EPA Superfund
Record of Decision:
PB95-964611
EPA/ROD/R10-95/121
January 1996
Pacific Hide and Fur
Recycling Co., Pocatello, ID
9/27/1995
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 10
1200 SIXTH AVENUE
SEATTLE, WASHINGTON
FINAL OPERABLE UNIT RECORD OF DECISION,
DECISION SUMMARY,
AND RESPONSIVENESS SUMMARY
FOR THE LEAD-CONTAMINATED
SOIL AND SCRAP MATERIAL
MCCARTY'S/PACIFIC HIDE AND FUR
SUPERFUND SITE
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Declaration for the
McCarty's/Pacific Hide and Fur
Superfund Site
Final Operable Unit Record of Decision
McCarty's/Pacific Hide and Fur
Pocatello, Bannock County, Idaho
Statement of Basis and Purpose
This decision document presents the selected remedial action
for soil and scrap material contaminated with lead remaining at
the McCarty's/Pacific Hide and Fur Site (the "Site") in
Pocatello, Bannock County, Idaho. This record of decision (ROD)
has been 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), 42 U.S.C. §9601 et seq.. and
to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP), 40 CFR Part 300.
This decision is based on the Administrative Record (AR) for this
Site, updated in July 1995, to include new information generated
since both the original ROD, signed on June 28, 1988, and the
Amended ROD, signed on April 29, 1992. The attached index
identifies the items in the AR upon which this decision is based.
The State of Idaho 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
threat to human health, welfare, or the environment.
/
Description of the Final Operable Unit Remedy
This operable unit is the second of two operable units for
this Site. The first operable unit involved remediation of soil
and scrap material contaminated with polychlorinated biphenyls
(PCBs) and commingled PCBs and lead.-
e9
This final operable unit addresses remediation of the
remaining soil and scrap material contaminated with lead. The
selected remedial action addresses all threats associated with
lead-contaminated soil and scrap material above lead health-based
levels under a future industrial land use scenario. Extensive
analyses conducted on samples from ground-water monitoring wells
located both on- and off-Site have not indicated the presence of
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lead or other contaminants at harmful levels. Therefore, ground-
water cleanup is deemed unnecessary and is not a component of
this operable unit remedial action.
The major components of the selected remedy include:
• Decontaminating and recycling contaminated scrap material
and, site preparation in anticipation of remedial
activities;
• Excavating all lead-contaminated soil above the Site-
specific cleanup level;
• Treating soil which has been designated as a Resource
Conservation and Recovery Act- (RCRA) characteristic waste;
• Properly disposing of both the non-treated and treated
soil at a permitted, municipal landfill (operated under 40
CFR 258) ;
• Backfilling excavated areas with clean soil from off-Site,
grading and restoring surface drainage;
• Implementing supplementary engineering controls and
environmental monitoring, such as air monitoring, to
minimize exposure to releases of hazardous substances during
cleanup activities;
• Performing one year of quarterly ground-water monitoring
to ensure the effectiveness of the cleanup and that no
contaminants, were mobilized during its implementation,
followed by monitoring well abandonment;
• Requiring institutional controls including permanent Site
fencing and restrictions limiting future property usage to
industrial operations only. These restrictions will
prohibit land uses allowed under residential/neighborhood
commercial and professional zoning.
• Long-term operation and maintenance requirements including
fence repair, as necessary. Reviews conducted no less often
than every five (5) years to ensure the remedy continues to
provide adequate protection of human health and the
environment.
Because this remedy will result in hazardous substances
remaining at the Site above health-based levels, reviews will be
conducted no less often than every five (5) years following
initiation of the remedial action to ensure the remedy continues .
to provide adequate protection of human health and the
environment.
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Declaration
This operable unit remedial action is protective of human
health and the environment, complies with federal and state
requirements that are legally applicable or relevant and
appropriate to the remedial action, and is cost effective; This
action utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable and satisfies the
statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal element.
Clarke ' Date
Regional Administrator
U.S. Environmental Protection Agency, Region 10
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MCCARTY'S/PACIFIC EIDE AND FUP
SUPERFUND SITE
RECORD OF DECISION
DECISION SUMMARY
TABLE OF CONTENTS
Page
INTRODUCTION 7
SITE HISTORY 8
ENFORCEMENT ACTIVITIES 9
SCOPE AND ROLE OF OPERABLE UNIT REMEDIAL ACTION 11
SUMMARY OF SITE CHARACTERISTICS 12
SUMMARY OF SITE RISKS 15
KEY FEATURES AND ARARS COMMON TO ALL ALTERNATIVES " 27
DESCRIPTION OF FINAL OPERABLE UNIT REMEDIAL
ALTERNATIVES 29 .
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 34
SELECTED REMEDY .40
STATUTORY DETERMINATIONS 42
DOCUMENTATION OF SIGNIFICANT CHANGES 46
Appendix A: THE RESPONSIVENESS SUMMARY 62
Appendix B: ADMINISTRATIVE RECORD 77
List of Figures
Figure 1 Site Location Map 48
Figure 2 Final Operable Unit Remedial Action Area 49
Figure 3 Ground-Water Monitoring Well Location and
Sampling Map 50
Figure 4 Residential Scenario - RME Cancer Risks and
Hazard Indices 51
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TABLE OF CONTENTS (continued)
List of Figures (continued)
Figure 5
Residential Scenario - Average Cancer Risks
and Hazard Indices 52
List of Tables
Table 1
Table 2
Table 3
Table 4
Table 5
Table 6
Table 7
Table 8
Table 9
Soil Sample Collection Summary 53
Summary of Potential Inorganic Elements
of Concern in Surface Soil 54
Summary of Potential Inorganic Elements
of Concern in Subsurface Soil 55
Summary of Potential Inorganic Elements
of Concern in Ground-Water 56
Potential Contaminants of Concern in
Soil and Ground-Water 57
Residential and Industrial Soil Ingestion
Exposure Factors 58
Industrial Scenario - RME Cancer Risks
: and Hazard Quotients .59
Comparison of Final Operable Unit
Cleanup Alternatives 60
Comparison of Remedies Between Region 10
"Industrial Use" Sites 61
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MCCARTY'S/PACIFIC HIDE AND FUR
SUPERFUND SITE
FINAL OPERABLE UNIT RECORD OF DECISION
Decision Summary
INTRODUCTION
Site Name. Location and Description:
The McCarty's/Pacific Hide and Fur Superfund Site consists
of approximately seventeen (17) acres located in the southern
half of Section 16, Township 6 South, Range 34 East of the Boise
Meridian, Bannock County, Idaho. The Site is situated at the
northwestern edge of Pocatello, Idaho at 3500 U.S. Highway 30
West. A vicinity map is shown in Figure 1.
The Site is comprised, of three contiguous properties
including the McCarty property; the Pacific Recycling facility
(owned and operated by Pacific Hide & Fur Depot, ..Inc.} and a
portion of the Union Pacific Railroad (UPRR) property currently
leased to Pacific Recycling. Current land use at the Site
includes an operating scrap yard and vacant .property on which
scrap operations were formerly conducted. The Site is located in
an industrial corridor along U.S. Highway 30 West. Several
residences are located within 0.3 mile of the Site.
Lead and Support Agencies;
The U.S. Environmental Protection Agency (EPA) is the lead
agency for this Superfund Site. The State of Idaho, through the
Idaho Division of Environmental Quality (IDEQ), has reviewed and
concurs with the response activities planned at the Site.
Administrative Record:
This ROD is based on the Administrative Record (AR) for this
Site and will become part of the AR file, in accordance with
§300.825,(a) (2) of the NCP. The AR is available for review at the
EPA Regional Office, 1200 Sixth Avenue, Seattle, Washington, and
at the Pocatello Public Library, 812 East Clark Street,
Pocatello, Idaho. An index of the AR is included with this
record of decision (ROD).
Highlights of Community Participation:
Community relations efforts prior to June 28, 1988 and
between June 28, 1988 and April 29, 1992, are described in the
Community Relations sections of the original and amended RODs for
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the first operable unit, respectively. The following
relations activities are relevant to this ROD:
October 31, 1994-
November 30, 1994
December 1, 1994
SITE HISTORY
The public comment period for the final
operable unit Proposed Plan. The
Proposed Plan was released to the public
on October 26, 1994. Copies were mailed
to over seventy-five (75) interested
parties on the community relations
mailing list. A display ad was placed
in the Idaho State Journal newspaper
describing the proposed cleanup plan and
the dates of the public comment period.
Citizens were asked to contact the EPA
project manager to request a public
meeting to discuss the proposed
alternatives for cleanup of the
remaining lead contamination at the
Site.
Public comment period extended an
additional thirty (30 days) after EPA
received a formal request for an
extension. A display ad was placed in
the Idaho State Journal newspaper
describing the extension to the public
comment period. The public comment
period was extended through December 31,
1994. Substantial written comments were
submitted to EPA during the public
comment period. A response to the
public comments is included in the
Responsiveness Summary, which is
attached to this ROD as Appendix A.
The McCarty property was used as part of a gravel mining
operation as early as 1949. The property was later used as a
metal salvaging yard from the late 1950's to 1983. Scrap metal
was bought and stored in and around a large gravel pit. Copper
from transformers was removed and the casings scrapped. . Residual
oil, contaminated with PCBs, was apparently allowed to drain
directly onto the ground. The capacitors were discarded directly
into the pit because they had no value.
Lead-acid batteries were also brought to the McCarty, UPRR
and Pacific Hide and Fur Depot, Inc., properties. In some
locations, battery casings were mixed with metal scrap in layers
up to four (4) feet thick. Lead in the batteries was sold for
reprocessing. Acid staining and corrosion from battery acids has
been observed in intermixed metal scrap recovered from the Site.
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Former employees who worked at the Site have reported that
batteries were cracked open, drained, and stored in four former
railroad boxcars located on both the Pacific Hide and Fur Depot,
Inc., and UPRR properties in the south central portion of the
Site. These boxcars were not known to have been moved around on
the Site during the time the recycling activities occurred.
Battery acid was reportedly drained in an area southwest of the
boxcars. The battery casings were either burned in a stove in
the boxcars for heat, shipped off the Site with the lead, or
dumped on the McCarty property.
Recycling operations on the McCarty property were conducted
by McCarty's, Inc., until 1979. In August 1979, Pacific Hide and
Fur Depot, Inc. (dba Pacific Recycling) purchased the northwest
section of the McCarty property and the right to engage in the
recycling business in that area. Pacific Recycling continued to
operate on the McCarty property until March 1983. Pacific
Recycling operates a recycling business on its property and
property currently leased-from UPRR.
ENFORCEMENT ACTIVITIES
EPA conducted an Emergency Removal Action at the Site in
March 1983. Over 500 capacitors and 100 cubic yards of PCB-
contaminated surface soil were removed and disposed off-Site.
Also, in March 1983, the United States Department of Justice
(DOJ), acting on behalf of EPA, filed both a civil and a criminal
action based on contamination discovered at the Site. The
criminal action was brought against Pacific Hide and Fur Depot,
Inc., and several of its employees, for alleged violations of the
Toxics Substances Control Act. Convictions were entered in the
criminal case on June 29, 1984. The verdicts were subsequently
overturned by the Ninth Circuit in United States v. Pacific Hide
& Fur. 768 F.2d 1096 (9th Cir. 1985), based on an improper jury
instruction. The civil action, which was subsequently stayed
pending resolution of the criminal suit, was brought against
Pacific Hide and Fur Depot, Inc., McCarty's, Inc., and individual
members of the McCarty family.
In September 1984, the Site was added to the National
Priorities List under CERCLA.
In March 1985, the United States renewed prosecution of the
civil action. Pacific Hide and Fur Depot, Inc., subsequently
named Idaho Power Company (IPCo} as a third party defendant.
IPCo had owned many of the.transformers and capacitors that had
been brought to the Site. DOJ filed an Amended Complaint,
identifying IPCo as an additional defendant.
On September 9, 1986, IPCo, McCarty's, Inc., members of the
McCarty family, Pacific Hide and Fur Depot, Inc., and EPA entered
into a Partial Consent Decree in which the defendants agreed to
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ccriV'-L a remedial investigation and feasibility study (RI/FS) of
PCB contamination at the Site. The completed RI/FS was submitted
to EPA for approval on March 9, 1988. The ROD was signed on June
28, 1988.
In July 1988, special notice letters were sent to Pacific
Hide and Fur Depot, Inc., McCarty's, Inc., members of the McCarty
family and IPCo, all of whom had been identified as potentially
responsible parties (PRPs). The special notice letters initiated
negotiations on a PRP-lead remedial design/remedial action
(RD/RA) . IPCo and EPA subsequently entered into a consent decree
in which IPCo agreed to complete the RD, implement the RA,
reimburse EPA for a portion of the past costs incurred by the
government, and fund three years of operation and maintenance.
This consent decree was lodged on May 30, 1989, and became
effective on September 25, 1989. At that time, PCBs were the
only hazardous substances known to be present above regulatory
limits.
Subsequent to entry of the Partial Consent Decree, but prior
to IPCo's completion of the design work for the remedial
alternative, EPA discovered lead at the Site at concentrations in
excess of recommended action levels. EPA determined that"the
selected PCB remedial alternative would not be protective. All
PCB remedial activities were stopped. IPCo .agreed to complete a
feasibility study to evaluate remedial alternatives for cleanup
of both PCBs and PCBs commingled with lead.
An investigation to identify PRPs who may be potential
sources of the lead contamination was completed by EPA in
December 1991. Letters were sent to several identified PRPs to
notify them of their potential liability, obtain additional
information, and seek their cooperation in undertaking and
financing further investigation and possible future cleanup.
On April 29, 1992, EPA issued an .Amended ROD. The Amended
ROD identified the selected remedial alternative for PCBs and
PCBs commingled with lead and other inorganic contaminants. IPCb
and EPA negotiated an Amended Partial Consent Decree. EPA
subsequently issued an-Administrative Order for RD/RA to enable
IPCo to promptly initiate cleanup of PCBs and PCBs commingled
with lead pending judicial entry of the Amended Partial Consent
Decree.
The Amended Partial Consent Decree was lodged with the Idaho
District Court (Court) on August 17, 1993. Substantial public
comments objecting to entry of the Amended Partial Consent Decree
were received from the parties who had been identified as PRPs
for the lead contamination. Following consideration of the
comments, the United States moved for entry of the Amended
Partial Consent Decree on December 23, 1994. The parties who had
submitted public comments filed formal objections with the Court,
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inquestii.ig that the Court not enter the Amended Partial G_-,isent
Decree.
Immediately following discovery of the lead contamination,
EPA began collecting .information concerning the delivery and
processing of lead batteries at the Site. Receipts obtained from
McCarty's, Inc., and Pacific Recycling disclosed ten (10) major
battery contributors.
In December 1992, EPA issued special notice letters to the
10 identified lead generators and the owners/operators of the
Site (Pacific Hide and Fur Depot, Inc., UPRR, McCarty's Inc., and
the McCarty entities). Subsequent negotiations for completion of
an RI/FS for the lead contamination were unsuccessful. Thus, EPA
retained a contractor to conduct the RI/FS. The Proposed Plan
was issued in October 1994. EPA re-evaluated the proposed remedy
as a result of comments received during the public comment
period. EPA's response to these comments appears in the
Responsiveness Summary of this ROD. Negotiations for
implementation of the selected remedial alternative will commence
shortly after the ROD is signed..
SCOPE AND ROLE OF THE OPERABLE UNIT REMEDIAL ACTION
Following discovery of the lead contamination, EPA divided
the Site into two operable units to expedite cleanup activities.
The first operable unit addressed cleanup of the PCB- and
commingled PCB/lead-contaminated soil. A comprehensive
discussion of the selected remedial action for the first operable
unit cleanup is included in the April 29, 1992 Amended ROD. The
first operable unit cleanup was completed in October 1993.
The second operable unit addresses the remaining lead-
contaminated soil at the Site. EPA has determined that lead
concentrations greater than 1,000 parts per million (ppm) may
present significant human health risks for Site workers.
Approximately 6,510 cubic yards of lead-contaminated soil
remaining at the Site exceed the 1,000 ppm level. Approximately
3,015 cubic yards of the 6,510 cubic yards of lead-contaminated
soil must be treated prior to disposal because it exceeds the
RCRA toxicity characteristic leachate procedure (TCLP) extraction
test level of 5 ppm. The TCLP test was used at this Site on
lead-contaminated soil to determine its mobility. The lead-
contaminated soil is considered to be the principal threat waste
at this Site because of the possible ingestion of soil that
contains lead above health-based levels.
The second operable unit remedial action is intended to be
the final response action for this Site. Extensive sampling of
ground-water monitoring wells located on- and off-Site, has not
indicated the presence of lead or other contaminants at harmful
levels. Therefore, ground-water cleanup is deemed unnecessary
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remedial action have beer, excluded- because they are no longer
representative of current Site conditions.
The data comparison presented in Table 3 identifies two
analytes, arsenic and lead, that exceed background and risk-based
criteria at depth under a future residential land use scenario.
Beryllium exceeds residential risk-based criteria at depth.
However, under the current/future industrial land use scenario,
lead is the only analyte that exceeds background and risk-based
criteria.
Samples were collected for TCLP analyses at 14 locations
identified during XRF screening as exhibiting lead concentrations
between 1,600 ppm and 28,600 ppm. Regression analysis was
performed on data collected during the 1990 and 1991 sampling
events. For the nine data pairs within the XRF calibration range
(380 to 10,000 ppm), the laboratory analytical results for TCLP
from unsieved soil samples and XRF measurements are marginally
correlative (r2 = .67) . Although the correlation between the XRF
measurements and TCLP values is insufficient to establish a
prediction of TCLP leachate values from an XRF measurement, the
data show that none of the samples with XRF lead measurements
below 4,000 ppm exceeded the TCLP regulatory limit for lead
(5 ppm) . TCLP analysis also indicated that no metals, other than
lead, exceeded RCRA criteria.
TCLP soil analyses were not performed during the RI because
the TCLP results from the samples collected in 1990 and 1991
remain representative of Site soil characteristics.
EPA estimates that 7,330 cubic yards of lead-contaminated
soil exceed EPA's recommended 400 ppm residential-based screening
level; an estimate of 6,510 cubic yards of soil exceeds a level
of 1,000 ppm. Other inorganic elements detected in Site surface
soil in concentrations above background included antimony,
arsenic, beryllium, cadmium, copper, manganese and zinc. These
elements were not.expected to result'in exposures to workers that
would exceed EPA's acceptable health-based levels. No
semivolatile organic compounds were detected at levels of
concern.
Surface soil contamination (from ground surface to 1 foot
below ground surface) is pervasive across the Site except in
those areas where extensive cleanup occurred under the first
operable unit and on portions of the Pacific Hide and Fur Depot,
Inc., property on which no known battery recycling operations
were conducted. At depths to eight (8) feet below ground
surface, areas exhibiting elevated lead concentrations are
limited to the north central access road to the gravel pit on the
McCarty property, the top of the east access road to the pit, and
two localized areas east of the pit on the Mccarty's property;
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and the historical location of the former battery boxcars on ^he
Pacific Hide and Pur Depot, Inc., and UPRR properties. Figure 2
depicts lead contamination at the Site at 400 ppm and 1,000 ppm
concentration contour intervals, and subsurface locations where
lead concentrations exceed 1,000 ppm.
Ground water beneath the Site occurs in two distinct water
bearing deposits (upper and lower aquifers) separated by a less
permeable clay layer. Under the Clean Water Act (CWA) (33 USC
1251, 40 CFR Part 230, 231), State Antidegradation Requirements/
Use Classification require every state to classify all the waters
within its boundaries according to intended use. EPA has
designated the upper aquifer as Class I IB since it is potentially
available for drinking water, agriculture or other beneficial
uses. The lower aquifer is Class I (i.e., drinking water). The
lower aquifer is very productive and. is used as the primary
drinking water source by local, private residents, businesses,
and the City of Pocatello (Supply Well No. 32) . No water supply
wells in the area have been found to utilize the upper aquifer.
The Michaud Gravel through which the upper aquifer flows does not
appear to be of sufficient saturated thickness to be used as a
major ground-water source. Depth to ground water in the upper
aquifer is between 34 to 38 feet below ground surface; and,
within the lower aquifer, 60 to 150 feet below ground surface
Ground water in the upper aquifer- flows to the northwest, an
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There are several inorganic analytes which exreec? either
MCLs or risk-based criteria including aluminum, antimony,
arsenic, chromium, iron, lead, manganese, nickel, and zinc. In
many instances, the exceedance occurred once and has not been
replicated. With the exception of lead, these compounds have not
been found in Site soil at levels of concern, and are, therefore,
not considered contaminants of concern at the Site. Lead did
exceed the federal action level of 15 ug/L in an up-gradient well
at 43.8 ug/L and down-gradient well at 18 ug/L, as documented in
the results from the March 1991 sampling event. However, these
results are considered anomalous because no exceedances of the
action level have been observed since the March 1991 sampling
event. Based on the extensive ground-water monitoring database
for this Site, EPA believes this Site does .not pose a threat to
ground water, and therefore, no ground-water remediation is
deemed necessary. However, lead, in the more highly contaminated
soil, may be leached or mobilized by rainwater infiltrating or
spills from industrial Site activities. TCLP results demonstrate
that lead-contaminated soil at the Site has the capacity to be
leached fairly readily.
There are no observable impacts to surface water, sediments
or air resulting from contaminants found at the Site.
The Site Characteristics - Remedial. Investigation section in
the original June 28, 1988 ROD, and the August 1991 "Interpretive
Report for XRF Screening and Confirmation Soil Sampling at
Mccarty's/Pad fie Hide and Fur and Union Pacific Railroad"
provide a historical perspective of Site investigations done to
characterize the nature and extent of contamination at the Site.
SUMMARY OF SITE RISKS .
The baseline risk assessment provides the basis for taking
action at the Site and indicates the exposure pathways that need
to be addressed by the remedial action. Risk assessments are
performed using information on the toxicity of Contaminants and.
assumptions regarding the extent to which people may be exposed
to them. This summary of the baseline Risk Assessment for the
Site is divided into five sections: identification of potential
contaminants of concern (COCs), exposure assessment, toxicity
assessment, risk characterization, which is an integration and
summary of the information gathered and analyzed in the preceding
sections and analysis of the uncertainty involved in developing a
risk assessment. The summary concludes with the results of the
Ecological Risk Assessment conducted for this Site.
The October 1994 baseline Risk Assessment evaluated risk
based on a future residential land use scenario. Upon further
review, EPA determined that the reasonably anticipated future
land use at the Site will be industrial, consequently, the
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June 9, 1395 Risk Assessment iddencuirr; evaluated risk based on a
future industrial land use scenario. The potentially exposed
populations in current and potential scenarios are primarily on-
Site workers.
Identification of Potential Contaminants of Concern (Screening
Analysis)
The selection of chemicals that potentially contribute to
human health risks at the Site, known as the potential COCs, was
a two-step process. First, the maximum concentrations of
contaminants detected in on-site soil and water were compared to
health based screening levels for drinking water, soil and air
developed by EPA Region III (Risk-Based Concentration Tables,
Second Quarter 1994, Region III, April 20, 1994) and to EPA's
MCLs. For lead, the health-based screening levels used for soil
(400 ppm) and water (15 ug/1) were those recommended by EPA
guidance. Those chemicals having concent-rat ions above these
screening levels were selected as potential COCs. Second, some
of the potential COCs identified in this first step were
eliminated from consideration as potential COCs by considering
several factors including frequency of detection, .calculated risk
levels, and background concentrations (for inorganics).
The potential COCs selected for soil and Class IIB ground
water (potential drinking water) shown in Table 5 were selected
using exposure parameters based initially on residential use of
the Site. Because EPA recommends that the residential scenario
be used for the initial screening (i.e., the selection of
potential COCs) for all risk assessments, the screening methods
used and the potential COCs selected did not change with the
addition of the industrial land use Risk Assessment in the June
1995 addendum.
Exposure Assessment
The exposure assessment estimates the type and magnitude of
exposures to the potential COCs at the Site. It considers the
current and potential future uses of the Site, characterizes the
potentially exposed populations, identifies the important
exposure pathways and quantifies the intake of each potential COG
from each medium for each population at risk. The result of the
assessment is a calculated daily dose of each potential COC per
body weight for each exposure medium.
Identification of Site Uses-, Exposed Populations and
Exposure Pathways
(a) Site Use Scenarios. The exposure assessment for the
Site considers two land use scenarios involving different groups
of potentially exposed populations. The October 1994 baseline
Risk Assessment considered future residential land use of the
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Site. The June 19P5 a-Jdecdutr; considered current and expected
future industrial land use of the Site.
(b) Potentially Exposed Populations. The two scenarios
described above have an associated population that may be exposed
to potential COCs.at the Site. The populations assumed for these
Site uses are described below.
(1) Residential. The Site would be developed for
residential use. People would spend 30 years of
their lifetime on the Site.
(2) Industrial. The Site would continue to be used
for industrial purposes. Workers would spend 25
years of continuous employment at the Site.
(c) Exposure Pathways. An exposure pathway is the
mechanism by which chemicals migrate from their source or .point
of release to the population at risk. Four elements comprise a
complete exposure pathway: (1) a source of a chemical release
(e.g., contaminated soil); (2) movement of contaminants through
environmental media (e.g., rain moving through contaminated soil
into ground water); (3) a point of potential human contact with a
contaminated medium (e.g., use of contaminated ground water for
drinking water); and, (4) entry into the body or exposure route
(e.g., ingestion of drinking water).
The exposure pathways considered in the October 1994
baseline Risk Assessment and June 1995 Risk Assessment addendum
varied depending on the land use and..-on the population .
potentially exposed. For example, in assuming future residential
land use of the Site, the following exposures were evaluated for
adults and children: (1) ingection of soil, (2) ingestion of
ground water, and (3) inhalation of vapor phase chemicals from
ground water while showering. Exposure from contaminants in-air
as a result of the generation and transport of fugitive dust from
surface soil was eliminated as an exposure route of concern
during the initial screening for potential COCs. This was done
by screening modeled air concentrations (derived from maximum
surface soil concentrations) to the Region III risk-based values.
Subsurface soils were evaluated as a part of the October 1994
baseline Risk Assessment to account for the possibility of future
excavation. Excavation can result in subsurface soils being
brought to the surface where contact by people can occur.
The results of the residential land use Risk Assessment
showed that exposures from ground-water ingestion. and inhalation
of volatiles from ground water were below levels of concern for
human health. Because exposures to workers via ground-water
ingestion and inhalation of volatiles would be much lower than
those for residents, the June 1995 Risk Assessment addendum done
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for worker exposure evaluated only ingestion cf conta-ninaced*
soils.
The methods used to assess exposure and toxicity and to
characterize risk are different for lead than for other
contaminants. Therefore, lead is discussed separately from the
other contaminants in the sections below.
A. Risks Related to Compounds Other Than Lead
Calculation of Exposure
EPA's Superfund guidance requires that the reasonable
maximum exposure (RME) be used to calculate potential health
impacts at Superfund sites. The RME is the highest exposure that
is reasonably expected to occur at the site. It is calculated
using conservative assumptions in order to represent exposures
that are both reasonable and protective. In the October 1994
Risk Assessment, both RMEs and average exposures were estimated
for the residential land use scenario and exposure pathways
described above. Average exposures were calculated in order to
represent exposures of a more typical person. In the June 1995
addendum, RMEs were estimated for the industrial land use
scenario.
To estimate exposure, data on the concentrations of
potential COCs in the media of concern at the Site (the exposure
point concentrations) are combined with information about the
projected behaviors and characteristics of the people who may
potentially be exposed to these media (exposure parameters).
These elements of the Site are described below.
(a) Exposure Point Concentrations (EPCs) . For the Octcbc™
1994 Risk Assessment (using a residential scenario), individual
surface and subsurface soil sample results for each sampling
location were used .as EPCs for both the RME and average exposure
calculations. This was done because the density of soil samples
was insufficient to calculate either an upper confidence limit oh
the average (for the RME) or an average (for the average) as an
EPC for a residential lot. Therefore, the reported concentration
is the EPC for that sample grid node location. Average EPCs were
calculated at locations at which duplicate samples were
collected. If a potential COC was not detected or if the
detected concentration was less than the background concentration
for inorganic analyses at a particular location, an EPC was not .
derived for that location. Tables 2-7 through 2-9 in the October
1994 baseline Risk Assessment contain the EPCs.for carcinogenic
and non-carcinogenic potential COCs in surface and subsurface
soil at the Site.
In the June 1995 addendum, Site-wide EPCs for industrial
exposures to soil were generated. The Site-wide EPC calculation
18
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v/ac used because the exposure area was assumed to be larger thsn .
a residential lot. Site-wide EPCs were calculated for the
Mccarty's, Inc. property separately, and for the UPRR and Pacific
Hide and Fur Depot, Inc. properties combined. Where greater than
ten (10) data points were available, the 95 percent upper
confidence limit on the mean was used as the. EPC to calculate the
RME. If less than 10 data points were available, then the
maximum detected concentration was used as the EPC for the RME.
(b) Exposure Parameters. The parameters used to calculate
the RME include body weight, age, contact rate, frequency of
exposure and exposure duration. Exposure parameters were
obtained from EPA Region 10 risk assessment guidance (EPA Region
10 Supplemental Risk Assessment Guidance for Super fund, EPA
1991a).
For all of the media, exposures were estimated assuming
long-term exposures to Site contaminants (e.g., under the
residential scenario: 24 years of daily use for an adult
resident, 6 years for a child resident, and 350 days/year; under
the industrial scenario: 25 years for an adult worker,
250 days/year, 5 days/week, and 8 hours/day).
Table 6 shows the residential and industrial soil ingestion
exposure factors (including exposure frequency and duration)
which are provided in EPA Region 10 risk assessment guidance.
Toxicity Assessment
The purpose of the toxicity assessment is to provide, where
possible, an estimate of the relationship between the extent of
exposure to a contaminant and the increased likelihood and/or
severity of adverse effects. This is done by weighing available
evidence regarding the potential for particular contaminants to
cause adverse effects in exposed individuals.
• EPA has conducted toxicity assessments for many chemicals
and publishes the resulting values, slope factors (Sfs) and
reference doses (RfDs), on the Integrated Risk Information System
(IRIS) or in the Health Effects Assessment Summary Tables
(HEAST). IRIS and HEAST were used as a source for Sfs and RfDs
for this Risk Assessment.
Sfs have been developed for estimating upper-bound excess
lifetime cancer risks associated with exposure to potential
cancer-causing chemicals. They are expressed in units of the.
inverse of milligrams per kilogram of body weight per day
(mg/kg-day)"1. Sfs are derived from the results of human
epidemiological studies or chronic animal bioassays to which
mathematical extrapolations from high to low dose and from animal
to human have been applied.
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RfDs have been cUsveloped t<"> indicate vhs potential for
adverse health effects from ingestion of COCs that exhibit non-
cancer effects, such as damage to organ systems (e.g., the
nervous system, blood forming system, etc.) and learning
disabilities. They are expressed in units of mg/kg-day. RfDs
are estimates within an order of magnitude; of lifetime daily
exposure levels for people, including sensitive individuals, that
are likely to be without risk of adverse effect.
Risk Characterization
The purpose of the risk characterization is to integrate the
results of the exposure assessment and the toxicity assessment to
estimate risk to humans from exposure to Site contaminants.
To estimate cancer risk, the Sf is multiplied by the
exposure expected for that chemical to provide an upper-bound
estimate of the excess lifetime cancer risk. This estimate is
the incremental probability of an individual developing cancer
over a lifetime as a result of exposure to cancer-causing
chemicals at a site. Tor example, an excess lifetime cancer risk
of 1 X' 10"6 indicates that, as a reasonable maximum, estimate, an
individual has an excess 1 in 1,000,000 chance of developing
cancer as a result of site-related exposure to a carcinogen over
a 70-year lifetime under the specific exposure conditions at .a
site.
In defining effects from exposure to noncancer-causing
contaminants, EPA-considers acceptable exposure levels as those
which da not adversely affect humans over their expected lifetime
with a built-in margin of safety. Potential concern for
noncarcinogenic effects of a single contaminant in a single
medium is expressed as a hazard quotient .(HQ) which is the ratio
of the estimated exposure from a site contaminant to that
contaminant's RfD. As exposures increase above the RfD (i.e., as
the HQ goes above 1), the likelihood for non-cancer health
impacts also increases. By adding the HQs for all contaminants
within a medium or across all media to which a given population
may reasonably be exposed, the hazard index (HI) can be
generated. The HI provides a. useful reference point for gauging
the potential significance of multiple contaminant exposures
within a single medium or across media.
Figures 4 and 5 depict the estimated upper-bound cancer
risks and His for Site soil assuming future residential land use
using RME (Figure 4) and average exposure (Figure 5) assumptions.
As shown on Figure 4 (RME assumptions), cancer risk estimates for
most individual sample points were between 1 X 10'€ and 1 X 10~4.
Only two sample points had contaminant levels resulting in
estimated cancer risks above 1 X 10~4. As discussed in the
October 1994 Risk Assessment, arsenic was the primary COC at most
20
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surface soil locations. Pclynuclear aromatic, hydrocarbons also
impacted risk.
The HI, which is the sum of the HQs of all of the COCs
detected at a given soil sampling point, was greater than one (1)
at several sample locations as shown on Figures 4 and 5. All of
these exceedances are below a value of 10. These non-cancer
risks are a result of elevated levels of antimony, arsenic,
cadmium, copper and manganese in the soil.
Table 7 presents the cancer risks, hazard quotients, and
hazard indices for soil ingestion under a RME future industrial
land use scenario.
As can be seen in Table 7, the contaminants at the Site
which yielded excess lifetime cancer risks to workers greater
than 1 X 10~6 assuming industrial exposure were arsenic and
dibenz(a,h)anthracene. Potential excess lifetime cancer risks
associated with industrial exposure to all contaminants in
surface soil at the Site were 7 X 10~6 on the McCarty property;
and, 1 X 10"S for the UPRR and Pacific Hide and Fur Depot, Inc.
properties combined. These risk estimates are within EPA's
acceptable risk range of 1 X 10~4 to 1 X 10~6.
B. Risks Related to Lead Only
There is a large body of scientific literature on the
toxicolpgical effects of lead in humans. Children appear to be
the segment of the population at greatest risk from the toxic
effects of lead. Health impacts from lead are primarily assessed
by using levels of lead in blood. At blood lead levels, of 40 to
100 micrograms per deciliter (ug/dL), children have exhibited
nerve damage, permanent mental retardation, colic, anemia, brain
damage, and death. Blood lead levels as low as 10 ug/dL (or
lower) have been associated with neurological and developmental
defects in children. Blood lead levels of concern for adults are
generally higher than for children. However, studies examining
the relationship between lead exposure and blood pressure suggest
that blood lead levels from as low as 7 ug/dL upward to
approximately 30 or 40. ug/dL may increase blood pressure. In
addition; studies suggest that low levels of exposure for
pregnant women may increase the risk for developmental effects in
the unborn child.
Lead was not included in the quantitative risk estimates
described above for the-other Site contaminants because:
(1) EPA-approved RfDs and Sfs are unavailable, and (2) for the
residential exposure, EPA guidelines specify the use of the EPA
Integrated Uptake Biokinetic (IUBK) model for estimating
acceptable lead levels in soil for children.-
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T"-~ i'UBK -model estimates the blood lead concentrat-ions
expected to result from exposure to lead concentrations in soil
and other media (e.g., air, water, diet, dust, and paint) for
children. EPA recommends a benchmark of either 95% of the
sensitive population of children having blood lead levels below
10 ug/dL or a 95% probability of an individual child having a
blood lead level below 10 ug/dL. When the IUBK model is run
using this benchmark and all the model's default parameters, an
acceptable soil level of about 400 ppm .is predicted for lead.
The IUBK model does not address lead exposure to older
children or adults. Therefore, potential risks associated with
exposures of adult residents and workers could not be
quantitatively evaluated using the IDBK model. However, the
exposure potential and sensitivity of older receptors are
generally lower than those of young children. To assess the
impacts of lead on workers, a 1,000 ppm soil lead level vas .
chosen as protective. This level has been used in the pas.t for
sites when the expected future land use is industrial.
Health impacts for lead were characterized by comparing the
exposure point concentrations calculated for lead ..in soil at the
Site using the methods discussed in the exposure assessment for
other Site contaminants, to 400 ppm -(for residential exposures)
in the October 1994 Risk Assessment, and to 1,000 ppm (for
industrial exposures) in the June 1995 Risk Assessment addendum.
In both cases, risks associated with either residential or
industrial exposures to the elevated concentrations of lead in
Site soil were determined to present significant risks to human
health. Therefore, a cleanup action to address the lead-
contaminated soil at the Site is considered warranted.
Uncertainty Analysis
The numerical results of a risk assessment (HQs and cancer
risk values) are uncertain because of limitations in knowledge
regarding exposure and toxicity. Where information is
incomplete, assumptions must be made: the greater the
uncertainty, the more conservative the assumptions to be
protective.of public health. Even when actual characteristics of
a population are known, selected exposure parameters are biased
toward overestimating rather than underestimating risk for the
majority of the population.
There were several general factors which were considered in
the uncertainty analysis. First, inherent variability exists in •
all analytical results. This variability or uncertainty in the
true result is dependent upon several factors, including the
sample matrix, analytical.method, and the particular analytical
laboratory performing the analysis. Secondly, samples collected
during the field investigations were intended to characterize the
nature and extent of the remaining contamination at the Site.
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Samplns collected in fhi~ manner provide considerable information
about the Site but are not statistically representative of the
contamination that may be present on the Site as a whole.
Thirdly, although not all chemicals detected in environmental
media at the Site were selected as potential contaminants of
concern, the Risk Assessment approach was sufficiently
conservative such that any of the chemicals excluded during the
screening process were considered unlikely to pose a significant
human health risk.
The toxicity assessment process compensates for the basic
uncertainties associated with calculating carcinogenic and
noncarcinogenic effects. This compensation is done through the
use of safety factors (uncertainty factors) and modifying factors
when assessing noncarcinogens, and the use of the upper 95th
percent confidence limit from the linearized multistage model for
the slope factor when assessing carcinogens. The use of the
safety factors and the upper 95th percent confidence Mmit in
deriving the RfDs and Sfs, respectively, ensures that the
toxicity values used in the risk estimation process are unlikely
to underestimate the true toxicity of a chemical.
A discussion is presented below on how specific
uncertainties in the risk assessment process might overestimate
or underestimate risk.
Some of the factors which might have led to a possible
overestimation of risk are as follows:
(1) The exposure assessment calculations assumed that the
concentrations of chemicals in the affected media are at steady
state (i.e., remain constant for the duration of the exposure
period which is 30 years in this assessment) . This may be true
for most inorganics in soil, however this assumption may not be
appropriate if contaminants are mobile or if they degrade in the
environment. Additionally, the Risk Assessment assumed that 100
percent of contaminants associated with the affected media were
bioavailable, however, the bioavailability of most chemicals in
most media is likely less than 100 percent.
(2) The exposure assumptions used for the residential
exposure are conservative ones (e.g., living on the Site for 30
years, 24 hours a day and 250 days per year) to provide a health-
protective assessment for the Site, in accordance with Region 10
risk assessment guidance. Actual risks for future residents may
be much lower than estimated by these assumptions.
In addition, based on comments received during the public
comment period on the Proposed Plan for the Site, EPA
reconsidered the likelihood of the properties shifting from
current industrial use to residential use in the future, and found
the possibility to be remote. The properties have been used for
23
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industrial purposes for the past 50 years; the properties ='-:e
zoned industrial, and are located in an industrial corridor.
(3) Exposures to subsurface soil on the Site will probably
be limited to workers during remediation activities, however,
this scenario represents a health-protective assessment. Actual
risks associated with exposure to subsurface soil may be much
lower than estimated for this scenario.
Conversely, there are factors which might have led to a
possible underestimation of risk. Some of these factors are as
follows:
(1) Although the RI included an investigation of all areas
where Site-related chemicals were suspected because of past
activities, the entire Site was not sampled potentially resulting
in an underestimation of total Site risks.
(2) .Some of the analytical detection limits that were used
in the Risk Assessment were .higher than the analytes' risk-based
screening concentrations. The use of such analytical detection
limits could allow potentially hazardous concentrations of some
chemicals to go undetected.
(3) Exposure point concentrations were calculated to
reflect Site-related risks only and not risks where detected
concentrations were less than naturally occurring background
concentrations of potential inorganic contaminants of concern.
As a result, the risks calculated do not represent overall rii-ks.;.
rather, they represent the maximum possible risks attributable to
Site contaminants.
For more detail regarding uncertainty, see Sections 2.1.7,
2.2.5, 2.3.2 and 2.4.3 of the October 1994 Risk Assessment.
Ecological Risk Assessment
The Ecological Risk Assessment evaluated the potential
ecological impacts associated with chemical contamination in the
surface soil and ground water at the Site.
Within the screening level of this Risk Assessment, six
inorganic contaminant concentrations in ground water exceeded
ecological risk-based screening concentrations. Of these, iron
and total chromium were the principal contaminants of potential
concern. However, the nearest location at which potential
exposures to ground water could occur for ecological receptors is
the Portneuf River, approximately 1,100 feet to the west of the
Site. At this distance, the concentrations of these compounds
would be expected .to decrease due to dilution and attenuation
resulting in minimal risks to aquatic species.
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in soil, the potential ecological r.^sks were attributable to
inorganic contaminants. Copper, lead, and zinc exceeded risk-
based concentrations for vegetation and soil invertebrates by
100-fold, or greater. Cadmium, mercury, and nickel exceeded
risk-based concentrations for either vegetation or soil
invertebrates, or both, by 10-fold or greater. Organic compounds
were detected in soil below all available risk-based
concentrations.
The concentrations of inorganic contaminants may be
sufficiently high in the surface soil to limit the growth of
vegetation and the soil invertebrate populations at the Site.
Lack of habitat limits the populations of other species which may
inhabit the Site. Therefore, the high concentrations of
inorganic contaminants in the soil are not expected to affect
small mammal or bird populations because exposure of species at
the Site is limited.
In summary, the Ecological Risk Assessment determined that
there is very limited potential for adverse impacts to either
plant growth or animal survival, and there is little potential
for Site-related adverse effects on water life in the Portneuf
River.
There are no critical habitats affected by the contamination
and there are no endangered species or habitats of endangered
species affected by Site contamination.
Risk Assessment Conclusion
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
threat to human health, welfare, or the environment.
EPA's Cleanup Objectives
The overall goal of a remedial action is to provide the most;
effective mechanism for protecting human health and the
environment from contaminated media associated with a site. To
facilitate selection of the most appropriate remedial action,
Site-specific cleanup objectives that specify the contaminants of
concern in each medium of interest, exposure pathways and
receptors, and an acceptable contaminant level or range of levels
that is protective of human health and the environment, have been
developed.
Cleanup actions are deemed necessary at the Site because
conditions there pose unacceptable long-term risks for current
and future workers. EPA's objectives for the cleanup are
presented below. The performance standards for the selected
remedy are found on pages 41-42 of the ROD.
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The cleanup objectives will be accomplished by removing the
lead-contaminated soil in order to minimize exposure to
contamination via direct contact, and therefore, further reduce
Site risks.
CLEANUP OBJECTIVES
Environmental Media
Soil and Dust
Ground Water
Chemicals of
Concern
Lead
.
Lead
Exposure Routes
Human exposure
through the incidental
ingestion of soil and
resuspended dust.
Infiltration of soil
contaminants to
ground water and
subsequent exposure
to humans via the
exposure routes for
ground water.
Ingestion
Receptors
Humans
-
Cleanup Objectives
Prevent ingestion of
contaminated soil
and dust at lead
levels above 1,000
ppm.
Prevent
infiltration/migration
of contaminants in
soil to ground water
that would result in
groundjwater
contamination in
excess of the
federal action level.
Prevent ingestion of
ground water
having contaminant
concentrations
above the federal
action level.
KEY FEATURES AMD APPLICABLE OR RELEVANT AMD APPROPRIATE
REQUIREMENTS COMMON TO ALL ALTERNATIVES
Remedial actions must comply with all legally applicable or
relevant and appropriate federal and state requirements (ARARs).
RCRA requirements pertaining to defining and characterizing
hazardous waste, land disposal restrictions, and generator and
transporter requirements are fundamental to all of the cleanup
alternatives (with the exception of the "Ground-Water Monitoring
and Property Restrictions" alternative).
Key features of the remedy and a comprehensive discussion of
the ARARs that are common to all of the alternatives (except the
"Ground-Water Monitoring and Property Restrictions" alternative
or as indicated) are as follows:
* Lead is the principal contaminant of concern of this
operable unit remedial action. Although no federal or
state chemical-specific ARARs exist for lead in soil,
26
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there is To-Be-Considered (TBC) guidance1 which w?..«?
utilized to determine protectiveness under a future
residential land use scenario. EPA's Revised Interim
'Soil Lead Guidance for CERCLA Sites and RCRA Corrective
Action Facilities (Office of Solid Waste and Emergency
Response [OSWER] Directive No. 9355.4-12; EPA 1994)
establishes a residential "screening level" of 400 ppm,
above which further study is warranted (i.e., in the
form of a site-specific risk assessment, which was
conducted for the Site).
Cleanup goals at sites with lead contamination have
typically been based on a residential cleanup goal
range of 500 to 1,000 ppm quoted from previous EPA
guidance. This guidance has since been superseded.
Current EPA guidance, identified in the preceding
paragraph, suggests considering the results from EPA's
IUBK model as well as other factors including costs of
remedial options, reliability of institutional
controls, technical feasibility, and/or community
acceptance to establish cleanup levels.
In the Proposed Plan issued for public comment on.
October 26, 1994, EPA recommended a Site-specific lead
cleanup level of 400 ppm based on future residential
land use. Upon further consideration, EPA has set the
final lead cleanup level at 1,000 ppm based on current
and future industrial (rather than residential) land
use. The 1,000 ppm cleanup level is sufficiently
protective for on-site workers, and has been used in
the past for sites where the expected future land use
is industrial. This is consistent with the present and
anticipated future land use scenario for this Site and
with the cleanup goals that were designated for the
PCB- and commingled PCB/lead-contaminated soil operable
unit cleanup completed in 1992. Furthermore, property
restrictions will be implemented to restrict • future
land use to industrial operations only. Reviews will
be conducted no less often than every five (5)- years to
ensure the remedy continues to provide adequate
protection of human health and the environment.
For soil failing TCLP, off-Site treatment and disposal
must meet all applicable regulations including RCRA
requirements for defining, characterizing and listing
hazardous waste (40 CFR 261), land disposal
restrictions (40 CFR 268) and EPA's Off-Site Disposal
are non-promulgated advisories, criteria, or guidance
issued by federal or state governments that are not legally
enforceable standards.
27
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Rule (40 CFR 300.440). Any off-Site transportation of
RCRA-characteristic soil must comply with RCRA
hazardous waste manifesting and transporter
requirements (40 CFR 262 subpart B and 40 CFR 263)., the
Department of Transportation Hazardous Materials
Regulations which address shipment of any hazardous
material off-site, all relevant Idaho Codes and
Supplements Sections 67-2929, 2930 (Supplement 1988)
and 49-2201 through 2212, and the Idaho Hazardous Waste
Management Regulations (IHWMR) Section 16.01.05006 and.
16.01.05007.
Scrap material that is not being recycled as part of
the operating Pacific Recycling business and which does
not interfere with remedial activities, will be
decontaminated, relocated and recycled. Following
decontamination the property owner(s) will be allowed
to store the material in an area on their respective
properties which is below the 1,000 ppm cleanup level
for lead in soil.
Each alternative requires excavation of ..contaminated
soils on-Site by conventional and protective methods.
During these activities, air monitoring will be
conducted and dust suppressive measures will be
utilized to control the release of dust and
particulates. These measures will comply with the
applicable federal Clean Air Act requirements (40 CFR
42.21 and 50) and the Idaho Rules and Regulations for
the Control of Air Pollution in Idaho (IDAPA
16.01650-.01651, et seq.. 16.01.01585-.01586,.and
16.01.01200). Pocatello is a federal nonattainment
area for particulate matter (PM10) . Dust control
measures must be implemented to prevent remedial
activities at the Site from causing or contributing to
a violation of the national ambient air quality
standards and Idaho state standards.
Occupational Safety and Health Act (OSHA) requirements
.(29 CFR Part 1910 and 1926) pertain to workers engaged
in response or other hazardous waste operations.
Excavation of the lead-contaminated soils is considered
a hazardous waste Operation at this Site. Although
this regulation is not an ARAR, remedial workers must
comply with these OSHA requirements.
EPA is requiring one year of quarterly ground-water
monitoring (with the exception of the "Ground-Water
Monitoring and Property Restrictions" and the on-Site
containment/fixation alternatives which each require 30
years of monitoring). Under the National Primary
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Drinking Water Regulation, Control of Lead and Copper
(40 CFR 141.80), the federal action level for lead at
the consumer's tap is 15 parts per billion. Under
Superfund policy, this federal action level is relevant
and appropriate as the cleanup standard for ground
water beneath the Site.
Selected institutional controls will be used to prevent
exposure to contaminants remaining at the Site at
concentrations above health risk levels.
Implementation of the controls will assure that the
remedy is protective of human health and the
environment. The controls will include installation
and maintenance of access restrictions (i.e., security
fences to prevent unauthorized access to non-workers).
In addition, land use restrictions, will be required
limiting future property usage to industrial operations
only. These restrictions will prohibit land uses
allowed .under residential/neighborhood commercial and
professional zoning. These controls will be
implemented no later than completion of the remedial
construction activities.
DESCRIPTION OF FINAL OPERABLE UNIT REMEDIAL ALTERNATIVES
EPA considered the following seven (7) cleanup alternatives
to address the remaining contamination at the Site:
Alternative 1 .- Ground-Water Monitoring & Property Restrictions
Alternative 2A - Limited Soil Removal/Soil Cap
Alternative 2B - Limited Soil Removal/Pavement Cap
Alternative 3A - Off-Site Disposal of All Surface Soil
Alternative 3B - Off-Site Disposal of Surface/Subsurface Soil
Alternative 4 - Soil Washing
Alternative 5 - On-Site Fixation/Containment
Although -the FS identifies a "No Action" alternative
(Alternative 1 above), it requires long-term ground-water
monitoring and property restrictions. By definition, this
alternative is not a "No Action" alternative. A "No Action"
alternative involves no treatment, engineering controls or
institutional controls. Even though ground-water monitoring and
property restrictions are required under this alternative, EPA
did not evaluate this alternative as a viable cleanup option for
this Site, given the limited extent and nature of the actions it
requires. Alternatives 2 through 5 provide varying degrees of
protection of human health and the environment. All of the
alternatives (except Alternative 1) involve treatment of some of
the lead-contaminated soil prior to off-Site disposal. A
comprehensive assessment of these alternatives against EPA's nine
evaluation criteria begins on page 34 of this document.
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mmon elements to each of the alternatives (with the
exception of Alternative 1) include the excavation and removal of
all lead-contaminated soil considered hazardous waste under RCRA,
ground-water monitoring, scrap management including
decontamination, relocation, and recycling, and long-term
operation and maintenance (O&M) activities. Since O&M costs
fluctuate considerably over time and from year to year, the total
estimated O&M costs over a 30-year period (time period used for
cost estimating purposes) are represented in the "Estimated 30-
Year O&M Costs" line item under each alternative.
Alternative 1: Ground-Water Monitoring and Property Restrictions
Estimated Capital Cost: $20,000
Estimated 30-Year O&M Costs: $803,388
Estimated Present-Worth Costs: $823,388
Estimated Implementation Timeframe: less than 1 month
The "Ground-Water Monitoring and Property Restrictions"
alternative would leave the contaminated soil and scrap in place,
as is. This alternative would, however, require repair and
maintenance of the fence, property restrictions limiting future
land use to industrial operations only, five-year reviews, and
implementation of a ground-water monitoring program. One of the
cleanup objectives for this Site is to prevent the infiltration/
migration of contaminants in soil to ground water resulting in
ground-water contamination in excess of Site-specific action
levels. Since none of the contaminated soil would be removed
from the Site under this- alternative, ground-water monitoring is
deemed necessary for protectiveness reasons.
Alternative 2A: Limited Soil Excavation and Soil Cap
Estimated Capital Cost: $4,034,287
Estimated 30-Year O&M Costs: $157,782
Estimated Present-Worth Costs: $4,192,069
Estimated Implementation Timeframe: 4 months
Under this alternative, excavation of all lead-contaminated
soil considered to be hazardous waste would be required, followed
by treatment and disposal in an off-Site permitted landfill. A
soil cap, consisting of compacted clean fill overlain with
tppsoil to allow revegetation over the remaining contaminated
soil above the cleanup level, would be installed. Property
restrictions limiting future land use to industrial operations
only would be implemented and, measures taken to restrict
activities that could disturb the soil cap. In addition, fiver
year reviews would be conducted, one (1) year of quarterly
ground-water monitoring performed to determine the effectiveness
of the cleanup and to ensure that no contaminants were
accidentally mobilized during implementation of the remedy,
monitoring well abandonment, and long-term O&M activities
including fence and cap repair.
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Alternative 2B: Limited Soil Excavation and Pavement Cap
Estimated Capital Cost: $4,324,277
Estimated 30-Year O&M Costs: $429,631
Estimated Present-Worth Costs: $4,753,908
Estimated Implementation Timeframe: 5 months
This alternative is almost identical to Alternative 2A
described above, except that a water resistant pavement cap would
be installed instead of a soil cap. The water resistant pavement
cap would consist of an 8-inch stone subbase overlain with four
(4) inches of bituminous concrete. Although a synthetic material
cap was also considered, the pavement cap was selected in this
alternative because of its durability; cost effectiveness and
ease of maintenance. Long-term O&M activities would be the same
as Alternative 2A above except maintenance of the cap would
include frequent inspections (at least annually) followed by
resurfacing of the wearing course (top 1 to 1.5 inches) due to
cracking, settlement, and/or subsidence that might occur.
Alternative 3A: Extensive Surface Soil Excavation
Estimated Capital Cost: $4,797,570
Estimated 30-Year O&M Costs: $149,660
Estimated Present-Worth Costs: $4,947,230
Estimated Implementation Timeframe: 4 months
This alternative requires the excavation of all contaminated
surface soil (to a maximum depth of 1 foot) which exceeds 1,000
ppm lead. In addition, subsurface soil which has been identified
as RCRA-characteristic waste would require excavation. All soil
failing the RCRA TCLP test for leachability requires treatment
prior to placement in an off-Site, permitted landfill. All
remaining excavated soil would also be disposed at a permitted
landfill. The Site would be backfilled and graded. The area
would then be mulched and seeded to provide a soil cap. One year
of quarterly ground-water monitoring would be performed to
determine the effectiveness of the cleanup and ensure that no
contaminants were accidentally mobilized during implementation of
the remedy followed by monitoring well abandonment. The entire
Site boundary would remain fenced, property restrictions
instituted to limit future land use to industrial operations only
and prevent disturbances to the subsurface lead-contaminated
soil, and five-year reviews conducted. Long-term O&M activities
would include fence repair arid assessment of the soil cap's
integrity.
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Alternative 3B: Surface and Subsurface Soil Excavation
Estimated Capital Cost: $4,950,894
Estimated 30-Year O&M Costs: $141,539
Estimated Present-Worth Costs: $5,092,433
Estimated Implementation Timeframe: 4 months
Unlike Alternative 3A above, all surface and subsurface,
lead-contaminated soil above the Site cleanup level of 1,000 ppm
would be excavated and disposed off-Site. Soil failing the RCRA
TCLP test would require treatment prior to off-Site disposal in a
permitted landfill. All remaining excavated soil would also be
disposed at a permitted landfill. The Site would be backfilled
and graded, as necessary, following the excavation. One year of
quarterly ground-water monitoring would be performed to determine
the effectiveness of the cleanup and ensure that no contaminants
were accidentally mobilized during implementation of the remedy
followed by monitoring well abandonment. The entire Site.
boundary would remain fenced, property restrictions instituted to
limit future land use to industrial operations only, and five-
year reviews conducted. Long-term O&M activities would include
fence repair, as needed.
Alternative 4: Soil Washing
Estimated Capital Cost: $5,291,677
Estimated 30-Year O&M Costs: $141,539
Estimated Present-Worth Costs: $5,433,216
Estimated Implementation Timeframe: 5 months
Under this alternative, .all contaminated surface and
subsurface soil exceeding the 1,000 ppm cleanup level would be
excavated. The soil would then be "washed" on-Site. The
"washing" procedure consists of four (4) basic steps: (1) the
soil is screened to remove oversize (2 inches and larger)
material, water is added and a soil/water slurry.created,
(2) using a hydrocyclone, the coarse- and fine-grained sand are
separated, (3) air flotation is used for treatment of the coarse
fraction, and (4) a sludge thickener is added to the slurry
overflow from the hydrocyclone. The water overflow is then
returned to the first step in the process for reuse. The
technology is designed to separate the lead-contaminated fine
particles from the coarser material. The finer particles
(residuals) are the fraction in which the lead is concentrated.
For this alternative, a sludge cake composed of the residuals
would be transported off-Site to a permitted, hazardous waste
facility, treated and disposed.
The excavated areas would be backfilled with the "cleaned"
soil if it meets the cleanup level, and/or additional clean fill,
and graded. Finally, off-Site treatment and disposal of:
(1) contaminated oversize material and, (2) residuals, as
mentioned above, and waste water resulting from the soil washing
would occur. The contaminated material and the waste water would
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be testae! tc- determine the appropriate type of off-Site treatment
and disposal necessary to meet all regulatory requirements.
One year of quarterly ground-water monitoring would be
conducted to determine the effectiveness of the cleanup and to
ensure that no contaminants were accidentally mobilized during
implementation of the remedy followed by monitoring well
abandonment. The entire Site boundary would remain fenced,
property restrictions instituted to limit future' land use to
industrial operations only, and five-year reviews conducted.
Long-term O&M activities would include fence repair, as needed.
Alternative 5: On-Site Fixation/Containment
Estimated Capital Cost: $4,432,015
Estimated 30-Year O&M Costs: $803,306
Estimated Present-Worth Costs: $5,235,321
Estimated Implementation Timeframe: 6 months
This alternative involves excavation, on-Site fixation of
the most highly contaminated soil, containment of the remaining
contaminated soil above the 1,000 ppm cleanup level and, off-Site
disposal of oversized material. Fixation involves..adding binding
agents to the contaminated soil to create a cement-like mass.
Once the soil has been 'fixated', it would be placed along with
the remaining soil into a permeable geotextile-lined, on-Site
containment cell (i.e., an excavated area large enough to hold
the cement-like mass and the other contaminated soil) and a .soil
cap placed over the cell. For cost estimating purposes under
this alternative, thirty (30) years of semi-annual ground-water
monitoring would be conducted to determine the effectiveness and
permanence of the remedy. The entire Site boundary would remain
fenced, property restrictions instituted to limit future land use
to industrial operations only ,and prevent activities that could
disturb the cell and cap, and five-year reviews conducted.
PRP Alternative Proposed During Public Comment Period
EPA was asked to consider another alternative in addition to
those described above. This alternative was suggested by the PRP
Group during the Proposed Plan public comment period. The
proposed alternative includes the installation of an industrial-
grade cap, consisting of a 4-inch thick asphalt layer underlain
by 6 inches of crushed rock, over the operational portions of
Pacific Recycling and OPRR where lead concentrations exceed the
cleanup level of 1,000 ppm. A Portland cement concrete pad would
be placed in the vicinity of the existing crane on property
leased from UPRR that is currently part of Pacific Recycling's
operating facility. Soil above 1,000 ppm lead on the McCarty
property would be consolidated in the northeast corner of the pit
and covered with 2 1/2 feet of clayey soil under a 1/2 foot
vegetative cap. Other components of the proposed alternative
include Site grading and berm construction for surface water
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control, scrap -relocation prior to cap c<--t:.Gt-.ructicri, installation
of permanent chain-link fencing, seeding and fertilizing of the
soil cap, and institutional controls. The proposed alternative
does not include excavation, treatment and off-Site disposal of
the RCRA-characteristic soil.
The PRPs estimate the cost for this alternative to be
approximately $1,210,000. A comparison of this alternative
against the nine criteria and the other alternatives considered
is presented in the following section.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
Each remedial alternative must be evaluated according to
nine criteria that serve as the basis for comparing the
alternatives, and for ultimately selecting an appropriate
remedial action. The evaluation criteria are divided into three
categories: (1) threshold criteria that relate directly to
statutory requirements and must be satisfied by the chosen
alternative; (2) primary balancing criteria that include.long-
and short-term effectiveness, implementability, reduction of
toxicity, mobility or volume, and cost; and (3). modifying
criteria that measure the acceptability of the alternatives to
state agencies and the community. A summary of relative
performance of the alternatives based on these criteria is
included in Table 8.
Alternative 1 ("Ground-Water Monitoring and Property
Restrictions") was included in the development and evaluation of
the final remedial alternatives to provide a basis for
comparison. However, this alternative does not meet the
threshold criteria, which include overall protection of human
health and the environment and compliance with ARARs. Under this
alternative, no remedial actions would be taken to address any of
the .contaminated material at the Site. Ground-water monitoring
and property restrictions are not considered adequate measures to
protect human health and the environment at this Site.
Therefore, this alternative is not discussed in the comparison
provided below.
A. Threshold Criteria
The remedial alternatives were first evaluated in relation
to the threshold criteria: overall protection of human health and
the environment, and compliance with ARARs. The threshold
criteria must be met by the alternatives to be considered as
potential remedies.
1. Overall Protection of Human Health and the Environment:
This criterion addresses whether a remedial alternative
protects human health and the environment. Protection is
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determined by assessing whether the risks associated with each
exposure pathway (i.e., ingestion of soil, ingestion of ground
water, and inhalation of vapor phase chemicals from ground water
while showering) are eliminated, reduced, or controlled through
treatment and engineering or institutional controls. The Risk
Assessment results indicate that risks posed at the Site are from
the incidental ingestion of lead-contaminated soil.
Alternatives 2 through 5 provide adequate protection of
human health and the environment. Alternatives 3B and 4,
however, provide the greatest level of protection because all
contaminated material would be removed from the Site above the
1,000 ppm cleanup level. Ranking third amongst all of the
alternatives in providing adequate protection, Alternative 3A
requires excavation, off-Site disposal of all soil above RCRA
regulatory levels, and capping of surface soil exceeding the .
1,000 ppm cleanup level. Following Alternative 3A in its degree
of protectiveness, Alternative 5 requires on-Site treatment of
all soil failing the RCRA regulatory level, containment of the
remaining soil above 1,000 ppm, and capping to prevent against
direct contact and ingestion. To a lesser extent, Alternatives
2A and 2B achieve protection by capping the Site thereby
preventing exposure to the contaminated soil.
2. Compliance with ARARs: .
The selected remedial action must comply with identified
substantive applicable requirements under federal and state laws.
Remedial actions must also comply with laws and regulations that
are not directly applicable, but do pertain to situations
sufficiently similar to those encountered at the-Site, so that
use of the requirements is well suited to the Site. These are
known as relevant and appropriate requirements. Evaluation of
the remedial alternatives with chemical-, location-, and action-
specific ARARs is necessary for determining compliance.
Alternatives 2 through 5 meet the ARARs for this Site, and
no waivers are necessary.
B. Primary Balancing Criteria
Each alternative that satisfies the threshold criteria is
evaluated against the following five balancing criteria:
3. Long-Tertn Effectiveness and Permanence:
This criterion evaluates the ability of a remedial
alternative to maintain reliable protection of human health and
the environment once remediation goals have been achieved. The
magnitude of the residual risk is considered as well as the
adequacy and reliability of controls.
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Alternatives 3B *nd 4 best -atisfy this criterion. Under
both alternatives, all contaminated material above the 1,000 ppm
cleanup level would be removed from the Site. Alternatives 2A,
2B, 3A, and 5 all include removing and treating all of the lead-
contaminated soil failing the RCRA hazardous waste test and
capping varying amounts of the remaining contaminated soil. The
likelihood of effectively and permanently maintaining either a
soil or a pavement cap under Alternatives 2A, 2B, 3A, 5 and the
alternative proposed by the PRP Group on the operating facility
is highly uncertain given ongoing scrap handling operations.
Long-term effectiveness is also dependent on assuming future land
use is limited to industrial activities only. The 1,000 ppm
cleanup level is not considered protective of children and
fetuses.
4. Reduction of Toxicity, Mobility or Volume Through Treatment:
This criterion addresses the statutory preference for
selecting remedial actions that use treatment technologies that
permanently reduce the toxicity, mobility or volume of the
hazardous substances.
Alternatives 4 and 5 reduce the mobility of the most highly
contaminated soil through on-Site treatment. Additionally,
Alternatives 2A, 2B, 3A and 3B reduce the mobility of the most
highly contaminated soil through treatment. Alternative 4 best
satisfies the regulatory preference for treatment and is the most
effective alternative for reducing the toxicity, mobility and
volume. Under Alternative 4, contaminants would be washed from
the soil, concentrated as fine material in the waste water, and
treated. Alternative 5 reduces the mobility of the most highly
contaminated soil using fixation prior to placement in the on-
Site landfill. However, soil above the 1,000. ppm cleanup level
which is not designated RCRA-characteristic soil would be
consolidated in the on-Site landfill thereby increasing the
volume.
5. Short-term Effectiveness:
This criterion refers to the period of time needed to
achieve protection, and any adverse impacts on human health and
the environment, specifically site workers and community
residents, that may be posed during the construction and
implementation period until cleanup goals are achieved..
Alternatives 2 through 5 are expected to create some short-
term risk to the community and Site workers associated with the
disturbance of contaminated dust generated during excavation of
the contaminated soil. However, during cleanup activities, no
visible dust will be allowed at the property boundaries, and dust
suppressant will be used. Alternatives 2A and 2B would pose the
fewest short term hazards because the least amount of
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contaminated soil would be excavated. The remaining soil above
1,000 ppm would be capped immediately.
The.implementation time required (including time to conduct
treatability studies, if necessary) ranges from 7 months
(Alternative 4) down to 3 months (Alternative 2A). Alternatives
2B, 3A, and 3B would require 4 months to implement and
Alternative 5 would require 6 months.
6. Implementability:
This criterion refers to the technical and administrative
feasibility of a remedial alternative, including the availability
of goods and services needed to implement the selected remedy.
Alternatives which would require excavation and off-Site
disposal of contaminated soil, with or without capping, are the
easiest to implement. These alternatives include 2A, 2B, 3A and
3B. The implementability of soil washing (Alternative 4) or on-
Site fixation/containment (Alternative 5) would have to be .
demonstrated using Site-specific testing of the technology (i.e.,
treatability testing).
Services necessary for implementing Alternatives 2A through
3B are expected to be available within the state of Idaho.
Alternatives 4 and 5 require particular expertise which may also
be available in-state. Finally, in-state and out-of-state
permitted municipal landfills (operated under 40 CFR 258) with
the capacity for handling the off-Site disposal of treated and
untreated soil are also available.
7. Cost:
Evaluation of project costs requires an estimation of the
net present value of capital costs and O&M costs. The costs
presented below (and in the 1994 FS) are estimates. Actual costs
could vary based on the final design and detailed cost
itemization.
Total estimated costs for the alternatives considered range
from approximately $4,192,069 (Alternative 2A- Limited Soil
Excavation and Soil Cap) to approximately $5,433,216
(Alternative 4- Soil Washing). The cost spread between the
estimate of the least expensive alternative (Alternative 2A) and
the most expensive alternative (Alternative 4) is $1,241,147.
Alternative 3B is at the higher end of the range with costs
estimated to be $5,092,433. Alternative 5 has costs associated
with ground-water monitoring estimated over a 30-year time
period.
As stated in the RI/FS, scrap management costs account for a
large percentage of the total remedial costs for Alternatives 2
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through 5. These alternatives all have costs associated with O&M
of the cleanup. which have been estimated over a 30-year time
period. Present worth of annual O&M costs were calculated using
a discount rate of 6 percent which is approximately the current
30-year treasury rate. Costs for all alternatives are estimates
only. Actual costs are likely to be within the +50 to -30
percent range.
C. Modifying Criteria
Modifying criteria were used in the final evaluation of the
remedial alternatives following the close of the public comment
period, and were used to modify the preferred alternative that
was discussed in the Proposed Plan. .
8 . State Acceptance:
This criterion refers to whether the IDEQ agrees with the
preferred remedial alternative.
IDEQ supports the preferred alternative of Site-wide surface
and subsurface excavation, treatment as necessary,., and off-Site
disposal of lead-contaminated soil above 1,000 ppm. IDEQ has
been involved with the development and -review of the final
operable unit RI/FS, the Proposed Plan, and this ROD.
9. Community Acceptance:
This criterion refers to the public support of a given
remedial alternative.
Community response is presented in the Responsiveness
Summary, which addresses the comments received during the public
comment period. Three letters were received during the comment
period: two from private citizens (one expressing support for the
cleanup and the other expressing concern over.the length of time
taken to study and clean up the Site, and' the. significant costs
associated with Superfund work) , and an extensive comment package
from the PRP Group. The PRP Group was primarily concerned with
the recommended cleanup level based on a future residential land
use scenario, the possible underestimation of the volume of
contaminated soil requiring remediation at the Site, the lack of
a current industrial land use" risk evaluation, and the proposed
remedy.
Nine Criteria Evaluation of PRP Group Proposed Alternative
EPA and IDEQ believe the alternative proposed by the PRP
Group during the public comment period as described on pages 33-
34 of the ROD, would not be as protective of human health and the
environment, nor as cost effective as EPA's selected remedy. EPA
has determined that, under any scenario, it is unacceptable to
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leave the most highly contaminated soil (i.e.. soil which is
RCRA-characteristic) untreated because of the potential threat to
ground water from leaching. There is a source of potable ground
water beneath the Site.
The industrial-grade cap included in the alternative
proposed by the commenters is considered inadequate based on the
design requirements of caps required at similar operating
facilities undergoing cleanup under state and/or federal
authorities. For example, an industrial-grade cap consisting of
12 inches of reinforced concrete over an impermeable liner
underlain by 6 inches of compacted aggregate was considered
adequate at a facility in Washington state, General Metals, where
recycling activities comparable to those conducted at Pacific
Recycling occur. The PRP Group's proposed cap design is not
comparable. In the non-operating areas of facilities, two
acceptable cap compositions were evaluated by EPA: a low
permeability asphalt cap composed of an 8 inch compacted gravel
subbase, a 6 inch asphaltic concrete binder course and a 3 inch
asphalt wearing course, and a cap consisting of a 6 inch
compacted .gravel subbase, a 3 inch low permeability asphalt
course and a 9 inch aggregate industrial asphalt surface.
Neither of these designs was proposed by the PRP Group for the
non-operating areas of the Site.
-The long-term permanence of the cap is especially important
for the type of alternative proposed by the PRP Group because of
the very high lead levels found in Site soils which pose the
principal threat at the Site. The nature of the on-going scrap
recycling activities, particularly movement of heavy equipment
and scrap, could compromise the effectiveness and permanence of
the cap, thereby increasing the risk of exposure to contaminated
Site soil, particularly given the composition of the cap in the
suggested alternative. Additionally, future activity on the
McCarty property where the soil cap would be placed over the
consolidated, lead-contaminated soil, would be severely
restricted.
The PRPs estimate the cost for this alternative to be
approximately $1,210,000. The estimated costs for implementing
the suggested alternative, modified to include excavation,
treatment and off-Site disposal of all RCRA-characteristic soil
and to reflect the cap design discussed above for both operating
and non-operating portions of the Site ranged from $5,350,000
to $5,440,000. This range is $200,000 to $300,000 more than the
selected remedy which is estimated to cost $5,092,433.
The PRP Group's alternative as described on pages 33-34 of
the ROD compares favorably with Alternative 2B in that it can be
relatively easily implemented, and would pose few short-term
risks. It is unclear whether this alternative would comply with
ARARs since EPA has not done a complete analysis. The PRP
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Group's suggested alternative would not reduce toxicicy, mobility
or volume through treatment. Even though capping is not
considered treatment, mobility of the contaminants would be
impeded by the cap. Neither EPA nor IDEQ favor capping of the
Site particularly because of the difficulty in maintaining long-
term permanence and effectiveness of the cap at an operating
facility and on property whose future use is currently unknown.
SELECTED REMEDY
The selected remedy at the Site is Alternative 3B, Site-wide
surface and subsurface- soil excavation and off-Site disposal of
lead-contaminated soil above 1,000 ppm, and decontamination/
recycling of scrap material. This remedy was selected because it
best satisfies the nine criteria previously identified. The most
important of the balancing criteria which clearly set this remedy
apart from the other alternatives are its long-term effectiveness
and permanence, its ease of implementation and relatively short
implementation time, and its cost competitiveness. It is
protective of human health and the environment, complies with all
applicable or relevant and appropriate environmental regulations,
and removes lead-contaminated soil to a level protective of
future industrial land use activities.
The specific components of the selected final operable unit
remedial action for lead-contaminated soil" include:
(1) Excavation, processing, transport and disposal of
approximately 6,510 cubic yards of lead-contaminated soil
(all soil above 1,000 ppm- total concentration) as follows:
(a) All soil above the lead cleanup level of 1,000 ppm but
below the RCRA-characteristic waste level will be
disposed in a permitted, municipal landfill operated
under 40 CFR 258,
(b) All soil designated RCRA-characteristic waste for lead
will be treated and disposed in a permitted, municipal
landfill operated under 40 CFR 258,
(c) Scrap material that is not being recycled as part of
the operating Pacific Recycling business and which does
not interfere with remedial activities, will be -
decontaminated, relocated and recycled. Following
decontamination, if necessary, the property owner(s)
will be allowed to store the material in an area on
their respective properties which is below the 1,000
ppm cleanup level for lead in soil. As stated in the
RI/FS, scrap management costs account for a large
percentage of the total remedial costs. It is feasible
that these costs could be significantly reduced if the
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owners of the scrrsp can determine a mutually
acceptable, cost-effective method of scrap disposition.
(d) The treatment and disposal facility must be acceptable
for Superfund waste under EPA's Off-Site Disposal Rule.
(2) Backfilling with clean soil from off-Site, grading and
restoration of surface drainage will occur following the
excavation;
(3) Implementing supplementary engineering controls and
environmental monitoring, such as air monitoring, to
minimize exposure to releases of hazardous substances during
cleanup activities;
(4) Requiring institutional controls including permanent fencing
to restrict public access to the Site, and property
restrictions limiting future property usage to industrial
operations only on all properties that comprise the Site
(the form of restrictions will be determined following
issuance of this ROD);
(5) One year of quarterly ground-water monitoring is required to
determine the effectiveness of the cleanup and ensure that
no contaminants were accidentally mobilized during
implementation of the remedy, followed by abandonment of the
monitoring wells;
(6) Reviews will be conducted no less often than every five (5)
years after commencement of the remedial action to ensure
that the remedy continues to provide adequate protection of
human health and the environment.
Remedial Action Performance Standards:
The final operable unit remedial action shall'be completed
subject to -the following standards of performance.
A. The final operable unit remedial action area is shown
in Figure 2. Surface and subsurface areas which
require remediation are also delineated on the figure.
B. Within the final operable unit remedial action areas,
all soil with lead concentrations of 1,000 ppm or above
shall be excavated, tested and treated if necessary,
and disposed off-Site. Lead-contaminated soil which
has a TCLP test result of less than the hazardous waste
characteristic test concentration in 40 CFR 261.24
shall be placed in a permitted, municipal landfill
operated under 40 CFR 258. Lead-contaminated soil
failing the RCRA TCLP leachate test which has a TCLP
test concentration equal to or greater than the
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hazardous waste characteristic level in 40 CFR 261.24
shall be treated prior to placement in a permitted,
municipal landfill operated under 40 CFR 258. Sampling
methods and protocols to be utilized in determining the
extent, character and fate of the contaminated soils
will be done in accordance with an EPA-approved
sampling and analysis plan.
C. All contaminated metal scrap remaining within the final
operable unit remedial action area as depicted in
Figure 2, except that currently undergoing recycling as
part of the operating Pacific Recycling business and
which does not interfere with remedial activities, will
be decontaminated and recycled.
D. There are two remedial compliance objectives which must
be addressed during verification of Site cleanup. One
objective is to verify that Site soil meets the 1,000
ppm cleanup level. Verification sampling to evaluate
the statistical compliance with the 1,000 ppm cleanup
level must be based upon a sufficient number of
analytical samples to calculate a statistically valid
upper confidence interval for the mean lead
concentration. The other objective is to determine
whether lead "hot spots" have been remediated.
Detailed procedures for meeting both of these
objectives will be established during remedial design.
E. Backfilling, grading and restoration of surface
drainage shall be conducted to the extent necessary to
ensure Site stability and prevent future drainage or
erosion problems.
F. All federal and state rules and regulations related to
protecting air quality (via air monitoring and dust
suppression), maintaining OSHA health and safety
standards, and ensuring the proper handling and
shipment of hazardous materials off-Site must be
complied with during the remedial action.
STATUTORY DETERMINATIONS
EPA's primary responsibility at CERCLA sites is to undertake
remedial actions that are protective of human health and the
environment. In addition, Section 121 of CERCLA, 42 U.S.C.
§9621, establishes several other statutory requirements and
preferences including: (1) a requirement that the remedial
action, when complete, complies with applicable or relevant and
appropriate environmental standards established under federal and
state laws unless a statutory waiver is invoked; (2) a
requirement that the remedial action be cost-effective and
utilize permanent solutions and alternative treatment
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technologies or resource recovery technologies to the maximum
extent practicable; and, (3) a statutory preference for remedies
that permanently and significantly reduce the volume, toxicity or
mobility of hazardous substances over remedies that do not
achieve such results through treatment.
The selected remedial action meets the statutory
requirements of CERCLA, and, to the extent practicable, the NCP.
The evaluation criteria are discussed below.
Protection of Human Health and the Environment:
The selected final operable unit remedial action is
protective of human health and the environment and will eliminate
the .risks above the 1,000 pptn lead cleanup level posed through
each pathway by removal, treatment to the .extent practicable, and
disposal of lead-contaminated soil.
For ground water, no remedial action under this final
operable unit cleanup is necessary to protect human health and
the environment. This conclusion is based on the results of
quarterly ground-water monitoring conducted in 1989-1990 and
resumed in 1990-1991 which confirm that there are no contaminants
at concentrations above federal drinking water MCLs or action
levels in ground water beneath the Site.
This remedial action will eliminate the source of lead
contamination at the Site above the 1,000 ppm soil cleanup level.
While this remedial action will effectively and permanently
remove on-Site lead-contaminated soils above levels protective of
on-Site workers under a future industrial land use scenario, lead
and PCBs will remain above residential health-based levels
thereby prohibiting unrestricted future land use. Reviews will
be conducted no less often than every five (5) years following
initiation of the remedial action to ensure adequate protection
of human health and the environment.
Compliance with Applicable or Relevant and Appropriate
Requirements:
Pursuant to Section 121(d) of CERCLA, 42 U.S.C. §9621(d),
remedial actions shall, upon their completion, reach a level or
standard of control for such hazardous substances, pollutants or
contaminants which at least attains legally applicable or
relevant and appropriate federal standards, requirements,
criteria, or limitations, or any promulgated standards,
requirements, criteria, or limitations under a state
environmental or facility siting law that is more stringent than
any federal standard (ARARs).
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The selected remedial action satisfies the requirements .of
this section of CERCLA by complying with all identified ARARs.
No ARAR waivers have been sought or invoked for any component of
the selected remedial action. The chemical- and action-specific
ARARs (there are no location-specific ARARs for this Site)
include the following:
RCRA regulations (40 CFR 261-263 and 268) as incorporated by
the applicable State of Idaho Regulation, address the
requirements for defining, characterizing and listing
hazardous wastes; for generators pertaining to manifesting,
transporting, and recordkeeping; for transporters pertaining
to shipment of hazardous wastes off-site; and, land disposal
restrictions. These regulations are applicable to the
characterization and appropriate disposal of lead-
contaminated soil from the Sice.
Clean Air Act (42 USC 7409. 7412) and the "Idaho Rules and
Regulations for the Control of Air Pollution in Idaho
(Citation Section 16.01.1011-1012, 16.01.1251-1253. and
16.01.1501-1504). are applicable to the control of fugitive
dust emissions during excavation and other field activities,
and pertain to compliance with the national ambient air
quality standards and national emission standards for
hazardous air pollutants. .
Idaho Solid Waste Management Regulations and Standards
Manual (Sections.16.01.6005.01 and 16.01.6008.07). are
relevant and appropriate to the management of all solid
wastes during their storage, collection, transfer, •
transport, processing, separation, treatment, reuse,
recycling, or disposal to prevent health hazards, public
nuisances, or pollution to the environment.
Idaho Administrative Procedures Act (Sections 16.01.2050,02,
16.01.2020.06. 16.01.2051. 16.01.2200, and 16.01.2800). are
relevant and appropriate to the protection of state ground
water against unreasonable contamination or deterioration.
These standards are designed to control and regulate the
public drinking water system in order to protect the health
of consumers. One year of quarterly ground-water monitoring
is required following completion of remedial construction
activities at the Site.
National Primary Drinking Water Regulation, Control of Lead
and Copper (40 CFR 141.80). sets the federal action level
for lead at the consumer's tap at 15 parts per billion.
Under Superfund policy, this federal action level is
relevant and appropriate as the ground-water standard for
the Site. Under the Clean Water Act (CWA) (33 USC 1251,
40 CFR Part 230, 231), State Antidegradation Requirements/
Use Classification require every state to classify all the
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vvo.Lers within its boundaries according to intended use.
There are two aquifers (upper and lower) beneath the Site.
EPA has designated the upper aquifer as Class IIB since it
is potentially available for drinking water, agriculture or
other beneficial uses. The lower aquifer is Class I (i.e.
drinking water) as it is the primary drinking water source
for the community.
National Oil and Hazardous Substances Pollution Contingency
Plan (40 CFR 300.440) contains the applicable procedures for
planning and implementing off-site response actions. At
this Site, the requirements of the Off-Site Disposal Rule
must be met.
Other Criteria. Advisories, or Guidance To-Be-Considered (TBC)
The following guidance was also considered:
EPA's Revised Interim Soil Lead Guidance for CERCLA Sites
and RCRA Corrective Action Facilities (Office of Solid Waste
and Emergency Response [OSWER] Directive No. 9355.4-12; EPA
1994) establishes a residential "screening level" of 400
ppm, above which further study is warranted (i.e., in the
form of a site-specific risk assessment, which was conducted
for the Site). A cleanup level of 1,000 ppm has been
selected for this Site since this level is considered
protective of on-Site workers; the property comprising the
Site is zoned industrial; and, property restrictions will
limit future property use to industrial activities only.
Remedial actions taken at this Site must further comply with
the Department of Transportation Hazardous Materials Regulations
(49 CFR, Parts 171, 172, 173 subparts A, B, J and N, and 177, 178
and 180, and subchapter C) which address shipment of any
hazardous material off-site, and all relevant Idaho Codes and
Supplements Sections, specifically 67-2929, 2930 (Supplement
1988) and 49-2201 through 2212, and the Idaho Hazardous Waste
Management Regulations (IHWMR) Sections 16.01.05006 and
16.01.05007. In addition, the Occupational Safety and Health Act
(29 CFR Parts 19010 and 1926) must be adhered to as it addresses
safety requirements for workers engaged in response or other
hazardous waste operations.
Cost-Effectiveness:
The cost-effectiveness of each alternative was evaluated,
including those which were screened out prior to the final
alternatives assessment in the Feasibility Study. The selected
final operable unit remedial action is cost-effective as it
affords overall effectiveness and protectiveness proportional to
costs. Other remedial alternatives including innovative
treatment technologies were considered, but were found to be
45
-------
generally mo-re costly without affording additional protectiveness
commensurate with their cost.
Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maximum
Extent Pract icable:
EPA and IDEQ have determined that the selected remedial
action represents the best balance of tradeoffs among the
alternatives considered with respect to EPA's nine evaluation
criteria. The remedy represents the maximum extent to which.
permanent solutions and treatment technologies can be utilized in
a cost-effective manner. It is protective of human health and .
the environment, and complies with all applicable environmental
regulations. This remedial.action also utilizes treatment where
feasible and practicable.
Preference for Treatment As a Principal Element:
By treating the most highly contaminated soil prior to
disposal at an off-Site permitted landfill, the selected remedy
satisfies the preference for treating the principal- threat posed
by the Site.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan was released for public comment in
October, 1994. The Plan identified a proposed cleanup level of
400 ppm, based on future residential land use.
After the public comment period, EPA reassessed the
likelihood of the properties within the Site being used for
residential development. Given the historical industrial land
use, and the likelihood that such use will continue, EPA has
decided it is appropriate to revise the lead cleanup level to
1,000 ppm. This significant change is a logical outgrowth based
on information available to the public during the comment period
on the Proposed Plan and RI/FS Report. The public could have
anticipated this change based on its knowledge of the historical
industrial land use of the properties comprising the Site; there
is no foreseeable change in future land use of the properties;
and, current zoning of the properties is for industrial use.
Previous EPA guidance recommended using a range of 500-1,000
ppm as an "interim soil cleanup level" at Superfund sites under a
future residential land use scenario. At the upper end of that
range, the 1,000 ppm level has been used extensively in the past
as a cleanup level at sites zoned for industrial use. EPA has
selected the cleanup alternative identified in the Proposed Plan
as the preferred remedy for the Site. However, by raising the
cleanup level from 400 ppm to 1,000 ppm, two new remedial
components have been added as cleanup requirements. These
46
-------
include property restrictions which will be implemented Lc limit
future land use to industrial operations only and, reviews which
will be required no less often than every five (5) years
following initiation of the remedial action to ensure adequate
protection of human health and the environment.
Addenda to the October 1994 RI/FS and Risk Assessment were
added to the AR for the Site in June, 1995. These addenda
document the change in the lead cleanup level for the Site from
400 ppm (recommended in the Proposed Plan) to 1,000 ppm. The
Risk Assessment portion of the addenda contains an evaluation of
risk based on a future industrial - land use scenario. An
evaluation of the capping alternative submitted during the public
comment period is included in the Feasibility Study addendum.
The Proposed Plan inadvertently omitted the requirement in
Alternative 3B to conduct one year of quarterly ground-water
monitoring following its implementation. The October 1994 FS
describes the ground-water monitoring component of the selected
remedy.
47
-------
McCartyrs/
Pacific Hide and Fur
Pocatello Street Guide
McCAFTTYS/PACIFIC HIDE AND FUR
Pocatello, Idaho
BASE MAP REFERENCE
Pocatello Street Guide
Scale 2.5' = 1 mile
Rgure 1
SITE LOCATION MAP
48
-------
Pacific Hide and Fur
Depot, Inc. Property
LEGEND
• • <
-1,000^
Roadways
Fence
Approximate Property Line
Lead Concentration liopleth (mg/Vg)
tgi-a^SS-M Surface Soil Lead Concentrations > 1,000 mg/kg
xxjoi Subsurface Soil Lead Concentrations > 1,000 mg/kg
— — — Final Operable Unit Remedial Action Area
100
200
Approximate Scale in Feet
300
McCARTYS/FKCIFIC HIDE AND FUR
Pocatello, Idaho
Figure 2
FINAL OPERABLE UNIT
REMEDIAL ACTION AREA
-------
MCCARTY'S/
PACIFIC HIDE AND FUR
SUI'ERFUND SITE
Hunzikcr
OOOW-2
HOW-4 BGW-5
(32
Groundivater
Flow Direction
LEGEND
9 Monitoring Wells
® Monitoring Wells
Abandoned November 1993
• Monitoring Well Sampling Location
A Groundwalcr Supply Well
Sampling Location
a Other Wells '
«— Railroad Tracks
Approximate Property Line
Fence
iffl
El Domsea East,
Middle. West
0 200* 400'
Approximate Scale in Feet
Foulger's.
Approximate Pit
Location
Approximate
Former Location T~
of Battery Boxcars |
H Murdock
B Murdock - Walker
-4
4 -X-,:^
Fowler
McCARTYS/FACIFIC HIDE AND FUR
Pocatello, Idaho
Figure 3
MONITORING WELL LOCATION
AND SAMPLING MAP
-------
Highway 30
w
100
1 McCarty's, Inc. Property
—"
Pacific Hide and Fur
Depot, Inc. Properly
,\**^ ' N
UPRK Properly
\ \ \
Approximate
Location of
UPRR Sludge Pit
\ \ \
Gale
LEGEND
Roadways
-*- Fence
—— Approximate Properly Line
\ Lead Concentration Isoplelh (mgAg)
4* Excess Lifetime Cancer Risk >lxlO'* and ilxlO'4
A Excess Lifetime Cnncer Ri.ik > Ix 10 '4
Q Hazard Index > I
100
200
Approximate Scale In Feel
300
McCARTYS/FKCIFIC HIDE AND FUR
Pocatello, Idaho
Figure 4
TOTAL EXCESS LIFETIME CANCER RISKS
AND HAZARD INDICES ASSOCIATED WITH
INCIDENTAL INGESTION OF SURFACE SOIL
(RME RESIDENTIAL ASSUMPTIONS)
-------
Highway 30
100
•
V McCarty's, Inc. Property 400
_i-rifc T^^X- ^.w" 1
Pacific Hide and Fur
Depot, Inc. Property
Gate
Approximate
Location of
UPRR Sludge Pil
\ \ \
LEGEND
Roadways
< H- Fence
•" "•"' Approximate Properly Line
\_ Lead Concentration Isoplelh (mg/kg)
HK E»ccss Lifetime Cancer Risk >l«l()'(' and£l»IO'4
A Encess Lifetime Cancer Risk >I»IO'4
O Hazard Index > I
100
200
300
Approximate Scale In Feel
McCARTYS/FACIFIC HIDE AND FUR
Pocatello, Idaho
Figure 5
TOTAL EXCESS LIFETIME CANCER RISKS
AND HAZARD INDICES ASSOCIATED WITH
INCIDENTAL INGESTION OF SURFACE SOIL
(AVERAGE RESIDENTIAL ASSUMPTIONS)
-------
Table 1
McCARTY'S/PACIFIC HIDE AND FUR - SOIL SAMPLE COLLECTION SUMMARY
Sampling Event
August 1990
May 1991
First Operable Unit
Remedial Action
Confirmation Sampling 1992
Remedial Investigation
October/November 1993
Total
Surface Soil
-------
Table 2
McCARTY'S/PACIFIC HIDE AND FUR - SUMMARY OF POTENTIAL INORGANIC ELEMENTS OF. CONCERN IN SURFACE SOIL
Analyte
Antimony
Arsenic
Beryllium
Cadmium
Copper
Lead
Manganese
Thallium
Zinc
Minimum
Detected
(mg/kg)
3.8
2.5
0.11
0.54
6.7
3.11
152
0.17
31.6
Maximum
Detected
(mg/kg)
76
91.6
2.91
125
11.200
234,297
1.270
7.3
91,330
Background
Soil
(95th
Percentile)
(mg/kg)
0.26
4.81
0.8
6.73
14.9
20.1
501
NA
84.1
No. of Locations
Exceeding
Background/
Total
No. of Samples*1'
21/40
34/40
8/40
26/40
33/40
87/1 10<2>
13/40
NA
39/40
Residential
Risk-Based
Concentration
(mg/kg)(3)
31c
0.37c
O.ISc
39n
2.900n
400n
390n
5.5n
23,000n
No. of Locations
Exceeding
Residential
Risk-Based
Concentration/
Total
No. of Samples*1^
9/40
40/40
26/40
11/40
6/40
62/1 10
22/40
1/40
1/40
Industrial
Risk-Based
Concentration
(mg/kg)*4>
820n
3.3c
1.3c
l.OOOn
76,000n
NA
lO.OOOn
I40n
610,000n
No. of Locations
Exceeding
Industrial
Risk-Based
Concentration/
Total
No. of Samples*1'
0/40
38/40
5/40
0/40
0/40
NA
0/40
0/40
0/40
in
NA - Not available.
c - Equivalent to an excess lifetime cancer risk of IxlO"6-
n • Equivalent to a hazard quotient of I.
(1) Total number on samples includes laboratory analyzed samples only; XRF screening data are not included.
(2) A total of 110 surface soil samples were submitted for laboratory analysis; XRF field screening measurements were collected at 214 surface soil sample locations.
(3) Equivalent to a residential excess lifetime cancer risk of IxlO"6 (c) or a hazard quotient of 1 (n). These reference values are from the Risk-Based
Concentrations Tables, Second Quarter 1994, Region III, Prepared by Roy L. Smith. Technical Support Section, Philadelphia, Pennsylvania. April 20. 1994.
The risk-based concentration presented for lead (400 mg/kg) is a conservative residential screening value. This reference value is from the Revised Interim
Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities, OSWER Directive No. 9355.4-12, Office of Solid and Emergency Response,
Washington. D.C., July 1994.
<4) Equivalent to an industrial excess lifetime cancer risk of IxlO"6 (c) or a hazard quotient of 1 (n). These reference values are from the Risk-Based
Concentrations Tables, January - June 1995, Region 111, Prepared by Roy L. Smith, Technical Support Section, Philadelphia, Pennsylvania, March 1995.
-------
Table 3
McCARTY'S/PACIFIC HIDE AND FUR - SUMMARY OF POTENTIAL INORGANIC ELEMENTS OF CONCERN IN SUBSURFACE SOIL
Analyte
Arsenic
Beryllium
Lead
Maximum
Detected
(mg/kg)
61.7
0.551
3.740
Background Soil
(95th Percentlle)
(mg/kg)
. 4.81
0.8
. 20.1
No. of Locations
Exceeding
Background/ •
Total No. of
Samples(I)
3/18
0/18
6/1 i«
Residential
Risk-Based
Concentration
(mg/kg)<*>
0.37c
0.1 5c
400n
No. of Locations
Exceeding Residential
Risk-Based
Concentration/
Total No. of Samples(1)
18/18
12/18
2/18
Industrial
Risk-Based
Concentration
(mg/kg)^'
3.3c
l.3c
NA
No. of Locations
Exceeding
Industrial Risk-Based
Concentration/
Total No. of Samples(1)
9/18
0/18
NA
NA - Not available.
w c - Equivalent to an excess lifetime cancer risk of IxlO"6'
«" n - Equivalent to a hazard quotient of 1.
(1) Total number on samples includes laboratory analyzed samples only; XRF screening data are not included.
(2) A total of 18 subsurface soil samples were submitted for laboratory analysis; XRF field screening measurements were collected at 12 additional subsurface soil sample
locations.
(3> Equivalent to a residential excess lifetime cancer risk of 1x10 6 (c) or a hazard quotient of 1 (n). These reference values are from the Risk-Based
Concentrations Tables, Second Quarter 1994, Region III, Prepared by Roy L. Smith, Technical Support Section, Philadelphia, Pennsylvania, April 20, 1994.
The risk-based concentration presented for lead (400 mg/kg) is a conservative residential.screening value. This value is from the Revised Interim Soil Lead
Guidance for CERCLA Sites and RCRA Corrective Action Facilities, OSWER Directive No. 9355.4-J2. Office of Solid and Emergency Response, Washington.
D.C., July 1994.
(4> Equivalent to an industrial excess lifetime cancer risk of IxlO'6 (c) or a hazard quotient of 1 (n). These reference values are from the Risk-Based
Concentrations Tables, January - June 1995, Region 111, Prepared by Roy L. Smith, Technical Support Section. Philadelphia, Pennsylvania, March 1995.
-------
Table 4
MCCARTY'S/PACIFIC HIDE AND FUR - SUMMARY OF POTENTIAL INORGANIC ELEMENTS OF CONCERN IN GROUNDWATER
(Units: «ig/L)
Analylc
Aluminum
Aniimonx
Arsenic
Chromium (tola!)
Iron
Nickel
Upgradient
MVV-1B
29 1
11.4
2.28
ND
222
ND
MW-SH
ND
18.3
2.4
5.3 1
57.7
ND
SHALLOW AQUIFER11'
Downgradlcnt
MW-2B
195
10.4
4.73
3.050
8.100
107
MVV-3B
34 J
6.98
2.32
6.4 J
124
8.7
MW-4B
148
9.98
2.8
I9J
396
39 J
MW-6B
38 J
9.28
2.42
ND
25.5
ND
MW-11S
46 J
91
2.24
ND
60.1
ND
MW-IS
20 J
9.28
2.35
ND
46.2
ND
MW-2S
20 J
II. 1
2.14
ND
284
ND
MW-9S
ND
2.6/
1.7 J
ND
ND
ND
Rlsk-Bastd
Criteria12)
1 lO.OOOn
I5n
0.038e
IBOc'O
NA
730n
MCL«»
50(s)
6
50
100
300
100
DEEP AQUIFER'"
Analyte
Antimony
Arsenic
Iron
Lead
Manganese
Nickel
Zinc
Upfiradlcnt
MW-IA
11.7
4.65
85.6
43.8
2.9 I
ND
6,110
Foulger's
4.2 1
2.25
53.8
2.1
2.5 1
ND
40.9
Downgradlent
MW-2A
9.28
1.2 1
1,760
18.1
52.7
ND
4,830
MW-3A
10.3
2.53
124
ND
39.3 J
453
63.6
MW-6A
8.48
2.5
ND
ND
I.I 1
ND
in
MW-11D
II. 1
2.69
14)
ND
I.I 1
ND
29.3
MW-1D
11.6
2.55
16 J
I.8J
I.I 1
ND
32.2
MW-2D
II. 1
2.78
117
1.3 J
14.4 J
ND
27.6
Walt'i
10.4
2.2
54.5
2.6 J
3.3J
ND
642
EPA-9
5.4 J
ND
1.220
ND
69.7
ND
15 J
EPA-10
6.7 J
ND
2.900
ND
123
ND
9.8 J
Risk-Based
Criteria'"
I5n
0.038c
NA
NA
39n
730n
ll.OOOn
MCL'J>
6
50
300
,j(5)
50(s)
. 100
5,000(s)
I • The analytc was analyzed for and was positively identified, but the associated numerical value may not be consistent with the amount actually present in the environmental sample. The data should be seriously
considered for decision-making and are usable for many purposes.
ND • Not detected.
c - Equivalent to an excess lifetime cancer risk of IxlO"6-
n • Equivalent to a hazard quotient of I.
(I) • Reported values are maximum detected concentrations.
(2) • Equivalent to a lifetime excess cancer risk of UIO"8 (c) or a hazard quotient of I (n). These reference values are from the Risk-Based Concentrations Tahiti. Second Quarter 1994, Region III, Prepared by Roy L.
Smith. Technical Support Section, Philadelphia. Pennsylvania. April 20, 1994.
(3) • Where MCLs are not available, secondary MCU are provided and denoted by an (s).
(4) • This is the risk-based criterion for chromium VI.
(5) - 15 »
-------
Tabk 5
MCCARTY'S/PACIFIC HIDE AND FUR
POTENTIAL CONTAMINANTS OF CONCERN IN SOIL AND GROUNDWATER
Chemical
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Manganese
Nickel
Tetrachloroethene
Trichloroethene
Bis(2-ethylhexyl)phthalate
Benzo(a)pyrene
Benzo(b)fluoranthene
Dibenz(a,h)anthracene
Aldrin
Aroclor 1254
Dieldrin
Soil
X
X
X
X
X
X
X
X
X
X
Groundwater
X
X
X
X
X
X
X
X
X
x
X
57
-------
Table 6
McCARTY'S/PACIFIC HIDE AND FUR
INDUSTRIAL AND RESIDENTIAL SCENARIOS: INCIDENTAL INGESTION OF SOIL
Equation:
Intake (mg/kg-day) = CS x IR x CF x EF'x ED jc Fl
BWiAT
where:
CS = Chemical concentration in soil (mg/kg) ED = Exposure duration (years)
IR = Ingestion rate (mg soil/day) Fl = Fraction ingested from contaminated source (unitless)
CF = Conversion factor (JO"6 kg/mg) BW = Body weight (kg)
EF = Exposure frequency (days/year) AT = Averaging time (days)
Variable
CS
IR
EF
ED
Fl
BW
AT
Receptor
Adult-Worker
Adult-Resident
Child-Resident
Adult-Worker
Adult-Resident
Child-Resident
Adult-Worker
Adult-Resident
Child-Resident
Adult-Resident
Child Resident
Adult-Worker
Adult-Resident
•Adult Resident
Child-Resident
Adult-Worker
Adult-Resident
Child-Resident
Adult-Worker
Adult-Resident
Child-Resident
Adult-Worker
Adult-Resident
Child-Resident
Case
RME
RME/Average
RME
RME/Average
RME/Average
RME
RME
Average
RME
RME
Average
RME/Average
RME
RME/Average
RME
RME/Average
RME/Average
RME
RME/Average
Value (Rationale)
Exposure point concentration in surface soil
50 rag/day2
100 rag/day2
200 ing/day* (Children 1-6 years old)
250 days/year3
350 days/year3 (assumes 2 weeks of vacation/year)
275 days/year2 (fraction of time spent at home, 0.75, multi-
plied by 365 days/year)
25yearsa
24 years2 (90th percentile duration at a single residence [30
years] less 6 years for child exposure duration)
9 years2 (50th percentile duration at a single residence)
6 years2 (entire duration of age group)
1.0
1.0
70 kg3 (average adult body weight) .
70 kg2 (average adult body weight)
15 kg2 (average for 1- to 6-year old age group)
Pathway-specific period of exposure for noncarcinogenic
effects (i.e., ED x 365 days/year), and 70-year lifetime for'
carcinogenic effects (i.e., 70 years x 365 days/year)2
2 United States Environmental Protection Agency
Seattle. Washington.
Abbreviations:
RME = Reasonable Maximum Exposure
August 16, 1991a, Supplemental Risk Assessment Guidance for Superfund. EPA, Region 10,
58
-------
Table 7
McCARTY'S/PACIFIC HIDE AND FUR
REASONABLE MAXIMUM EXPOSURE • INDUSTRIAL SCENARIO
CANCER RISKS FOR SOIL INGESTION
Location
McCarty's, Inc. Property
Pacific Hide and Fur/UPRR Properties
Arsenic
4.2 X IO'6
i.oxio-J
Beryllium
4.0 X lO'7
9.7 X IO'7
Benzo(a)pyrene
8.5 X IO'7
ND
Benzo(b)fluoranthene
1.6X10'7
ND
D!benz(a,h)anthracene
I.6X 10'6
ND
HAZARD QUOTIENTS FOR SOIL INGESTION
Location
McCarty't, Inc. Property
Pacific Hide and Fur/UPRR Properties
Antimony
0.039
0.088
Arsenic
0.022
0.052
Beryllium
0.000052
0.00013
Cadmium
0.043
0.076
Copper
0.056
0.090
Total Cancer Risk
7.1 X IO'6
1.1 X 10'5
Manganese Hazard Index
0.041 0.2
0.073 0.4
in
u>
-------
TABLE 8
MCCARTY'S/PACIFIC HIDE AND FUR • COMPARISON OF FINAL OPERABLE UNIT CLEANUP ALTERNATIVES
Evaluation
Crlterle:
Overall
Protections!
Public
Health & the
Environment
Compliance
with ARARs
long-term
Effectiveness
Reduction of
Toxlclty,
Mobility &
Volume
Short-term
Effectiveness
Implementeblllty
Cost
State
Acceptance
Community
Acceptance
Alternative 2A
Soil Removal/Soil Cap:
Ejicavate/treat/off-slte disposal ol RCRA
toll only* cap non-RCRA toll, Institutional
controls, 5-year reviews, 1-yr. QW
monitoring.
Moderately protective. RCRA waste
treated/ disposed oil-site. Risks
transferred to IF. Potential
pathways/risks reduced; some potential
for air releeaes from excevatlon &
transport.
Meets all ARAHa.
Poor. Risk of dlroct contact reduced; rlaka
transferred to LF. Soil cap difficult to
maintain at operating facility; future risks
to QW If cep falls.
Averege. Moil highly cont. material
solidified: removed to off-site, permitted
IF. Volume reduction through off-elte
disposal of RCRA soil only.
Dust emlsalons during excavation;
potential distribution of contaminated soil
during trensport off-site to LF; response
objectives could be achieved within 3
months.
Tech. & admin, feasible. Excavation eesy.
to Implement; straightforward eep
construction.
Current eat. -S4. 2
Unacceptable.
No apeclflo comments received from local
cltlienry.
Alternative 28
Soil Removel/Asphalt Cap: Seme ea
All. 2A except cep Is asphalt.
Moderately protective. Same es Alt.
JA. Asphalt cep considered more
protective (more durable and less
permeable).
Meets ell ARARs.
Poof. Risk of direct conlect reduced;
risks transferred to LF. Uncertainty
with maintaining cep Integrity; future
risks to OW If cap falls.
Averege. Moat highly cont, material
solidified; removed to off-site,
permitted LF. Volume reduction
through off-site disposal of RCRA soli
only.
Oust emlsalons during excavation;
potential distribution of contamlneted
soil during transport off-site to LF; '
response objectives could be
echleved within 4 months.
Tech. & edmln. feasible. Excavetlon .
easy to Implement; straightforward
cap construction.
Currant est.*f4.6
Unacceptable.
No specific comments received from
locel citizenry. PRP Group favors
modified version.
Alternative 3A
Soil Removal/ Subsurface Soli Cep:
Seme as Alt. 2 A, Including
removal/off-stte disposal of non-RCRA
surface soil >1,000ppm.
Protective. Seme es Alt. 2A except
ell soil >1,000ppm efeurfece
removed. Soli cap over subsurface toll
> 1 .OOOppm. Potentlel for elrborne
releases from excavation and
transport. Risk transferred to LF.
Meets ell ARARs.
Fair. Risk of direct contact reduced;
risk! transferred to LF, Only
subsurface soil > 1 .OOOppm left on.
site; uncertainty with maintaining cap
Integrity; future risks to GW If cap
falls.
Average. Most highly eont. materiel
solidified; disposed In off-site,
permitted LF along with surface soil
> 1 .OOOppm. Volume reduction
through off-site disposal of RCRA toll
and aurface aoll > 1, OOOppm.
Oust emissions 'during excavation;
potential distribution of eontamlneted
eoll during trensport off-site to LF;
response objectives could be echleved
within 4 months,
Tech. & edmln. feasible. Excavation
easy to Implement; strelghtforwerd
cep construction.
Current est.- 44.96
Unacceptable.
No specific comments received from
locel cltlienry. PRP Group opposes soli
remove!.
Alternative 38
Soil Removal: Same es Alt. 2A,
Including removal/off-slle disposal
of ALL non-RCRA soil > 1, OOOppm.
Soil csp unnecessary.
Very Protective. Same es Alt, 2A
except ell soil > 1 .OOOppm
removed from site. Potential
pathwaya/rlsks eliminated; potential
tor airborne releases from
excavation and transport. Risk
tranaferred to LF.
Meets ell ARARs.
Good. Risk ol direct contect
eliminated; risks transferred to LF.
Threat to QW from lead
> 1, OOOppm eliminated.
Averege. All aoll > t, OOOppm
removed from site. RCRA aoll
treeted prior to placement In off-
site, permitted LF. Volume
reduction through off-site disposal.
Oust emissions during excavation;.
. potentlel distribution of
contemlnated soil during transport
off-site to LF; response objectives
could be achieved within 4 months.
Tech. & edmln. feeslble.
Excavetlon easy to Implement.
Current est.-»5.1
Stele concurs.
No specific comments received
from locel citizenry. PRP Group
opposes soil removal.
Alternative 4
Soli Washing: Site-wide
treatment of all soil
> 1, OOOppm. Seme es Alt. 2
except es noted end soil cap
unnecessary.
Very Protective. All soil
>1, OOOppm treated. Potential
pathways/risks eliminated;
potential for airborne releases
from excavation. Risk
transferred to LF from
"waste* generated during
washing.
Meets all ARARs.
Good. Risk of direct contect
eliminated. Threat to GW
from lead > 1, OOOppm
eliminated. Some risk
trsnsferred to LF.
Averege. All soil > 1, OOOppm
treeted via 'washing'; off-site
dlsposel of contaminated
residuals. Reduction In volume
& mobility.
Oust emissions during
excavation; response
objectives could be achieved
within 7 months. Limited
Impacts expected from
trensport of contemlnated soil
& weste water off-site.
Complex to construct end
Implement. Significant
materials processing and
treatabinty testing req'd.
Speclellted equipment, skilled
labor necessary.
Current est.> (5.4
State concurs.
No specific comments
received from local cltlienry,
PRP Group opposes soli
remove).
Alternative 5
On-Slte Fixation/
Containment: Site-wide
treatment/ czpplng of ell
RCRA soil; containment/
capping of nin-RCRA
> 1, OOOppm. Same as Alt.
2 except 30-yr g.w.
monitoring.
Moderately Protective. All
RCRA soli (rented prior to
plecement In on-Slte LF. Soil
> t, OOOppm consolidated In
on-Slte LF. Potentlel
pathweye/rbks reduced;
potential for airborne
releeses from excevenlon.
Meets all ARARs.
Fair. Risk of direct contect
reduced. Pc'manence of
fixated matt -lal unknown.
Uncertainty with
maintaining cap Integrity;
future risks to QW It cep
falls.
Averege. All fiCRA loll
treeted prior to placement In
on-slte cell; soil
> 1 .OOOppm consolidated In
cell. Increese In volume but
reduction In mobility.
Oust emission! during
excavation; response
objectives could be achieved
within 6 months.
Complex to construct and
Implement. Cep & location
of cell would Interfere w/
future lend use. Significant
materials processing & treet.
testing req'd.
Current eat. « 16.0
Unaeeeptabla.
No specific comments
received from local citizenry.
PRP Group fevors modified
version.
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Comparison of Remedies Between Region 10 "Industrial Use" Sites
Site Name
Lead Cleanup
Level
Selected Remedy
Comparison to McCarty's/
Pacific Hide and Fur
Harbor
Island Soil
and Ground-
water
1,000 ppm; no
excavation of
hot spots
(inconclusive
TCLP results)
3" asphalt cap in parking
lots; reinforced concrete cap
in areas of heavy equipment
use
Facility operations are
not similar. Asphalt cap
in low impact areas.
Lacks potable GW source
beneath Site.
Gould
1,000 ppm
(surface); TCLP
(subsurface)
Tried recycling to recover
lead from battery casings;
stabilization w/soil cap;
remedy under reconsideration
Facility operations are
not similar. 1988 ROD
requirements more
stringent than those
proposed at this Site.
Tacoma Tar
Pits
166 ppm (based
on "acceptable
dose"); 1,000
ppm (for hot
spot excavation
in "peripheral
areas")
Operating facility (treatment
of contaminated soils; .
engineered cap). Non-
operating facility
(stabilization, RCRA
cover/grass, institutional
controls)
Much more stringent
requirements (not
comparable to this
Site).
South
Tacoma
Field
1,000 - 18,000
ppm (cap);
above 18,000
ppm (soils fail
TCLP-
treatment)
Soil or asphalt cap depending
on long-term land use; treat
above 18,000 ppm & dispose on-
Site.
Facility operations are
not similar. Amount of
cont. soil & costs major
factors in remedy
selection.
General
Metals
(Washington
State-lead
Site)
1,000 ppm
Operating facility (12?'
reinforced concrete, imperm.
liner & 6" compacted subbase;
Non-operating portion (9" ADOT
large aggregate induet.
surface, 3" low permeability
asphalt & 6" compacted
subbase)- revised
Facility most like this
Site. Fairly
substantive and
expensive cap required
on operating portion in
comparison to cap
proposed by PRPs.
Bunker Hill Mining/Metallurgical Complex is not comparacie to otner "inaustriaJ. use" sites
in Region 10 and, was therefore, not considered in this analysis.
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APPENDIX A
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RESPONSIVENESS SUMMARY
MCCARTY'S/PACIFIC HIDE AND FDR
RECORD OF DECISION - FINAL OPERABLE UNIT
This responsiveness summary summarizes and responds to
substantive comments received during the public comment period
regarding United States Environmental Protection Agency's (EPA's)
proposed cleanup plan for the McCarty's/Pacific Hide and Fur
Superfund Site located near Pocatello, Idaho. The Proposed Plan
was based on information in the October 1994 remedial
investigation/feasibility study (RI/FS) report. The RI/FS and
the Proposed Plan are available for review at the Pocatello
Public Library and at EPA's offices in Seattle, Washington.
Copies of the Proposed Plan were mailed to local citizens that
were on a mailing list developed as part of the Community
Relations Plan for this Site.
Three comment letters were received during the public
comment period. EPA's response to these comments follows.
Comments and Agency Responses
A. Private Citizens' Comments: . Two letters were received
from private citizens residing in Pocatello. One of the letters
expressed support for the cleanup of the lead contamination at
the Site. The other expressed concern over the length of time
taken to study and clean up the Site, and the significant costs
of Superfund work. EPA responded in some detail to this
citizen's concerns in a letter to Congressman Michael D. Crapo
dated January 10, 1995. The private citizen sent two letters,
one to EPA and the other to. his congressional representatives
expressing his concerns to which EPA replied. These letters,
together with the Agency's response, are in the Site
Administrative Record (AR) for this remedial action.
Response: In short, EPA believes that the selected remedy
for the remaining lead-contaminated soil can be easily and
relatively quickly implemented, and is cost effective. The
reader is referred to the AR for this remedial action for a
detailed response to the private citizen's concerns as mentioned
above.
B. Potentially Responsible Party (PRP) Group Comments: EPA
received an extensive comment package from a group of parties
that had previously been identified as potentially responsible
parties at the Site. The PRP Group submitted comments on behalf
of ANR Freight System, Inc., AT&T, FMC Corporation, McCarty's,
Inc., and certain McCarty individuals, Monsanto Company, Pacific
Fruit Express Company, Pacific Hide and Fur Depot, Inc., J.R.
Simplot Company, Terteling Company, Inc., and Union Pacific
Railroad. The comment package, dated December 29, 1994, is in
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the AR for this Site. The PRP Group's comments can be divided
into six (6) categories:
1. cleanup goals
2. recommended remedy
3. soil contamination estimates
•4. risk assessment
5. miscellaneous
6. Region 10 site comparisons
Comments 1 and 2 below are from Exhibit A of the PRP Group's
comment package entitled Significant Issues Applying To All Of
The Documents.
. Comment 1. Cleanup Goals- The PRP Group expressed concern
that EPA had not evaluated risks for a current/future industrial
land use scenario. The PRP Group was also concerned that EPA had
assumed the property would be made available for unrestricted
future land use as opposed to strictly industrial use, noting
that the property is located in an industrial corridor, is zoned
as such, and has been'used in this manner "...for more than 50
years ". ..
Response: In the October 1994 Risk Assessment, it was
assumed that future land use could be residential. Therefore,
potential health risks and cleanup goals were estimated under a
future residential land use scenario for the soil contaminants of
concern identified in the baseline Human Health Risk Assessment.
These contaminants included antimony, arsenic, cadmium, copper,
lead, and manganese. :
The cleanup level for lead assuming future residential
exposure was set at 400 ppm. This value is the health protective
screening level calculated using the EPA's Integrated Uptake
Biokinetic (IUBK) model recommended by EPA Superfund guidance.
The 400 ppm value was calculated using EPA default "exposure
assumptions developed for the model. Although site-specific data
can be used in the IDBK model, such data were lacking for this
Site.
Following EPA's decision to assume future industrial land
use when determining cleanup goals, an addendum to the original
Risk Assessment was prepared. This addendum calculated potential
health impacts to workers. Lead was the only contaminant of
concern identified for workers. A cleanup level of 1,000 ppm for
lead in soil was set. The 1,000 ppm cleanup level is
sufficiently protective for on-Site workers, and has been used in
the past for sites where the expected future land use is
industrial. This is consistent with the present and anticipated
future land use scenario for this Site and with the cleanup goals
that were designated for the polychlorinated biphenyls- (PCB) and
64
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/ l
1992.
ead- contaminated soil operable unit cleanup completed in
In combination with the cleanup of the contaminated soil, a
critical element of the selected remedy requires placing and
enforcing property restrictions to prohibit land uses allowed
under residential /neighborhood commercial and professional
zoning.
Comment 2 . Recommended Remedy- The PRP Group expressed
concern that unrestricted future land use had not been stated as
a remedial action objective (RAO) for the Site and, that all of
the alternatives with the exception of "Ground-Water Monitoring
and Property Restrictions" achieved the stated RAOs. The PRP
Group states that if the capping alternative they advocate were
selected, the cap's integrity could, in fact, be managed by
proper design and maintenance. Further, tKfe PRP Group is
concerned that the excavation and off -Site disposal alternative
is not the most cost effective. According to the PRP Group, an
excavation and off -Site disposal alternative "simply moves the
contaminated materials from the current property to another off-
Site location" thereby transferring risks. In addition, it poses
health risks during transport. Finally, the PRP Group states
that EPA should have considered a "capping only" alternative
(i.e., without excavation and off -Site disposal).
Response: In response to the concern that unrestricted
future land use had not been considered as a cleanup objective
(synonomous with RAO) at the Site, EPA indicated in sub-section
2.1.3.2 of the October !1994 FS entitled Future Land Use that
"[i]n the future, the Site may be developed for residential
and/or industrial use. For the future land use scenario, Site
residents were considered potential receptors, as required by EPA
Region 10 guidance (EPA 1991) . This scenario is [also]
protective of current Site workers, workers who may be on-Site
during remediation activities, and any trespassers or Site
visitors. "
With respect to the concern regarding cap integrity, the
engineering designs of the caps proposed in the October 1994 FS
would have to be altered considerably to withstand the current
scrap recycling activities on the Pacific Recycling and Union
Pacific Railroad properties. Prevention of contact with
contaminated soils (a primary cleanup objective) is a major
concern because of the possibility of cap failure due to
recycling activities or future industrial activities at the Site .
Under the selected remedial action, the most highly
contaminated soil requires treatment prior to placement in a
permitted municipal landfill. Since the soil following treatment
is no longer considered hazardous waste, disposal in the
permitted municipal landfill is acceptable. The remaining soil
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which coas not require treatment will also be disposed in a
permitted municipal landfill. These landfills must meet and
maintain all applicable EPA requirements. While these same
requirements can be achieved on-Site, the costs are higher, there
are long-term management issues to consider, and the type of
future property use would be greatly limited.
A discussion of risks related to the off-site transport of
Comprehensive Environmental Response, Compensation and Liability
Act (CERCLA) wastes is typically provided in the site health and
safety plan as.recommended in "Risk Assessment Guidance for
Superfund, Human Evaluation Manual, Part C - Risk Evaluation of
Remedial Alternatives":
"It is important to note, however, that factors not
associated directly with hazards particular to a given
site (e.g., risk of accidents during off-site motor
vehicle transport) are not usually considered during
the FS, but instead should be addressed prior to
remediation in the site health and safety plan."
The cost effectiveness of the preferred alternative was
another concern raised by the PRP Group. Based on EPA's decision
to restrict future land use to industrial activities only, EPA
re-evaluated the cap design requirements for Alternatives 2A and
2B based on a review of other Superfund sites in the region with
similar business operations. The resulting modifications to
these alternatives based on this review increased costs
significantly. The estimated costs range from approximately
$5,355,678 to $5,440,224 which, are higher than the selected
remedial action.
EPA and the Idaho Department of Environmental Quality (IDEQ)
do not believe that a "capping only" alternative would adequately
protect human health.and the environment at this Site. Given the
nature of the operating business and its practices, and the
unpredictability of future Site activities, considerable
uncertainty exists with the timely identification and repair of
any failures in the cap. .Over 45%- of the remaining contaminated
soil is considered a Resource Conservation and Recovery Act-
(RCRA) characteristic waste based on leaching tests. A viable
source of potable water lies beneath the Site. A primary cleanup
objective for the Site is to prevent the infiltration/migration
of contaminants in soil to ground water that would result in
ground-water contamination in excess of Site-specific action
levels, threatening human health.
Comment 3 below is from Exhibit A of the PRP Group's comment
package entitled Remedial Investigation. The PRP Group
identified five areas of concern regarding soil contamination
estimates. This comment has been divided into five parts and EPA
is responding accordingly.
66
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Comment 3, Tart 1. Soil Contamination Estimates - The
first area of concern is the Concentration Isopleth Maps for
Lead. The PRP Group contends that .the x-ray fluorescence (XRF)
field screening measurements yielded generally lower results than
the laboratory confirmation analyses, implying that the soil
volume estimates may have been underpredicted.
Response 3, Part 1: The correlations between the XRF and
laboratory data for samples collected in 1990 and 1991
(r2 = 0.76), and 1993 (r2 = 0.996) were considered adequate to
characterize the extent of lead contamination in soil at the
Site. Use of an XRF instrument, a cost effective field screening
method, allowed for significantly more data points to be analyzed
than if fixed laboratory analysis were solely utilized. A
sensitivity, analysis, was presented in Section 4.8.7.1, Table 4-6,
of the October 1994 FS.
Comment 3, Part 2. The second area of concern is the Depth
of Lead in Soils. The PRP Group suggested that the number,
representativeness and reliability of subsurface samples was
insufficient to accurately determine the volume of lead-
contaminated soil remaining at the Site.
Response 3, Part 2: In 1991, interval sampling using XRF
was performed in approximately thirty (30) on-Site locations to
determine the depth of lead contamination in both the "hot spots"
and the less contaminated areas. Exclusive of the "hot spots",
lead contamination was generally limited to the top six (6)
inches of. soil and oftentimes, to the top 2-3 inches.
During the first operable unit remedial action, twenty-five
(25) of the forty-three (43) confirmation sampling sectors were
excavated to a depth of six (6) inches below ground. The other
eighteen (18) sectors were excavated to depths between twelve
(12) and twenty-four (24) inches.
Confirmation samples collected by EPA to verify attainment
of the PCB cleanup goals, and which were also analyzed for lead,
and.samples collected within the boundary of the first operable
unit during the 1993 RI, confirmed that lead contamination was
generally confined within the top six (6) inches of soil. Lead
concentrations in samples collected in the areas excavated to six
(6) inches below ground during the first operable unit were
generally consistent with background soil lead concentrations or
below the XRF instrument detection limit of 48 ppm, indicating .
that soil lead concentrations were below 1,000 ppm at a depth
less than six (6) inches.
Exclusive of the "hot spots", the depth of soil lead
contamination across the Site is assumed to be similar to that
encountered.within the limit of the first operable unit cleanup.
67 .
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The assumption of surficial contamination is supported by the
fact that surface soil contamination in areas where battery
recycling did not occur is primarily attributed to tracking by
vehicles and personnel, and deposition by airborne particulates.
Finally, the reported lead concentration (25,300 ppm) for
the sample collected on the eastern portion of the Union Pacific
Railroad property appears to be an anomaly. Many other samples
have been collected in this area of the Site and this high lead
concentration cannot be reproduced. There.is no historical
information (i.e., aerial photographs) or testimonial deposition
information that indicates that battery recycling activities were
conducted in this location.
Comment 3, Part 3. The third area of concern is the
Comparison Criteria for Identification of Extent of Contamination
in Soils. The PRP Group's concerns relate to EPA's use of the
95th percentile of the background sample data set instead of
using maximum background•concentrations, thereby artificially
enlarging the Site's contaminated area.
Response 3, Part 3: On-Site lead sample data..were compared
to the 95th percentile of the background soil sample data set.
Using the 400 ppm residential screening value for lead as a
comparison, the 95th percentile value was 20.1 ppm and the
maximum background sample concentration was 23.5 ppm.
Therefore, whether on-Site data were compared to the 95th
percentile or maximum background concentration is immaterial
since the residential lead screening value of 400 ppm (which was
the recommended cleanup level for lead in soil in the Proposed
Plan) is considerably greater than either of them.
Comment 3, Part 4. A fourth area of concern related to
calculating risk-based concentrations under a future residential
scenario versus an industrial scenario and the resulting effect
on determining the extent of contamination at the Site.
Response 3, Part 4: The issue of calculating risk-based
concentrations under a future residential scenario versus an
industrial scenario and the resulting effect on determining the
extent of contamination at the Site was addressed in the response
to Comment 1 above. The volume of soil requiring cleanup under
the future industrial land use scenario is approximately 820
cubic yards less than under the future residential land use
scenario.
Comment 3, Part 5. Finally, the PRP Group believes that it
is inappropriate to compare subsurface soil data to risk-based
concentrations.
Response 3, Part 5: Subsurface soils are evaluated as a
part of the Risk Assessment to account for the possibility of
68
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future excavation. Excavation can. r-*»svlt in subsurface soils
being brought to the surface where human contact can occur.
Therefore, information on potential risks from subsurface soils
is useful in determining if future land use restrictions or other
institutional controls are necessary.
Comment 4 below is~from Exhibit A of the PRP Group's comment
package entitled Baseline Human Health and Ecological Risk
Assessment. The PRP Group identified five areas of concern with
the results presented in EPA's Baseline Human Health and
Ecological Risk Assessment. This comment has been divided into
five parts and EPA is responding accordingly.
Comment 4, Part 1. Risk Assessment - The first area of
concern is Exposure Scenarios. The PRP Group contends that the
lack of an industrial use scenario provides no estimation of
risks associated with the current Site and its probable future
land use giving the decision-makers less information when
considering various risk management options. They assert that
the risk calculations represent a significant overestimation of
Site risks for industrial workers.
Response 4, Part 1: These concerns are addressed in EPA's
response to Comment 1 above.
Comment 4, Part 2. The second area of concern is Exposure
Point Concentrations (EPCs). The PRP Group believes that EPA's
use of individual sample results to establish risk, rather than
using average concentrations across the Site overstates the risk.
They noted that EPA guidance states that an "[a]verage
concentration is most representative of the concentration that
would be contacted at a site over time." In contrast, the
approach used in the baseline Risk Assessment for this Site is
analogous to a "hot spot" analysis.
Response 4, Part 2: EPA's risk assessment guidance states
that "averaging soil data over an area the size of a residential
backyard (e.g., an eighth of an acre) may be most appropriate for
evaluating the residential soil pathways". Therefore, because
the October 1994 Risk Assessment assumed a future land use of
residential, the appropriate exposure unit to be used for the
exposure point concentration was a residential lot.
Also, according to EPA guidance, the exposure point
calculation should be the 95th percentile upper confidence limit
(UCL95) on the average of the soil concentration values. To
calculate the UCL95, data from 10 to 20 samples per exposure area
should be used. Calculation of the UCL95 for residential lot
sizes at the Site was not possible because the density of soil
samples was insufficient. Therefore, estimates of risk for each
soil sample were made.
69
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For the industrial scenario, the EPCs were based upon
average soil concentrations. This is because the exposure area
was assumed to be larger than a residential lot and sufficient
sampling points were available to calculate average values.
Site-wide EPCs were calculated for the Mccarty's, Inc. property
separately, and for the UPRR and Pacific Hide and Fur Depot, Iric.
properties combined. Where greater than ten (10) data points
were available, the UCL95 on the mean was used as the EPC. If
less than 10 data points were available, then the maximum
detected concentration was used as the EPC. The June 1995 Risk
Assessment addendum provides the results of the Site-wide EPC
calculation under the industrial scenario.
The Site-wide EPCs for lead were determined to be 234,297
ppm for the McCarty's, Inc., property and 4,840 ppm for the
combined UPRR and Pacific Hide and Fur Depot, Inc., properties.
As recommended by national EPA guidance, the maximum detected
concentration on the McCarty property was used as the EPC because
the 95 percent upper confidence limit was greater than the
maximum detected on-Site lead concentration.
Comment 4, Part 3. The third area of concern is Potential
Risks Associated with Lead. This concern relates Co EPA's
recommendation in the Proposed Plan based on a residential land
use scenario of setting a Site-specific cleanup level for lead at
400 ppm. -
Response 4, Part 3: This concern was previously addressed
in EPA's response to Comment 1 above.
Comment 4, Part 4. The fourth area of concern is Chromium
as a Chemical of Potential Concern in Ground Water. The PRP
Group is concerned that chromium was identified as a contaminant
of concern in ground water but was not found in Site soil, and
was detected in only one on-Site well.
Response 4, Part 4: Additional testing of the well with
elevated chromium concentrations indicates that the problem is
well-specific and probably relates to its construction. An
addendum to the RI has been prepared documenting this
clarification. This information is available in the Site AR for
this remedial action.
Comment 4, Part 5. The final area of concern is Aver acre and
Reasonable Maximum Exposures. The PRP Group's concern relates to
EPA's calculation of these two exposure values, characterizing
them as nearly identical in the baseline Human Health Risk
Assessment.
Response 4, Part 5: The reasonable maximum exposure (RME)
is calculated using mid-range values for some exposure parameters
and upper-bound values for others. This is done so that the
70
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combination of all of these parameters in an exposure equation
results in an estimate of the "reasonable" exposure not the worst
possible exposure. Average or more typical values are used to
calculate the average exposure.
A 10-fold difference in exposure (and risks) for cancer and
a smaller difference for non-cancer effects were calculated for
the baseline Human Health Risk Assessment between the RME versus
average exposure (assuming a future residential land use
scenario). As recommended by EPA Region 10's risk assessment
guidance, different values were used for exposure frequency and
exposure duration in calculating the RME versus average
exposures. For soil intake, the same values were used for both
the RME and average exposure calculations because a value of 200
milligrams per day for children is considered to be an upper end
of the average. It is one of the average values used in the RME
calculation and, is also an appropriate value in calculating the
average exposures.
For the exposure point concentrations, the UCL95 on the
average and the average value would ideally be used for
calculating the RME and average exposures, respectively. This
could result in substantial differences in the exposure estimates
between RME and average exposure. However, as has previously
been described, it was not possible to adequately calculate an
average or a UCL95 on the average for the residential scenario
due to the small number of samples (in many cases, n=l) in areas
that would represent a residential plot.
.The average exposure value was not calculated for the
industrial scenario because Region 10 risk assessment guidance
provides no default values for this scenario. Therefore, only
RME values were calculated for the industrial scenario.
The Site-wide EPCs for lead were determined to be 234,297
ppm for the McCarty's, Inc., property and 4,840 ppm for the
combined UPRR and Pacific Hide and. Fur Depot, Inc., properties.
The maximum detected concentration on the McCarty property was
used as the EPC because the UGL95 was greater than the maximum
detected on-Site lead concentration.
Comment 5 below'is from Exhibit A of the PRP Group's comment
package entitled Feasibility Study.
Comment 5. Miscellaneous - There were eleven (11) areas of
concern identified under this heading. The issues, pertained to:
1. Remedial Action Objectives and Cleanup Goals
2. Recommended Remedy
3. Capping Alternatives
4 . No Action Alternative
5. Volume Estimates
6. Estimation of RCRA Characteristic Soils
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7. Documentation of Cost Estimates
8. Scrap Management
9. Long-term Ground-water Monitoring
10. Technical Memoranda (Inconsistencies Between the
Technical Memorandum and the RI/BRA/FS Documents,
and Multiple Revisions to the Technical Memoranda)
11. Proposed Plan for Final Cleanup
The PRP Group's concerns are reiterations of those
previously raised earlier in their comment package. In the case
of comments 1, 2, 3, 5 and 6, the PRP Group is concerned with:
(a) EPA's initial decision to select a cleanup level for
the Site based on a future residential land use scenario,
without considering a current and expected future industrial
use scenario.
(b) the selection of a remedy requiring excavation and off-
Site disposal of contaminated soil instead of capping the
Site.
(c) EPA's estimation of the volume of contaminated soil
above the proposed cleanup level.
Response: EPA's response to Comments 1, 2 and 3 of this
Responsiveness Summary address concerns 1, 2, 3, 5 and 6 listed
above.
Miscellaneous Comment #4 - No Action Alternative: The PRP
Group's concern is that the FS concluded that the resultant risks
associated with the no-action alternative would be the same as
those identified in the October 1994 baseline Human Health Risk
Assessment. They disagree since this alternative included
institutional controls restricting property use. The PRP Group
contends that resultant risks for industrial workers, had an
assessment been conducted using a current industrial scenario,
would have been far less than the risks presented in the baseline
Risk Assessment.
EPA Response to Comment #4: The "no action" alternative
identified in the Proposed Plan and October 1994 FS is actually a
"limited action" alternative since it includes repair and
maintenance of a Site fence, property restrictions on future land
use, five-year reviews, and implementation of a ground-water
monitoring program. It is, therefore, accurate to assign some
measure of protectiveness to the "limited action" alternative.
However, a "no action" alternative most likely would not result
in any reduction in risk since it typically does not contain any
cleanup measures.
Miscellaneous Comment #7 - Documentation of Cost Estimates:
The PRP Group's expressed concern that there was no back-up
72
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documentation provided in the PS for the source of the cost
estimates.
EPA's Response to Comment #7: With respect to documentation
of cost estimates, these were developed based on: (1) published
cost data, (2) EPA contractor cost data gathered from other
sites, (3) cost data from the first operable unit remedial action
at the Site, and, (4) vendor-, company- and facility- supplied
information. This information is readily available to the
public.
Miscellaneous Comment #8 - Scrap Management: The PRP Group
requested documentation regarding the need for scrap handling and
the basis for the 8,000 ton estimate of scrap requiring staging
and decontamination.
EPA's Response to Comment #8: The one cost item that was
incorrectly reported in the cost estimates provided in Appendices
A and B of the October 1994 FS is the "Debris Removal" line item.
This cost ($1,080,000) should have been reported as a lump sum,
not a unit cost. This estimate was based on the assumption that
all scrap in contact with contaminated soil would be relocated to
a decontamination area, decontaminated, moved to a temporary
staging area, and moved again to a final location. Due to the
large volume of scrap, it is assumed that most scrap would need
to be moved twice after decontamination. As stated in the RI/FS,
scrap management costs account for a large percentage of the
total remedial costs for Alternatives 2 through 5. It is
feasible that these costs could be significantly reduced if the
owners of the scrap can determine a mutually acceptable, cost-
effective method of scrap disposition.
Miscellaneous Comment #9 - Long-Term Ground-Water
Monitoring: The PRP Group disagreed with EPA's ground-water
monitoring program described in the Proposed Plan. They argued
it was excessive; that fewer wells should be' sampled and fewer
compounds included in the analytical program; and, that there
were inconsistencies in the requirements between the
alternatives.
EPA's Response to Comment #9: Long-term ground-water
monitoring requirements will be finalized during remedial design.
These requirements include number of wells to be sampled and the
list of analytes. One- year of quarterly ground-water monitoring
is a required component of the selected remedy. Monitoring is
necessary to ensure that no contaminants were mobilized during
implementation of the remedy and that all federal and state water
quality standards are maintained; The requirement to conduct
long-term monitoring under Alternative 5 was considered necessary
to determine the effectiveness and permanence of the remedy which
would involve stabilizing all of the most highly contaminated
soil (i.e., RCRA-characteristic waste) overlain with unstabilized
73
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but contaminated soil above 1,000 ppm. This alternative involves
on-Site disposal in a containment cell.
The PRP Group expressed concern with apparent
inconsistencies between the Technical Memoranda (Revised Remedial
Action Objectives/ Remedial Technologies, Alternatives and
Screening, and Comparative Analysis of Alternatives) and the
October 1994 Remedial Investigation/Risk Assessment/Feasibility
Study, as well as the multiple revisions to the Technical
Memoranda. The Technical Memoranda provided preliminary
information for use in preparing the Remedial Investigation, Risk
Assessment and Feasibility Study. This process is iterative,
hence the multiple revisions, and, therefore, differences between
these Technical Memoranda, Risk Assessment and the RI/FS are to
be expected.
The PRP Group raised seven (7) issues regarding the content
of the Proposed Plan. These issues related to the:
(1) classification of hazardous waste; (2) calculation of future
residential risk rather than current Site risk;
(3) clarification of language explaining EPA's current technical
guidelines for calculation of "risk" associated with lead
exposure; (4) ground-water monitoring as a component of the
preferred alternative; (5) description of the effectiveness of
the remedy; (6) maintenance of a cap's integrity; and, (7) the
selected remedy's satisfaction of the nine criteria.
(1) Issue - Soils left in-place should not be classified as
hazardous waste unless they are excavated.
Response - This statement is untrue. The soil has been
tested and now, following the first operable unit cleanup,
approximately 46% of the remaining contaminated soil at. the
Site fails TCLP. Even if the contaminated soil which tests
as hazardous waste is left in place, RCRA closure
requirements would be relevant and appropriate at the Site.
(2) Issue - The summary of Site risks did not include an
evaluation of any of the current exposure scenarios.
Response - The Summary of Current Site Risks and Risks
Following Cleanup might have been more appropriately titled
"Summary of Future Residential Site Risks and Risks
Following Cleanup" since risk calculations (of current Site
conditions and post-cleanup Site conditions) were based on a
future residential land use scenario.
(3) Issue - The Proposed Plan language explaining EPA's current
technical guidelines for calculation of "risk" associated
with lead exposure should have distinguished between the
availability of information on adults versus children.
74
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Response - The .reference to "Technical Guidelines" in- the
Proposed Plan refers to the lack of toxicity values for
lead. Therefore, lead is not included in either
carcinogenic or noncarcinogenic risk calculations. Rather,
EPA guidance was used to determine whether a cleanup action
was necessary at the Site, and to what level the lead should
be remediated.
(4) Issue - Ground-water monitoring was not listed as a
component of the preferred alternative.
. Response - The Proposed Plan inadvertently omitted the
requirement to conduct one year of quarterly ground-water
monitoring following implementation of the remedy. The
October 1994 FS describes the ground-water monitoring
component of the selected remedy.
(5) Issue - The Proposed Plan overstates the effectiveness of
the remedy when indicating that it eliminates or treats all
of the soils above 400 ppm.
Response - By removing 'all of the lead-contaminated soil to
the cleanup level, the selected remedy removes the
contamination at the Site to a level considered protective
of on-SiTte workers. Treatment of all RCRA-characteristic
waste is a required component of the'selected remedy. Non-
RCRA characteristic waste can be disposed in a permitted,
municipal landfill operated under 40 CFR 258 without
treatment.
(6) Issue - The cap's integrity can be managed through
engineering design and maintenance.
Response - Previous responses have already been offered in
this Responsiveness Summary addressing the question of
maintaining a cap's integrity. The "capping only"
alternative is not considered viable as a remedy for this
Site based on issues of protectiveness, long-term
effectiveness, and cost.
(7) Issue - EPA's selected remedy does not best satisfy the nine
criteria.
Response - EPA maintains that the selected remedy best
satisfies the nine criteria as previously discussed.
Comment 6 below is from Exhibit E of the PRP Group's comment
package Summary of Precedents Established by USEPA Region 10 on
Other Sites.
Comment 6. Region 10 Site Comparisons - The PRP Group
independently performed an evaluation of exposure scenarios used
75
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in the assessment of risk at nine (9) sites in Region 10. The
PRP Group asserts that "[t]he characterization of risks posed by
continued industrial uses clearly influenced the previous remedy
.selection at [this Site] and... at other similar sites [in the
region] ." They also re-iterated their concern with the Agency's
'initial stated preference for unrestricted land use at the Site,
which has since been modified. As stated in the ROD, a cleanup
level has been established based on industrial land use with
property restrictions.
The PRP Group identified six (6) sites within Region 10
where capping or covering was a component of the selected remedy
for soils. According to the PRP Group, four (4) of these sites
were metals salvage yards and recycling facilities similar to the
McCarty's/Pacific Hide and Fur Site.
Response: EPA's assessment of the sites submitted by the
PRP Group is provided in Table 9.
76
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APPENDIX B
77
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(PHFA3) Pacific Hide & Fur - Final Site Remediation Administrative Record INDEX
HEADING: I. 0. . SITE BACKGROUND
SUB-HEAD: 1.1. . Site Background Summary
1. 1. . - 1021717
DATE: 08/01/93 PAGES: 91
AUTHOR: Unknown/Woodward-Clyde Consultants
ADDRESSEE: Unknown/McCarty's/Pacif ic Hide & Fur PRP Group
DESCRIPTION: Site Background Summary Mccarty's/Pacific Hide & Fur Superfund
Site Pocatello, Idaho
SUB-HEAD: 1. 2.
1. 2.
X-Ray Fluorescence
- 0000001
DATE: 08/.16/90 PAGES: 29
AUTHOR: Unknown/Ecology and Environment, Inc.
ADDRESSEE: Unknown/EPA
DESCRIPTION: Sampling and Analysis Plan, Quality Assurance/Quality Control Plan,
Health and Safety Plan for X-Ray Fluorescence Screening
Confirmation Soil Sampling (incorporated by reference only, see PHF
Addendum Admin. Record Doc. #1.2 000001}
1. 2.
DATE:
AUTHOR:
ADDRESSEE:
DESCRIPTION:
- 0000002
12/18/90 PAGES: 173
Unknown/Ecology and Environment, Inc.
Unknown/EPA
X-Ray Fluorescence Screening Confirmation Soil Sampling at
Mccarty's/Pacific Hide and Fur Pocatello, Idaho (This document is
incorporated by reference only, see Pacific Hide and Fur Addendum
Admin. Record Doc. # 1.2 000002 for actual copy)
1. 2.
DATE:
AUTHOR:
ADDRESSEE:
DESCRIPTION:
- 0000003
08/02/91 PAGES: 172
Unknown/Ecology and Environment, Inc.
Unknown/EPA
Technical Data Rpt. for X-Ray Fluorescence Screening and
Confirmation Soil Sampling at Mccarty's/Pacific Hide and Fur
Superfund Site, — & UPRR (incorporated by reference only, see PHF
Addendum Admin. Record Doc. 1.2 000003)
1. 2.
DATE:
AUTHOR:
ADDRESSEE:
DESCRIPTION:
- 1033715 .
05/01/92 PAGES: 462
Unknown/Ecology and Environment, Inc.
Unknown/EPA
Interpretive Report for X-Ray Fluorescence Screening and
Confirmation Soil Sampling at McCarty's/Pacific Hide and Fur
Superfund Site and Union Pacific Railroad
09/11/95
U. S. Environmental Protection Agency, Region 10
Page
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(PHFA3) Pacific Hide & Fur - Final Site Remediation Administrative Record INDEX
HEADING: 2. 0. . REMEDIAL INVESTIGATION/FEASIBILITY STUDY
SUB-HEAD: 2. 1. . Correspondence
2. 1. - 1033717
DATE: 09/08/94 PAGES: 2
AUTHOR: Ann Williamson/EPA
ADDRESSEE: Gordon Brown/Idaho Dept. of Health and Welfare
DESCRIPTION: Formal request to the state to identify applicable or relevant and
appropriate requirements (ARARs) or other requirements to be
considered in evaluating potential cleanup, measures
2. 1. - 1028281
DATE: ll/J.0/94 PAGES: 6
AUTHOR: Ann Williamson/EPA
Unknown/Unknown
Cover letter and attached copy of EPA's volume calculations
relating to the contaminated soil at McCarty's/Pacific Hide and Fur
Superfund site (sent to Addressees listed)
ADDRESSEE
DESCRIPTION
2. 1. . - 1028293
DATE: 07/13/95 PAGES: 1
AUTHOR: Ann Williamson/EPA
File/EPA
Memorandum discussing addenda to the McCarty/Pacific Hide and Fur
Remedial Investigation, Risk Assessment and Feasibility Study -
June 1995
ADDRESSEE
DESCRIPTION
SUB-HEAD: 2. 2.
2.
Work Plan
- 1021718
DATE: 05/01/94 PAGES: 435
AUTHOR: Unknown/Ecology and Environment, Inc.
ADDRESSEE: Unknown/EPA
DESCRIPTION: McCarty's\Pacific Hide and Fur Work Plan, Sampling and Analysis
Plan, Quality Assurance Project Plan, Data Management Plan, and
Health and Safety Plan, Remedial Investigation Feasibility Study,
Final Operable Unit
SUB-HEAD: 2. 3.
2. 3.
Technical Memorandums
- 1021730
DATE: 04/21/94 PAGES: 18
AUTHOR: Sheila Fleming/Ecology and Environment, Inc.
ADDRESSEE: Ann Williamson/EPA
Cover letter and attached Technical Memorandum on the Need for
Modeling of Site Characteristics for the Mccarty's/Pacific Hide and
Fur Superfund Site
DESCRIPTION:
09/11/95
U. S. Environmental Protection Agency, Region 10
Page
-------
(PHFA3) Pacific Hide & Fur - Final Site Remediation Administrative Record INDEX
2. 3. - 1033114
DATE: 10/01/94 PAGES: 44
AUTHOR: Unknown/Ecology and Environment, Inc.
ADDRESSEE: Unknown/EPA
DESCRIPTION: Technical Memorandum Revised Remedial Action Objectives
Mccarty's/Pacific Hide and Fur Pocatello, Idaho
2. 3. - 1033115
DATE: 10/01/94 PAGES: 47
AUTHOR: Unknown/Ecology and Environment, Inc.
ADDRESSEE: Unknown/EPA
DESCRIPTION: Technical Memorandum Remedial Technologies, Alternatives and
Screening Final Operable Unit Mccarty's/Pacific Hide and Fur
Pocatello, Idaho
2. 3. . - 1033116
DATE: 10/01/94 PAGES: 82
AUTHOR: Unknown/Ecology and Environment, Inc.
ADDRESSEE: Unknown/EPA
DESCRIPTION: Technical Memorandum Comparative Analysis of- Alternatives, Final
Operable Unit McCarty's/Pacific Hide and Fur Pocatello, Idaho
SUB-HEAD: 2. 4. . Site Characterization Summary
2. 4. - 1021719
DATE: 06/01/94 PAGES: 912
AUTHOR: Unknown/Ecology and Environment, Inc.
ADDRESSEE: Unknown/EPA
DESCRIPTION: Revised Site Characterization Summary Report/Remedial Investigation
Report, Final Operable Unit : Mccarty's/Pacific Hide and .Fur
Appendices A through M
2. 4. - 1021720
DATE: 06/01/94 PAGES: 1086
AUTHOR: Unknown/Ecology and Environment, Inc.
ADDRESSEE: Unknown/EPA
DESCRIPTION: Revised Site Characterization Summary Report/Remedial Investigation
Report Final Operable Unit McCarty's\Pacific Hide and Fur
Appendices N through Y
2. 4. - 1033119
DATE: 10/01/94 PAGES: 155
AUTHOR: Unknown/Ecology and Environment, Inc.
ADDRESSEE: Unknown/EPA
DESCRIPTION: Final Site Characterization Summary Report : Final Operable Unit
Mccarty's/Pacific Hide and Fur
SUB-HEAD: 2.5. . Risk Assessment
09/11/95 U. S. Environmental Protection Agency, Region 10 Page 3
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(PHFA3) Pacific Hide & Fur - Final Site Remediation Administrative Record INDEX
2. 5. - 1033120
DATE: 10/01/94 PAGES: 234
AUTHOR: Unknown/Ecology and Environment, Inc.
ADDRESSEE: Unknown/EPA
DESCRIPTION: Baseline Human Health and Ecological Risk Assessment, Final
Operable Unit McCarty's/Pacific Hide and Fur
SUB-HEAD: 2. 6. . Remedial Investigation/Feasibility Study (RI/FS)
2. 6. - 1033113
DATE: 11/23/92 PAGES: 19
AUTHOR: Unknown/Cannon Microprobe
ADDRESSEE: Sam McNary/U.S. Bureau of Mines
DESCRIPTION: Letter discussing 1 fragment of metal well casing and 3 filter-
papers hosting light brown to reddish powdery solids, excerpt from
"Minerals in Soil Environments" attached
2. 6. - 1033117
DATE: 10/01/94 PAGES: 162
AUTHOR: Unknown/Ecology and Environment, Inc.
ADDRESSEE: Unknown/EPA
DESCRIPTIpN: Remedial Investigation, Final Operable Unit, McCarty's/Pacific
Hide and Fur
2. 6. - 1033118
DATE: 10/01/94 PAGES: 182
AUTHOR: Unknown/Ecology and Environment, Inc.
ADDRESSEE: Unknown/EPA
DESCRIPTION: Feasibility Study, Final Operable Unit, Mccarty's/Pacific Hide
and Fur
2. 6. - 1033175
DATE: 11/10/94 PAGES: 6
AUTHOR: Ann Williamson/EPA
ADDRESSEE: Jim Price/Spencer Fane Britt & Browne
DESCRIPTION: Cover letter and attached copy of EPA's volume calculations
relating to the contaminated soil at McCarty's/Pacific Hide and Fur
(Letter addressed to addressees listed on cover letter)
SUB-HEAD: 2. 7. . Applicable and Relevant or Appropriate Requirements.
2. 7. . - 1033110
DATE: 09/28/94 PAGES: 3
AUTHOR: Gordon Brown/Idaho Division of Environmental Quality
ADDRESSEE: Ann Williamson/EPA
DESCRIPTION: Cover letter and attached ARARs and "To-be Considered" materials
09/11/95 U. S. Environmental Protection Agency, Region 10 Page
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(PHFA3) Pacific Hide & Fur - Final Site Remediation Administrative Record INDEX
HEADING: 3.0. . TECHNICAL AND GUIDANCE DOCUMENTS
SUB-HEAD: 3.1, . EPA Guidance
3. 1. . - 1033112
DATE: 07/14/94 PAGES: 25
AUTHOR: Elliott P. Laws/EPA
ADDRESSEE: Regional Administrators I-X/EPA
DESCRIPTION: OSWER Directive # 9355.4-12, "Revised Interim Soil Lead Guidance
for CERCLA Sites and RCRA Corrective Action Facilities"
09/11/95 U. S. Environmental Protection Agency, Region 10 Page
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(PHFA3) Pacific Hide & Fur - Final Site Remediation Administrative Record INDEX
HEADING: 4. 0. . PUBLIC PARTICIPATION
SUB-HEAD: 4.1. . Proposed Plan/Comments
4. 1. . - 1028287
DATE: 01/09/94 PAGES: . 2
AUTHOR: Aniko R. Molnar/Southern Pacific Lines
ADDRESSEE: Ann Williamson/EPA
DESCRIPTION: Letter requesting a meeting with EPA to discuss concerns regarding
the Proposed Plan
4. 1. - 1033163
DATE: 10/26/94 PAGES: 10
AUTHOR: Unknown/EPA
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Proposed Plan for Final Cleanup, McCarty's/Pacific Hide and Fur
Superfund Site
4. 1". . - 1028292
DATE: 11/17/94 PAGES: 2 - .
AUTHOR: Aniko Molnar/Southern Pacific Lines
ADDRESSEE: Ann Williamson/EPA
DESCRIPTION: Letter requesting a 30 day extension of the public comment period
for EPA's Proposed Plan, and requesting a meeting with EPA to
clarify certain issues regarding the Proposed Plan
4. 1. -r 1028291
DATE: 11/28/94 PAGES: 1
AUTHOR: Gabe Faulk/Unknown
ADDRESSEE: Ann Williamson/EPA
DESCRIPTION: Letter commenting on the site cleanup and requesting a copy of the
study that EPA performed at the site
4. 1. . - 1028290
DATE: 11/29/94 PAGES: 3
AUTHOR: Kenneth Harten/Unknown
ADDRESSEE: Ann Williamson/EPA
DESCRIPTION: Letter commenting on the Proposed Plan, newspaper article attached
4. 1. - 1028289
DATE: 11/30/94 PAGES: 4
AUTHOR: Ann Williamson/EPA
ADDRESSEE: Aniko Molnar/Southern Pacific Lines
DESCRIPTION: Letter granting 30 day extension to the public comment period on
the Proposed Plan and addressing request for meeting as requested
in 11/18/94 letter, and discussing 6 issues raised in 11/17/94
letter
09/11/95
U. S. Environmental Protection Agency, Region 10
Page
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(PHFA3) Pacific Hide & Fur - Final Site Remediation Administrative Record INDEX
4. 1. . - 1028288
DATE: 12/14/94 PAGES: 23
AUTHOR: Michael D. Crapo/Congress of the United States
ADDRESSEE: Gerald A. Emison/EPA
DESCRIPTION: Letter requesting assistance from EPA in responding to constituent
communication (enclosed)
4. 1. - 1033249
DATE: 12/29/94 PAGES: 195
AUTHOR: James T. Price/Spencer, Fane, Britt & Browne
ADDRESSEE: Ann Williamson/EPA
DESCRIPTION: Transmittal letter and attached comments of the McCarty's/Pacific
Hide & Fur PRP Group to EPA's plan for the final operable unit
cleanup
4. 1. . - 1028286
DATE: 01/10/95 PAGES: 1
AUTHOR: Ann Williamson/EPA
ADDRESSEE: Aniko Molnar/Southern Pacific Lines
DESCRIPTION: As requested in the 1/9/95 letter, EPA will .review comments
submitted by the Group during the extension to the public comment
period on the proposed plan, and then determine whether a meeting
is warranted
4. 1.
DATE:
AUTHOR:
ADDRESSEE:
DESCRIPTION:
- 1028285
01/11/95 PAGES: 2
Gordon Brown/Idaho Division of Environmental Quality
Ann Williamson/EPA
Letter regarding State of Idaho's response to McCarty's/Pacific
Hide and Fur PRP's 12/29/95 letter to EPA, requesting that EPA
reconsider their decision to utilize the Residential Scenario for
clean up criteria
4. 1.
DATE:
AUTHOR:
ADDRESSEE:
DESCRIPTION:
- 1028284
03/06/95 PAGES: 1
George Spinner/Idaho Division of Environmental Quality
Ann Williamson/EPA
Letter regarding the State's position on the revision to the
McCarty's/Pacific Hide and Fur Proposed Plan
4. 1.
DATE:
AUTHOR:
ADDRESSEE:
DESCRIPTION:
- 1028283
03/14/95 PAGES: 18
Brian D. Linnan/Woodward-Clyde
Aniko Molnar/Southern Pacific Lines
Cover letter and attached final version of the conceptual cover
plan for the McCarty's/Pacific Hide and Fur Superfund Site
09/11/95
U. S. Environmental Protection Agency, Region 10
Page
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(PHFA3) Pacific Hide & Fur - Final Site Remediation Administrative Record INDEX
4. 1. . - 1023282
DATE: 03/16/95 PAGES: 5
AUTHOR: James T. Price/Spencer Fane Britt & Browne
ADDRESSEE: James D. Oesterle/EPA
DESCRIPTION: Letter presenting thoughts about the site remedy and articulating
reasons that the capping and cover remedy would be the most
appropriate at the Site
09/11/95 U. S. Environmental Protection Agency, Region 10 Page
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