemical Company
property and vacant property located west and north of the
Woodbury facility. The decision to expand the RI/FS to these
additional areas was formalized in the September 1986 ROD
amendment. The amendment designated off-site incineration of the
highly contaminated rubble areas of the 2.2-acre lot as Operable
Unit I (GUI). The remaining soils with contaminants above 3 ppm
total pesticide concentration and soil? :n areas tc the vest were
designated as OUII.
Additionally, an engineer's ccst estimate developed during pre-
design studies exceeded the +50/-30 standard established by EPA
guidance for cost estimates to implement remedial action. The
pre-design studies also projected that contaminated soils within
OUII would double the original estimated volume of contaminated
soils. In consideration of these factors, EPA determined that it
would be more cost-effective if remedial action for OUI was
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ATTACHMENT A
DECISION SUMMARY
delayed for simultaneous implementation with the remedial action
for OUII. EPA refers to OUI and OUII as the First Study Area and
Second Study Area, respectively.
The remedial investigation for the Second Study Area was
completed in August 1989. The feasibility study was completed in
September 1989.
Communication with potentially responsible parties (PRPs) for the
Woodbury site was initiated by EPA through general notice letters
to the following:
i. Ross Woodbury, President, Woodbury Industries, Inc.
(10/26/82);
2. Chicago, Rock Island and Pacific Railroad (10/26/82);
3.- The Dow Chemical Company (2/i7'83);
4. Farmland Industries, Inc. (2/17/83);
5. Colorado and Eastern Railroad Company (8/26/85); and
6. McKesson Chemical Company (8/5/86).
These general notice letters also contained Requests for
Information pursuant to section I04(e) of the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA).
EPA issued Special Notice letters to PRPs in June 1987, pursuant
to section I22(e) of CERCLA. The PRPs were provided with an
opportunity to negotiate with EPA to conduct the RI/FS for the
Second Study Area. Additional Requests for Information pursuant
to section I04(e) of 'CERCLA was included in these letters.
Special Notice letters were sent to the following PRPs:
i. Chicago Pacific Corporation;
2. Colorado and Eastern P.aiirra::
3. Farmland Industries, Inc.;
4. Dow Chemical Company; and
5. McKesson Corporation.
McKesson presented EPA with a good faith offer to conduct the
RI/FS during the Special Notice period. EPA negotiated an
5.
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ATTACHMENT A
DECISION SUMMARY
Administrative Order on Consent (Order) with McKesson (docket
number CERCLA-VIII-88-4 ) to conduct the RI/FS. The Order was
signed by both parties on December 21, 1987. McKesson has
conducted the RI/FS and reimbursed EPA for a portion of its
oversight costs under the Order.
EPA again initiated contact with several PRPs in May 1989. An
additional round of i04(e) requests was sent to the following
PRPs:
i. Vera Woodbury;
2. H. A. Woodbury;
3. Herb Woodbury;
4. Reid Ames Woodbury;
5. Ross Woodbury;
6. Farmland Industries, Inc.; and
7. The Dow Chemical Company.
In late July 1989, EPA first learned that the Maytag Corporation
had acquired Chicago Pacific. Demand letters were sent on
September 12, 1989, to the Colorado and Eastern Railroad,
Farmland Industries, Inc., the McKesson Corporation, and the
Maytag Corporation for reimbursement of $936,208.07 in past costs
incurred by EPA.
III. Highlights of Community Participation
All requirements for public participation as specified in Section
113(kX2)(B)(i-v) of CERCLA and the National Contingency Plan
were satisfied during the remedial action process.
Community relations activities for r.h
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ATTACHMENT A
DECISION SUMMARY
In early August 1989, EPA distributed an information notice to
residents in the vicinity of Woodbury. The poster, published ir
English and Spanish, addressed concerns about potential exposure
of local residents to contaminants.
In August 1989, the RI and the draft FS were completed and an
initial remedial alternative (the Proposed Plan) was chosen. EPA
took several measures to announce the Proposed Plan and to seek
comments and questions from the public, as listed below.
i. Copies of the Proposed Plan, and the remedial
investigation and feasibility study reports were made
available to the public in the Adams County Public
Library, the Colorado Department of Health, and EPA' s
own Records Center in downtown Denver.
2. EPA mailed a third fact sheet, which described the
Proposed Plan as well as six other remedial alternatives
that had been evaluated. This fact sheet was also hand-
delivered to residents in areas adjacent to the site. A
Spanish version of the fact sheet was made available to
interested members of the community.
3. EPA announced a public comment period during which ail
interested persons were invited to submit comments and
questions. The comment period was held from
September i, 1989, to September 22, 1989.
4. EPA conducted a public meeting on September 15, 1989, to
describe the results of the RI/FS, present the Proposed
Plan, and answer questions from the public.
5. EPA published a press release and a public notice in the'
Commerce City newspaper, The Commerce City Sentinel,
announcing all of the activities listed above.
EPA' s response to written comments received during the
public comment period and oral comments made at the community
meetinc are addressed in the F.9spcr.s:v5ness Surrary, an
attachment to this ROD.
IV. Scope and Role of Operable Unit Response Action
During the course of EPA's investigative studies, a phased
approach for study of the site was established. An RI/FS for the
First Study Area was completed in February 1985. Remedial action
of the First Study Area was delayed for simultaneous
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ATTACHMENT A
DECISION SUMMARY
implementation with the remedial action for the Second Study
Area. The current remedial investigation evaluates sampling
efforts specific to the Second Study Area and was completed in
August 1989.
Due to the advancement of innovative technologies since the
completion of the 1985 RI/FS for the First Study Area, the
current feasibility study has incorporated consideration of the
hazardous substances from the First Study Area as well as
contaminants from the S-Tond Study Area in the development of
alternatives for the si.i. After evaluating the individual risk
assessments developed for both study areas, sitewide and
contaminant-specific cleanup levels were developed for ten
indicator chemicals.
The remedy selected for the site is set forth in this ROD which
incorporates and .builds upon the 1985 ROD for the First Study
Area, as amended. This will ensure that the selected remedy for
the Woodbury site fulfills all current requirements for the
protection of human health and the environment, and other
evaluation criteria, including requirements from the Superfund
Amendments and Reauthcnzation Act of 1986 which was enacted
after the 1985 ROD for the First Study Area was issued.
This response action will prevent current and future exposure to
the contaminated soils and reduce contaminant migration from
these soils to the ground water. EPA does not anticipate that
future response action will be required fcr this site.
v. Site Characteristics
The predominant activity at the site was the formulation of
pesticides during the 1950s and 1960s. The contamination at the
site results from residual pesticides and related metals and
solvents contained within rubble and debris from the 1965
Woodbury Company fire. Investigations at the site indicate that
pesticide contamination occurs in concentrated areas associated
with existing rubble piles and pcssirly rtr.er past activities.
Surface water runoff at the sit*, v-;:- r'ir.s from *as*. to west
across the site, tends to carry ct-: ?.-<:r,2: icn frrm the rubble
piles onto the properties located tr i^ • est. Other site
activities typical of a chemical-handling facility also are
probable contributors to the contarrinatirn of soils en the
McKesson property. For example, spills during packaging, loading
and unloading, etc., may account for "hot spots" noted during the
investigation of the Second Study Area.
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ATTACHMENT A
DECISION SUMMARY
Other unidentified activities may also have contributed to the
contamination found at the site. A significant amount of
unauthorized dumping of trash and waste materials has been
observed at the site.
Present land use near the site includes a substantial nur.oer of
industries which use solvents. Evaluation of ground water
samples indicates a general area of contamination near the site.
Ground water sampling results indicate that volatile organic
compound (VOC) concentrations in upgradient off-site wells were
the same or higher than those detected in on-site wells. In
downgradient off-site wells, the VOC concentrations were
essentially the same as the concentrations detected in the on-
site wells, indicating that VOC contamination of the ground water
may result from upgradient, off-site sources. It is possible,
however, that solvent handling and disposal practices during
previous operations at the Woodbury.site could have contributed
significant amounts of contamination.
VI. Summary of Site Risks
CERCLA mandates that EPA protect human health and the environment
from current and potential exposure to hazardous substances at
the site. Therefore, EPA conducted risk assessments to evaluate
the risks posed by the presence of contaminants at the site. The
risk assessments identified a number of chemical compounds ;hat,
because of health risks, are chemicals of concern for the site.
The risk assessments performed for the site concluded that the
exposure scenarios presenting the highest risk include direct
contact with soils (ingestion and dermal absorption) and
potential ingestion of contaminated ground water. Other exposure
scenarios such as inhalation of contaminated dust or chemical
vapors volatilized from soils were considered to present lower
risks.
A number of exposure pathways potentially exist at this site.
These pathways include human and environmental populations
located on-site and off-site. Pathways involving c--site
populations appear most likely to lead tr unacceptacle exposure
levels. Those involving high levels of human activity or the
potential fo: human activity in areas where environmental-media
samples analyzed had the highest levels of indicator chemicals
are as f- '.lows :
o Industrial workers and maintenance/security workers in
the northeast portion of the site.
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ATTACHMENT A
DECISION SUMMARY
o Industrial workers and maintenance/security workers in
the southern portion of the site.
o Residents living near the site.
Of the contaminants found at the site, ten toxic substances
within the soil are considered to be chemicals of concern. These
chemicals fall into three categories: metals (arsenic and zinc);
pesticides (aldrin, chlordane, 4,4-DDT, dieldrin, and toxaphene );
and organics (PCDD, tetrachloroethene, and trichloroethene). A
list of these chemicals, maximum analyzed soil concentrations,
and cleanup levels are presented in Table 1.
Concentration levels of these chemicals in the soil and sediment
are associated with a maximum excess lifetime cancer risk of
2.0 E-3. This risk is a probability that is expressed in
scientific notation. An excess lifetime cancer risk of 2.0 E-3
means that if no cleanup action is taken by EPA, two additional
persons out of 1,000 has a chance of contracting cancer as a
result of exposure to the contaminated soil.
EPA has determined that cleanup of the site should reduce the
excess lifetime cancer risk posed by the site to 1.0 E-6. This
cleanup target would reduce the probability of contracting cancer
as a result of exposure to the contaminants in the soil to one
additional person in 1,000,000. Because there are no Federal or
s:;-.5 cleanup standards for contamination in soil, this cleanup
ta:. -?t was established for this site as part of the RI/FS. The
clc-r.up. target was established to reduce direct contact exposure
to a protective level, as well as to ensure that the migration of
chemicals to the ground water is minimized.
No threatened cr endangered species are known to inhabit the area
on or near the Woodbury site. No environmental populations of
recreational or commercial significance are believed to be at
risk at or near the site.
Given the proximity of the resi'tents tr *h« site, the industrial
nature of the area, and the general contamination of the ground
water aquifer beneath the site, th? risks from current and
potential exposure to contaminated media from this site are
unacceptable. Since the remedy selected will eliminate any
potential contamination resulting from the Woodbury site, EPA
does not anticipate that future response action will be required
for this site.
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ATTACHMENT A
DECISION SUMMARY
TABLE 1
CHEMICALS OF CONCERN, MAXIMUM SOIL CONCENTRATIONS
AND ACTION LEVELS FOR WOODBURY
Chemical of
Concern
Aldrin
Arsenic
Chlordane
4,4-DDT
Dieldrin
PCDD
Tetrachlorethene
Toxaphene
Trichloroethene
Zinc
Maximum Soil
Concentration3
1
1
7
2
8
2
1
7
3
5
.2E + 2
.2E+1
.7E+3
.OE + 3
. 1E+2
.8E-3
.5E-1
. 1E+3
.3E-1
.8E+3
Action
2.
5-
3.
1 .
3.
3.
1 .
5.
5.
60
Level3
5E-i
10
3E+0
2E+1
OE-l
OE-5b
9E*0
7E.O
2E-1
-80
Reference: RI Report, HLA 1989
a
All concentrations in milligrams per kilogram or parts per
million (ppm).
b
Actior level determined for 2,3,7,8-isomer of PCDD.
1 1
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ATTACHMENT A
DECISION SUMMARY
VII. Description of Alternatives
The detailed analysis of remedial technologies, presented in the
FS report, resulted in the development of seven alternatives for
site remediation. For all cases, except the No Action
alternative, it may be necessary to demolish and dispose of the
two buildings located on-site, including their foundations, prior
to remediation of the site. Other prerequisite activities
include proper disposition of the concrete slab, removal of three
empty storage tanks, and temporary rerouting of utilities located
along 54th Avenue.
ALTERNATIVE NO. 1 - NO ACTION
The No Action alternative would consist of no remedial
activities. The soil would remain in its current condition.
Observed drainage paths, exposure points, and ground water would
be monitored to evaluate chemical migration. A public health and
environmental evaluation would be conducted every five'years.
For purposes of cost comparison, monitoring would be assumed to
continue for a 30-year period, which is the design life for an
EPA-funded remedial action.
ALTERNATIVE NO. 3 - CLAY CAP, REGRADE, AND REVEGETATE
Approximately 3350 cubic yards (cy) of soil containing indicator
chemicals above proposed EPA action levels would be excavated
from the following areas:
Slopes and drainage ditches on the western and northern
portions of the site, approximately 2000 cy, and
Soil and rubble from the First Study Area,
approximately 1350 cy.
The soil would be consolidated and compacted on the site. Soil
containing the 2,3,7,8-isomer of polychlorinated dibenzo-p-
dioxin (PCDD), if encountered, would be incinerated off-site.
The site would be graded to facilitate proper drainage, clean
fill would b« placed in the excavated portions of the site, and
the cap would be vegetated. A cap would be constructed over the
portion of the site that contains indicator chemicals. The
concrete-paving slab would remain in place. The perimeter of the
cap would extend a minimum of 10 feet beyond the area of affected
soil.
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DECISION SUMMARY
The four-acre cap would be constructed of the following layers,
in ascending order from the layer nearest the waste:
A clay layer 2 feet thick to provide long-term
minimization of precipitation infiltration;
A 30-mil polyvinyl chloride (PVC) membrane to reduce
infiltration;
A drainage layer of one foot of sand and one foot of
gravel, with PVC drainage tiles to collect
precipitation infiltration. Geotextile filter fabric
would be placed on top of the drainage tiles to prevent
clogging of the tiles;
A topsoil layer two feet thick to support vegetation;
and
A vegetation layer that provides ground cover to
minimize soil erosion. The vegetation procedure would
consist of seeding, fertilizing, and mulching.
Surface water and water from the drainage layer of the cap would
be collected in drainage swales located at the edge of the capped
area and would be conveyed to existing drainage areas to the
north and south. The cap would be vegetated to minimize erosion,
and the capped area would be fenced and posted with warning
signs. Deed restrictions would also be implemented.
The time required for implementation of this remedial action is.
estimated at 1-1/2 years. Approximately eight months would be
required for cap design and contractor selection. Construction
of the cap is estimated to take an additional year.
ALTERNATIVE NO. 4 - OFF-SITE INCINERATION, CLAY CAP, REGRADE. AND
REVEGETATE
Under this alternative, approximately 850 cy of buried debris and
associated soil exceeding the California List halogenated organic
compound (HOC) levels and soil containing the 2,3,7,8-isomer of
PCDD above EPA action levels (if encountered) would be excavated
from the site and transported to an off-site EPA-p«rmitted
incinerator for treatment and disposal. As with Alternative
No. 3, the affected soils above proposed EPA action levels on
slopes and in drainage ditches and rubble piles from the First
Study Area would be consolidated on the site. Fill would be
placed in the excavations, and a cap would be constructed on-
site.
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ATTACHMENT A
DECISION SUMMARY
The four-acre cap would be constructed of the following layers,
in ascending order from the layer nearest the waste:
A clay layer two feet thick to provide long-term
minimization of precipitation infiltration;
A 30-mil PVC membrane to reduce infiltration;
A drainage layer of one foot of sand and one foot of
gravel, with PVC drainage tiles to collect
precipitation infiltration. Geotextile filter fabric
would be placed on top of the drainage tiles to prevent
clogging of the tiles;
A topsoil layer two feet thick to support vegetation;
and
A vegetation layer that provides ground cover to
minimize soil erosion. The vegetation procedure would
consist of seeding, fertilizing, and mulching.
Surface water and water from the drainage layer of the cap would
be collected in drainage swales located at the edge of the capped
area and would be conveyed to existing drainage areas to the
north and south. The cap would be-vegetated to minimize erosion,
and the capped area would be fenced and posted with warning
signs. Deed restrictions would also be implemented.
The time required for implementation of this remedial action is
estimated at 1-1/2 years. Planning and engineering is
anticipated to take six months, with the excavation/incineration
portion of this alternative taking four months. The cap
construction is anticipated to require eight months to complete.
ALTERNATIVE NO. 8 - OFF-SITE INCINERATION, OFF-SITE LANDFILL,
REGRADE, AND REVEGETATE
Alternative No. 8 is an excavation and off-site disposal project
that involves incineration of all affected soils exceeding the
California List HOC levels and soil containing the 2,3,7,8-
isomer of PCDD above EPA action levels (if encountered). This
material would be transported to an off-site incineration
facility for treatment and disposal. This alternative also
involves excavation of affected soils between the action levels
and the HOC levels and transportation to an off-site Resource
Conservation and Recovery Act (RCRA) permitted landfill. The
volume of soil that would require incineration has been estimated
U
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ATTACHMENT A
DECISION SUMMARY
at 800 cy from the First Study Area and 50 cy from the Second
Study Area. The remaining 11,520 cy of soils rubble and paving
slab would be excavated and transported directly to an off-site
RCRA-permitted landfill. After all affected soil is removed, the
excavated area would be' backfilled with clean fill, compacted,
and vegetated.
Alternative No. 8 would require approximately 1-1/2 to 2 years to
implement, with the engineering design and contractor selection
estimated to take six months.
ALTERNATIVE NO. 9 - OFF-SITE INCINERATION, ON-5ITE LANDFILL,
REGRADE, AND REVEGETATE
Alternative No. 9 involves excavation of approximately 850 cy of
soil exceeding California List HOC levels and soil containing the
2,3,7,8-isomer of PCDD above EPA action levels (if encountered)
and transportation off-site for treatment and disposal. A
landfill cell, with an approximate capacity of 13,600 cy and
which would comply with Subtitle C of RCRA, would be constructed
within the site. The remaining soil and rubble above EPA action
levels would then be excavated and placed in the on-site
Subtitle C landfill. The excavated areas would be backfilled
with clean fill, compacted, and vegetated. Signs and fencing
would be placed around the site to restrict access. Deed
restrictions would be implemented to restrict future land use.
Construction of the landfill is anticipated to take approximately
1-1/2 years in addition to the 3 years required to complete the
design and contractor selection.
ALTERNATIVE NO. 10 - OFF-SITE INCINERATION, SOIL WASHING/
BIODEGRADATION. REGRADE. AND REVEGETATE
This alternative is a removal/treatment remedial action that
involves excavation of California List HOCs from the site and
soil containing the 2,3,7,8-isomer of PCDD above action levels
(if encountered) and transport to an off-site incinerator. The
concrete paving slab that covers the McKesson property would alsc
be excavated and shipped off-site to a RCRA-permitted land
disposal unit, if required. The soils remaining on the site
above the specified action limits would be excavated and treated
by a soil-washing process. The treated soils from this process
would be placed in an on-site landfill. Residuals from the soil-
washing process that do not meet specified action limits would be
incinerated or disposed in an off-site landfill.
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ATTACHMENT A
DECISION SUMMARY
The wash water generated from this process would be treated in a
fixed-film bioreactor or by activated carbon filters, and the
effluent would be discharged to a publicly owned treatment works
(POTW). The volume of soil from the site that would require
incineration is 850 cy. The volume of concrete and soil
residuals from the soil-washing process requiring off-site land
disposal is estimated to be 3060 cy/ and it is estimated that an
additional 1800 cy would not meet the soil-washing action limits.
The remaining 9460 cy of soils treated by the soil-washing
process would be placed in a landfill constructed on-site. After
all soils containing indicator chemicals above proposed EPA
action levels were removed or treated, the excavated area(s)
would be backfilled with clean fill, compacted, and revegetated.
The on-site landfill would be closed, and the site would be
vegetated.
The soil-washing process was unable to attain health-based action
levels during treatability studies which used contaminated soil
samples from the site. Therefore, no time frame is given for
implementation of this alternative.
ALTERNATIVE NO. 11 - ON-SITE INCINERATION, ON-SITE LANDFILL,
REGRADE, AND REVEGETATE
All soil and rubble above action levels on-site would be treated
in an on-site mobile, continuous-bed combustor incinerator
equipped with flue-gas scrubbers and precipitators.
Approximately 12,320 cy of material would be treated. It is
anticipated that the incinerated soil would not be considered
hazardous under RCRA and would be disposed in a Subtitle D
landfill constructed on-site. The site would oe vegetated, and
deed restrictions would be implemented.
Implementation, which includes engineering design, contractor
selection, landfill construction, mobilization and
demobilization, and treatment, is estimated to take 3 to 4 years
to complete.
VIII. Summary of Comparative Analysis of Alternatives
This section presents a comparison of alternatives using nine
component criteria. These criteria, which are listed below, are
derived from requirements contained in Section 300.68(h)(2) of
the National Contingency Plan and CERCLA sections i2i(a) and ( b.'.
1 . Protection of human health and the environment;
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ATTACHMENT A
DECISION SUMMARY
2. Compliance with ARARs;
3. Reduction of toxicity, mobility, or volume;
4. Long-term effectiveness and permanence;
5. Short-term effectiveness;
6. Implementability;
7. Cost;
8. State acceptance; and
9. Community acceptance.
ALTERNATIVE NO. 1 - NO ACTION
1 . Protection of Human Health and the Environment
Under the No Action alternative, no remediation would take place
and, based on the characteristics of the contaminants present,
the risks to human health and the environment described in the
endangerment assessment would not change. Current EPA guidance
requires that a public health and en-vironmental evaluation be
conducted every five years for any alternatives in which toxic
chemicals remain on-site. The five-year public health and
envir -imental evaluations would allow assessment of whether
future action or remediation would be required.
2. Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
There are no chemical-specific or action-specific ARARs
pertaining to a No Action alternative. However, action levels
developed for the site would not be achieved.
3. Reduction of Toxicity, Mobility, or Volume
Under this alternative, no reduction of toxicity, mobility, or
volume would occur.
4. Long-term Effectiveness and Permanence
The results of long-term monitoring would determine how and when
the source chemicals may impact the surrounding community and
local workers. As time elapses, natural bacteriological
17
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ATTACHMENT A
DECISION SUMMARY
attenuation may lessen public exposure. Data from previous site
investigations indicate that this may already be happening;
however, the time required for the action levels to be achieved
under current conditions would be difficult to accurately
predict. Monitoring of the attenuation would be performed by
sampling observed drainage paths and ground water to assess the
concentrations of migrating contaminants. Because of the
uncertainties regarding natural attenuation, the No Action
alternative cannot be considered effective from a short-term
perspective and would not sufficiently reduce toxicity and volume
from a long-term perspective.
5. Short-term Effectiveness
Because no activities would take place other than periodic
monitoring, the No Action alternative would not result in any
short-term effectiveness.
6. Implementability
The No Action alternative is readily implementable. This
alternative would consist of annual monitoring and a public
health and environmental evaluation every 5 years. Sediment
and/or soil sampling would be conducted in observed drainage
paths, and ground-water sampling would be conducted utilizing
existing wells.
Monitoring would require that a team of two people spend
approximately two days each year collecting samples and
submitting them for laboratory analysis. Analytical results
would be evaluated and reported. The five year review would
assess changes at the site that may affect the risks posed by the
presence of contaminants in the soil.
7. Cost
Minimal capital costs are anticipated for the No Action
alternative. Operation and maintenance (O&M) costs of
approximately $147,900 per year are proiected for sampling and
inspection. A public health and environmental evaluation every
five years would cost approximately $37,000. Assuming a
monitoring period of 30 years, this equates to a present-worth
cost for the No Action alternative of Si,636,TOO.
8. State Acceptance
No comments were received from the State of Colorado (State)
regarding this alternative. Since the State has concurred on
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ATTACHMENT A
DECISION SUMMARY
EPA's preferred alternative, it is assumed that the No Action
alternative is not acceptable to the State.
9. Community Acceptance
Comments received during the public comment period indicate that
the community is opposed to on-site containment of the
contaminated soil. Therefore, this alternative is not considered
to be acceptable to the public.
ALTERNATIVE NO. 3 - CLAY CAP, REGRADE, AND REVEGETATE
1 . Protection of Human Health and the Environment
The cap would protect human health .to the extent that it
eliminates exposure via dermal contact and ingestion. It reduces
the potential for soil contaminants to leach into the vadose
zone. The proposed periodic inspections would identify potential
problems with burrowing animals, and corrective actions could
then take place. The requisite 5-year public health and
environmental evaluations would continually evaluate risks and
any necessary actions could be taken.
2. Compliance with ARARs
This alternative is considered on-site containment. The cap
would comply with relevant and appropriate RCRA requirements by
employing a three-layer design.
ARARs for this alternative apply to excavation and consolidation
of the soil. During implementation of this alternative, OSHA
health and safety regulations would be followed by workers during
all phases of the site work. Federal Clean Air Act (CAA)
National Air Quality standards and State of Colorado Air Quality
regulations are applicable in controlling particulate emissions
and vapors during excavation and consolidation activities. The
cap would b« designed to meet RCRA technology standards and would
meet substantive aspects of RCRA Closure and Post-Closure
requirements for a land disposal facility.
3. Reduction of Toxicity, Mobility, or Volume
Capping would not reduce the toxicity or volume of the affected
soils at the site. However, the toxic effects of the afi^cted
soils would be reduced by the elimination of the main exposure
pathways.
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ATTACHMENT A
DECISION SUMMARY
A cap reduces the mobility of affected media and significantly
reduces the risks of dermal contact and incidental ingestion of
soil particles. Capping also reduces the potential for soil
contaminants leaching into the vadose zone by providing an
impermeable layer over the affected soil, which should prevent
surface water from infiltrating below the cap.
4. Long-term Effectiveness and Permanence
Capping would be effective in the long term in eliminating direct
contact and inhalation risks from the affected soil. The capping
alternative would be less effective than a removal or treatment
alternative because the physical or chemical characteristics of
the affected soil would not be changed. A cap may be subject to
failure as a result of erosion or settlement. A monitoring
program must be established to inspect the cap for signs of
erosion, subsidence, consolidation, or settlement. With a
program of continued monitoring and maintenance, this alternative
would be effective in indefinitely containing the affected soil.
5. Short-term Effectiveness
Capping results in the immediate effect of reducing hazards
related to direct contact and migration of contaminants into the
ground water. This alternative requires less construction time
than the other candidate alternatives, which involve either
complete excavation of total affected soil (soil with indicator
chemicals above EPA action levels) or treatment of all affected
soil. Risks of exposure during implementation would, therefore,
be significantly less for cap construction than for other
alternatives.
The primary potential risk during construction would be from the
generation of dust during excavation, transport, and material
handling. During construction activities, the air quality on and
near the site would be monitored to assess resulting potential
health risks due to the release of volatile organic compounds
(VQCs) or dust containing pesticides.
6. Implementability
This alternative is easily implementable with conventional
equipment. The cap for the Woodbury site would be constructed
after the soil containing indicator chemicals above proposed EPA
action levels had been excavated from the site. Approximately
eight months would be required for cap design and contractor
selection. Construction of the cap is estimated to take an
additional year. The entire site must be vegetated immediately
20
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ATTACHMENT A
DECISION SUMMARY
following final grading to maintain the integrity of the cap and
prevent erosion damage on excavated areas. Construction of the
cap would not be possible during the winter months. Seeding is
usually most effective in late summer or early fall.
7. Cost
The estimated present-worth cost to construct a cap at this site
is approximately S3,965,100. This cost includes capital, O&M,
and periodic monitoring. Capital costs are estimated to be
$2,927,400, and annual operating costs are expected to be
$33,000, plus $37,000 for a public health and environmental
evaluation every 5 years.
8. State Acceptance
No comments were received from the State regarding this
alternative. Since the State has concurred on EPA's preferred
alternative, it is assumed that Alternative No. 3 is not
acceptable to the State.
9. Community Acceptance
Comments received during the public comment period indicate that
the community is opposed to on-site containment of the
contaminated soil. Therefore, this alternative is not considered
to be acceptable to the public.
ALTERNATIVE NO. 4 - OFF-SITE INCINERATION, CLAY CAP, REGRADE,
AND REVEGETATE
1. Protection of Human Health and the Environment
The cap would protect human health to the extent that it
eliminates exposure via direct contact and ingestion. It reduces
the potential for soil contaminants to leach into the vadose
zone. The proposed periodic inspections would identify potential
problems with burrowing animals, and corrective actions could
then take place. The requisite 5-year public health and
environmental evaluations would continually evaluate risks and
any necessary actions could be taken.
2. Compliance with ARARs
ARARs for this alternative apply to excavation, consolidation,
and transportation of the affected soil. During implementation
of this alternative, OSHA health and safety regulations would be
21
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ATTACHMENT A
DECISION SUMMARY
followed by workers during all phases of the site work. Federal
CAA National Air Quality standards and State of Colorado Air
Quality regulations are applicable in controlling vapor and
particulate emissions during excavation and consolidation
activities.
For off-site incineration, additional requirements must be met,
as off-site transportation involves waste notification,
manifesting, pre-transport requirements, and transportation
restrictions. Waste notification is required under 6 CCR 1007-3,
Part 99, for generation of transport of a hazardous waste.
Because affected soils would be excavated prior to transport to
an off-site facility, a Notification of Hazardous Waste Activity
form (Form 8700-12) must be completed, indicating the type of
activities to be conducted. Waste manifests would also be
required under 6 CCR-l007-3, Part 262, Subpart B, indicating the
content of the waste, mode of transport, and destined facility.
All waste must be packaged and transported in accordance with
U.S. Department of Transportation (DOT) regulations, in addition
to requirements for the facility and transporter.
The cap would be designed to meet RCRA technology standards and
would meet substantive aspects of RCRA Closure and Post-Closure
requirements for a land disposal facility. HOCs would be
excavated and treated by incineration with disposal of the
incinerated soil in compliance with the incinerator operation
permit requirements.
3. Reduction of Toxicity, Mobility, or Volume
Off-site incineration effectively reduces the toxicity of the
affected soil and would reduce the quantity of the affected soil
at the site.
Capping would not reduce the toxicity or volume of the affected
soils at the site. However, the toxic effects of the affected
soils would be reduced by the elimination of the main exposure
pathways.
A cap reduces the mobility of affected media and significantly
reduces the risks of dermal contact and incidental ingestion of
soil particles. Capping also reduces the potential for soil
conta-:nants leaching into the vadose zone by providing an
impermeable layer over the affected soil, which should prevent
surface water from infiltrating below the cap.
22
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ATTACHMENT A
DECISION SUMMARY
4. Long-term Effectiveness and Permanence
Incineration is effective in the long term in reducing the
toxicity of affected soil. Capping would be effective in the
long-term in eliminating direct contact and inhalation risks.
The capping alternative would be less effective than a removal or
treatment alternative because the physical or chemical
characteristics of the remaining affected soil would not be
changed. A cap may be subject to failure as a result of erosion
or settlement. A monitoring program must be established to
inspect the cap for signs of erosion, subsidence, consolidation,
or settlement. With a program of continued monitoring and
maintenance, 'his alternative would be effective in indefinitely
containing the contaminated soil.
5. Short-term Effectiveness
Capping crcd-c^s th = immediate effect of reducing the hazards
related to direct contact and migration of contaminants into the
vadose zone. This alternative requires less construction time
than other alternatives that involve complete excavation and/or
treatment c: affected soil above EPA action levels. Risks of
exposure during implementation would, therefore, be significantly
less than for other.alternatives that require excavation and/or
treatment of all affected soil.above EPA action levels. Site
construction personnel would be at risk during excavation of the
soils and transport to the consolidation areas. Off-site
populations would be exposed to some potential risk during the
transport of soil to the incinerator.
The primary potential risk during construction would be from the
generation of dust during excavation, transport, and material
r. = r,dl: ~.o. I.rin-; construe" irn activities, the air quality on and
near the site would be monitored to assess resulting potential
health risks due to the release of VOCs or dust containing
pesticides.
6. Implementability
Alternative No. 4 would b.e easily implemented with conventional
construction equipment and readily available labor and materials.
There are no particular technical difficulties associated with
excavation and transport of the soil to the off-site incinerator.
Special handling and/or containers would be required to safely
contain the soil during transport.
23
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ATTACHMENT A
DECISION SUMMARY
Excavation of the soil requiring incineration and excavation of
the soil to be consolidated on-site could proceed at the same
time so that no delays in the schedule would occur with regard to
off-site incineration.
Approximately eight months would be required for cap design and
contractor selection. Excavation and cap construction is
estimated to take an additional year. The site must be vegetated
immediately following final grading to maintain the integrity of
the cap and prevent erosion damage on excavated areas.
Construction of the cap would not be possible during the winter
months. Seeding is usually most effective in late summer or
early fall.
7. Cost
The estimated present-worth cost of this alternative is
approximately $5,909,700. This cost includes capital, O&M, and
periodic monitoring. Capital costs are estimated to be
$4,648,300, and annual operating costs are expected to be
$33,000, plus $37,000 for a public health assessment every five
years.
8. State Acceptance
No comments were received from the State regarding this
alternative. Since the State has concurred on EPA's preferred
alternative, it is assumed that the Alternative No. 4 is not
acceptable to the State.
9. Community Acceptance
Comments received during the public comment period indicate that
the community is opposed to on-site containment of the
contaminated soil. Therefore, this alternative is not considered
to be acceptable to the public.
ALTERNATIVE NO. 8 - OFF-SITE INCINERATION, OFF-SITE LANDFILL,
REGRADE, AND REVEGETATE
i. Protection of Human Health and the Environment
Alternative No. 8 provides a high degree of protection of human
health and the environment by complete removal from the site of
all affected soil above action levels. Off-site incineration of
soils containing HOCs from the site would provide long-term
effectiveness by significantly reducing or eliminating the
24
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ATTACHMENT A
DECISION SUMMARY
toxicity and mobility of pesticides. The majority of risJt
present at the site would be transferred to an off-site
Subtitle C landfill.
2. Compliance with ARARs
The ARARs associated with this alternative are related to
excavation of the affected soil.
For on-site activities, fugitive dust and particulate emissions
would be of concern. During implementation of this alternative,
OSHA health and safety regulations would be followed by workers
during all phases of site work. Federal CAA National Air Quality
standards and State of Colorado Air Quality regulations would be
applicable in controlling particulate and vapor emissions
resulting from excavation and transportation activities.
For off-site incineration and land disposal, additional
requirements must be met, as off-site transportation involves
waste notification, manifesting, pre-transport requirements, and
transportation restrictions. Waste notification is required
under 6 CCR 1007-3, Part 99, for off-site disposal of a hazardous
waste. Because affected soils would be excavated prior to
transport to an off-site disposal facility, a Notification of
Hazardous Waste Activity form (Form 8700-12) must be completed.
Waste manifests would also be required for hazardous wastes under
6 CCR-i007-3, Part 262, Subpart B, indicating the content of the
waste, mode of transport, and destined disposal facility. All
waste must be packaged and transported in accordance with DOT
regulations in addition to requirements for the disposal facility
and transporter.
3. Reduction of Toxicity, Mobility, or Volume
Alternative No. 8 would result in complete elimination of
toxicity, mobility, and volume of all contaminated soil above
action levels at the site after implementation has been
completed. With respect to the incineration process, it is
anticipated that pesticides and HOCs would be completely
destroyed.
With affected soil above action levels removed from the site, the
risks resulting from potential infiltration and direct human
contact would be eliminated.
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ATTACHMENT A
DECISION SUMMARY
4. Long-term Effectiveness and Permanence
The major advantage of this alternative is the permanent
treatment of highly contaminated soil and removal from the site
of the remaining affected soil posing unacceptable risks.
5. Short-term Effectiveness
Of the other alternatives involving treatment (No. 9 and No. n),
Alternative No. 8 has the third highest (best) rating for short-
term effectiveness. Although no n-site treatment would occur
that results in airborne emissions the entire site would be
excavated, creating opportunity f: dust emissions. Minimal
stockpiling of waste would be required, which would minimize
exposure to dust. Alternative No. 8 could be implemented in two
years. This relatively short implementation time is due, in
part, to higher, throughput rates or capacity at off-site
incineration facilities and the minimization of material handling
on-site.
The primary potential risk during construction would be from the
generation of dust during excavation, transport, and material
handling. During construction activities, the air quality on and
near the site would be monitored to assess resulting potential
health risks due to the release of VQCs or dust containing
pesticides.
Off-site populations would be at risk from the transportation of
hazardous wastes; however, appropriate precautions would be taken
to minimize risk (e.g., transport materials during evening hours
or light traffic periods).
6. Implementability
Alternative No. 8 would be easily implemented with conventional
construction equipment and readily available labor and materials.
With respect to the alternatives involving soil treatment, this
alternative would be the easiest to implement. The primary
reason for the ease of implementation is that phased work would
not be a concern and handling of the affected soil would be
minimized.
In total, Alternative No. 8 would require approximately 1-1/2 to
2 years to implement, with the engineering design and contractor
selection estimated to take six months. Of the alternatives
which offer a high degree of protection to human health and the
environment (Alternatives No. 8, 9, and 11), Alternative No. 8
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ATTACHMENT A
DECISION SUMMARY
would require the least amount of time to implement (2 years
versus 3 to 4 years).
7. Cost
The estimated present-worth cost for this alternative is
approximately 56,962,600. This cost includes construction, O&M,
and periodic monitoring. Capital costs are estimated to be
$5,707,600, and annual operating costs are expected to be
$31,400.
While Alternatives No. 9 and 11 offer approximately the same
degree of protectiveness, Alternative No. 8 is considerably more
economical than their respective costs of $10,331,400 and
$10,912,700.
8. State Acceptance
The State supports the selection of this alternative as a remedy
for the site.
9. Community Acceptance
Based on comments received during the public comment period, the
community supports the selection of this alternative as a remedy
for the site.
ALTERNATIVE NO. 9 - OFF-SITE INCINERATION, ON-SITE LANDFILL,
REGRADE, AND REVEGETATE
i. Protection of Human Health and the Environment
This alternative would provide a high level of protection of
human health by partial removal and destruction of the affected
soils by incineration. The landfill portion would protect human
health to the extent that it eliminates unacceptable risks with
respect to direct human contact and airborne emissions. In
addition, encapsulation of the affected soil significantly
reduces the potential for infiltration of pesticides into the
vadose zone.
Routine O&M would ensure long-term performance of this
alternative. The required 5-year public health and environmental
evaluations would continually evaluate risks and any necessary
actions could be taken.
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ATTACHMENT A
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2. Compliance with ARARs
The ARARs associated with this alternative are related to
excavation and the siting of a landfill for on-site disposal.
For on-site activities, fugitive dust and particulate emissions
from the excavation, stockpiling, and placement in the Subtitle C
landfill would be of concern. During implementation of this
alternative, OSHA health and safety regulations would be followed
by'workers during all phases of site work. Federal CAA National
Air Quality standards and State of Colorado Air Quality
regulations would be applicable in controlling vapor emissions
during construction and excavation activities.
For off-site incineration and on-site Subtitle C disposal,
additional requirements must be met. In addition to ARARs for
the on-site landfilling governed by RCRA, the off-site treatment
involves waste notification, manifesting, pre-transport
requirements, and transportation restrictions. Waste
notification is required under 6 CCR 1007-3, Part 99, for off-
site disposal of hazardous waste. Because affected soils would
be excavated prior to transport to an off-site disposal facility,
a Notification of Hazardous Waste Activity form (Form 8700-12)
must be completed. Waste manifests would also be required under
6 CCR-1007-3, Part 262, Subpart B, indicating the content of the
waste, mode of transport, and disposal facility. All waste must
be packaged and transported in accordance with DOT regulations in
addition to requirements for the disposal facility and
transporter. These ARARs and requirements are attainable with
this alternative.
3. Reduction of Toxicity, Mobility, or Volume
The off-site incineration portion of the alternative would result
in elimination of toxicity and mobility and a small reduction in
volume. It is anticipated that most pesticide contaminants would
be completely destroyed through incineration.
The soil and rubble not sent off-site for disposal by
incineration would remain untreated; therefore, no reduction in
toxicity or volume is anticipated. The Subtitle C landfill
reduces the mobility of the affected soils via complete
encapsulation and would result in significant reduction or
elimination of risks from direct contact and infiltration into
the vadose zone. The reduction in mobility is directly related
to the effectiveness of the site cover O&M performed over the
life of the facility.
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ATTACHMENT A
DECISION SUMMARY
4. Long-term Effectiveness and Permanence
Off-site incineration of soils containing HOCs from the site
would provide long-term effectiveness by significantly reducing
or eliminating the toxicity and mobility of pesticides. With
proper maintenance, no potential for direct human contact or
infiltration to the underlying ground water would exist from
these soils and rubble. By encapsulating the remaining affected
soil, the potential for human exposure would be greatly reduced.
5. Short-term Effectiveness
This alternative would take approximately 4 years to implement.
During this period, risks to construction personnel would be from
the excavation and stockpiling activities. The use of water and
chemical dust suppressants, covering the stockpiles, and personal
protection for site personnel would.reduce these risks. An air-
monitoring program (described in previous alternatives) would be
implemented before, during, and after the remedial effort, as
required. Additional short-term risk would be posed by off-site
transportation of soils to the incinerator.
6. Implementability
The Subtitle C landfill would be constructed on the site using
conventional construction equipment and is technically feasible.
Construction of the landfill is anticipated to take approximately
1-1/2 years in addition to the 3 years required for design and
contractor selection.
7. Cost
The estimated present-worth cost for this alternative is
approximately $10,331,400. This cost includes capital, 0AM, and
periodic monitoring. Capital costs are estimated to be
$8,339,300, and annual operating costs are expected to be
$31,400, plus $37,000 every five years for a public health
assessment.
8. State Acceptance
No comments were received from the State regarding this
alternative. Since the State has concurred on EPA's preferred
alternative, it is assumed that Alternative No. 9 is not
acceptable to the State.
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ATTACHMENT A
DECISION SUMMARY
9. Community Acceptance
Comments received during the public comment period indicate that
the community is opposed to on-site containment of the
contaminated soil. Therefore, this alternative is not considered
to be acceptable to the public.
ALTERNATIVE NO. 10 - OFF-SITE INCINERATION, SOIL WASHING/
BIODEGRADATION, REGRADE. AND REVEGETATE
i . Protection of human health and the environment
This alternative most closely fulfills the intent of SARA by
providing a remedy that reduces toxicity and mobility of the
contaminants for long-term, permanent protection of human health
and the environment through reduction or elimination of potential
exposure routes (i.e., migration into the vadose zone and direct
human contact). However, this alternative does not meet the
remedial response objectives for the site since action levels
could not be attained during treatability studies.
2. Compliance with ARARs
The ARARs associated with this alternative are related to
excavation, soil washing, disposal, and transportation of
affected soil.
For on-site activities, fugitive dust and particulate emissions
would be of concern. During implementation of this alternative,
OSHA health and safety regulations would be followed by workers
during all phases of site work. Federal CAA National Air .Quality
standards and State of Colorado Air Quality regulations would be
applicable in controlling potential vapor emissions during
construction and soil-washing activities.
For off-site incineration and land disposal, additional
requirements must be met, as off-site transportation involves
waste notification, manifesting,' pre-transport requirements, and
transportation restrictions, waste notification is required
under 6 CCR 1007-3, Part 99, for off-site disposal of hazardous
waste. Because affected soils would be excavated prior to
transport to an off-site disposal facility, a Notification of
Hazardous Waste Activity form (Form 8700-12) must be completed.
Waste manifests would also be required und*»r 6 CCR-1007-3,
Part 262, Subpart B, indicating the content of the waste, mode of
transport, and disposal facility. All waste must be packaged and
transported in accordance with DOT regulations in addition to
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ATTACHMENT A
DECISION SUMMARY
requirements for the disposal facility and transporter.
For the soil-washing process, discharge from the wash-water
treatment process must meet the requirements set forth in the
State of Colorado Pretreatment Regulation 4.3.0, effective
July i, 1989, prior to discharge of the treated wash-water to a
POTW.
3. Reduction of toxicity, mobility, or volume
Alternative No. 10 would result in partial elimination of
toxicity, mobility, and volume of the affected soil above action
levels at the site after implementation is completed. With
respect to soils containing high levels of pesticides (HOCs), it
is anticipated that most would be completely destroyed through
incineration, thereby eliminating their toxicity. With respect
to soil washing, the toxicity would be greatly reduced, although
results from treatability tests indicate that soil washing would
not meex the health-based action levels developed for the site.
Soil washing tests indicate that with regard to the distribution
of metals, pesticides, and arsenic in the soil matrix, the
highest concentrations are found in the fine silts and clays
(-200 mesh fraction).
The initial trials provided an overall reduction in pesticide
concentrations of approximately 66 percent. The washed soil met
EPA action levels for DDT but did not attain the action levels
for chlordane, dieldrin, or aldrin. Additional tests such as
gravity separation on the washed soil product indicated an
additional SO percent reduction of pesticide concentrations.
Soil action levels were still not attainable. The surfactants
evaluated during this study appeared to have no significant
effect on the reduction of pesticide concentrations during the
soil washing process.
4. Long-term effectiveness and permanence
This alternative would result in complete destruction of HOCs but
not a significant detoxification by the soil-washing process of
the remaining contaminants. Therefore, this alternative is not
effective in the long term.
5. Short-term effectiveness
Alternative No. 10 would take approximately two years to
implement. During this period, risks to construction personnel
would be from the excavation and stockpiling activities. The use
of water and chemical dust suppressants, covering the stockpiles,
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ATTACHMENT A
DECISION SUMMARY
and personal protection for site personnel would reduce these
risks. Due to the extensive nature of on-site treatment
activities, this alternative is one of the least effective in the
short term. An air-monitoring program (described in previous
alternatives) would be implemented before, during, and after the
remedial effort, as required. Additional short-term risk would
be posed by off-site transportation of soils to the incinerator.
6. Implementability
From an engineering standpoint, this alternative would be
implementable. This alternative would be the second most
difficult to implement due to the complex phasing requirements.
Because of the limited space within the site, several activities
must be conducted concurrently. From a technical standpoint, the
soil washing process cannot attain action levels developed for
the site. Therefore, this alternative cannot be effectively
implemented.
7. Cost
The estimated present-worth cost for this alternative is
approximately $9,925,985. This cost includes construction, O&M,
and periodic monitoring. Capital costs are estimated to be
$8,059,900, and annual operating costs are expected to be
$31,400, plus $37,000 for a public health assessment every 5
years.
8. State Acceptance
while a long-term, permanent alternative that reduces the
toxicity and mobility of site contaminants is highly desirable,
the inability of the soil washing process to achieve action
levels prevents acceptance of this alternative by the State.
9. Community Acceptance
No comment was made by the public regarding this alternative,
though, it is assumed that this alternative is not acceptable to
the community since action levels could not be achieved.
ALTERNATIVE NO. 11 - QN-SITE INCINERATION, ON-SITE LANDFILL,
REGRADE, AND REVEGETATE
1. Protection of Human Health and the Environment
This alternative fulfills the intent of SARA by providing a
remedy that reduces toxicity and mobility of contaminants for
32
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ATTACHMENT A
DECISION SUMMARY
long-term, permanent protection of human health and the environ-
ment through reduction or elimination of potential exposure
routes (i.e., migration of pesticides to the vadose zone and
direct human contact). Routine maintenance and the five-year
public health and environmental evaluations vould ensure
continued protection.
2. Compliance with ARARs
•The ARARs associated with this alternative pertain to excavation,
stockpiling, screening/ size reduction, incineration,
construction, and monitoring of the Subtitle D landfill. The
construction and excavation activities, excluding monitoring,
would result in fugitive dust generation and particulate
emission. During implementation of this alternative, OSHA health
and safety regulations would be followed by workers during all
phases of the site work. Federal CAA National Air Quality
standards and State of Colorado Air Quality regulations are
applicable in controlling vapor and particulate emissions during
excavation, stockpiling, treatment, and disposal activities.
3. Reduction of Toxicity, Mobility, or Volume
This alternative would result in significant reduction of
toxicity and mobility with a slight decrease in volume.
Incineration would yield complete destruction of nearly all
contaminants in the soil and rubble, thereby reducing the
toxicity. The residual generated by the incineration process
would be placed in an on-site Subtitle D landfill, further
reducing its mobility. With the toxicity minimized and all
residuals immobilized with the Subtitle D landfill, risks
resulting from potential pesticide migration to the vadose zone,
air emissions from the residuals, and direct human contact would
be negligible.
4. Long-term Effectiveness and Permanence
This alternative would result in significant detoxification of
contaminants in the soil and rubble. Upon completion of the
incineration process, the treated soil and rubble placed in an
on-site Subtitle D landfill would present negligible risks from
direct contact or contaminant migration into the vadose zone.
5. Short-term Effectiveness
Alternative No. 11 would take three to four years to implement.
During this period, stringent engineering controls on air
emissions would be in place to minimize adverse impacts to human
33
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ATTACHMENT A
DECISION SUMMARY
health and the environment. Risks related to direct contact and
inhalation of the indicator chemicals would be elevated slightly
over present conditions as a result of the excavation process.
An air-monitoring program (described in previous alternatives)
would be implemented before, during, and after the remedial
effort, as required. This program would commence prior to any
construction removal activities to obtain a baseline analysis of
air quality.
6. Implementability
The crucial component to successful implementation of this
alternative is phasing. Because of the limited space within the
site, several activities must be conducted concurrently. Imple-
mentation, which includes engineering design, contractor
selection, landfill construction, mobilization and
demobilization, and treatment, is expected to take three to four
years.
7. Cost
The estimated present-worth cost for this alternative is
approximately $10,912,700. This cost includes construction, O&M,
and periodic monitoring. Capital costs are estimated to be
$8,617,600, and annual operating costs are expected to be
$31,400, plus $37,000 for a public health assessment every 5
years.
8. State Acceptance
No comment for this alternative was made by the State. It is
presumed that the State would not support Alternative No. 11
since the public is strongly opposed to on-site incineration
alternatives.
9. Community Acceptance
In general, the community is strongly opposed to on-site
incineration and, therefore, does not support this alternative to
remedy the site.
IX. The Selected Remedy
Based on consideration of the requirements of CERCLA, the
detailed evaluation of the alternatives, and public comments,
both EPA and the State of Colorado have determined that
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ATTACHMEKT A
DECISION SUMMARY
Alternative 8: Off-site Incineration, Off-cite Landfill,
Regrade, and Revegetate is the most appropriate remedy for the
Woodbury Chemical Site in Commerce City, Colorado.
Alternative No. 8 involves excavation and incineration of all
affected soils exceeding the California List HOC levels from the
site and soil containing the 2,3,7,8-isomer of PCDD above EPA
action levels (if encountered). This material would be trans-
ported to an off-site incineration facility for treatment and
disposal. This alternative also Involves excavation of affected
soils between the action levels and the HOC levels for disposal
in an off-site RCRA-permitted landfill. The volume of soil that
would require incineration has been estimated at 800 cy from the
First Study Area and 50 cy from the Second Study Area. The
remaining 11,520 cy of soil, rubble, and the paving slab would be
excavated and transported directly to an off-site RCRA landfill.
After all affected soil was removed, the excavated area would be
backfilled with clean fill, compacted, and vegetated.
Altenatives No. 8, 9, and 11 would provide approximately the same
level of risk reduction and protectiveness. Of these,
Alternative No. 8 is the most cost-effective with an estimated
present-worth cost of $6,962,600. Additionally, the community
does not prefer Alternatives No. 9 and 11 because the hazardous
wastes would not be removed from the site.
Response Objectives
The response objectives for soil remediation at Woodbury are to
control exposure through direct contact to an acceptable level
and to ensure that the migration of contaminants to ground water
is minimized. Target clean-up objectives were developed based on
(i) concentrations which correspond to carcinogenic health risks
from 1E-7 to 1E-4, (2) ARARs, and (3) background levels.
Acceptable contaminant levels for the chemicals of concern are
generally the 1E-6 risk-based action levels derived in response
to the Endangerment Assessment. Background concentrations in
some cases, however, were higher than the risk-based cleanup
goal. In these cases, remediation to the background level was
considered protective.
It is anticipated that minor changes may be made to the remedy as
a result of the remedial design and construction process. In
general, these changes would reflect modifications resulting fro."
the engineering design process and would not encompass a
significant change to a component of the remedy or the remedy
itself.
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ATTACHMENT A
DECISION SUMMARY
X. Statutory Determinations
EPA's primary responsibility at Superfund sites addresses
remedial actions that are protective of human health and the
environment. In addition, section 121 of CERCLA provides several
other statutory requirements and preferences. These statutes
specify that the selected remedial action for the site must
comply with applicable or relevant and appropriate environmental
standards established under Federal and State environmental laws
unless a waiver is granted. The selected remedy must also be
cost effective and utilize permanent treatment technologies or
resource recovery technologies to the maximum extent practicable.
The statute also contains a preference for remedies that
permanently or significantly reduce the volume, toxicity, or
mobility of hazardous substances. The following sections discuss
how the selected remedy for contaminated soils at Woodbury meet
these statutory requirements.
i . Protection of Human Health and the Environment
The selected remedy protects human health and the environment
through destruction of contaminants with off-site incineration
and removal of contaminants from the site to a RCRA Subtitle C
landfill. This remedy would permanently eliminate the direct
contact threat currently posed .by soils and would minimize future
adverse effects on ground-water quality by eliminating the most
concentrated sources of waste above the water table. The cancer
risks associated with source areas would be reduced to an
acceptable level of 1.0 E-6. There are some short-term risks
associated with the selected remedy during soil r.andling
operations, but these can be minimized with protective and
preventative measures. The majority of risk present at the site
would be transferred to an off-site Subtitle C landfill. Of all
the alternatives, the selected remedy provides the highest degree
of protection to human health and the environment.
2. Attainment of ARARs
The selected remedy would address and comply with all ARARs for
worker protection, on-site dust emissions, and other on-site
activities. All ARARs are attainable for the selected remedy.
3. Cost Effectiveness
EPA believes the selected remedy is cost effective in mitigating
the risk posed by contaminated soils in a reasonable period of
time. The selected remedy effectively and permanently reduces
contamination to acceptable levels. Present net worth costs
36
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ATTACHMENT A
DECISION SUMMARY
associated with Alternative 8 are approximately $6,962,600.
Other alternatives were either more expensive or achieved a
significantly lower level of protectiveness and permanence.
4. Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the
Maximum Extent Practicable
EPA analyzed the alternatives to determine which would utilize
treatment technologies to the maximum extent practicable. The
selected remedy would achieve the response objectives of
controlling direct contact exposure to contaminated soils and
minimizing adverse impacts on ground-water from soil
contamination.
By employing off-site incineration and off-site disposal, the
selected remedy uses permanent treatment technologies to the
maximum extent practicable. This remedy involves destruction and
removal of contaminants and an overall reduction in contaminant
toxicity, mobility, and volume. Therefore, a permanent solution
for the site is achieved and it can be returned to productive
use.
5. Preference for Treatment as a Principal Element
By incinerating highly contaminated soils, the selected remedy
addresses the principal risks at th-e .site through the use of
treatment technologies. Therefore, the statutory preference for
remedies that employ treatment as a principal element is
satisfied. The remaining soils would be contained in an off-site
RCRA Subtitle C landfill rather than undergo a treatment process.
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RECORD OF DECISION - ATTACHMENT B
WOCDBURY CHEMICAL COMPANY SUPERFUND SITE
RESPONSIVENESS SUMMARY
September 25, 1989
The Woodbury Chemical Company Superfund Site is located in
Commerce City, a northern suburb of Denver, Colorado. The site
is surrounded by light and heavy industry including automobile
salvage yards and a petroleum refinery. The nearest residential
area to the Woodbury site is a mobile home park approximately
one-third mile to the southwest. The residential and commercial
population within a one-mile radius of the site numbers
approximately 3,000 persons. The majority of this population
lives in the residential areas to the southwest of the site.
A. OVERVIEW
At the time of the public comment period, the Environmental
Protection Agency (EPA) had already selected a preferred
alternative for the Woodbury Chemical Company site in Commerce
City, Colorado. EPA's recommended alternative addressed
environmental concerns presented by soils contaminated with
pesticides, volatile organic chemicals, and metals, and would
eliminate the principal threat of contaminated soil to ground
water, on-site workers, and the surrounding residents. The
selected remedy specified in the Record of Decision (ROD)
involves off-site incineration of approximately 2,050 cubic yards
of soils prior to disposal in an off-site landfill and off-site
disposal of approximately 10,635 cubic yards of soils above
cleanup levels.
Based on comments received during the public comment period, the
nearby residents, the city council of Commerce City, and the
Colorado Department of Health support the off-site incineration
and landfill alternative for cleanup of soil contamination at the
Woodbury site. The McKesson Corporation, a potentially
responsible party (PRP) for the site, has submitted written
comments which state that the cleanup levels are too
conservative. In general, the community is strongly opposed to
on-site incineration and prefers a cleanup alternative which can
be implemented as quickly as possible.
These sections follow:
0 Background on Community Involvemeff*
0 Summary of Comments Received during Public Comment
Period and EPA's responses,
0 Remaining Concerns, and
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ATTACHMENT B
RESPONSIVENESS SUMMARY
Community Relations Activities at the Woodbury Chemical
Company site.
B. SUMMARY OF COMMUNITY INVOLVEMENT
Since the September 1983 addition of the Woodbury site to the
National Priorities List of hazardous wastes, community interest
has been minimal. During the 1985 public comment period for the
First Study Area, no comments or inquiries were received. The
recent 1989 public comment period resulted in marginal community
participation as well. While there are several local community
groups active in other Superfund activities, no specific concerns
regarding the Woodbury site have been presented to EPA.
C. SUMMARY OF COMMENTS RECEIVED DURING PUBLIC COMMENT PERIOD
EPA solicited written and oral comments from the public during
the public comment period that began September 1, 1989, and ended
on September 22, 1989. Comments received during that time are
categorized by subject and summarized, with EPA's response,
below.
Comments on the Preferred Alternative
1. Comment: A resident at the public meeting expressed the
opinion that EPA's preferred alternative was acceptable to
the community. It was also stated that the Woodbury site
should be cleaned up as soon as possible, because the
residents are overwhelmed with other concerns (i.e. the
Rocky Mountain Arsenal Superfund site, the Sand Creek
Superfund site, a medical waste incinerator, etc.)
EPA Response: EPA will continue to keep the residents
informed of activities at the Woodbury site. In addition,
addresses for residents in the Woodbury community will be
added to the mailing lists for other sites in this area, so
that the residents can receive accurate and timely
information regarding Superfund sites in their community.
2. Comment: A resident questioned how the contaminated soil
would be transported and how the dust resulting from
remedial action at the site would be controlled.
EPA Response; Both of these concerns will be addressed in
greater detail during the upcoming remedial design phase for
the Woodbury site. During remedial activities, the air
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ATTACHMENT B
RESPONSIVENESS SUMMARY
quality on and near the site would be monitored to assess
the resulting potential health risks due to the release of
volatile organic compounds or dust containing pesticides.
3. Comment: Cogswell and Eggleston, P.C. submitted written
comments on behalf of the City and County of Denver.
Cogswell and Eggleston stated that insufficient information
had been developed by EPA to support the selection of a
remedy that addresses and adequately protects the health,
welfare, and environmental concerns in surrounding areas
that may be affected by the Woodbury Chemical Company site.
Specifically, 1 ) no sampling was conducted along 54th Avenue
to determine the southern extent of contamination, 2)
sampling and analysis for dioxins and furans was not
conducted as part of the RI, and 3) airborne migration of
contaminants to the south and south - southwest was not
evaluated.
Response: Samples taken from along 54th Avenue did indicate
the presence of pesticide concentrations in excess of action
levels developed for the site. However, these areas are
directly associated with rubble piles. Extensive efforts
were made to determine the exact boundary of the
contamination due to buried rubble at the 54th Avenue border
to the site. 'Samples were analyzed for dioxins and furans
as discussed in Chapter 4 of the RI. These results are also
visually displayed in Figure 4.8. Sampling of soil at the
0.1 foot depth was conducted throughout the site. Areas
directly to the south and south - southwest of rubble piles
do- not indicate contamination due to airborne migration.
The quality and amount of data, and the interpretation of
the data, are sufficient to select appropriate technologies
and alternatives. The chemicals of concern and their
approximate areal and vertical extent are known so that a
decision to remedy the site can be made.
Comments on the Development of Action Levels
4. Comments: Harding Lawson Associates (HLA) submitted written
comments on behalf of the McKesson Corporation. HLA
questioned the use of a 30-year duration period for exposure
when the Sand Creek site used only 20 years. HLA believes
that this discrepancy has resulted in the development of
overly conservative values for the industrial nature of the
site. Also, HLA recommends that an average exposure value
should be used instead of the maximum plausible exposure
values.
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ATTACHMENT B
RESPONSIVENESS SUMMARY
EPA Response; Guidance for Public Health Evaluations such
as the "Superfund Public Health Evaluation Manual" provide
standard assumptions to determine risk and, therefore,
action levels, at Superfund sites. However, if more
accurate site-specific information is available, these
assumptions are to be modified to give a better
representation of risk at the site. With regard to
Woodbury, a residential community exists within one-third
mile of the site. This community possesses unique
attributes which required a more conservative approach to
the determination of risk and the resulting action levels.
While the action levels may be conservative considering the
present industrial nature of the site, it is EPA policy to
consider future residential use, recreational use, etc. EPA
cannot rely on current use or zoning to limit future
scenarios. Since few restrictions can be imposed in
perpetuity, EPA feels that it is reasonable to consider
these possible future uses.
Public Participation Process
5. Comment: A resident commented that more residents would
have attended the public meeting had they been provided more
advance time to plan their attendance.
EPA Response: EPA used .several different methods to notify
residents of the September 15, 1989, meeting. A notice was
published in the August 31, 1989, Commerce City Sentinel in
addition to the distribution of approximately 500 fact
sheet/Proposed Plans within the 54 block residential area to
the southwest of the site.
Superfund Process and Policy
6. Comment: A resident questioned why the McKesson Corporation
was responsible for cleanup of the Woodbury site, if other
PRPs would also be responsible for cleanup, and why the
Woodbury Company was not being made to pay for the cleanup.
EPA Response; The Superfund law, as written in 1980, states
that anyone who has generated a hazardous substance found at
a site, present and former owners of a site, and certain
transporters who disposed of hazardous substances at a site,
are liable for payment of Superfund cleanup costs. As a
current owner of part of the Woodbury site, the McKesson
Corporation may be liable for payment of cleanup costs. An
additional three PRPs have been identified, including the
Colorado and Eastern Railroad, Farmland Industries, and the
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ATTACHMENT B
RESPONSIVENESS SUMMARY
Maytag Corporation. Witn regard to the Woodbury Chemical
Company, a formal search was conducted to determine if the
Woodbury Chemical Company is able to fund cleanup costs at
the site. It was discovered during the search that the
Woodbury Chemical Company, whose name had been changed to
the Missouri Chemical Company several years earlier, had
been dissolved in the late 1970's.
7. Comment: A resident asked how Superfund sites were ranked
(i.e. how did the Sand Creek site acquire a ranking of 38)7
EPA Response: The value of 38 which is given to Sand Creek
simply identifies the site as the 38th site to be added to
the National Priorities List. It is not a comparative
ranking of the potential danger present at a site.
D. REMAINING CONCERNS
EPA was unable to address one additional concern during the
remedial planning activities. Several residents asked how and
where the contaminated soils would be transported for
incineration and landfill. EPA was unable to address this
concern because this information will not be developed until the
details of the remedial design are established. Several options
are available and EPA will inform thrf residents of these
decisions as soon as the remedial design is complete.
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ATTACHMENT B
RESPONSIVENESS SUMMARY
COMMUNITY RELATIONS ACTIVITIES
WOODBURY CHEMICAL COMPANY SUPERFUND SITE
July 1983
March 1985
August i989
September 1
to
September 22,
1989
A Community Relations Plan, as required by CERCLA,
was developed by EPA. The goals of the community
relations efforts is to involve the public in
activities and decisions regarding the Woodbury
site.
EPA distributed a fact sheet to residents and
businesses in the area as well as the Commerce
City government and the Colorado Department of
Health. The fact sheet presented the Proposed
Plan for the First Study Area, as well as six
other remedial alternatives that had been
evaluated.
Comments were solicited from the public during a
three-week public comment period from March 11 ,
1985 to April 1, 1985.
EPA distributed an information notice to residents
in the vicinity of Woodbury. The poster,
published in English and Spanish, addressed
concerns about potential exposure of local
residents to contaminants.
The RI and draft FS were completed and an initial
remedial alternative (the Proposed Plan) was
chosen. EPA took several measures to announce the
Proposed Plan and to seek comments and questions
from the public.
EPA published a press release and a public notice
in the Commerce City newspaper, The Commerce City
Sentinel, announcing all of the activities listed
above.
Copies of the Proposed Plan, and the remedial
investigation and feasibility study reports
were made available to the public in the Adams
County Public Library, the Colorado Department of
Health, and EPA's own Records Center in downtown
Denver.
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ATTACHMENT B
RESPONSIVENESS SUMMARY
EPA mailed a third fact sheet, which described the
Proposed Plan as veil as six other remedial
alternatives that had been evaluated.
EPA announced a public comment period during which
all interested persons were invited to submit
comments and questions.
September 15, EPA conducted a public meeting to describe the
1989 results of the RI/FS, present the Proposed Plan,
and answer questions from the public.
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