PB97-964205
                                EPA/541/R-97/125
                                January 1998
EPA Superfund
      Record of Decision:
       RSR Corp., OU 4 (Groundwater) & OU 5
       Dallas, TX
       4/3/1997

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      RECORD  OF  DECISION
      ;RSR ^CORPORATION ISupERFUNb' SITE
           ^OPERABLE -UNITING ;
         -.-.•-. ^ 'if."^-:-. ••^••'- v-, ..-:• ^^v!:-.'*^i:.»^>^^-PJi':*:'* ''•'•''•
                 *
         arid ''GROUND WATffiR PORTION
OF OPERABLE UNIT NO j; 4^ SMELTER FACILITY
               .-; DALLAS •>
               -...».- ... • - . - .. _• 9 .
                  Prepared by:
         U. S. Environmental  Protection Agency
                   Region 6
                  Dallas,  Texas

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                 DECLARATION FOR THE RECORD OF DECISION
                     RSR CORPORATION SUPERFUND SITE
            OPERABLE UNIT NO. 5 - BATTERY WRECKING FACILITY
                                  and
     GROUND WATER PORTION OF SMELTER FACILITY (OPERABLE UNIT NO. 4)

       Statutory Preference for Treatment as a Principal  Element
              is Not Met and  Five-Year  Review is Required
SITE NAME AND LOCATION

RSR Corporation Superfund Site, Operable Unit  (OU) No. 5
and Ground Water portion OU No. 4, Dallas, Dallas County, Texas


STATEMENT OF BASIS AND PURPOSE

The United States Environmental Protection Agency (EPA) presents its
decision in this Record of Decision  (ROD) for source and ground water
of Operable Unit (OU) No. 5, the location of the former battery
wrecking facility,  and for the ground water portion of OU No. 4, of the
RSR Corporation Superfund Site (RSR Site).  EPA's decision is in
accordance with the Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA or Superfund), 42 U.S.C. § 9601 et seq.,  and,
to the extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan  (NCP), 40 C.F.R. Part 300.  The decision is
based on materials and documents EPA relied on or considered that are
contained in the Administrative Record  for OU No. 5.  Copies of the
Administrative Record for OU No.  5 are  available for public review' at
three repositories,  one of which is located in west Dallas within the
RSR site and near OU Nos. 4 and 5.  EPA bases this decision on the
results of a remedial investigation, feasibility study, and human
health risk assessment conducted at OU  No 5.

The State of Texas,  through the Texas Natural Resource Conservation
Commission  (TNRCC),  concurs with EPA's  selected remedy for OU No. 5 and
the ground water portion of OU No. 4 of the RSR Site.
ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances, as  defined  in
Section 101(14) of CERCLA,  42 U.S.C.  §  9601(14), and  further  defined  in
Section 302.4 of the NCP,  40 C.F.R. § 302.4,  from  the  RSR  Site,  if not
addressed by implementing  the response  action  selected in  this  ROD, may
present an imminent and  substantial endangerment to public health,
welfare, or the environment.

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DESCRIPTION OF THE REMEDY

Operable Unit No. 5 and the ground water portion of OU No. 4 are part
of five operable units of the RSR Site.  OU No. 5 includes the former
battery wrecking facility where batteries were disassembled and other
property currently owned by RSR Corporation. . The ground water portion
of both OU Nos.  4 and 5 are addressed as part of this ROD for the RSR
site.  The selected remedy will address contamination of the former
battery wrecking facility and the ground water portion of OU No. 4.

The major components of the selected remedy include:

      •    Decontamination of Buildings, Demolition of the Former
           Battery Wrecking Building and Off-site Disposal;

      •    Containment of the Former Surface Impoundment, Former
           Landfill and Slag Burial Area/Other Soils.

      •    No Action on the Ground Water Portion of OU No. 4 and OU No,
           5.

Arsenic, antimony and lead, the primary contaminants of concern at OU
No. 5, are hazardous substances, as defined in Section 101(14) of
CERCLA, 42 U.S.C. § 9601(14), and further defined in Section 30'2.4 of
the NCP, 40 C.F.R. § 302.4.
STATUTORY DETERMINATIONS

The selected remedy is protective of human health and the environment,
complies with federal and State requirements that are legally
applicable or relevant and appropriate to the remedial action, and is
cost-effective.  This remedy utilizes permanent solutions and
alternative treatment to the maximum extent practicable for this
Operable Unit.  However, due to the size of the former landfill'
portion, slag burial area/other soils, it was determined\impracticable
to excavate and treat the chemicals of concern effectively.  Thus, the
remedy for this Operable Unit does not satisfy the statutory preference
for treatment as a principal element of the remedy.

The future land use may be limited to industrial use based on current
zoning and the reasonably anticipated future zoning.  The remedy
achieves cleanup levels that allow most, if not all, of OU No. 5  to be
available for the reasonably anticipated future land use, which is
industrial use.

Because  this  remedy will result  in hazardous substances remaining on-
site  above health-based levels,  allowing for future  industrial use,
five-year reviews will be necessary at OU No. 5 of  the RSR Site to
ensure  that the remedy continues  to provide adequate protection of
human health  and the environment.

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SIGNATURE AND AGENCY ACCEPTANCE  0?  THE  REMEDY
Admini
Defxfty Regional Administrator
U.S. EPA - Region 6
                                                         Date

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                  RECORD OF DECISION
              CONCURRENCE DOCUMENTATION
                          FOR THE

               RSR CORPORATION SUPERFUND SITE
       OPERABLE UNIT NO. 5 - BATTERY WRECKING FACILITY
                            and
GROUND WATER PORTION OF SMELTER FACILITY (OPERABLE UNIT NO. 4)
                 GU
                       Ann  D. Schober
                Site Remedial Project Manager
                    Michael  C. Barra
                       .te Attorney
                  cius cttmaarria, Chief
                     Texas Section
                William K. Honker, Chief
           Arkansas, Oklahoma and Texas Branch
                   Mark  Peycke, Ohief
            Litigation and Enforcement Branch
                 Jice of Regional Counsel
              Pam Phillips, Deputy Director
                   Superfund Division
            Myron O.Knudson, P.E . , Director
                   Superfund Division

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                            DECISION SUMMARY
                     RSR CORPORATION SUPERFUND SITE
                           OPERABLE UNIT NO 5.
                              DALLAS,  TEXAS

                            TABLE OF CONTENTS
TITLE


I.

II.

III.

IV.

V.

VI.

VII.

VIII.

IX.

X.

XI.
                 PAGE

Site Name,  Location, and Description 	  1

Site History and Enforcement Activities  ....  1

Highlights  of Community Participation  	  3

Scope and Role of Operable Units	4

Site Characteristics 	  5

Summary of  Site Risks	19

Remedial Action Goals  	  27

Description of Alternatives  	  29

Summary of  Comparative Analysis  	  36

Selected Remedy  	  42

Statutory Authority Findings and Conclusions
of Law	44
XII.
Documentation of Significant Changes
46

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                        LIST OF TABLES AND FIGURES
 TABLES

 Table  1
 Table  2
 Table  3
 Table  4
 Table  5
 Table  6
 Table  7
 Table  8
 Table -9
 Table  10
 Table  11
Chemicals of Potential Concern
Exposure Assumptions
Toxicity Values - Noncancer Effects
Toxicity Values - Cancer Effects
Summary of Risks (Former Surface Impoundment)
                 (Former Landfill)
                 (Buildings)
                 (Other Soils (0-2. feet) )
Summary of Risks (Other soils (0-10 feet) )
Summary of Risks (Sediment)
Summary of Risks (Surface Water)
Summary of Risks
Summary of Risks
Summary of Risks
FIGURES

Figure 1
Figure 2
Figure 3
Figure 4
Figure 5
Figure 6
Figure 7
Figure 8
Figure 9
Figure 10
Figure 11
Figure 12
Figure 13
Figure 14
Figure 15
Figure 16
Figure 17

APPENDIX
RSR Site Vicinity Map
OU No. 5 Site Map
Subarea 1 Topography
Subarea 2 Topography
Subarea 3 Topography
Subarea 4 Topography
Registered Well & Surface Water Intake Locations
OU No. 5 Site Features
On-site Buildings and Structures
Residual Dust Sample Concentrations
Surface Water & Sediment Sample Concentrations
Surface Soil Sample Concentrations
Subsurface Soil Sample Concentrations
Ground water Monitoring Wells and Elevations
Ground water Monitoring Wells Sampling Concentrations
Conceptual Exposure Areas
Alternative 3 Components
A.   Responsiveness  Summary
B.   Adult  Lead  Cleanup  Level
C.'   Technical Memorandum
D.   TNRCC  letter  of concurrence
.E.   ARARs  Evaluation
F.   TNRCC  letter
G.   Revised  Cost  Estimates

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                            DECISION SUMMARY
                     RSR CORPORATION SUPERFUND SITE
             OPERABLE UNIT NO.  5  -  BATTERY  WRECKING FACILITY
                                  and
     GROUND WATER PORTION OF SMELTER FACILITY  (OPERABLE UNIT NO. 4)
I.    SITE NAME, LOCATION, AND DESCRIPTION

The United States  Environmental  Protection Agency (EPA)  is addressing
the release  or threat of release of hazardous substances at the former
battery wrecking facility,  Operable Unit (OU) No. 5 and  the ground water
portion of OU No.  4 of the  RSR Corporation Superfund Site (RSR Site)
under the authority provided in  the Comprehensive Environmental
Response, Compensation,  and Liability Act (CERCLA),  42 U.S.C. § 9601 et
seq.  (also known as Superfund)  and consistent with the National Oil .and
Hazardous Substances Pollution Contingency Plan  (NC?), 40 C.F.R. Part
300.  The RSR Site is located in west Dallas, Texas and  encompasses an
area approximately 13.6 square miles in size.  The RSR Site is very
diverse and  includes large  single and multi-family residential
neighborhoods, multi-family public housing areas and some industrial,
commercial and retail establishments.  The population in this area is
approximately 17,000.

For approximately 50 years,  a secondary lead smelting facility, located
at the southeast corner of  the intersection of Westmoreland Road and
Singleton Blvd., processed  used  batteries and other lead-bearing
materials into pure lead,  lead alloys, and other lead products.  This
smelter property,  known as  OU No. 4, is approximately 6.5 acres in size
and contains several inactive structures.  Other industrial property
related to the smelter,  the former battery wrecking facility, referred
to as OU No. 5,  is located  on the southwest corner of the Westmoreland
Road and Singleton Boulevard intersection.  The smelter  operations
ceased in 1984.
II.   SITE HISTORY  AND ENFORCEMENT  ACTIVITIES

OU No. 4  is the location at the RSR Site where secondary lead smelting
operations were conducted from the early 1930s until 1984.  The basic
inputs into the smelting process were lead scrap and lead from used car
batteries.  In the first step of the smelting process the batteries were
disassembled at the battery wrecking facility  (OU No. 5) using hammer-
mills to  break the batteries into  small pieces.  The lead posts and
grids were then sent  across the street to the smelter facility  (OU No.
4) to produce soft pure lead or specialty alloys.   In the refining
process alloy elements, such as antimony, arsenic,  and  cadmium, were
added as  necessary to produce the  desired product.

An extensive review of available historical  information concerning  the
smelter's operation indicates that from approximately 1934  until  1971

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the lead smelting facility and associated battery wrecking operations
were operated by Murph Metals, Inc. or its predecessors.  In 1971, RSR
Corporation acquired the lead smelting operation and operated under the
name Murph Metals.  RSR continued to operate the smelter and associated
battery wrecking operations until the acquisition of the facility by
Murmur Corporation  (Murmur).  In 1984, the City of Dallas declined to
renew the smelter's operating permit.  The smelter and associated
battery wrecking facility have not been operated since 1984.

During 1984 and 1985, TNRCC (formerly the Texas Water Commission)
conducted inspections on the smelter and battery wrecking facilities and
identified several violations that involved the treatment, storage or
disposal of hazardous wastes.   In 1986, TNRCC approved a closure plan to
be implemented by Murmur for portions of the battery wrecking facility
located at OU No. 5.  However, Murmur was unable to obtain certification
by TNRCC of final closure,  due to a dispute between Murmur and its
contractor.  In June of 1991 the State of Texas referred the case
regarding the closure to the Superfund program for assessment.
Immediately following this referral, TNRCC began receiving complaints
from residents alleging that slag and battery chips had been disposed of
on their properties.

In 1991,  EPA began soil sampling in west Dallas to determine the
presence of soil lead contamination.  The results indicated that
contamination existed in some residential areas near the smelter  (OU No.
1) where fallout of contamination from the smelter stack had occurred
and where battery chips or slag had been used as fill in residential
yards and driveways.  Consequently, EPA initiated an emergency removal
action in the residential areas consisting of removal and off-site
disposal of contaminated soil and debris in excess of removal action
cleanup levels.  This removal action in the residential area  (OU No. 1)
was completed in June of 1994.

In 1993,  EPA initiated remedial investigations of the smelter and
related properties  (OU Nos. 4 and 5) and alleged smelter waste disposal
areas (OU No. 3).  In addition, an investigation of and removal  action
at OU No. 2, the public housing residential area, was initiated  by the
Dallas Housing Authority under EPA oversight pursuant to a CERCLA
Administrative Order on Consent.                                 :

On May 10, 1993, EPA proposed the RSR Site to the National Priorities
List (NPL) of Superfund sites  (58 Fed. Reg. 27,507).

A field investigation was conducted in the Spring of  1994 on OU  Nos. 4
and 5.  During this investigation three areas of immediate concern were
identified.  More than 500 waste drums, 73 uncontained  residual
waste/debris piles  and approximately.  50 laboratory containers were  found
on OU Nos. 4 and 5.  In July  1994, EPA authorized the preparation of an
Engineering Evaluation/Cost Analysis  (EE/CA) report  to  support  the
conduct -of a non-time-critical removal action to abate  the  immediate
threat to human health and the environment posed by  the presence of
these material at OU Nos.  4 and  5.    A 30-day public  comment  period  on
the proposed removal action as described  in the  EE/CA report  began  on
September 16,  1994.  The proposed  rerr.oval entailed removal  and  off-site

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treatment and disposal of all drums, residual waste/debris piles and
laboratory containers.  On December 22, 1994, the Action Memorandum
authorizing this removal action was signed.  EPA commenced site
activities for the non-time-critical removal action on May 30, 1995 and
completed these activities by July 14, 1995.

On September 29, 1995, the RSR Corporation Superfund Site was finalized
on the NPL (60 Fed. Reg. 50435).

EPA notified several potentially responsible parties (PRPs) and provided
them the opportunity to perform or finance the RI/FS for OU No. 4 and 5.
The PRPs did not agree to perform or finance these response actions.
EPA performed the RI/FS for OU No. 4 and 5 with funding from the
Hazardous Substance Suoerfund (Fund).
III.  HIGHLIGHTS  OF COMMUNITY  PARTICIPATION

EPA has performed public participation activities for OU No. 5 and the
ground water portion of OU No. 4 as required in CERCLA Section .113(k),
42 U.S.C. § 9613(k), and Section 117,  42 U.S.C. § 9617.  The Remedial
Investigation Report, Feasibility Study, Baseline Human Health Risk
Assessment Report, Supplemental Ground water Investigation and the
Proposed Plan for OU No. 5 and the ground water portion of OU No. 4 of
the RSR Site were released to the public on May 10,  1995.  On or before
May 10, 1995, EPA made available to the public these documents as well
as other documents and information EPA relied on or considered in
selecting the preferred alternative, Alternative No. 3 - Decontaminate
and Dismantle Battery Wrecking Facility and Dispose Off-site;
Decontaminate Vehicle Maintenance Building; Evaluate, Cap and close in
accordance with RCRA the Former Surface Impoundment and the Former
Landfill; Cap Slag Burial Area/Other Soils that exceed remedial goals.
These documents were contained in an Administrative Record File for OU
No. 5  (or draft Administrative Record) available for review at 3
locations; the West Dallas Public Library  located at the RSR Site, the
EPA Region 6 library in Dallas, and the TNRCC library in Austin, Texas.
The notice of the availability of the Proposed Plan and the
Administrative Record File was published in The Dallas Morning News on
May 9, 1996.  The public comment period commenced on June 17, 1996 and
ended on August  16, 1996.  EPA con-ducted a public meeting on July  9,
1996 to receive public comments from the community. EPA's responses to
all comments received during  the public comment period are included in
the Responsiveness Summary, which is included as Appendix A. to this
Record of Decision  (ROD).

This ROD presents EPA's selected remedial  alternative for OU No.  5 and
the ground water  portion of OU No.  4 of the RSR Site in Dallas, Texas.
The selected remedy will provide protection of human health and the
environment  in accordance with CERCLA and  consistent with the NCP.  This
decision is based, on the Administrative Record for  OU No. 5.

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IV.  SCOPE  AND  ROLE OF OPERABLE  UNITS

There are five OUs of the RSR site,  which are distinct geographical
areas that are illustrated in Figure 1 and described below:

   OU No.  1  - Private  residential areas potentially impacted by
historical operations of the smelter;

   OU No.  2  - The Dallas  Housing  Authority's  public housing development
located northeast of the smelter facility;

   OU No.  3  - Former  landfills  and smelter waste disposal  areas
located at three different sites within west Dallas;

   OU No.  4  - The smelter facility;

   OU No.  5  - Former  battery wrecking facility and other industrial
tracts  of land associated with the smelter and located across
Westmoreland Road from the smelter facility.

This ROD addresses only OU No.  5, the location of the former battery
wrecking facility, and the ground water portion of OU No.  4.  OU No. 5
consists of the former battery wrecking facility, which includes the
battery wrecking building, the vehicle maintenance building, a former
surface impoundment,  a former landfill and other undeveloped property.
OU No.  4 is the location of the former secondary lead smelter facility.
Because the nature of some of the former operations and wastes at OU
Nos. 4  and 5 are similar, EPA conducted certain studies of the two OUs
simultaneously,  such as the ground water investigation.

Final Records of Decisions for OU Nos. 1 and 2 were issued on May 9,
1995. A final Record of Decision for OU No. 4  (except for the ground
water component) was issued on February 28, 1996.   EPA is currently
completing a Remedial Investigation at OU No. 3 and a Proposed Plan
outlining a recommended Superfund response action for OU No. 3 will be
released at a later date.

This ROD for OU No. 5 and the ground water portion of OU No.4, is EPA's
final decision to address the contamination associated with all of  the
on-site buildings, the former surface impoundment, the former landfill,
slag burial area/other soils and ground water.   Potential ingestion,
dermal contact and inhalation of materials present on OU No. 5
contaminated with lead, arsenic, and antimony  in excess of  remedial
goals  (described  fully in Section VII.) pose unacceptable risks to  human
health and  the environment.  The purpose of the  selected response action
is to prevent current or  future  exposure to the  contaminated materials
at OU No. 5 and  the ground water portion of OU No.  4.

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SITE
         RESIDENTIAL PROPERTY IOU NO. V 30UNOAHY

         DALLAS MOUSING AUTHORITY IDMA) PROPERTY (Ou NO. 21

         SLAQ Puts lOu NO. 31. SITES V 3, AND 4

         MuRMuR/RSR SMELTER-TRACT \ IOU NO. 41

         OtnEfl MuRMER/RSA INDUSTRIAL PROPERTY (Ou NO. SI
               FIGURE   1
              VICINITY  MAP
OPERABLE UNITS  (OU)  NOS. 1,2.3,4 &  5
 RSR  CORPORATION  SUPERFUND  SITE
             DALLAS. TEXAS

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V.       SITE CHARACTERISTICS

This section presents an overview of the characteristics of OU No. 5,
the'former battery wrecking facility (also referred to herein as the
"site").  For purposes of discussion of the Remedial Investigation
findings, OU No. 5 was divided into Subareas 1 through 4.  Figure 2
shows the identification layout of the OU No. 5 Subareas.

This Section contains a summary of the site soils, geology,
hydrogeology,  ground water, topography, surface water,  climate and land
use.  Followed by a detailed description of the pertinent site features,
such as all of the on-site buildings and other significant features.
Finally, a discussion of the findings of the field investigation is
included in the Nature and Extent of Contamination Section.  Note that
all of this information can be found in greater detail in the Remedial
Investigation Report and supporting Technical Memorandums, which are all
part of the Administrative Record for Operable Unit No. 5.


  A.  Soils

Tne USDA Soil Conservation Service (SCS),  identified the Trinity-Frio
soils as the major soil type surrounding and including OU No. 5.
Trinity-Frio soils are floodplain soils,  poorly drained, clayey, with
low permeability (less than 0.06 in/hr) and high water capacity.
Because these soils are primarily found in flat, low-lying areas, runoff
and the potential for these soils to erode is minimal.

The specific soil complex on OU No. 5 is the Houston Black-Urban
Complex, Ferris-Urban Land Complex, and the Trinity-Urban Land Complex.
The Houston Black-Urban Complex consists of deep, moderately well
drained, nearly level and gently sloping soils and areas of Urban Land.
 Subareas 1 and 4 would fall under the classification of Urban Land,
which is typical of areas characterized by disturbed soil and fill
material that have greatly altered the natural soil type.  Permeability
is very slow and runoff potential associated with the Hous.ton Black soil
classification is rated as medium.  The majority of Subarea 2 and 3
soils are classified as Ferris-Urban Land Complex.  This soil unit
consists of deep, well drained, sloping and strongly sloping soils and
areas of Urban land.  Permeability is very slow, and the runoff  is
rapid.  The erosion hazard for the Ferris-Urban Land Complex soils is
severe.


  B. Regional Geology

In the vicinity of the OU No.  5 site, the predominant geologic  units  are
of the Upper Cretaceous Age.   The  formations consist of  (in descending
order) the Austin Chalk Formation, the Eagle Ford Shale  Formation,  the
Woodbine Formation, and the Grayson Marl and Main Street  Limestone
Formation.  The geologic units making up the Cretaceous  system  in north-
central Texas form a southeastward-thickening wedge extending into  the
East Texas Embayment.  This sedimentary wedge ranges in  thickness from
zero in the west to nearly 75CO feet in the  southeast.   Regional dip  is

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SMCUTOH avo.
 SU8MKA4
             V _
                             ASSUCO OU NO. 5

                             BOUOARV
              2
              t
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               CONKMATttN MWM> SITE
                   OMJLAS. Tf XAS

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to the east and southeast at 15 to 40 feet per mile but increases .as
much as 300 feet per mile on the flanks of the Preston anticline,
located in Grayson County, north of Dallas.

Geologic maps of the surface soils indicate the OU No. 5 site is
situated at the bottom of the surface expression of the contact between
the top of the Eagle Ford Shale Formation and the overlying Austin
Chalk.  As documented by logs of deep wells in the area, the full
thickness of the Eagle Ford Shale Formation, which overlies the Woodbine
Formation, is present beneath the OU No. 5 site.

The Eagle Ford Shale Formation is composed primarily of dark shales with
occasional thin stratas of sandstone, limestone, and bentonite.  The
Eagle Ford Shale Formation has two members, the Arcadia Park being the
upper, and the Britton being the lower member.  The  upper beds of the
Arcadia Park member are present in the surface soils at the OU No. 4.
The Arcadia Park is described as a basal blue clay twenty  (20) feet
thick; overlain by one to three feet of thin limestone flags; overlain
by an uppermost part of some seventy-five  (75) feet of blue shale with
calcareous concretions of various size, which is unconformable overlain
by the Austin Chalk.  The underlying Britton member is typically 250-300
feet thick and consists mostly of blue clay/shale.  The Eagle Ford Shale
Formation is commonly referred to as an aquitard overlying the Woodbine
Formation.


  C. Site Geology

Beneath OU No. 5,  Quaternary alluvial deposits vary in thickness from a
few feet in the southeast corner to over 30 feet in Subarea 1.  The RI
included drilling of soil and geoprobe borings in the fill and alluvial
deposits beneath the site.  The soil bo-rings were drilled to a depth of
up to 72 feet, to a.point where the Eagle Ford shale was generally
encountered.

Each boring encountered clays or silty clays, with occasional silt or
sand.  The top of the Eagle'Ford, sometimes seen as a weathered 'shale,
was encountered at elevations ranging from 484 feet mean sea level  (MSL)
to 402 feet MSL (beneath the former surface impoundment) across the
site.  It gradually increases in elevation toward the eastern portion of
Subarea 2.
  D.  Hydrogeology

In north-central Texas,  the  two most important water-bearing
stratigraphic units are  the  Woodbine Group, a minor aquifer, and the
Trinity Group, a major aquifer.  A major  aquifer  is defined as  one which
yields large quantities  of water in a comparatively large area  of the
State, and a minor aquifer is defined as  one which yields large
quantities of water in small areas, or  relatively small quantities of
water in  large areas  of  the  State.  Both  aquifers provide municipal,
domestic, industrial, and some irrigation supplies to  the north-central
portion of the State.  It should be noted

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that water for Dallas residents is provided by the City of Dallas water
system, which draws its water from surface reservoirs many miles from OU
Nos. 4 and 5.

The Woodbine Aquifer is of Upper Cretaceous age and is composed of sand
and sandstone.  The nearest outcrop of the Woodbine Formation to OU Nos.
4 and 5 is in far northwestern Dallas County and eastern Tarrant County,
a minimum of 10 miles from the OU No. 5 site.  Groundwater flow within
the Woodbine is generally to the east.  In the vicinity of OU Nos. 4 and
5, the depth to the Woodbine from the ground surface is approximately
200 to 250 feet.

The Trinity Group Aquifer is comprised of Lower Cretaceous age
formations (the Paluxy,  Glen Rose, Twin Mountains, and Antlers)  which
are older and encountered at greater depths than the Woodbine and other
geologic units present within OU Nos. 4 and 5. These geologic units were
deposited in fluvial,  deltaic,  and shallow marine depositional
environments, and are typically comprised of sands interbedded with
clays,  limestone, dolomite,  gravel, conglomerates, and evaporates (the
latter are present in the upper Glen Rose).  Outcrops of Trinity Group
formations are found in Parker County, approximately 60 miles west of
Dallas County.  Within the RSR Site, the depth to the Trinity Aquifer
from the ground surface is approximately 1,300 to 1,500 feet to the
Paluxy formation and approximately 2,500 feet to the Twin Mountains
Formation.

The Quaternary alluvial deposits also contain small amounts of water in
this area, although they are not classified as a minor or major aquifer
by the State.  The shallow groundwater in the vicinity of OU Nos. 4 and
5 is not generally considered a water supply aquifer due to its overall
low yield and slightly saline quality.  According to a RCRA Facility
Assessment completed by the TWC (now TNRCC) for the Smelter Facility in
1988, the alluvial system was not believed to be hydraulically connected
to the deeper Woodbine aquifer due to the presence of the 300-foot-thick
Eagle Ford shale beneath the site.  Groundwater was generally
encountered at depths of 5 to 10 feet below ground surface in the RI
monitoring wells installed to depths of up to 24 feet  (completed at the
base of the alluvial materials overlaying the Eagle Ford).


  E.  Groundwater Quality

In the Dallas area, the general quality of groundwater from the Trinity
Aquifer ranges from 500 to 3,000 mg/1 total dissolved solids  (TDS),
which indicates fresh to slightly saline water.  Sulfate and chloride
concentrations do not exceed secondary drinking water standards of
300 mg/1.  Increasingly poor quality  (high TDS) water  from this aquifer
in parts of  the Dallas-Ft. Worth area in  recent years has been
attributed to over-pumpage of the aquifer.

Only the lower part of the Woodbine Aquifer  (i.e., the upper  sand unit
at a depth of 730 to 830 feet)  is considered  to be suitable for
development  due  to high iron concentrations  in the rest  of the aquifer.
In the Dallas area, groundwater from  various  units of  the Woodbine

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Aquifer is in the 1,000 to 3,000 mg/1 range for IDS (slightly saline),
and sulfate concentrations generally exceed TNRCC's recommended drinking
water limit of 300 mg/1 (30 TAG § 290.113).  Wells completed on or near
the outcrop tend to produce groundwater of a higher quality-  .The
primary uses of water derived from the Woodbine are for domestic
livestock and public supply.  However, due to  (1) an increasing
dependence on surface water for public supplies,  (2) historically large
withdrawals of water from the Woodbine, and (3) low permeabilities of
the Woodbine's water-bearing zones,  this aquifer  is no longer used as a
primary source of drinking water for Dallas County, and is not used by
the City of Dallas.

The primary source of recharge for both the Trinity and Woodbine
Aquifers is considered to be precipitation on outcrop surfaces.
Recharge from streams flowing across the outcrop, and surface-rwater
seepage from lakes, streams, and ponds are considered secondary sources.
No primary recharge areas are located within five miles of OU Nos. 4 and
5.  As stated previously,  the outcrop surfaces for the Woodbine and
Trinity Formations are located a minimum distance of 10 miles to the
west of OU Nos.  4 and 5.

The water contained in the Quaternary alluvial deposits is a result of
surface infiltration from runoff and likely interacts directly with
surface water features in the area rather than the underlying aquifers
due to the presence of the Eagle Ford Shale Formation aquitard.


  F.  EPA Ground water Classification

Based on the Guidance on Remedial Actions for Contaminated Ground water
at Superfund Sites  (EPA/540/G-88/003), EPA generally classifies ground
water as Class I, Class II,  or Class III.  These  classifications are
considered guidelines for determining the appropriate amount of
remediation for a Superfund site and are paraphrased below.

•       Class I  (special ground water)  is:
         (1)   highly vulnerable to contamination  based on hydrological
        characteristics; and
         (2)   either irreplaceable as a drinking  water source or
        ecologically vital.

•       Class II  (current and potential  sources  of  drinking  water  and
        water having other  beneficial  uses) is  categorized  as:
        '(1) .  Class IIA,  ground water that is currently used; or
         (2)   Class IIB,  ground water that is potentially available for
        drinking  water, agriculture,  or other  beneficial  use.

•       Class III  (ground water  not  considered-a potential  source of
        drinking  water and  of  limited beneficial use)  has the following
        characteristics:
              total dissolved solids greater than 10,000 milligrams per
         liter  (mg/1),  or
              is otherwise contaminated by naturally.occurring
        constituents or human  activity net associated with a particular

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        waste disposal activity or another site beyond levels that
        allow remediation using methods reasonably employed in public
        water treatment systems.

        Class III ground water is:

         (1)   Class IIIA,  ground  water that is interconnected  to surface
        water or adjacent ground water that potentially could be used
        for drinking water; or

         (2)   Class IIIB,  ground  water that has no interconnection to
        surface water or adjacent aquifers.


  G.  Topography

The RSR Site is  located oh the margin between the Blackland Prairie and
the Eastern Cross Timbers  physiographic provinces.  The RSR Site
topography is characterized by low,  flat to gently undulating  surfaces.
Most of the RSR  Site is located on a floodplain terrace of the Trinity
River.  The northern and western edges of the RSR Site are bounded by
the Trinity River levee.   The topography for each of the subareas of OU
No. 5 are discussed below:

        Subarea 1 - In Subarea 1 the  surface  drainage  is generally  from
the southeast to the northwest.  The former surface impoundment was
filled in by previous remediation activities,  which created a  mound 10
to 15 feet above the surrounding.area.  The topographic relief across
Subarea 1 is approximately 30 feet,  not including the surface
impoundment mound (See Figure 3).

        Subarea 2 - Subarea 2  has a high point along  the east boundary
line  (adjacent to Westmoreland Road).   The majority of the surface flow
in this Subarea  drains to  the west and north.   The topography in this
area varies due  to former  site activities,  including former landfilling
activities.  The difference in elevation across Subarea 2 is
approximately 60 feet (See Figure 4).

        Subarea 3 -  Subarea  3 generally slopes  from  the east to the
west, with the higher elevations along Westmoreland Road.  The
topographic relief across  the Subarea is approximately 30 feet  (See
Figure 5).

        Subarea 4 - Subarea  4  is generally flat  with  surface  flow
towards the northwest and the  topographic  relief  across is 3 feet  (See
Figure 6).


  H.  Surface Water

The Trinity River and its tributaries, and  Fishtrap Lake in the Dallas
Housing Authority area  (OU No. 2), are the only major  surface water
bodies in the vicinity of OU N'o. 5, as shown  in Figure 7).  The West

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LEGEND
..0   TOPOGRAPHIC CONTOUR
     SHOWING GROUND
     ELEVATION IN FEET MSL.
     DRAINAGE PATHWAY
                                                                                                                SITE TOPOGRAPHY
                                                                                                                    SUBAREA 1
                                                                                                               OPERABLE  UNIT NO. S
                                                                                                         RSR CORPORATION SUPERFUND SITE
                                                                                                                  DALLAS. TEXAS

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Wl SIMOKtl AND ROAD
                                                                                FIGURE ~
                                                                              SITE TOPOGRAPHY

                                                                             OPERABLE LMIT NO.  5
                                                                       RSR CORPORATION SLVERFUND SITE
                                                                                DALLAS, TEXAS

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LEGEND
     UNCt



     STUDY ABtA



     1OPOCHAPMIC CONIOUW

     S>lOWING CflOUNO

     ELEVATIONS IN fit' MSL


     DRAINAGE PATHWAY
                                                                                LA  Kl UNION  PARKWAY
                                                           -\
v,     -
   X

     F-
                                                                                               \
                                                                                                            o
                                                                                                            n
                                                                                                          FIGURE 5
                                                                                                        SITE TOPOGRAPHY
                                                                                                           SUBAREA 3
                                                                                                      OPERABLE UNIT NO. 9
                                                                                                 RSR CORPORATION SUPERFUND SITE
                                                                                                         DALLAS. TEXAS

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                                               SINGLE"! ON  BLVD.
 LEGEND

^^^— SIUOX *.Ht»

     FtNCt
     fOHOOB»PMIt
     CON i OUR
     SttOWING
     GROUND
     EUVAtlONS
     IN (til MSl
                                                 SUBARFA  A
                                                   f.XlSTING 'BUH DING
                                                                                              FIGURE
                                                                                           SITE TOPOGRAPHY
                                                                                              8U6AREA 4
                                                                                          OPERABLE UNIT NO. S
                                                                                     RSR CORPORATION SUPERFUO SITE
                                                                                             DALLAS.  TEXAS

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                                                                                                                          a--
                                                                                                                                   "Bf"
   40
                       W
                                                                    44
                                                                20*
                                                                           23
                                                                             22
                                                                             •* »24
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                                        29*  .   .31
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                                                        • 39
                                                                   32.
                                                                      36
                                                                                                   A46
                                                                                      25.
                                                                                              26
                             CAOlMO STATION
A  SUR'ACE WATIR INTAKES
                                                                                 •33
                                                                                                                       16
                                                                                                                                               •w •
                                                                                                                       •13
                                                                                                                           • 14
                                                                                                                                    CACM3 STATION
                                                                                                                                  .17
MIC..SHMIU

Si»nfALt AA
                   i(R wtus

              GAGING STATIONS
           FIGURE 1
     REGISTERED WELL AND
SURFACE  WATER INTAKE LOCATIONS
 OPERABLE UNITS NUMBERS 4  ft  S
RSR CORPORATION SUPERFUND SITE
          DALLAS.  TEXAS

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Fork flows east-northeast from Grand Prairie  (500 to 1,000 feet from the
western edge of OU No. 1) before joining the Elm Fork to form the main
channel.  From the confluence of the West and Elm Forks, the Trinity
River flows east and then south  (approximately 4500 feet north of OU No.
5 at its closest point).  A surface drainage channel (approximately 3000
feet northwest of OU No. 5)  empties into the Old West Fork channel,
which joins the Trinity River at a pumping station between Westmoreland
and Hampton Roads.

The Texas Water Code specifies all segments of the Trinity River Basin
for recreational use.  None of the river segments are specified for
domestic water supply.


  I.  Climate

The climate in Dallas County is temperate to hot.  During the winter,
cold surges of air cause the moderate temperature to drop,  thereby
producing cool winters with occasional snow.  Rainfall  throughout the
County is relatively consistent throughout the year, with a slight
increase usually in the spring.  Wind direction is primarily from the
south-southeast.  In the DFW area,  the average annual windspeed for 1992
was 9.9 miles per hour (mph).


  J. Lan.d Use and Zoning

The battery wrecking facilities and other industrial property are all
located on land designated as OU No. 6.  The four Subareas designated in
OU No. 5 are all located in a commercial/industrial zoned area by the
City of Dallas.  Areas surrounding OU No. 5 comprise a mixture of
residential, commercial, and industrial facilities.  Based on the 1994
City of Dallas zoning map Subareas 1 and 4 of OU No. 5 are currently
zoned as Industrial Manufacturing  (IM).  IM zoning for the City of
Dallas includes, industrial, wholesale distribution and storage, and
support office and retail uses.  Subareas 2 and 3 are currently zoned as
SUP 98  (IR).  This property has limited uses under the Industrial
Research (IR) zoning code as stipulated in specific use permit  (SUP)
number 98.   IR zoned property is generally designated for industrial
research that includes industrial,  wholesale distribution and storage
and supporting office and retail.  The surrounding land, which comprises
OU No. 1 of the RSR site, is zoned primarily for single-family
residential, multi-family residential, light and heavy industrial uses
and, to a lesser extent, commercial and retail.  The reasonably
anticipated future land use of OU  No. 5 is commercial/industrial based
on the past and current zoning map for this area.


  K.   On-Site Buildings and Features

OU No. 5 has two buildings  on-site as shown on Figure 8.  These  include
the Former  Battery Wrecking Facility building and  the Vehicle
Maintenance Buildir.g.  The  following sections briefly  describe  the
construction and present physical  condition of each  building based  on  a

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«*-«e mtDf
                                                   LEGEND

                                                 - ASSIACO OU NO. 5
                                                   BOUTCAftV
                                                   ACTIVE FACILITY - NOT
                                                            IN RI/FS
                                             — —  DRAINAGE PATHWAY
                                         SITE FEATUCS &
                                      O*ENA«Lf IMT NO. S
                                R3R OOHPQMATlON «FERRM> SITE
                                         DALLAS. TEXAS

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visual review of the structures by a structural engineer in March and
April 1994 during the RI field activities.  The structural survey
Technical Memorandum, dated January 1995,  is contained in the
Administrative Record for OU No. 5.  Other on-site features,  such as the
former surface impoundment, the slag burial area on Subarea 1,  and the
landfill area in Subarea 2, are -also discussed.

         1.   Former  Battery Wrecking Facility Building

The former battery wrecking facility building is a pre-engineered metal
building clad with uninsulated siding and  roofing.  The roofing and
siding are rusted,  dented,  or otherwise damaged in several locations.
The facility originally consisted of a 100 foot by 220 foot metal
building.  Based on historical aerial photographs, this building was
enlarged in the 1980's to the present size of 150 feet by 360 feet.
Several deficiencies were observed in the  former battery wrecking
facility during the structural inspection, and they include:   poorly
attached roof panels and light fixtures,  deteriorated concrete, weakened
and deteriorated column bases and roof beams.  Some of the building
columns have suffered significant damage  and others have rusted
completely through at the base and are supported by the roof  structure.
The appearance of the former battery wrecking facility indicated that
the structure is likely to experience structural failures in  the near
future unless major rehabilitation is performed.

         2.  Vehicle Maintenance Building

The vehicle maintenance building is a pre-engineered metal building
formerly used as a vehicle garage.  Historical aerial photographs
indicate it was built between late 1979 and early 1981.  The  exterior of
this building indicates no rust, and only  minor dents are apparent.  The
interior appears to be in fair condition  with the exception of the
restroom/office area.  The structure is approximately 13 years old, and
may have several years of useful life remaining.  Some interior
refurbishing would be required if the building is to remain in service.

         3 .  Underground Storage Tanks

Two underground storage tanks (USTs) were  identified from TNRCC tank
registration forms to be located on OU No. 5.  These forms indicate that
limited information is available about the two USTs.  Based on the
information from these forms the two USTs  were constructed of steel of
unknown capacity and are approximately 19  years in age.  One tank  is
believed to contain gasoline and the other diesel fuel.  The approximate
location of the USTs is just south of the  former battery wrecking
building.

         4.   Former  Surface  Impoundment

The former surface  impoundment is  located in Subarea 1 of OU No.  5  in
the area west of the former battery wrecking facility building  (See
Figure 8).  According to the information  obtained by EPA the surface
impoundment was used to contain, neutralize and settle wastewater  and
waste by-products from the lead-acid battery crushing and stripping

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operations.   Reportedly the surface impoundment was constructed of
natural clay soils and incorporated an earthen dike to provide a 2 foot
freeboard.  During operation a concrete lined spillway discharged into
the drainage ditch that parallels the railroad tracks located along the
north boundary of Subarea 1.  Historical aerial photos indicate that the
area was used for liquid storage beginning in the 1940s,  and the latest
configuration is believed have been constructed in the late 1960s.
Earlier characterizations of the sludge in the surface impoundment found
high concentrations of lead, up to 63.9 percent,  and an average sludge
thickness or depth of 80 inches.  The volume of sludge in the pond
(prior to RCRA closure activities) was estimated at 240,000 cubic feet.

As part of RCRA closure activities conducted by the current owner
(Murmur)  in  1988, the surface impoundment was backfilled with soil that
was excavated from the southeast section of Subarea 1 and stabilized
with cement  kiln dust.  The RCRA closure plan called for a 4 foot thick
clay cap over the entire surface impoundment area, where the stabilized
soil was placed, including the existing dikes.  The top was to be graded
for a 5 percent slope and side sloped of 4 horizontal to 1 vertical.
During the 1994 EPA field investigation, erosion gullies were observed
on the side  slopes in several places, but the cap appeared to be intact
and stable.   Boring logs during the field investigation indicated the
cap varies from 4 to 6 feet in thickness, with a vegetative cover.

         5.   Former Landfill

Based on a review of historical aerial photographs, it appears that
landfilling  operations occurred in an area located in Subarea 2.
However no records, permits or other documents regarding the landfill
activities have been located.  Based on the data gathered during the
1994 field investigation, the extent of the landfill was estimated as
shown in Figure 8.  The thickness of the landfill material varied from 2
feet to over 14 feet.  Test pits during the RI typically encountered two
to three feet of a clay soil at or near the surface.  Below the clay
layer material consisting of ground or shredded automobile parts  (glass,
rubber hoses, plastic, and assorted metal parts)  were found.  Additional
debris consisting of battery casings, slag, white powder and metal
fragments were also found.


         6.   Slag  Burial  Area

During a review of previous investigation  information generated as part
of the 1988 RCRA closure areas, slag burial areas were identified in
Subarea  1.  Some of the  slag burial area is located beneath the existing
paved parking area in Subarea  1.  Figure 9  illustrated the estimated
extent of the slag fill  material.


  L.  Nature and  Extent  of  Contamination

As part  of the  RI, all potential  sources and  areas  of contamination  were
investigated.   These  areas  included  all  of the surfaces  and  floors  of
the buildings and  structures,  residual  waste  piles,  the  surface  and

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LEGEND
     OU S. SUB ARE A 1
     INVESTIGATION LIMITS
                                                                                                                             MIUIMCU MO
                                                                                                                            	«JBMiA I
                                                                                                                            OfVUKI IMIT NO. S
                                                                                                                      MM CMKMATON KMWlM) SITE

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subsurface soils, the stormwater runoff and sediments and the ground
water.  Samples were collected and analyzed from each of these areas to
evaluate the nature and extent of contamination.  Migration to the
subsurface soils and the ground water was also investigated through
exploratory borings, test pits and the installation of ground water
monitoring wells.

A summary of the findings of the RI and the non-time critical removal
action is provided in the discussions below, however, as stated
previously, all of this information can be found in detail in the
Remedial Investigation Report and supporting Technical Memorandums,
which are all part of the Administrative Record for OU No. 5.  As stated
previously, to facilitate discussion of the data,  OU No. 5 was divided
into four Subareas  (Defined in Section V.G.).

        1.  Buildings and Structures Results

An asbestos survey was completed to assess the potential for the
presence of asbestos containing materials in buildings and structures.
A total of nine  (9)   samples were collected and analyzed for the
presence of asbestos.  None of the nine (9) samples from the OU No. 5
buildings and structures contained asbestos.

Supplemental dust sampling was also conducted in both OU No. 5 buildings
in May 1995.  Five  (5)  dust samples from inside the former battery
wrecking building and two (2)  from inside the vehicle maintenance
building were collected using a high-volume dust sampler and analyzed
for the Total Analyte List  (TAL) metals.  Also during the field
investigation in the spring of 1994, an X-ray Fluorescence  (XRF)
instrument was used to estimate concentrations of metals on readings"on
the building surfaces (e.g. walls and floors).

The dust samples collected as part of the supplemental sampling
indicated, lead ranging from 51,200 parts per million (ppm) to 68,400
ppm, arsenic concentrations ranging from 6.3 ppm to 113 ppm, and cadmium
ranging from 2.4 ppm to 36 ppm.  Antimony concentrations were detected
at a range of 7 ppm to 91 ppm.  Figure 10  shows the sampling locations
and results for lead, arsenic and cadmium.

The XRF data from the former battery wrecking facility's and concrete
floors also indicated contamination from lead, cadmium and arsenic.  The
maximum concentrations detected in the buildings using XRF were 171,677
ppm, 3,481 ppm and  392 ppm  lead, arsenic and cadmium, respectively.

As stated previously in Section V.K.I the  former battery wrecking
building is in advanced stages of disrepair and deterioration.  This
combined with the elevated  concentrations  of lead, cadmium  and arsenic
present on and within the former battery wrecking  facility  surfaces  give
rise to potential releases  or migration of  contamination.   Precipitation
and/or high winds could cause re-suspension of  the depositions on  the
buildings, structures and equipment surfaces as fugitive  dust.  Human
activities have  the  potential to cause  the  re-suspension  of  these
depositions into the air or surface water  runoff.  Subsequent transfer
of  the contamination by air or  stormwater  runoff  is  also  likely.

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 LEQEM?


       FENCE

—  FlElD INVESTIGATION LIMITS

*      iAMPlE |OC* I IONS
  1   CONCENTRATIONS AHt  IN

     PARTS P€R  MIILION.
             SMOKIM wtnt
     ANALYSED  FOR TAHCtl
     ANAITIt I 'SI  TOlAI Mil Alb
FORMER SURFACE       /
UJPOUNDUENT         /
                                        |         /'        FORMER BATTERY
                                                                                                                                            BUILDING
                                                                                                                                                      •X.MMO gnou

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         2.   Surface water and Sediment Results

Surface water samples were also collected from OU No. 5 to determine the
nature and extent of surface water contamination.  Figure 11 illustrates
the surface drainage flow direction and the elevated concentrations of
lead, arsenic and cadmium detected in the eleven (11) samples collected
from Subarea 1.  The range of concentrations for lead in the surface
water samples were non-detect to 173 parts per billion (ppb).  The
highest lead level was detected along the west boundary,  south of the
former surface impoundment.   Arsenic concentrations ranged from not
detected to 5.1 ppb,  with highest level also located along the west
boundary, south of the former surface impoundment.   Cadmium was not
detected in any of the eleven (11)  surface water sampling locations.
The dissolved metal concentrations were analyzed in two of the surface
water samples and were significantly lower than those detected in the
total metals analysis.  The  low dissolved metals results show that
metals concentrations are probably associated with  particulate (total
suspended solids).

A total of twenty-five (25)  sediment samples were collected from twenty-
two locations within OU No.  5.   Figure 11 illustrates the locations and
concentrations of lead, arsenic and cadmium detected in the sediment
samples.  Lead levels varied from 8.0 ppm to 5,380  ppm,  with the highest
level detected on-site west  of  the former landfill  area.   The range of
arsenic concentrations detected was from 1.4 ppm to 47.2 ppm.  Levels of
arsenic increased along the  drainage channel crossing Subarea 1,
reaching 17.4 ppm where the  drainage channel exits  the west boundary of
OU No. 5.  Cadmium was detected at eight (8)  samples at concentrations
ranging from 0.6 ppm to 45.9 ppm.  The maximum concentration of cadmium
was detected in a drainage west of the former landfill.

Some semi-volatile organic compounds were detected  in the sediment
samples collected at OU No.  5.   The compounds detected were primarily
polynuclear aromatic hydrocarbons (PAHs)  and pthalates.   Most of the
elevated concentrations of PAHs were detected in the area of the former
landfill.  In addition a variety of pesticides were detected in four
sediment samples all collected  in Subarea 2,  the area of the former
landfill.  All of the concentrations of pesticides  were less than 0.017
ppm, the concentration detected of dieldrin.   Since the pesticides were
detected in.the drainages as sediment, it is likely that periodic
surface water flow within the drainages transported sediments form off-
site areas or as a result of potential historical pesticide use at the
OU No. 5 site.  Four different  Polychlorinated Biphenyl Compounds  (PCBs)
were detected in eight (8) sediment sampling locations at OU No. 5.  All
of the detected concentrations  of PCBs were less than 0.5 ppm, with four
(4) detections in the area of the former landfill,  three  (3) detections
in the area of the former surface impoundment, and one (1) detection in
drainage in the northern portion of Subarea 3.

Sediments likely represent a continuous source for potential off-site
migration via re-entrainment in stormwater runoff.    Re-suspension of
exposed, surface sediment depositions as fugitive dust could also occur
due to high winds or human activities.
                                    14

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              I O* *ATf*VTM SAtfUt
                W

   ARSENIC CADMIUM  AND LEAD
   CONCENTRATIONS  IN WATER
 SAMPLES AND SEDIMENT SAMPLES
     OPERABLE  UNIT NO. 5
RSR CORPORATION SUPERFUNO  SITE
         DALLAS.  TEXAS

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         3.   Surface  Soils  (0-2  feet)  Results

Both surface and subsurface soils were evaluated at various locations
across the OU No. 5 site.  For purposes of the RI and this document,
surface soil, includes the horizon from zero to two  (2) feet below ground
surface  (bgs).

In Subarea 1, southeast of the former battery wrecking facility
building, XRF measurements were made on a 25 foot by 25 foot grid along
the slag burial area.  In this area lead was detected at 50 of the 61
XRF locations,  with the range of concentrations from 53 ppm to 19,946
ppm.  Arsenic was detected using XRF at three (3) of the 61 XRF
locations and concentrations ranged from 31 ppm to 46 ppm.  Cadmium was
detected in five (5)  of the 61 locations, with concentrations ranging
from 74 ppm to 333 ppm.

Soil samples were also collected in Subarea 1 for TAL metals analysis.
The maximum concentrations detected in TAL metals analysis was 65,900
ppm for lead, 2,160 ppm for arsenic and 191 ppm for cadmium.  See Figure
12 for locations and concentrations of lead,  arsenic and cadmium surface
soil samples.

Samples from battery chip and slag fragments were collected separately
from the ground surface at four locations in Subarea 1.  Each sample was
analyzed for TAL metals and Toxicity Characteristic Leaching Procedure
(TCLP)  metals.   The locations and TAL concentrations of these samples
are also shown in Figure 12.  For the exposed battery chips, the maximum
lead,  arsenic and cadmium concentrations were 7,280 ppm, 114 ppm, and
2.3 ppm,  respectively.  The TCLP analysis showed that lead
concentrations for two (2) samples exceeded the TCLP criteria of 5,000
ppb of lead  (e.g. 8,380 ppb and 89,600 ppb).   For the exposed slag
samples,  the maximum lead concentration detected was 51,600 ppm, the
maximum arsenic concentration detected was 2,450 ppm and the maximum
cadmium concentration detected was 26.2 ppm.   The TCLP analysis of the
slag samples also showed that the criteria of 5,000 ppb of lead was
exceeded (e.g.  53,600 ppb and 211,000 ppb).

In Subarea 2, the location of the former landfill, lead surface soil
concentrations detected ranged from 24.1 ppm to 65,900 ppm.  Arsenic
concentrations in Subarea 2 ranged from 24.1 ppm to 303 ppm.  The range
of cadmium concentrations in Subarea 2 ranged from non-detect to 75.1
ppm.  In Subarea 3, lead, arsenic and cadmium surface soil
concentrations were lower, and the maximum levels detected were 433 ppm,
13.5 ppm and 2.9 ppm, respectively.  See Figure 12.

In Subarea 3, three  (3) soil samples were collected from the 0-2 foot
horizon.  As shown in Figure 12 the maximum concentrations of lead,
arsenic and cadmium detected were 433 ppm, 13.5 ppm and 2.9 ppm,
respectively.

These results indicate higher levels  of contaminants  associated with
affected surface soils in Subarea 1,  the area of  the  former battery
wrecking facility, and in Subarea 2,  the former  landfill.  The  surface
soils in these areas  likely represent a continuous  source  for potential
                                    15

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   ARSENIC CADMIUM AND LEAD
      CONCENTRATIONS IN
  SURFACE SOIL  SAMPLES (0-2  U)
      OPERABLE  UNIT  NO. 5
RSR CORPORATION SUPERFUNO  SITE
         DALLAS.  TEXAS

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off-site migration via re-entrain.-nent in stormwater runoff.  Re-
suspension of soil as fugitive dust could also occur due to high winds
or  inadvertent human activities.


         4.   Subsurface Soils  (greater than 2  feet bgs)  Results

Subsurface soil samples at various depths across OU No. 5 were collected
and analyzed to determine the vertical extent of soils contamination
from past operations.  The locations of soil  and geoprobe borings from
which subsurface samples were collected are presented in Figure 13.
Subsurface soils samples were also collected  from test pit excavations.
Results of the soil borings sampling and test pit investigations are
discussed below.

Nine soil borings and nine geoprobe locations were placed in Subarea 1.
Subsurface samples were collected from these  locations and the
concentrations of lead, cadmium and arsenic detected are illustrated in
Figure 13.  The highest concentrations of lead detected were in a boring
in the former surface impoundment at 5 - 6 foot depth (24,100 ppm)  and
in a boring in the slag burial area at the 2-3 foot depth  (24,000
ppm).  Maximum arsenic and cadmium concentrations detected in Subarea 1
were in the area of the former battery wrecking facility at the 2-4
foot depth at 312 ppm and 11.4 ppm, respectively.  Four test pits were
also excavated in Subarea 1,  and two test pits were located in the slag
burial area.  The concentrations of lead, arsenic and cadmium were
de.tected, from a test pit in the slag burial area were as high as 96,500
ppm, 2,940 ppm and 34.1 ppm respectively at the 10 foot depth.  One test
pit was excavated through the asphalt parking lot between the battery
wrecking facility building and the vehicle maintenance building  (slag
burial area) and a 10 foot layer of slag, batteries, battery chips and
wood pieces was encountered.

In Subarea 2, the area of the former landfill, 16 borings were placed as
shown in Figure 13.  Subsurface soil samples  were collected at various
depths at several locations.   The highest lead, arsenic and cadmium
subsurface concentrations detected in Subarea 2 soil borings were 5,130
ppm, 99.9 ppm,  and 94.8 ppm,  respectively, in the 2-4 foot horizon.
A total of 31 test pits were excavated in order to estimate the extent
of the former landfill area in Subarea 2.  A typical test pit excavation
within the landfill area of Subarea 2 consisted of the following layers
from the surface down:

         •     One to two feet of surface soil sometimes mixed with a
light, fluffy,  fibrous material and pieces of corroded metal;

         •     Two to three foot clay layer;

         •     Three to six feet of shredded automobile parts, battery
chips, and industrial refuse;

         •     Two to five feet of natural clay underlain by  shale.

-------
   ARSENIC CADMIUM AND LEAD
      CONCENTRATIONS IN
    SUBSURFACE  SOIL SAMPLES
     OPERABLE  UNIT NO. 5
RSR CORPORATION SUPERFUNO SITE
         DALLAS.  TEXAS

-------
Samples of subsurface automotive and industrial debris contained
elevated Total Petroleum Hydrocarbons (TPH) and concentrations of PCBs
ranging from 8 ppm to 11 ppm.  Volatile analysis of one test pit sample
also indicated low levels of benzene, ethyl benzene, and xylene.


Seven borings were also placed in Subarea 3, the area south of the
former landfill.  Samples were collected at 3 of the boring locations
for TAL metals analysis.  Only one boring sample at the 4.5 - 5 feet
depth indicated elevated levels of lead, arsenic and cadmium, at
concentrations of 2,320 ppm, 29.1 ppm and 49.0 ppm, respectively.  See
Figure 13.

Two test pits were excavated in Subarea 4, the vacant lot north of
Subarea 1, and both pits contained buried industrial debris at a depth
of 4 to 7 feet.

Subsurface soils potentially represent a source of contamination
migration via entrainment or dissolution by infiltrated precipitation
and subsequent vertical percolation to the shallow alluvial deposits.


        5.  Ground water Investigation  Results

The two most important water-bearing units in the Dallas area are the
Woodbine Group, classified by the State as a minor aquifer, and the
deeper Trinity Group, classified by the State as a major aquifer.  In
the vicinity of OU Nos. 4 and 5, the depth to the Woodbine aquifer from
the ground surface is approximately 200 to 250 feet and the depth to the
Trinity aquifer is approximately 1,300 to 1,500 feet.  Only the lower
part (approximately 730 to 830 feet) of the Woodbine aquifer is
considered to be suitable for development, however this aquifer is no
longer used as a primary source of drinking water for Dallas County, and
is not used by the City of Dallas due to  (1) an increasing dependence on
surface water for'public supplies,  (2) historically large withdrawals of
water from the Woodbine, and (3) lower permeabilities of the Woodbine.

The shallow ground water in the vicinity of OU Nos. 4 and 5 is not
classified by TNRCC as a major or minor water supply source due to its
overall low yield and slightly saline quality.  The shallow ground water
system under OU Nos. 4 and 5 may migrate to surface drainage channels in
the area and thereafter to the Trinity River.  The Trinity River is  not
used as a drinking water supply.  The drinking water supply for the  west
Dallas community  is provided by the City of Dallas water system which
draws from surface water reservoirs located many miles from the RSR
Site.  The Texas  Department of Health and the Dallas City Code
requirements limit the  installation of private wells in the RSR
Corporation Superfund Site area  (general vicinity of Westmoreland Road
and Singleton Boulevard) in any ground water aquifer.

The RI included an investigation of the current conditions of the ground
water conditions  beneath OU No. 5 and OU  No.  4, as  well as the  nature
and extent of any ground water  contamination  related to pas't  operation
of the secondary  lead smelter and associated  battery wrecking
operations.

-------
The soil borings drilled on OU Nos. 4 and 5 generally encountered fill
material and alluvial material consisting of clays, silts, or sands to a
depth of 10 to 25 feet bgs, at which depth the weathered Eagle Ford
shale was encountered.  During the RI, shallow ground water monitoring
wells were installed at seven  (7)  locations across OU No. 4.  These
monitoring wells were completed to depths of 12.3 to 25.7 feet bgs.
There are eight  (8)  existing ground water monitoring wells located on OU
No. 5.  All eight (8) wells are shallow, 17.8 to 29.9 feet bgs, and one
well has been dry since it was installed in 1981.  Also during the RI,
seven (7) additional wells were installed on OU No. 5.  The depths of
the wells on OU No.  5 ranged from 7.5 feet to 65 feet bgs.

Ground water elevations and samples were collected from these monitoring
wells at two separate events in May 1994 and in June 1994.  A
supplemental ground water investigation was also conducted to enhance
the characterization of the shallow alluvial aquifer in June 1995.  This
investigation involved collecting another round of ground water samples
from each monitoring well and performing slug tests on each well to
estimate in-situ hydraulic conductivity of the water bearing strata.

The ground water elevations during the May 1994 and the June/July 1995
sampling events indicated a northwest-trending gradient.  Figure 14
illustrates the ground water elevations from the June/July 1995
monitoring event.  In the ground water monitoring well sampling events
Lead was detected in a range of 1.2 ppb to 2,250 ppb,  while
concentrations of arsenic ranged from Non-Detect (ND)  to 77 ppb.  While
the results from the second round of sampling in June/July 1995
indicated significantly lower lead concentrations,  ranging from ND to
646 ppb.  Cadmium was not detected in either round of sampling.  The
lower second round concentrations coincide with a lower level of Total
Suspended Solids (TSS) compared to the previous round, suggesting that
the majority of the  metals contamination is associated with particulate
material.  Figure 15 illustrates the results of the lead, arsenic and
cadmium detected in the OU Nos. 4 and 5 monitoring wells from the
June/July 1995 sampling event.

During the slug tests the monitoring wells demonstrated relatively low
yield, with the majority of the wells bailed dry during purging
activities.  Based on the water level changes documented during the slug
tests, the expected yield for the shallow alluvial aquifer appears to be
significantly less that 1 gallon per minute at most locations.  This
yield could not be maintained at any one location for any period of
time, since most wells were purged dry in a .relatively short time
period.

The shallow ground water in the vicinity of OU Nos. 4 and 5 is not
considered to be a potential water supply due to its overall low  yield
and slightly saline quality and the availability of the City of Dallas
water supply, as well as potable supply permitting requirements.  Based
on the character cf the shallow ground water, the yield estimates of
less than 1 gallon per minute, the domestic use of this system  is
unlikely.  In addition, the expected migration pathway  of the  shallow
ground water is  the Trinity River  or its tributaries and neither  are
used as  a drinking water supply within  3 miles.  Since  the shallow
ground water beneath OU Nos.  4 and 5 is not considered  to be a  potential
drinking water supply  (i.e. a Class III aquifer),  further evaluation  in
                                    is

-------
                                                                 	J
                                           I
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    '   ^s-ofi3"'
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                                                            230-
                                                     ASSUMED 00 NO. 3
                                                     BOUNDARY
                                                — — OU NO. 4
                                                     BOUNOAflY
                                              »5-o:o
-------
5-3CO'
     5. '8
                     AS.-3.P-
                                                               •   MONITORIMO NEU. LOCATION
                                                               3.  U  • T»« AHAtYTE WAS

                                                               BU?S*OT 06TECTEO
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                                                       J*€/JULT «B SAMH.MO EVCNT
                                                            OFEMABLE IMT NO. ft
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                                                               DALLAS.  TEXAS

-------
the Risk Assessment and Feasibility Study was not conducted and no
action is recommended for the ground water beneath OU Nos.  4 and 5.


         6.  Non-time critical removal action

EPA commenced a removal action at OU Nos. 4 and 5 on May 30, 1995 and
completed all work by July 14, 1995.  Waste materials present at' 90
residual/debris piles and drum location's were addressed during 'the
removal.  This included more than 600 drums of waste material, and more
than 60 containers of waste laboratory chemicals.  This resulted in a
total of over 740 cubic yards of consolidated waste being manifested to
a off-site hazardous waste landfill for stabilization or encapsulation;
1700 gallons of hazardous liquids being manifested to an off-site
incineration facility;  20 cubic yards of debris being sent to a class I
nonhazardous landfill;  more than 15,500 gallons of collected rainwater
and drummed monitoring  well water being permitted for discharge into the
sanitary sewer system;  22 lab packs of chemicals being manifested to an
incineration facility;  one box of medical waste being sent to a medical
incineration facility;  and 11 gas cylinders and 8 lead/acid batteries
being recycled.  All of the materials were removed from OU Nos. 4 and 5
and disposed in accordance with the requirements specified in EPA's
Action Memorandum, dated December 22, 1994.

As part of the removal  action, testing of the surfaces once a residual
waste/debris pile was removed was performed to document the
concentrations of any contamination remaining on the concrete surfaces
following the removal action.  This testing was performed using a field
portable Spectrace 9000 x-ray fluorescence (XRF) instrument.   The
maximum concentrations  detected on the OU No. 5 surfaces following the
removal using XRF for lead, arsenic and cadmium were 103,177 ppm, 3,328
ppm, and 397 ppm, respectively.   These results indicate elevated levels
of lead, arsenic and cadmium are still present on the concrete floors of
the buildings and structures.
VI.  SUMMARY OF SITE RISKS

A.  Risk Assessment Description

An evaluation of the potential risks to human health and the environment
from OU No. 5 contaminants was conducted as part of the baseline risk
assessment.  The risk assessment was conducted as part of the RI.  The
baseline risk assessment is an analysis of the potential adverse human
health effects  (both current and future) resulting from exposures of
humans to hazardous substances present on OU No. 5.  By definition, a
baseline risk assessment evaluates risks that may exist under the no-
action alternative  (that is, in the absence of any remedial actions to
control or mitigate releases).  The baseline risk assessment provides
the basis for taking the remedial action and indicates the exposure
pathways that need  to be addressed by the remedial action.

The Summary of  Site Risks section of the ROD summarizes the results of
the baseline risk assessment.  Calculations and  a more detailed  analysis
r.ay be found in the baseline Human Health Risk Assessment and Ecological
Risk Assessment reports for OU No. 5, contained  in the Administrative
                                    19

-------
Record for OU No. 5.

B.  Human Health Risks

The baseline risk assessment was divided into two parts: the human
health evaluation and the ecological evaluation.  The baseline risk
assessment for the human health risks was based on Reasonable Maximum
Exposure  (RME).  The human health evaluation considered all contaminated
media, such as the buildings and structures dust, sediments, surface
water and the soils.  The baseline risk assessment assumed that the
reasonably anticipated future land use of OU No. 5 would be
commercial/industrial, based on the City of Dallas current zoning map.
Therefore, the potential risk to the following populations most likely
to be exposed at OU No. 5 were evaluated:

        o     Current and Future On-site trespassers (adults and
              children)
        o     Current On-site Facility and Railroad Workers
        o     Future On-site Commercial/Industrial Workers

The risk assessment conducted at OU No. 5 of the RSR site was done in
accordance with  EPA guidance, specifically the Risk Assessment Guidance
for Superfund: Volume I:  Human Health Evaluation Manual (Part A)
(Interim Final,  EPA/540/1-89/002,  December 1989).  The major components
of the baseline  risk assessment are: identification of contaminants of
concern,  exposure assessment, toxicity assessment, and risk
characterization.   For purposes of the risk assessment, the risks are
evaluated by exposure areas which are  related to future land use
considerations.   The exposure areas for the OU No. 5 HHRA are defined as
follows and are  shown graphically in Figure 16:

        Exposure Area  1, -  Former surface impoundment
        Exposure Area  2 -  Former landfill
        Exposure Area  3 -  Buildings
        Exposure Area  4 -  Other soils  (0-2  feet and 0-10  feet)
        Exposure Area  5 -  Sediment
        Exposure Area  6 -  Surface Water

Highlights of the findings for the major components of the risk
assessment for the site are summarized below.
C.  Identification of Chemicals of Potential Concern

The samples collected as part of the field investigation and analyzed
through the Contract Laboratory Program  (CLP) were used in the risk
assessment to estimate risks to human receptors at OU No. 5.  This
includes data for soil, sediment, dust, and surface water.  Ground water
results were not used quantitatively in the risk assessment  (see
rationale in Section V. (Site Characteristics) L.5.).

Not all data collected as part of the removal or field investigations
were used in the HHRA.  Data associated with the materials removed
during the ncn-time critical removal action were not used for estimating
risks.
                                    20

-------
   	•?
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                                                        LEQtND

                                                        ASSLftCD OU NO. 5
                                                        BOUNDARY


                                                        ACTIVE FACILITY - NOT
                                                        INCLUDED IN RI/FS
                                               •» «o»  SEQUENT AND SURFACE
                                                     WATER SAVR.1NO
                                                     LOCATION
                                                            ONLY SA**LINO
                                                    LOCATION


                                                     ESTIMATED EXTENT of
                                                          lAL LANOF'i.1.
                                                     EXPOSURE AREA i
                                                     ICOOUER SUBCACt
                                                     IMPOUTCMENTI


                                                     EWOSURC AfCA 2
                                                     (FORVEB LANOf .LL!


                                                     EXPOSURE AI«A 3
                                                     (BUILOINO P(-US
                                                     STRUCTURE SI


                                                     EXPOSURE AREA 4
                                                      IOTHER
                                                         EXPOSURE AREAS S. •
                                                         ISURFACC WATER  AND
                                                         SEDIMENTS)
                                                         AREAS H9
                                              OPtRABU UNIT NO. S
                                             CORPORATION KMRFUND SITE
                                                 DALLAS. TEXAS :

-------
Concentrations of metals detected in surface soil sar.ples were compared
to regional background soil concentrations.  Metals were evaluated to
determine potential chemicals of concern  (COPCs) for use in the HHRA.
The COPCs identified for each of the exposure areas  are listed in Table
1.

D.  Exposure Assessment

The objective of the exposure assessment is to estimate the type,
magnitude,  frequency, duration and route of exposure of the contaminants
of concern.  The contaminant sources, as a result of past operations,
are soil, sediment and residual materials in the buildings that contain
the COPCs.   The COPCs are released through physical/chemical processes
that include, leaching, precipitation-induced runoff,  wind entrainment
or direct contact.

As discussed above, the shallow ground water in the area of OU Nos. 4
and 5 is not being used as a potable water supply,  nor is it expected to
be used as  a water supply, therefore, ingestion of ground water is not
considered  a complete pathway for purposes of this risk assessment.
Drinking water is provided by the City of Dallas through a series  of
surface water reservoirs.  The nearest public supply well is about 3,750
feet east of the intersection of Westmoreland Road and Singleton
Boulevard.   This City of Dallas well is capped and no longer used  as a
public water supply.  The well is approximately 2,540 feet deep.

The following exposure scenarios and pathways were quantitatively
evaluated in the HHRA:

         •     Current and Future On-site Trespassers (children and
              adults) and Railroad Workers - Incidental ingestion  of
              soil and sediment,  dust,  inhalation of resuspended
              particulate, and dermal contact with soil, dust or surface
              water.

              Current or Future Commercial/Industrial Worker -
              Incidental ingestion of soil and sediment, dust,
              inhalation of resuspended particulate, and dermal contact
              with soil and sediment, dust, or surface water.

Exposure scenarios were evaluated using standard EPA default exposure
parameters  for average  (typical) and Reasonable Maximum Exposure  (RME)
conditions.  RME is defined as the "highest exposure that is reasonably
expected to occur at a site.  The intent of the RME is  to estimate a
conservative exposure case.  Trespasser and commercial  exposure
scenarios evaluated  in the HHRA used standard EPA default exposure
parameters  for average  (typical) and RME scenarios.  These parameters
are presented in Table 2.

At the present time, EPA  does not have an  approved  model  for estimating
blood-lead levels  in adults that are exposed  to environmental  sources  of
lead.  Consequently, for  this HHRA,  lead  exposure to adults  (trespasser
and commercial/industrial worker scenarios) was estimated using a
screening-level model  developed by Bowers  e_t  al .  J1994).  This  model
uses a biokinetics  slope  factor derived  from  the work  of  Pocock et  al.
 (1933),  who measured blood-lead levels  in  over  7,000 middle-aged  men in
                                    21

-------
Tahle |
C'hvmu-iils of Potential Concern
KSK Corporation Superfund Site
Operable Unit No. 5

Kxposurc Area 1
Surface
linpoundnicnl






".illinium

'nh.ill 	
1 . .,,1
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N'ukel 	 . 	
Selenium 	 . 	
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Aeenaplilliene 	 	 	 	
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Alpha elllol.l.llie 	
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HisiJeihsllK-vslil'lillKil..!.-
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X
X
X
X

X
X

X

X

Kxposurv Area 2
ftirmiT
Landfill



X

X
X







Kxposurc Area 3
Buildings








_


x
x

Kxposurc Area 4
Other Soils
(0 • 2 feel)


X
X

X
X



x



Kxposure Area 1
Other Soils
(0- 10 feel)
Kxposure Area 5
Sediment


X
X
X
X
X

X

X
X
X
X
X

X
X

X
X

X
X
X
X
X
X
X "
X
X
X
Kxposure Area 6
Surface Water

X
X
X
X


X
X
X
X
X
X

Jlul\l I I
               •M H\SM\ XI. S slieel Sheet I
                                                                                 Page 1 of 2

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                                                                                  Table  1
                                                                      Chemicals of Potential Concern
                                                                      KSK Corporation Superfund Site
                                                                     	Opemhle llnil No. 5	
           Chimical Nairn1
                                       Kxposure Area I
                                           Surface
                                        Impoundment
Kornirr
Landfill
KxpiiMure Area
   Buildings
Other Soils
 (0 • 2 feet)
Other Soils
(0 - 10 feet)
Exposure Area 5
   Sediment
Exposure Area 6
 Surface Water
                 dl
4.4  ODD
   i hilt\l
         i I
 •JtllliMllt.Mt II
        cT*;iMN for sclcclifi^ cxpt).surc areas lor
                   '^MNMS >!K-CI Sluvi I
                                                                                    Page 2 of 2

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Table 2-
Exposure Assumptions -Worker"
RSR Corporation Superfund Site
Operable Unit No. 5
Exposure Parameter
Soil/Scdiment/Building Dust Ingestion Rate
(nig/day)
Inhalation Rale (m'/hour)
Skin Surface Area (tin"')
Soil-to-Skin Adherence Factor (mg/eiir)
lixposure Time (hours/day)
Hxposure Frequency (days/year)
Hxposure Duration (years)
Hoily Weight (kg)
Averaging Time- Noncancer (years)
Averaging Time -Cancer (years)
Current Occupational- Adult
Typical Exposure
50
2.5
5000
0.2
1"
52"
9
70
y
70
Reasonable Maximum
Exposure
50
2.5
. 5000
1
2"
52"
25
70
25
70
Future Occupational- Adult
Typical Exposure
50
2.5
5000
0.2
X
250
y
70
y
70
Reasonable Maximum
Exposure
50
2.5
5000
1
8
250
25
70
25
70
Source:
'FI'A. iy92a, unless otherwise noted.
''Uased on professional judgment or site-specific (actors.

-------
24 British towns to estimate blood-lead levels of adults exposed to
environmental sources of lead.  The study yielded a biokinetics slope
factor of 0.375 micrograms/deciliter  (mg/dL)  blood-lead per mg/day lead
uptake.   Although there is no EPA guidance on the blood lead level that
is considered appropriate for protecting adults,  both EPA and the Center
for Disease Control (CDC) recommend that there should be no more than a
five  (5)  percent likelihood that a young child should have lead value
greater than 10 ug/dL.  Since exposed workers could include pregnant
women, and because the fetus is exposed to lead levels nearly equal to
those of the mother, the health criterion selected for use in this
evaluation is that there should no more than a five (5) percent chance
that the fetus of a pregnant woman would have a lead level above 10
ug/dL.  The health goal is equivalent to specifying that the 95th
percentile of the lead distribution in fetuses does not exceed 10 ug/dL.

E.  Toxicity Assessment

The toxicity assessment involves identifying the COPCs which may cause
adverse health effects in exposed individuals.  The toxicity assessment
seeks to develop a reasonable appraisal of the associations between the
degree of exposure to a chemical and the possibility of adverse health
effects.   Whether or not a toxic response occurs depends on the chemical
and physical properties of the toxic agent, the degree of exposure to
the agent, and the susceptibility of an individual to the particular
effect.  To characterize the toxicity of a particular chemical, the type
of effect it can produce and how much is needed to produce that effect
must be known.

For purposes of the risk assessment, health effects are divided into two
categories; noncancer and cancer effects.  Noncancer health effects
include a variety of toxicological end points and may include effects on
specific organs or systems, such as the kidney, liver, nervous system
and lungs.  There are two categories of noncancer health effects, acute
or subchronic, which are short-term, and chronic, which are long-term.
Some chemical exposures that result in, or are suspected in, the
development of cancer are referred to as carcinogens.  EPA's carcinogen
classification scheme, using a weight of evidence approach to determine
the likelihood of a chemical's carcinogenic potential in humans, is
described below.

Category    Meaning	    	Basis	
   A        Known human       Sufficient evidence of increased cancer
            carcinogen        incidence in exposed humans.

   Bl       Probable human    Sufficient evidence of increased cancer
            carcinogen        incidence in animals,  with suggestive
                              evidence from studies of exposed humans,

   B2       Probable human    Sufficient evidence of increased cancer
            •^--carcinogen      incidence in animals,  but lack of data
                              or insufficient data from humans.

   C        Possible human    Suggestive evidence of carcinogenicity
            carcinogen        in animals.

-------
   D        Cannot be         No evidence  or  inadequate  evidence  of
            evaluated         cancer  in animals  or humans.

   E        Noncarcinogen     Evidence  of  noncarcinogenicity
                              in humans.

Toxicity values are quantitative expressions of the dose-response
relationship for a chemical and are expressed as cancer slope factors
and noncancer reference doses, both of which are specific to the route
of exposure.  The chronic reference doses  (RfDs), which are expressed in
terms of mg/kg-day are presented in Table  3 for the chemicals of concern
for the OU No. 5 site.  The dose-response  relationship for cancer
effects is expressed as a cancer slope factor (SF) , which is the upper-
bound estimate of the probability of a response per unit intake of a
chemical over a lifetime.  The SFs for the chemicals of concern,at the
OU No.  site are described in Table 4 and  are expressed as the inverse
of mg/kg-day.


F.  Human Health Risk Characterization

The risk of cancer from exposure to a chemical is described in~terms of
the probability that an individual exposed for his or her entire
lifetime will develop cancer by age 70.  For carcinogens,     . :
risks are estimated as the incremental probability of an individual
developing cancer over a lifetime as a result of exposure to the
carcinogen.  Excess lifetime cancer risk is calculated from the
following equation:

Risk = CDI x SF

where:

risk = a unitless probability (e.g.,  2 X 10-5) of an individual
developing cancer;

CDI = chronic daily intake averaged over 70 years  (mg/kg-day); and

SF = slope-factor, expressed as  (mg/kg-day)-1

These risks are probabilities that are generally expressed in scientific
notation  (e.g., 1 x 10-6).  An excess lifetime cancer risk of 1 x  10-6
indicates that, as a reasonable maximum estimate, an individual.has a 1
in 1,000,000 chance of developing cancer as a result of site-related
exposure to a carcinogen over a 7C-year lifetime under the specific
exposure conditions at a site.

The potential for noncarcinogenic effects  is evaluated by comparing an
exposure level over a specified time period  (e.g., lifetime) with  a
reference dose derived for a similar exposure period.  The ratio of
exposure to toxicity is called  the hazard quotient.  By adding the
hazard quotients  for all contaminants of concern which affect the  same
target organ  (e.g., liver) within a medium or across all media to  which
a given population may reasonably be exposed, the  Hazard Index  (HI) can
be generated.

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Table ^
Toxicity Values -Noncancer Health Effects
RSR Corporation Superfund Site
Operable Unit No. 5
Page 1 of 3 I
Chemical
Systemic Toxicity II
(mg/kg/day) ||
Critical Effect
Chronic Reference Dose (RfD) ||
Oral
Source
Inhalation'
Source
Inorganics
Aluminum
Antimony
Arsenic
Banum
Beryllium
Cadmium (food)
Cadmium (water)
Chromium III
Chromium VI
Cobalt
Copper
Lead
Manganese (food)
Manganese c water i
Mercury
Nickel i soluble salts i
Selenium
Silver
Thallium ie>
Vanadium
Zinc

Blood glucose, cholesterol
Keratosis. hyperpipmenution
Increased blood pressure
Organ changes, decreased body
weight
Protemuna
Protemuna
None observed
Increase in tissue chromium
connection

Gastrotm.stmal imution

CNS
CNS
CNS. kidney
Decreased bods organ weight
Hair nail loss, dermatins
Argyna
Increased SCOT i liven.
increased serum 1.DH c blood i.
diopeiu i ham
Renal
Anemia

0.0004
0.0003
0.07
0005
0.001
0.0005
1
0.005

0.0."
1C)
0.05
005
0.0003
002
0005
0.0)5
0 1XXX)8
()(HP
<> 3

IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
-
HE AST

IRIS
IRIS
HE AST
IRIS
IRIS
IRIS
IRIS
HEAST
IRIS


--
0.00014


--


-

--
0.000014
0.000014
0.000086

--
-




--
1"





-•



IRIS
IRIS
HEAST

•-




Organic; ||
I.l.l-Tnchlnroeirune
2-Buunone
2 Methyln.iphthale.ie
4.4 ODD
4.4 DDE
4.4 -DDT
Acenaphthene
Acenaphthvlene
Acetone
Anthracene
Ar.>cl.-r-i:4: .n
Liver
CNS. feiouuic



Liver lesions
Liver

Liver, kidney. CNS
None observed
Ocular jnd immunoli'iiu..!!
•-•Itects. distorted naiK
009
0.6



00005
Oi)6

0 1
n ."•
1) lltHXO
HEAST
IRIS



IRIS
IRIS

IRIS
IRIS
IRIS
o.:9
0.29









HEAST 1
IRIS ||









I  11431 <
r (/.«f.v.':
               n ""'f.D

-------
Table ^
Toxicity Values -Noncancer Health Effects
RSR Corporation Superfund Site
Operable Unit No. 5
Page 2 of 3
Chemical
Aroclor- 1248(0
Aroclor- 1254(0
Aroclor- 1260(0
Benzo( a )amh race ne
Benzo(a>pyTene
Benzo(b)fluorantnene
Benzo(g.h.i)perylene
Benzo( k )fluoranthene
bis(2-Ethylhexyl)phthalate
Burylbenzylphthalate
Carbazole
alpha-Chlordane
gamma -Chlordane
Chrysene
Di-n-hul>'lphthalale
Di-n-ncrylphthalate
Diberui a. h (anthracene
Dihen/ofuran
Dieldnn
Diethylphthalate
Endosulfan 1
Endosullan II
Endosulfan sultaic
Endnn
EnJnn aldehyde
Endnn ketone
Fluoranthene
Fluorene
Hepuchlor epoxide
Indenoi 1.2.3-cdipyrene
Methylene Chlnnde
N-S'nrosodiphenylamine
Naphthalene
Phenamhrenc
Phenol
P\rene
Tnchlornelhene
Systemic Toxicity
(mg/kg/day)
Critical Effect
Ocular and immunological
effects, distoned nails
Ocular and immunological
effects, distoned nails
Ocular and immunological
effects, distorted nails

-
--

-
Liver
Liver, kidney

Liver hypertropy
Liver hypertropy
-
Increased mortality
Liver, kidney

Kidney
Liver
Decreased weight, growth
Kidnes
Kidne>
Kidney
CNS convulsions, liver lesions
CSS convulsions, liver lesion.s
CNS convulsions, liver lesions
Liver, kidney
Decreased eryihrocvie count
Liver

Liver

Ocular and internal lesions

Reduced I'etal body wni>rus
Kidnes
Increased rel.tti\e lucr •Aeij.'hl
Chronic Reference Dose (RfD)
Oral
0.00002
0.00002
0.00002


--
--

002
0.2

--


O.I
0.02
-
0.004
ii IXXX)S
O.H
U.OIK)
O.lKXt

00003


004
0.04
0000013

0.06

1) 04

1! «>
n 03
I) i«/6
Source
IRIS
IRIS
IRIS



••
--
IRIS
IRIS

-

-
IRIS
HE AST

ECAOlg)
IRIS
IRIS
IRIS
IRIS

IRIS


IRIS
IRIS
IRIS

IRIS

ECAOihi

IRIS
IRIS
ECAOii.
Inhalation'



--
--



-
--










--
-






•;

O.S6






Source






--
-

--
--
-•




-













HEAST 1






1 I 1431 5post n
r nsse
-------
Chemical
Systemic Toxicity
(nig/kg/day)
Critical Effect
Chronic Reference Dose (RfD)
Oral
Source | Inhalation' [ Source
                                                 Table
                           Toxicity Values -Noncancer Health Effects
                                  RSR Corporation Superfund Site
                                         Operable Unit  No. 5
                                                                                          Page 3 of 3
    HEAST  =  Health Effects Assessment Summary Tables (I994o.
    IRIS     =  Integrated Risk Information System (1995d).
            =  Information not available.
    CNS     =  Central Nervous System.
    U)      Dem jd from jubchronic inhalation reference concentration (RfC)
    (b)      Denved from chronic inhalation reference concentration (RfC)
    Ic)      EPA work group considered it inappropriate to develop an RfD for inorganic lead.
    Id)      Toxiciry values correspond to nitnte.
    (e)      Toxiciry values correspond to thallium chloride
    (f)      Toxicity values correspond to Aroclor-1254.
    (g)      Provisional RfD: memo from Kenneth Poiner. ECAO to Bill Dana, Oregon DEQ. OI/24/92.
    (h)      Provisional RfD; memo from Joan Dollarhide. ECAO to Debbie Siehers. EPA Region V  July 22. 1994.
    ID      Provisional RfD; memo from Joan Dollarhide. ECAO. April 1992.
1114.'I  ?p.
-------
Table A
Toxicity Values Cancer Health Effects
RSR Corporation Superfund Site
Operable Unit No. 5
Page 1 of •
Chemical
Carcino
Tumor Site
Weight-of-
Evidence*
Source
genie Potency (mg/kg/day) '
Oral Slope
Factor
Source
Inhalation Slope
Factor1"
Source
Inorganics
Aluminum
Antimonv
Arsenic
Barium
Ber\ Ilium
Cadmium
Chromium III
Chromium VI
Cobalt
Copper
Lead
Manuanc.se
Mercury
Nickel (refinery dust)
Selenium
Silver
Thallium
Vanndium
/.'me
•
—
Lung
--
Lung. Bone
Lung

Lung
—
--
K idnev
--
—
Respiratory System
--
—
—
--
--
--
D
A
D
132
HI
U
A
--
1)
B2
D
D
A
I)
D
D
--
D
--
DWHA1
IRIS
DWHA'
IRIS
IRIS
DWHA'
IRIS
--
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
DWHA'
--
IRIS
--
—
1.5
--
4.3
—
--
--
--
-
--
--
-
--
--
-
-
--
-
-
—
LPAJ
--
IRIS
—
--
--
--
--
—
--
--
--
--
-
--
—
--
—
—
15
--
8.4
6.3
—
42
—
—
.
—
—
0.84
--
—
—
--
--


IRIS
—
IRIS
IRIS
—
IRIS
—
—
—
—

IRIS
—
—
—
—
-
1)1 N77II) \VI'S

-------
Table 4-
Toxicity Values- Cancer Health Effects
RSR Corporation Superfund Site
Operable Unit No. 5
Page 2 of •
Chemical
Carcino
Tumor Site
Weight-of-
Evidi-nce*
Source
genie Potency (mg/kg/day) '
Oral Slope
Factor
Source
Inhalation Slope
Factor"
Source
Organic*
IJ.I-Trichloroethane
2-Btitanone
2-Meihvlnaphlhalene
4,-T-DDD
4,4'-i)Di:
4,4'-l)m
Acenaphlhene
Acenaphthylenc
Acetone
Anthracene
Aroclor-1242'
Aroclor-1248'
A roc lor- 12 54'
Aroclor-12601
Ben/o(a)anthracene
Ben/o(a)pyrene
Ben/.o(b)nuoranihene
Uenzo(u.h,i)perylene
Uenzo(k)fluoranthene
his(2-L:thvlhcxyl)phthalatc
Butvlbenzvlphthalaie
—
—
—
l.ung, Liver
l.ivcr
l.ung. Liver
—
—
—
--
l.iver
Liver
Liver
Liver
Liver, Lung
Gul, respirator}'
tract
Liver, Lung,
Thorax
--
Liver, Lung,
Thorax
Liver
Leukemia
D
D
--
B2
B2
B2
--
D
D
D
B2
B2
R2
B2
B2
B2
B2
D
B2
B2
C
IRIS
IRIS
-
IRIS
IRIS
IRIS
--
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
--
--
--
0.24
0.34
0.34
-
--
--
--
7.7
7.7
7.7
7.7
0.73
7.3
0.73
--
0.073
0.014
-
--
—
--
IRIS
IRIS
IRIS
—
»
--
—
IRIS
IRIS
IRIS
IRIS
L;PAS
IRIS
KPA"
--
LPA8
IRIS
--
—
—
. —
—
..
0.34
..
—
—
—
—
—
—
—
—
--
--
—
--
~
--
..
-.
..
..
-.
IRIS
..
..
..
—
—
..
—
—
—
--
--
—
--
--
--
1)1 N77.1D Wl'.s

-------
Table 4
Toxicily Values- Cancer Health Effects
RSR Corporation Superfund Site
Operable Unit No. 5
Page 3 of •
Chemical
Carba/ole
alpha-C'hlordane
namma-Chlordane
Chrvsene
()i-ii-hulvlphthalate
l)i-n-octvlphthalaie
r)iben/.(a.h)anthracene
Dibcn/.oluran
Dieldrin
Diethvlphthalale
Lndosulfan 1
Lndosullan II
1 ndosullan sultalc
l-ndrin
l-ndrin aldehvde
l-ndrin kctonc
1 luoranthene
Tluorene
lleptachlor epoxide
lndeiu>( 1 .2.3-cd)pyrene
Melhylene Chloride
N-N'ilrosodiphcnylamine
Naphthalene
Phenanthrene
Carcino
Tumor Site
Liver
l.iver
Liver
Liver
—
--
Mammary gland
--
Liver, Lungs
—
--
--
-
'
--
--
--
--
Liver
Liver
Liver, Lung
Liver
--
--
Weight-of-
Evidence"
B2
B2
132
B2
D
--
B2
D
B2
n
--
--
--
D
D
D
D
D
B2
B2
B2
B2
D
D
Source
HEAST
IRIS
IRIS
IRIS
IRIS
..
IRIS
IRIS
IRIS
IRIS
--
--
--
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
genie Potenc
Oral Slope
Factor
0.02
--
—
0.0073
—
--
7.3
--
16
--
--
-
--
--
--
-
--
--
9.1
0.73
0.0075
0.0049
--
--
v (mg/kg/day)'1
Source
HEAST
--
--
EPAB
—
--
EPA"
--
IRIS
--
-
-
--
--
--
--
-
-
IRIS
EPA"
IRIS
IRIS
--
--
Inhalation Slope
Factorb
—
—
—
—
—
--
-
--
16
—
—
—
—
—
--
--
—
—
9.1
—
0.0016
—
—
-
Source
-.
..
„
„
1
—
—
..
IRIS
—
—
—
—
..
•
—
.
..
IRIS
-.
IRIS
..
—
-
\M'5

-------
                                                                 Table *+
                                                   Toxicity Values-Cancer Health Effects
                                                      RSR Corporation Superfund Site
                                                            Operable Unit No. 5
                                                                                                                                Page 4 of
Chemical
Phenol
P\ re ne
Trichloructhene
Carcino
Tumor Site
—
—
Lung, Liver
Weight-of-
Evidcnce"
D
D
132
Source
IRIS
IRIS
HEAST
CI99I)
eenic Potency
Oral Slope
Factor
—
--
0.0 II
f (mg/kg/day) '
Source
—
—
HEAST (1991)
Inhalation Slope
Factor"
—
..
0.006
Source
..
..
HEAST (1991)
 IIEAST -=       Health Effects Assessment Summary Tables (1994i).
 IRIS                    Integrated Risk Information System (I995d).
                         Information not available.
 'Wcight-of-Evidencc Groups: A is Human Carcinogen; B is Probable Human Carcinogen (Bl-limited evidence of carcinogenicity in humans, B2-sufficienl
 evidence of carcinogenicity in animals with inadequate or lack of evidence in humans); C is Possible human Carcinogen; D is Not Classifiable as to Human
 Carcinogenicity.
 ''Derived from unit risk factor assuming an inhalation rate of 20 m'/day and a 70 kg bodyweight.
 'Drinking Water Health Advisory. USF.PA Office of Drinking Water.  April 1992.
 "'Arsenic oral slope factor from. Special Report on Ingested  Inorganic Arsenic, July 1988, EPA/625/3-87/013.
 •Drinking Water Health Advisory. USEPA Office of Drinking Water.  January 1987.
 'Toxicily values are for total polychlorinated biphenyls (PCBs).
 "Provisional Guidance for Quantitative Risk Assessment of Polycyclic Aromatic Hydrocarbons.  EPA/600/R-93/089. July 1993.
1)1 N77l|)\\l'5

-------
The HQ is calculated as follows:

Non-cancer HQ = E/RfD
where:

E = Daily Intake (either chronic or sub-chronic)

RfD = reference dose; and

E and RfD are expressed in the same units and represent the same
exposure period (e.g., chronic, subchronic, or short-term).

A summary of risks across all exposure pathways and exposure scenarios
for each exposure area evaluated in the OU No. 5 risk assessment are
included in Tables 5, 6, 7, 8, 9, 10 and 11.  According to the
assumptions used in this evaluation, the estimated excess cancer risks
exceeded 10 -6 for the following exposure scenarios and exposure areas:

Exposure Area 1; Former Surface Impoundment
+  All scenarios

Exposure Area 2; Former Landfill
4  All scenarios

Exposure Area 3; Buildings
4  All scenarios

Exposure Area 4; Other Soils  (0-2 feet)
4  All scenarios

Exposure Area 5; Sediment
4  All scenarios except typical current commercial/Industrial Worker


The estimated hazard indices  (His) exceeded one for the following
exposure scenarios and exposure areas:

Exposure Area 2; Former Landfill
4  Current and Future Commercial/Industrial Worker (typical and RME)
*  Adult and Child Trespasser  (typical and RME)

Exposure Area 3; Buildings
4  Future Commercial/Industrial Worker  (typical and RME)

Exposure Area 4;  (Other Soils  (0-2  feet)
4  Adult and Child Trespasser  (typical and RME)

Exposure Area 4;  (Other Soils  (0-10 feet)
4  Future Commercial/Industrial Worker  (typical and RME)
4  Adult and Child Trespasser  (typical and RME)

Exposure  to  Lead
Estimated risk  from  exposure  to  lead  in  soil  and  sediment  within OU No.
5 was evaluated for  adult  trespassers  and  workers.   Children trespassers
were  not quantitatively evaluated  due  to the  lack of  an  appropriate

-------
Table ^
Summary of Risks
Exposure Area 1: Former Surface Impoundment
RSR Corporation Superfund Site
OU No. 5
_, . ...... RME
_ . Typical Lifetime _
Pathway Jr Exces
Excess Cancer Risk
Current Commercial/Industrial Worker
nhalation 1 x 10"
ngestion 6 x 10 6
Dermal NA
Total 6 x 10 *
Lifetime _, .
_ Typical Hazard „...,.. . , .
s Cancer , . RME Hazard Index
,. . Index
lisk

6xlO'7 0.01 0.02
2xl05 0.1 0.1
NA NA NA
2 x 105 0.1 0.1
Future Commercial/Industrial Worker
Inhalation 4 x 10 6
Ingestion 3 x 10 5
Dermal NA
Total 3 x 10 5
1 x I05 0.4 0.4
8x10"* 0.5 0.5
NA NA NA
9 x 10 s 0.9 0.9
Child Trespasser (7 - 16 yrs.)
Inhalation 7 x 10*
[ngestion 2 x I05
Dermal NA
Total 2 x 10 5
1 x 10 0.006 0.01
2x10' 0.4 0.4
NA NA NA
2 x 10 5 0.4 0.4
Adult Trespasser
Inhalation 3 x 10"'
Ingestion 1 x 10 "
Dermal NA
Total 1 x 10 '
5.x 10" 0.002 0.005
1 x 10 "' 0.2 0.2
NA NA NA
1 x 10 5 0.2 0.2
NA = Not applicable.

-------
Table >
Summary of Risks
Exposure Area 2: Former Landfill
RSR Corporation Superfund Site
OU No. 5
_ . Typical Lifetime RME Lif
Pathway _ _ „. „
Excess Cancer Risk Cam
Current Commercial/Industrial Worker
Inhalation 5 x 10'7
ngestion 3 x IO'5
dermal NA
Total 3 x 10 5
etime Excess Typical RME Hazard
:er Risk Hazard Index Index

3xl06 0.007 0.01
8 x 105 ' 2 2
NA 0.003 0.02
8 x 10s 2 2
ruture Commercial/Industrial Worker
nhalation 2 x 10"
ngestion 1 x I0~*
)ermal NA
Total 1 x 10-*
5 x IO"5 0.3 0.3
4 x 10"4 9 9
NA 0.01 0.07
4 x IO-1 9 9
Child Trespasser (7 - 16 yrs.)
nhalation 3 x 10
ngestion 1 x I0~*
dermal NA
Total 1 x IO"1
7xl07 0.005 0.01
1 x IO-4 6 6
NA 0.005 ' 0.02
1 x ID"1 6 6
Adult Trespasser
Inhalation 1 x 10
ngestion 7 x 10""
)ermal NA
Total , 7 x 10 5
3 x 10 " 0.002 0.004
7 x 10 '• 4 4
NA 0 003 0.02
7 x 10 5 4 4
NA = Not applicable.

-------
Table ' I
Summary of Risks
Exposure Area 3: Buildings
RSR Corporation Superfund Site
OU No. 5
_ . Typical Lifetime RME Lift
Pathway _ _ „
Excess Cancer Risk Cane
Current Commercial/Industrial Worker
nhalation 3 x IO"7
Ingestion 2 x iO6
Dermal NA
Total 2 x 10*
etime Excess Typical Hazard RME Hazard
•er Risk Index Index

2xlO'6 0.01 0.03
6xl06 0.1 0.1
NA 0.001 0.007
8x10'' 0.1 0.1
•'uture Commercial/Industrial Worker
nhalation 1 x 10s
Ingestion 1 x IO5
)emnal NA
Total 2 x 10 s
3 x 10s 0.5 0.5
3 x 10 ' 0.6 0.6
NA 0.007 0.04
6 x 10 5 1 1
rhild Trespasser (7-16 yrs.)
nhalation 2 x 10
Ingestion 8 x 10*
)ermal NA
Total 8 x 10 *
4 x 10 7 0.009 0.02
8xl06 0.4 0.4
NA 0.002 0.01
8 x 10 * 0.4 0.4
Adult Trespasser
nhalation 7 x 10'"
Ingestion 5 \ 10 h
)ermal NA
Total 5 x 10 •*
1 x l(r 0.003 0.006
5 x IO6 0.3 0.3
NA 0.001 0.007
5 x 10" 0.3 0.3
NA = Not applicable.

-------
Table r
Summary of Risks
Exposure Area 4: Other Soils (0-2 feet)
RSR Corporation Superfund Site
OU No. S
„ .. Typical Lifetime RME Lil
Pathway „ *
Excess Cancer Risk Can
Current Commercial/Industrial Worker
Inhalation 1 x 10 7
ngestion 6 x 10 6
)ermal NA
Total 6 x 10 6
retime Excess Typical RME Hazard
cer Risk Hazard Index Index

6 x 10 7 0.005 0.01
2 x 10"5 0.8 0.8
NA 0.002 0.01
2 x 10 5 0.8 0.8
Child Trespasser (7 - 16 yrs.)
Inhalation 7 x 10""
Ingestion v 2x 10"'
Dermal NA
Total 2 x 10 5
1 x IO"7 0.003 0.006
2x10" 3 3
NA 0.003 0.02
2 x 10 5 3 3
Adult Trespasser
nhalation 3 x 10s
ngestion 1 x 10°
Derma! NA
Total 1 x 10 5
5 x 10" 0.001 0.002
1x10' 2 2
NA 0.002 0.01
1 x 10 s 2 2
>IA = Not applicable

-------
Table =»
Summary
of Risks
Exposure Area 4: Other Soils (0-10 feet)
RSR Corporation
Superfund Site
OU No. 5
„ . Typical Lifetime RME Lif
Pathway Jr
Excess Cancer Risk Cant
Future Commercial/Industrial Worker
Inhalation 4x10*
ingestion 3 x 10 5
Dermal 4x 10 6
Total 4 x 10 5
etime Excess Typical Hazard RME Hazard
•er Risk Index Index

1 x 10° 0.2 0.2
9xl05 10 10
6x 10° 0.003 0.02
2 x 10-* 10 10
Child Trespasser (7-16 yrs.)
Inhalation 8 x 10*
ngestion 3 x 10
Dermal 2 x 10*
Total 3 x 10 5
2xl07 0.003 0.007
3 x 105 8 8
8 x 10" 0.001 0.006
4 x 10 5 8 8
Adult Trespasser
nhalation 3 x 10s
ngestion 2 x 10^
Dermal 1 x 10*
Total 2 x 10 5
6x10' 0.001 0.003
2 x 10'' 5 5
5 x 10'" 0.0007 0.003
2 x 10 5 5 5

-------
Table • -?
Summary of Risks
Exposure Area 5: Sediment
RSR Corporation Superfund Site
OU No. 5
n .•. Typical Lifetime Excess RME Li
Pathway „
Cancer Risk Cai
Current Commercial/Industrial Worker
nhalation 6 x 10"
ngestion 5 x 10"
Dermal 1 x IO"7
Total 6 x 10 7
fetime Excess Typical Hazard RME Hazard
icer Risk Index Index

4x 10"* 0.003 0.007
1 x 10"6 0.02 0.02
2 x 10"6 0.003 0.02
3 x 10^ 0.03 0.05
ruture Commercial/Industrial Worker
Inhalation 2 x 10"
ngestion 2 x IO"6
>ermal 6 x IO"7
Total 3 x 10 *
7xl07' O.I ' O.I
7 x IO"6 0.08 0.08
9 x IO"6 0.02 0.08
2xlOs 0.2 0.3
Child Trespasser (7 - 16 yrs.)
nhalation 5 x 10'"
ngestion 2 x 10"*
Dermal 2.x 10 "
Total 2 x 10 •*
9x 10 9 0.002 0.004
2x 10 6 0.06 0.06
1 x 10* 0.005 0.03
3 x 10 * 0.07 0.09
Adult Trespasser
nhalation 2 \ 10'"
ngestion 1 x l()'h
Dermal 1 x 10
Total 1 x 10"
3 x 10 g 0.0008 0.002
1 x I0'h 0.03 0.03
7 x 10" 0.003 0.02
2 x 10 * 0.03 0.05

-------
Table \\
Summary of Risks
Exposure Area 6: Surface Water
RSR Corporation Superfund Site
OU No. 5
„ , Typical Lifetime Excess RME Lil
Pathway „ „.
Cancer Risk Can
Current Commercial/Industrial Worker
Inhalation NA
Ingestion NA
Dermal 8x 109
Total 8x10"'
etime Excess Typical Hazard RME Hazard
cer Risk Index Index

NA NA NA
NA NA NA
4x10* 0.001 0.002
4 x 10 8 0.001 0.002
Tuture Commercial/Industrial Worker
nhalation ' NA
ngestion NA
Dermal 3x 10 7
Total 3 x 10 7
NA NA NA
NA NA NA
9xlO? 0.04 0.04
9 x 10 7 0.04 0.04
rhild Trespasser (7 - 16 yrs.)
nhalation N'A
ngestion NA
Dermal 1 x 10*
Total 1 x 10*
NA NA NA
NA NA NA
3 x 10s 0.002 0.004
3 x 10 " 0.002 0.004
Adult Trespasser
nhalation NA
ngestion NA
Dermal 9x 10 "
Total 9x10*
NA NA NA
NA NA NA
2\ 10* 0.001 0.002
2 x 10 " 0.001 0.002
NA = Not applicable.

-------
model, however, it would be expected that their risk would be greater
than that of the adult trespassers because children are more vulnerable
to adverse effects from lead exposure than adults.   A target cleanup
goal of 2,000 ppm was determined based on the blood-iead model developed
by Bowers et al.  and corresponds to a blood-lead distribution where
approximately 95 percent of the exposed population has blood-lead levels
less than 10 ug/dL.

In the OU No. 5 risk assessment, among all receptor groups, incidental
inhalation or ingestion  of soil and dust contributes the greatest
percentage of the overall risk  (as high as 100 percent) compared to the
other pathways.  Most of the cancer risk from these pathways  (i.e.
ingestion and inhalation) in all of the exposure areas may be
attributable to arsenic.  Similarly, for noncancer risks, dermal contact
of cadmium was a significant contributor to the total HI.


G.  Uncertainties Associated with Human Health Risk Calculations

Within the Superfund process,  baseline quantitative risk assessments are
performed in order to provide risk managers with a numerical
representation of the severity of contamination present at a site, as
well as to provide an indication of the potential' for adverse public
health effects.  There are many inherent and imposed uncertainties in
the risk assessment methodologies.   The HHRA is subject to uncertainty
from a variety of sources including the following:

   *        Sampling, analysis and data validation
   4        Fate and transport estimation
   *        Exposure estimation
   *        Toxicological data.
   *        Blood-lead model

While not all encompassing, the following identifies a number of site-
specific factors that may lead to an over- or underestimation of risks
for OU No..5:

*  Analyses  for the metals were not species specific, and,  therefore,
   metals were assumed to be completely boiavailable, which may
   overestimate risks.

*  Contaminant concentrations in soil,  sediment, and surface water were
   assumed to remain constant, which may result an over- or
   underestimation of future risks.


H.  Ecological Risks

An ecological risk assessment  (ERA) was also conducted  for OU No.  5 to
quantitatively determine  the  actual or potential effects to plants and
animals on-site.  The ERA was conducted as a part of  the RI in  order  to
evaluate if the COPCs from  the  former battery wrecking  facility pose  a
risk to the environment  in  the  absence of  remedial  action.  A summary is
provided in the following paragraphs.

OU No. 5 includes both  terrestrial  and aquatic  habitat  areas.   The
presence of the former  battery  wrecking  facility precludes  the  usability

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of certain OU No.  5 areas by ecological organisms.  The terrestrial
habitats are disturbed in may areas by historical and/or ongoing human
activity.  There are fields of opportunistic weed species and stands of
shrubs and trees.   The aquatic areas are intermittent and are dry
several months of  every year.  The drainages in the south may be fed by
stormwater runoff  from surrounding facilities.

An investigation was first conducted to determine the occurring
ecological receptor populations.  The predominant populations were
comprised of opportunistic mammals (rats and house mice) and aquatic
species  (fathead minnows, gambusio affinis and crayfish).  A
quantitative assessment was conducted for the assessment of exposure and
risk to these on-site resident organisms.  This approach entailed the
evaluation of site exposure conditions by comparison of exposure point
concentrations to  literature-derived toxicity values (for the
terrestrial assessment) or ambient water quality criteria and sediment
toxicity benchmarks (for the aquatic assessment).  This is a
conservative screening approach which serves to identify the predominant
COPCs contributing to site ecological risk.

Inorganic COPCs were selected by comparison to regional background data
for soils and sediment.  There were no appropriate background
concentrations for surface water.  All detected organic COPCs (in all
media) were retained for analysis within the ERA.

A reasonable maximum exposure (RME) point concentration was derived from
the results of the abiotic media analysis.  Due to the limited data
available, the observed maximum concentration of COPCs within surface
water and sediment were chosen to represent the RME concentration.  The
95C upper confidence limit (95* UCL)  was used as the exposure point
concentration for  surface soil exppsure point concentrations.

An evaluation of surface water and sediment exposure and risk to aquatic
life was conducted.  For determination of aquatic risk, the surface
water and sediment RME was compared directly to ambient water quality
criteria and sediment toxicity benchmark values.

An evaluation of surface water and surface soil exposure and risk to
terrestrial life was conducted by developing screening level wildlife
criteria for water  (based upon receptor ingestion rates) and by
calculating exposure dose for ingested soil and contaminated food
sources that have  accumulated COPCs through soil.  An assessment for
small mammals and  birds was conducted.  Observed surface water COPC
concentrations were compared to  the derived criteria for risk
estimation.  The calculated soil and contaminated food dose was compared
to literature-derived  no-observed- adverse-effect-levels  (NOAELs) and
lowest-adverse-effect-levels  (LOAELs) to determine risk.

The quantitative evaluation of risk was conducted by a hazard quotient
method.   If the resulting quotient was greater  than one  (1), the
Analyte was considered to contribute to ecological risk.   The
predominant ecological risk attributable  to OU  No. 5 is  due  to the
presence of inorganic  COPCs within the soil.   In particular,  the
presence of copper  and lead are  of concern.  The COPCs  present within
the surface water  and  sediment are likely  to be  less of  a  concern  since
the drainages are  intermittent.

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I.  Risk Assessment Conclusions

Actual or threatened releases of hazardous substances from this site,  if
not addressed by implementing the response action selected in this ROD,
may present an imminent and substantial endangerment to public health,
welfare, or the environment.
VII. REMEDIAL ACTION GOALS

The results of the field investigation and engineering analyses have
identified the following contaminant source areas on, OU No.  5 of the RSR
site and the associated affected media:
   Area of Concern                          Media

  Former Surface Impoundment                Soil
  Former Landfill                           Soil
  Buildings and Structures                  Soil and dust
  Other Soils/Slag Burial Area              Soil
  Sediment and Surface water Runoff         Sediment and water
Principal threat wastes are those source materials considered to be
highly toxic or highly mobile that generally cannot be reliably
controlled and that present a significant risk to human health or the
environment should exposure occur.  There are no principal threats at OU
No. 5 of the RSR site.

Low level threats are those source materials that generally can be
reliably managed with little likelihood of migration and present a low
risk in the event of exposure.  The low level threats at the site are
the contaminated material in the former surface impoundment, former
landfill,and the other soils/slag burial area.  The arsenic, cadmium and
lead contamination present in these areas are less mobile and have a
reduced migration potential due to the chemical and physical properties
of the soil cover.  Other low level threat areas include the'dust
associated with the buildings.  Although the concentrations of arsenic
and lead are elevated within the buildings, exposure of the contaminated
dust may be limited by controlling access to the area.

As discussed in the Section VI. SUMMARY OF SITE RISKS, the arsenic
contributed most significantly to the carcinogenic and non-carcinogenic
risk at the site and antimony contributed greatly to the noncarcinogenic
risk.  Furthermore, lead concentrations are present above calculated
acceptable levels based on the lead exposure evaluation done in the risk
assessment.

The remedial action objectives for OU No.  5 of the RSR site 'are to
minimize exposure to  the lead, arsenic, 'and antimony present in the
former surface impoundment, former landfill, buildings and  structures,
and other soils/slag  burial area  by direct contact,  inhalation and
ingestion, and to reduce the potential  for migration  of these
contaminants.  In order to meet  these remedial ob]ectives,  remedial
action goals for  lead, arsenic,  antimony  have  been established.   For  the

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purposes of this document,  the remedial action goals are the same as
action levels.  These action levels are used as a "trigger" to initiate
an action.   The remedial action goals are outlined below and again as
cleanup goals in the Selected Remedy Section of this document.


Remedial Action Goals or Cleanup levels:

   Former Surface Impoundment

   Eliminate  the potential  for incidental ingestion,  and/or dermal
   contact  with contaminated surface soils in the former surface
   impoundment with  arsenic in excess  of 32.7 ppm,  and/or  lead  in
   excess of  2,000 ppm by on-site  and off-site receptors.
   Former  Landfill

   Eliminate  the potential  for incidental  ingestion,  and/or  dermal
   contact with contaminated  surface  soil  in  the  former  landfill  with
   arsenic in excess of  32.7  ppm ,  and/or  lead  in excess  of  2,000 ppm
   and/or  antimony in excess  of 818 ppm by on-site and off-site
   receptors.

   Buildings  and Structures

   Eliminate  the potential  for incidental  ingestion,  and/or  dermal
   contact with contaminated  material in the  buildings and  structures
   with arsenic in excess  of 32.7  ppm ,  and/or lead  in  excess of 2,000
   ppm by  on-site and off-site receptors.

   Slag Burial Area/Other  Soils

   Eliminate  the potential  for incidental  ingestion,  and/or  dermal
   contact with contaminated  soil in  the slag burial  area/other  soils
   with arsenic in excess  of  32.7 ppm and/or  lead in  excess  of 2,000 ppm
   by on-site and off-site  receptors.

   Stormwater Runoff and Sediments

   Manage  and control off-site migration of contaminated  Stormwater
   runoff  through federal  Stormwater  requirements and meet  federal  and
   State RCRA closure and  disposal  requirements for sediments.


The 32.7 ppm action  level  for arsenic is based  on the 1X10-5 risk,   since
the 1X10-6 level  corresponds to  a  level lower than background.   The  813
ppm action level  for antimony is based on reducing the risk to 1X10-6.
The 2,000 ppm action level for  lead  is based on  input of site specific
data into the Adult  Lead Exposure  Model (See Appendix B), which  is  the
latest available  model  for estimating non-residential lead exposure.
The Adult Lead  Exposure Model uses site specific  exposure parameters
consistent with  t'r.e  risk assessment.

3y addressing the contamination  associated with  the  buildings,
                                    23

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structures, equipment and soils, the associated OU No. 5 site specific
risks described in Section VI. will be reduced or eliminated.

As stated previously with regard to the ground water, regardless of any
site-related contamination,  the shallow ground water in the vicinity of
OU Nos. 4 and 5 is not considered as a potential water supply due to its
overall low yield and slightly saline quality and the availability of
the City of Dallas water supply, as well as potable supply permitting
requirements.  The expected migration pathway of the shallow ground
water is the Trinity River or its tributaries and neither are used as a
drinking water supply within 3 miles.  It is on this basis that the
shallow ground water beneath OU Nos. 4 and 5 are not considered to be a
potential drinking water supply (i.e. a Class III aquifer).  Therefore,
no action is recommended for the shallow ground water beneath OU Nos. 4
and 5 .
VIII.  DESCRIPTION OF ALTERNATIVES

A Feasibility Study was conducted to develop and evaluate remedial
alternatives for OU No. 5 of the RSR site.  This report is included in
the Administrative Record for OU No. 5.  Remedial alternatives were
assembled from applicable technologies/process options and were
evaluated for effectiveness, implementability, and cost based on best
professional judgement.  The'alternatives selected for detailed analysis
were compared to the nine criteria required by the NCP.  As required by
the NCP, the no action alternative was also evaluated to serve as a
point of comparison for the other alternatives.

OU No. 4 Waste Disposal - The alternatives developed as part of the OU-
No. 5 FS and presented in the Proposed Plan contained the potential for
the disposal of nonhazardous debris from the remedial activities on OU
No. 4 and the proposed building demolition on OU No. 5 in the former
landfill.  The Record of Decision for OU No. 4 included an Alternate
Component, which called for the disposal of nonhazardous building
debris/soil in the former landfill located on OU No. 5, subject to
public comment in the OU No. 5 Proposed Plan.  Based on public comments
received on the disposal of OU Nos. 4 and 5 nonhazardous debris in the
former landfill, the remedial alternatives presented below do not
include the disposal of nonhazardous debris in the former landfill.
Public comments and EPA responses to comments are included in Appendix
A. Responsiveness Summary.

The remedial action goals or cleanup levels set  forth above in Section
VII., are the concentration levels below which contaminated media can be
left on-site and managed for a future  industrial land use.  The remedial
alternatives described herein address  the contamination associated with
the former surface impoundment, the former landfill, the buildings and
structures, and other  soils/slag burial area.

As stated in Section VII. Remedial Action Goals, the shallow  ground
water in  the vicinity  of OU Nos. 4 and  5  is not  considered as a
potential water supply due  to its overall low  yield and  slightly  saline
quality and the availability of the City  of Dallas  water  supply,  as  well
as potable supply permitting requirements.  The  expected  migration
pathway of the  shallow ground water is  the Trinity  River  or  its

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tributaries and neither are used as a drinking water supply within 3
miles.  It is on this basis that the shallow ground water beneath OU
Nos.  4 and 5 are not considered to be a potential drinking water supply
(i.e. a Class III aquifer).  Therefore, the shallow ground water beneath
OU Nos. 4 and 5 is not considered in any of the alternatives described
below, and no action is recommended for the shallow ground water.


   1.  Remedial Action Alternatives

The remedial action alternatives for OU No. 5 of RSR site are presented
below followed by a description of the common elements of each
alternative.
   Alternative la:

   Alternative Ib:

   Alternative 2:
   Alternative 3:
   Alternative 4:
No Action

Institutional Controls

In-place decontamination of
Buildings/Structures; Containment of the
Former Surface Impoundment, the Former
Landfill and the Slag Burial Area/Other
Soils

Decontaminate Buildings: Demolish the
Former Battery Wrecking Building;
Containment of the Former Surface
Impoundment, the Former Landfill and the
Slag Burial Area/Other Soils

Decontaminate Buildings: Demolish the
Former Battery Wrecking Building;
Containment of the Former Surface
Impoundment, the Former Landfill and the
Slag Burial Area/Other Soils; Excavate
other soils  (up to 2 feet bgs) exceeding
Remedial Action Goals and Place in Former
Landfill
   2.   Common Elements

All of the alternatives with the exception of Alternative la have the
following common elements:  (1)  all general requirements associated with
contractor mobilization and demobilization, bonds and  insurance,
decontamination facilities, a health and safety program, and a community
relations program;  (2) all general site work such as repair of existing
perimeter fence and sampling of surface water;  (3)  short-term ground
water and surface water monitoring;  (4) Alternatives 2, 3, and 4 also
include a provision for air monitoring during remediation and long-term
ground water monitoring of the former  landfill;  (5) all of the
alternatives with the exception of Alternatives  la  and l.b involve
decontamination of  the buildings, structures using  standard cleaning
methods, such as steam cleaning or vacuum  dusting;  and (6) all of the
alternatives do not contain a component for on-site disposal of
                                    30

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nor.hazardous debris generated from OU No. 4 and 5 remedial activities in
the former landfill located on OU No. 5(see OU No. 4 Waste Disposal).

All costs and implementation times are estimates.  The costs have a
degree of accuracy of +50- to -30- pursuant to the Guidance for
Conducting Remedial Investigations and Feasibility Studies Under CERCLA
- Interim Final, OSWER Directive 9955.3-01, October 1988.

A brief description of the alternatives evaluated to address the
contaminated media on OU No. 5 of the RSR site follows.
   Alternative la - No Action

   Major Components of Alternative- la:
Evaluation of the No Action alternative is required by the NCP,'40
C.F.R.   § 300.430 (e) (3) (ii) (6),  and is used as a baseline against which
other alternatives are evaluated.  Under this alternative, no remedial
action would be undertaken to treat, contain, or remove contaminated
media at OU No. 5.  No institutional or operational controls would be
implemented to restrict access to OU No. 5 or to restrict exposure to
contaminants.  Monitoring would not be a component of this alternative.
Under 'the No Action alternative contaminated material would be left in
place in an uncontrolled state and potentially endanger human health and
the environment.

   Treatment Components:
There are no treatment components under Alternative la.

   Containment Components:
There are no containment components under Alternative la.

   General Components:
There is no time needed to implement Alternative la, since no remedial
action is undertaken.  And the costs are provided below:


   Capital Costs:            $0
   Annual Operation &
   Maintenance:              $0
   Present Worth:            $0
   Alternative Ib - Institutional Controls

   Major Components of Alternative Ib:
This alternative  includes taking  steps to have deed notices or a land
use restriction placed in the deed records of the OU No. 5 properties to
warn potential buyers and lenders of  the presence of contamination.
Such deed notices and land  use  restrictions may  be difficult  to obtain
and enforce and may meet with substantial opposition from many different
sources.  In  addition, this  alternative  includes the repair of ,
approximately 9,100 linear  feet of fencing, posting warning signs,  and
providing 24-hour-a-day guard services.  Short-term ground water
monitoring well and surface, water samples would  also be  collected  and
analyzed three times annually at  three ground water locations and  to
                                    31

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surface water  locations under this alternative.

   Treatment Components:
There are no treatment components for the contaminated media under this
Alternative Ib.

   Containment  Components:
There are also no containment components under Alternative Ib.

   General Components:
The estimated time needed to implement Alternative Ib, is less  than 1
year.  The estimated costs for implementation of this alternative are
provided below:

   Capital Costs:             $  227,000
   Annual Operation &
   Maintenance(0-5 years):    $  162,700
   Annual Operation &
   Maintenance(6-30 years):   $  155,500
   Present Worth:             $  2,649,000
   Alternative 2 - In Place treatment of Buildings/Structures;
Containment of the Former Surface Impoundment, Former Landfill,  Slag
Burial Area/Other Soils

   Major Components of Alternative 2:
This alternative includes in-situ (in place) decontamination of  the
contaminated buildings and structures; containment of the former surface
impoundment and the other soils/slag burial area; containment of the
former landfill, including a cap design plan;  monitoring of ground
water and stormwater.  This alternative leaves the buildings and
structures in place following decontamination.

Prior to performing any work, a structural investigation would be
necessary to assess the stability and safety of the buildings and
structures in order to withstand the in place decontamination process.
For the purpose, of estimating costs, it was assumed that shoring and
bracing would be necessary prior to decontamination, due to the  poor
condition of the buildings and structures.   Without maintenance and
rehabilitation, it is considered that these buildings would be a safety
hazard during remediation activities.

The short-term monitoring  (first five years) required under this
Alternative assumed that two  (2) new ground water monitoring wells would
be  installed and monitored annually  and  that a third existing well would
also be monitored  annually.   In addition,  two  (2) surface water
locations would also  be sampled annually.   The long-term component of
this alternative  (years 6  through 30) assumes  that  two  (2)  existing
wells would be  used  for ground water  sampling.   The  former  landfill  and
surface impoundment would  be  inspected  quarterly  and the monitoring
wells would be  sampled annually to  meet  landfill  closure requirements.

   Treatment Components:
The water generated  as a  result of  building and  structure
                                    32

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decontamination activities (such as steam cleaning)  or other dust
suppression activities would be collected,  sampled and pretreated,  if
necessary,  prior to discharge to the City of Dallas'  .Publicly Owned
Treatment Works (POTW).   In addition,  any dust collected as part of
decontamination activities must be sampled prior to disposal to
determine if hazardous.   Collected dust that does not pass TCLP
requirements must be treated accordingly (i.e.
stabilization/solidification) prior to disposal.

   Containment  Components:
Under Alternative 2 the contaminated soils in the'area of the former
surface impoundment, the former landfill, and the slag burial area/other
soils would be  capped.  A description of the capping methods, materials,
and procedures.are discussed below for each of the areas.

   Former Surface Impoundment - The estimated areal  extent of the former
   surface  impoundment is  45,000 square feet.   In 1989 the former
   surface  impoundment was  capped with approximately  two (2)  feet of
   clay soil.   This cap  was placed at  a slope of 3:1  and based on visual
   inspection is  currently  experiencing some erosion  and minor
   sloughing.   This alternative included an engineering evaluation  of
   the existing cap and  a  determination of  compliance with RCRA closure
   standards.   For cost  estimating purposes under this alternative  it
   was assumed  that the  cap on the former surface impoundment would
   require  replacement.   Under this assumption the existing cap would be
   stripped of  vegetation  and reworked and  recompacted,  followed by the .
   two (2)  feet of clay  soil  over the  entire area and then two (2)  feet
   of topsoil and vegetation.  The former surface impoundment must  be
   closed in compliance  with  RCRA closure requirements.

   Former Landfill - The estimated areal extent of the former landfill
   is approximately 503,000 square feet.  Currently the landfill area is
   covered  with vegetation  and consists of  irregular  topography.  This
   alternative  assumes a complete landfill  capping design plan that
   would address  surface preparation prior  to the installation of the
   cap.  The former landfill  area would be  closed in  accordance the
   State of Texas closure  and remediation requirements,  including but
   not limited  to 30 TAC Section 335.   The  cover system in a
   nonhazardous waste landfill is a function of the bottom liner system
   and the  liquid management  strategy for the site.   Depending on site-
   specific considerations, designs based on natural  soils as well as
   designs  that resemble a multilayer cover may be required.  For
   purposes of  estimating costs,  this alternative assumed that a
   multilayer cover would be required. .It was also assumed that
   quarterly inspections of the cover would be required.

   Slag Burial  Area/Other Soils - The estimated areal extent of the
   contaminated soil outside of the former surface impoundment and the
   former landfill areas on OU No. 5 is approximately 1,480,000 square
   feet.  This  alternative includes covering the contaminated soils  area
   with two (2) feet of clean backfill and revegetating with native
   grasses.


   General Components:
The  estimated  time  needed  to implement  Alternative 2,  is  less  than 1
                                    33

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year.  The estimated costs for implementation of this alternative are
provided below:

   Capital Costs:             $  6,995,000
   Annual Operation &
   Maintenance(0-5 years):    $  8,609
   Annual Operation &
   Maintenance (6-30 years):   $  5,300
   Present Worth:             $  7,091,000


   Alternative 3 - Decontaminate Buildings/Structures,  Demolish Former
Battery Wrecking Facility and Dispose Off-site; Containment of Former
Surface Impoundment, Former Landfill, Slag Burial Area/Other Soils.

   Major Components of Alternative  3
This alternative includes decontamination of the contaminated buildings
and structures, in addition to the  demolition and disposal of the Former
Battery Wrecking Facility; containment of the former surface impoundment
and the other soils/slag burial area; containment of the former
landfill, including a cap design plan;  monitoring of ground water and
stormwater.

The Former Battery Wrecking Facility Building would be sampled to
classify waste type for disposal, including TCLP.  Controlled
dismantling and demolition activities would be conducted using standard
dust suppression methods and performed using wrecking balls, bulldozers,
and similar means.  For cost estimating purposes, it was assumed that 20
TCLP samples would be collected and analyzed and that all of the
building debris could be disposed in a non-hazardous landfill.

The short and long-term monitoring  requirements for Alternative 3 are
similar to Alternative 2, with the  addition of the annual inspection and
repair of the pavement areas  (former battery wrecking facility area).

   Treatment Components:
The treatment components of this Alternative are identical to those in
Alternative 2.

   Containment Components:
The containment components of Alternative 3 are also identical to  those
described for Alternative 2.

   General Components:
The estimated  time  needed to  implement Alternative 3,  is  less  than  1
year.  The estimated  costs  for  implementation  of this  alternative  are
provided  below:

   Capital Costs:            $ 9,237,015
   Annual Operation &
   Maintenance (0-5  years):   $ 9,400
   Annual Operation &
   Maintenance(6-30 years):  $ 6,000
   Present Worth:            $ 9,343,800

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   Alternate component:

Written comments submitted on the OU No. 5 Proposed Plan requested
flexibility in the former landfill cap, in order to allow for
redevelopment options  in this portion of OU No. 5.  In response to these
comments an alternate component for Alterative 3 was developed to allow
for the potential redevelopment of the former landfill area on OU No. 5.
Since the objective of the cap described for the former landfill is to
prevent direct contact or migration of the contaminated material within
the former landfill, an alternative barrier or cap- form would be
acceptable.  Under this alternate component, the following activity
related to the former  landfill is permitted:

   *        Regrade the former landfill area in order to support an
            asphalt or concrete surface cover to allow for
            Commercial/Industrial redevelopment;

   4        Comply with all ARARs, such as federal and State closure and
            remediation requirements,  including but not limited to those
            in the Texas Administrative Code (T.A.C.), 30 T.A.C. 335,
            Subchapters A.,  F. and S.

Included in Appendix C is a Technical  Memorandum that outlines the
asphalt or concrete surface covers that may be utilized and the
associated range of cost estimates.  Either of these covers would
achieve the remedial action objectives, but must be constructed in
accordance with all ARARs, including,  but not limited to, State closure
and remediation requirements found in 30 T.A.C. 335, Subchapters A., F.
and S.


   Alternative 4 - Decontaminate Buildings/Structures, Demolish Former
Battery Wrecking Facility and Dispose Off-site; Containment of Former
Surface Impoundment, Former Landfill;  Excavate and Dispose Slag Burial
Area/Other Soils  (up to 2 feet)

   Major Components of Alternative 4
This alternative includes decontamination of the contaminated buildings
and structures, in addition to the demolition and disposal of the Former
Battery Wrecking Facility; containment of the former surface
impoundment; containment of the former landfill, including a cap design
plan; excavation of slag burial area/other soils  (up to 2 feet)
exceeding remedial action goals and disposal in the former landfill;
monitoring of ground water and stormwater.

The Former Battery Wrecking Facility Building would be sampled to
classify waste type for disposal, including TCLP.  Controlled
dismantling and demolition activities would be conducted using standard
dust suppression methods and performed using wrecking balls, bulldozers,
and similar means.  For cost estimating purposes, it  was assumed that  20
TCLP samples would be  collected and analyzed and  that all of the
building debris could  be disposed in a non-hazardous  landfill.

Under this alternative, soils  located  in the slag burial area/other
soils area that exceed Remedial Action Goals would  be excavated  up  to  a
maximum depth of  two  (2)  feet.  The excavated material would be  sampled
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to classify for waste disposal.  Soils that exceeded TCLP requirements
would be treated and disposed of off-site, soils that were classified as
non-hazardous would be disposed of in the former landfill.  The
excavated area would be backfilled and graded.

The short and long-term monitoring requirements for Alternative 4 are
identical to those described for Alternative 3.

   Treatment Components:
The treatment components of this Alternative are identical to those in
Alternative 2.

   Containment Components:
Under Alternative 4 the containment components would be the same as
Alternative 2.

   General  Components:
The estimated time needed to implement Alternative 4, is less than 1
year.  The estimated costs for implementation of this alternative are
provided below:

   Capital  Costs:             $ 22,489,192
   Annual Operation &
   Maintenance(0-5 years):    $ 8,600
   Annual Operation &
   Maintenance(6-30 years):   $ 5,300
   Present Worth:             $ 22,564,906
IX.         SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

The EPA uses nine criteria to evaluate alternatives for addressing a
Superfund site.  These nine criteria are specified in the NCP, 40 C.F.R.
§ 300.430(e)(9) and (f)(l). The criteria are categorized into three
groups: threshold, primary balancing, and modifying.  The threshold
criteria must be met in order for an alternative to be eligible for
selection.  The primary balancing criteria are used to weigh major
tradeoffs among alternatives.  The modifying criteria are taken into
account after state and public comments are received on a Proposed Plan.


Nine Criteria
The nine criteria that EPA uses in evaluating the  remedial alternatives
are as follows:

   Threshold Criteria

Overall Protection  of Human  Health and  the Environment addresses  the  way
in which  an alternative would  reduce, eliminate, or control  the risks
posed  by  the site to human health and the environment.  The  methods  used
to achieve  an  adequate level of protection vary  but may include
treatment and  engineering  controls.  Total elimination of  risk  is often
impossible  to  achieve.  However, a remedy must minimize risks  to  assure
that human  health and the  environment are orotec'ed.
                                    36

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Compliance with  "applicable or relevant and appropriate requirements
(ARARs)" assures that an alternative will meet all related Federal,'
State,  and local requirements.

   Balancing Criteria

Long-term Effectiveness and Permanence addresses the ability of an
alternative to reliably provide long-term protection for human health
and the environment after the remediation goals have been accomplished.

Reduction of Toxicity, Mobility, or Volume of Contaminants through
Treatment assesses how effectively an alternative will address the
contamination at a site.  Factors considered include the nature of the
treatment process; the amount of hazardous materials that will be
destroyed by the treatment process; how effectively the process,reduces
the toxicity,  mobility, or volume of waste; and the type and quantity of
contamination that will remain after treatment.

Short-term Effectiveness addresses the time it takes for remedy
implementation.  Remedies often require several years for
implementation.  A potential remedy is evaluated for the length, of time
required for implementation and the potential impact on human health and
the environment during implementation.

Imp 1ementab!lity addresses the ease with which an alternative can be
accomplished.   Factors such as availability of materials and services
are considered.

Cost  (including capital costs and projected long-term operation and
maintenance costs) is considered and compared to the benefit that will
result  from implementing the alternative.

   Modifying Criteria

State Acceptance allows the state where the site is located to review
the proposed plan and offer comments to the EPA.  A state may agree
with,  oppose,  or have no comment on the proposed remedy.

Community Acceptance allows for a public comment period for interested
persons or organizations to comment on the proposed remedy.  EPA
considers these comments in making its final remedy selection.  EPA
addresses the public comments in a  Responsiveness Summary, which is
included as part of the ROD.


   Comparative Analysis

The following discussion provides the comparative analysis for each
remedial alternative for OU No. 5 against the nine criteria:


1.          Overall Protection of Human Health and the Environment

Alternatives la  and  Ib do not protect human health and  the environment
and do  not achieve the Remedial Action Goals defined  for CU No.  5.
                                    37

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Alternative Ib is only marginally more protective than la because it
potentially reduces access to contamination,  but likewise does nothing
to reduce the presence of the contamination.   These alternatives do not
reduce exposure of the public and environment to the contaminated
materials at OU No. 5.

Alternative 2 does provide a level of protection of human health and the
environment.   Some of the Remedial Action Goals are achieved by
reducing the exposure to contamination associated with the buildings and
structures.   However, residual contamination is likely to remain in
inaccessible areas in the former battery wrecking building,  due to the
poor condition of this building.  This may result in releases of
contamination through stormwater runoff as it further deteriorates
and/or collapses.  The Remedial Action Goals  for the former  surface
impoundment, the former landfill and the slag burial area/other soils
area would also be met under this alternative.   Only the Remedial Action
Goal for the stormwater runoff may not be met.

Alternative 3 also provides protection, but offers a slightly greater
degree of protectiveness than Alternative 2,  since contamination in and
on the former battery wrecking building are eliminated by demolition,
decontamination and off-site disposal of the  debris.  As an  added
benefit, physical and safety hazards associated with the building are
also eliminated.  Remedial Action Goals for the former surface
impoundment, the former landfill and the slag burial area/other soils
area would also be met under this alternative.   The alternate component
described for Alternative 3, which allows for a different cap on the
former landfill (i.e. concrete or asphalt) would achieve the Remedial
Action Goals for the former landfill area and also allow for future
commercial/industrial development.

Alternative 4 provides essentially the same degree of protectiveness as
Alternative 3.  However, under Alternative 4, the surface soils (0-2
feet) that exceed the Remedial Action goals would be excavated and
placed in the former landfill providing a more stringent cap than the
soil cover described for these areas.  Remedial Action Goals for the
buildings and structures, the former surface  impoundment, and the former
landfill would also be achieved.
2.          Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)

Alternatives la and Ib do not meet any of the ARARs that have been
identified for OU No. 5, such as: federal and State RCRA closure
requirements, specifically, 40 C.F.R. Part 264, Subparts B, C and D,
which establish minimum standards defining acceptable management of
hazardous wastes, 40 C.F.R. Part 264, Subparts I, J, L and N, which set
operating and design and storage, as well as landfill design
requirements for hazardous wastes; relevant portions of the State of
Texas Industrial Solid Waste and Municipal Hazardous Waste requirements
(30 T.A.C. § 335),  such as  Subchapters A., P. and S., and Risk
Reduction Standard  No. 3  (30 T.A.C. § 335.562); and 40 C.F.R. Parts 122
and 125, which describe management practices of stormwater runoff
requirements and State risk reduction rules.

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For Alternative 2,  even though some residual contamination in the former
battery wrecking building may be left in place in an uncontrolled state
in inaccessible areas the following ARARs would generally be achieved:
federal and State RCRA closure requirements, specifically, 40 C.F.R.
Part 264,  Subparts B, C and D, which establish minimum standards
defining acceptable management of hazardous wastes, 40 C.F.R. Part 264,
Subparts I, J, L and N, which set operating and design and storage,  as
well as landfill design requirements for hazardous wastes; relevant
portions of the State of Texas Industrial Solid Waste and Municipal
Hazardous Waste requirements in the Texas Administrative Code (T.A.C.)
(30 T.A.C. § 335),  such as  Subchapters A., F. and S., and Risk
Reduction Standard No. 3 (30 T.A.C. § 335.562); and 40 C.F.R. Parts 122
and 125, whi'ch describe management practices of stormwater runoff
requirements.  However, potential releases from residual contamination
from the former battery wrecking building may prevent compliance with
certain ARARs like federal stormwater management requirements. .This
alternative would also comply with RCRA handling, transportation,
treatment and disposal requirements (30 T.A.C. § 335.11, § 335.91, §
335.508).   State and federal chemical-specific ARARs for air quality  (30
T.A.C. § 118.1, 30 T.A.C. § 111.115, 40 C.F.R., § 50.3 and 51.160)
during remedial action would also be met.  Furthermore,  all off-site
disposal would be at facilities in compliance with EPA's Off-site
Policy, specifically  all hazardous substances, pollutants or
contaminants removed off-site pursuant to this action for treatment,
storage, or disposal shall be treated,  stored, or disposed of at a
facility in compliance with RCRA, as determined by EPA,  pursuant to
CERCLA Section 121(d){3), 42 U.S.C. § 9621  (d)(3), and the following
rule:  "Amendment to the National Oil and Hazardous Substances Pollution
Contingency Plan;  Procedures for Planning and Implementing Off-Site
Response Action:  Final Rule."  58 Fed. Reg. 49200 (September 22, 1993),
and codified at.40 C.F.R. § 300.440.

All of the components of Alternatives 3 and 4 will meet all of the ARARs
identified for OU No. 5, including: federal and State RCRA closure
requirements, specifically,  40 C.F.R.  Part 264, Subparts B, C and D,
which establish minimum standards defining acceptable management of
hazardous wastes, 40 C.F.R. Part 264, Subparts I, J, L and N, which set
operating and design and storage, as well as landfill design
requirements for hazardous wastes; relevant portions of the State of
Texas Industrial Solid Waste and Municipal Hazardous Waste requirements
in the Texas Administrative Code  (T.A.C.)  (30 T.A.C. §  335), such as
Subchapters A., F. and S., and Risk Reduction Standard  No. 3  (30 T.A.C.
§ 335.562); and 40 C.F.R. Parts  122 and  125, which describe management  .
practices for stormwater runoff; RCRA handling,  transportation,
treatment and disposal requirements  (30  T.A.C. §  335.11,  § 335.91,  §
335.508);  State and  federal chemical-specific ARARs  for  air quality  (30
T.A.C. §  118.1,  30 T.A.C. § 111.115, 40~C.F.R.,  §  50.3  and 51.160).
Furthermore, all disposal off-site would be at  facilities  in compliance
with  EPA's Off-site  Policy.


3.           Long-term Effectiveness and Permanence

Since  none of  the contamination  (which  remained  after the non-time
critical  removal action)  at OU  Mo.  5 will  be  treated  or removed,  long-
term  effectiveness and oermaner.ce  will  not  be  achieved  under

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Alternatives la and Ib.

Alternative 2 does not completely achieve long-term effectiveness and
permanence.  Residual amounts of contamination associated with
inaccessible areas of the former battery wrecking building may remain.
Moderate long-term effectiveness and permanence is achieved for the
former surface impoundment,  the former landfill,  and the slag burial
area/other soils,  since residual risk is low.  The cap will require
long-term monitoring and maintenance to be effective.

Alternative 3 has  a higher degree of long-term effectiveness and
permanence than Alternative 2,  since contamination associated with the
buildings, structures, and equipment is removed,  decontaminated as
appropriate, and disposed of off-site.  Moderate long-term effectiveness
and permanence is  achieved for  the contaminated soils,  since residual
risk is low.  The  cap on the former surface impoundment, former landfill
and the slag burial area/other  soils would require long-term monitoring
and maintenance to be effective.  The cover outlined under the Alternate
Component of Alternative 3 would also have a moderate level of long-term
effectiveness and  permanence.
                                                             /
Alternative 4 provides a similar degree of long-term effectiveness and
permanence as Alternative 3, since the remedial activities would result
in the containment of the sources of contamination at OU No. 5.
4.          Reduction of Toxicity, Mobility or Volume Through Treatment

Alternatives la and Ib provide no reduction in toxicity, mobility or
volume of contaminants through treatment.

Alternative 2 provides a reduction in the toxicity, mobility, and volume
of some of the contamination associated with the buildings and,
structures and equipment through the cleaning and decontamination
process.  This reduction will be achieved through the collection of the
decontamination process water or vacuum dust and subsequent treatment,
discharge or disposal.   However,  some residual contamination may
remain in the buildings and structures.   The mobility of contaminants
in the former surface impoundment, the former landfill, and the slag
burial area/other soils is reduced by the cap, but the containment
action will not reduce the toxicity or volume.

Alternative 3 provides a slightly greater reduction of toxicity,
mobility, and volume than Alternative 2 through the decontamination and
subsequent treatment process  (of decontamination rinsate) and the
demolition process. All of the contamination associated with the former
battery wrecking building would be removed once the building is
demolished.

Alternative 4 orovides a similar  level of reduction as Alternative  3.
5.          Short-Term Effectiveness

Alternatives  la and  Ib have minimal short  term  effectiveness  for  the
community,  since r.o  removal of ar.y contaminated media  occurs  under  this

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alternative.  Short-term effectiveness is not achieved for trespassers.

Under Alternative 2 short-term risk to the community may increase during
implementation.-  There is also a potential for exposures to workers
during the remedial action.  Heavy vehicular traffic may cause some
nuisance to the community.  However, all appropriate regulations and
safety measures will be  instituted and strictly followed.

Alternatives 3 and 4 also involve an increase of short'-term risk to the
community during implementation as well-as risk to remedial action
workers during demolition activities. Heavy vehicular traffic may cause
some nuisance to the community.  However, dust control and other safety
measures will be implemented to protect the community and the workers.


6.          Tmplementability

There is no action to implement under Alternatives la.  Implementation
of some aspects of Alternative Ib, such as posting warning signs and
fencing are readily implementable.  However,  land use and deed
notification or restrictions may be difficult or impossible to obtain
and enforce.

Alternative 2 is implementable.  The technical feasibility of cleaning
methods such as, steam cleaning or vacuum dusting, landfilling,  and soil
containment is proven, and equipment, personnel and resources generally
are available.  The condition of former battery wrecking building may
ultimately prevent the removal of contaminants to safe levels.

Alternative 3 is also readily implementable.   The technical feasibility
of demolition of the former battery wrecking facility is proven  and
equipment, personnel and other resources generally are available.  The
physical conditions of the buildings and structures would require the
implementation of certain safety measures during demolition.  Personnel,
equipment and facilities needed for the capping and containment
components this alternative (including the Alternate Component)  are
readily available.

The implementability of Alternative 4 is nearly identical to that of
Alternative 3.  The technical feasibility of conducting the excavation
and placement of the soils into the former landfill is also well
understood and readily available.
7.          Cost

Alternative la is the least expensive of all the alternatives evaluated,
but does not meet any of the other evaluation criteria.  Alternative  Ib
has a relative low cost, but like Alternative Ib, does not meet any of
the other evaluation criteria. Alternative 2 is  in  the mid range
compared to the other alternatives and meets some of  the other criteria.
The cost of Alternative 3 is high, relative to Alternatives  la, Ib and
2, but meets most of the other evaluation criteria.   Alternative  4 is
the most expensive, but meets all of the other criteria.

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8.          State Acceptance

The TNRCC has reviewed copies of the RI, Risk Assessment,  FS and this
Record of Decision and has provided technical support on all EPA efforts
at OU No. 5.  The TNRCC on behalf of the State of Texas concurs with
EPA's selected remedial action for the Former Battery Wrecking Facility,
OU No. 5, of the RSR site (See Appendix D).
9.          Community Acceptance

Comments were received from the community during the public comment
period which opened June 18, 1996, and closed August 17,  1996.   A
public meeting-was held on July 9, 1996 to receive verbal comments.  All
comments received have been addressed, and responses are  included in the
Responsiveness Summary (Appendix A)  to this ROD.  EPA carefully
considered all comments in making the final decision on the selected
remedial action for OU No. 5.   Based on comments received a modification
to the alternatives, as proposed was made.  This change to the
alternatives is discussed in Section VIII. DESCRIPTION OF ALTERNATIVES,
and involves the disposal of nonhazardous material in the former
landfill.   An Alternate Component was also developed to  supplement
Alternative 3, to address public comment.  These changes  are also
described in Section XII. DOCUMENTATION OF SIGNIFICANT CHANGES.
X.          THE SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the detailed
analysis using the nine criteria,  and the public comments, EPA has
determined that Alternative 3 - Decontaminate Buildings; Demolish Former
Battery Wrecking Building and Dispose Off-site; Containment of the
Former Surface Impoundment, the Former Landfill and the Slag Burial
Area/Other Soils is the most appropriate remedy for OU No. 5 of the RSR
site .

The major components of this remedy include:

            Decontamination of the former battery wrecking building and
            the vehicle maintenance building  (estimated 60,600 square
            feet) ;

            Demolition of the former battery wrecking  building using
            conventional methods and off-site disposal of debris
            (estimated 55,800 square feet);

            Evaluate existing cap on the former surface impoundment,
            upgrade or replace as necessary,  in order  to  complete  RCRA
            closure  (estimated 45,000 square  feet/;

            Cap  the former  landfill  in accordance with applicable
            landfill closure requirements  (estimated  503,000  square
            feet;;

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            Cap the Slag Burial Area/Other Soils Areas that exceed
            Remedial Action Goals (estimated 1,480,000 square feet) with
            two (2) feet of clean backfill and revegetating with native
            grasses;

            No action is recommended for the shallow ground water.  The
            shallow ground water beneath OU Nos. 4 and 5 is not
            considered to be a potential drinking water supply  (i.e. a
            Class  III aquifer) .

All activities will be in compliance with federal and State ARARs,
specifically those for RCRA closure and remediation,  RCRA handling,
transportation,  treatment and disposal requirements,  asbestos disposal
requirements,  and  State and federal chemical specific ARARs for air
quality during remediation.  Appendix E. includes the ARARs analysis for
OU No.  5.   In addition, all off-site disposal of material must in
compliance with EPA's Off-site Policy at the time of disposal.  Figure
17 illustrates the areas on OU No.  5 to be addressed by Alternative 3.

The estimated time for completion of this remedy is less than one year
and the estimated  costs for this alternative are:

   Capital Costs:             $ 9,237,015
   Annual  Operation &
   Maintenance(0-5 years):    $ 9,400
   Annual  Operation &
   Maintenance(6-30 years):   $ 6,000
   Present Worth:             $ 9,343,800

The alternate component of Alternative 3, is also acceptable, contingent
upon implementation by the property owners or a prospective purchasers.
Under the  alternate component, all  of the former landfill may be
regraded and covered with asphalt or concrete.  See Section VIII.
DESCRIPTION OF ALTERNATIVES.
Remedial Action Goals

The purpose of this remedial action is to control risks posed by direct
contact, ingestion, and inhalation of the contaminated material
associated with the buildings,  the former surface impoundment, the
former landfill, and the slag burial area/other soils.  The results of
the baseline risk assessment indicate that the greatest excess lifetime
cancer risk at the site currently is 4X10-4 from ingestion of
contaminated materials in the former landfill  (by the future  industrial
worker).  This risk relates primarily to ingestion of arsenic.  Lead on-
site was also determined to be present at unacceptable levels.  A model
used to predict adult blood levels estimated blood-lead levels for a
current or future worker on-site.  This remedy will address arsenic in
excess of 32.7 ppm, antimony in excess of 818 ppm, and lead in excess of
2,000 ppm present  in or as part the buildings and structures, the former
surface impoundment, the former landfill and the slag burial  area/other
soils.  The 2,000 ppm corresponds to the acceptable level, as predicted
by the Adult Lead Model  (see Appendix B), the  32.7 ppm corresponds to an
excess cancer risk of the 1X10-5, and the level  for antimony  corresponds
to an excess cancer risk of 1X10-6.

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             ASSLteO OU NO. 5
             BOUNDARY


             ACTIVE  FACILITY - NOT
             INCLUDED IN BI/FS
                 ACTION
   ALTERNATlVf 3
      OPERAflLf IMT NO. 9
R9R OONPOAATION ftKNFWO »Tf
         OMXAS.  TEXAS

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XI.         STATUTORY AUTHORITY FINDINGS AND CONCLUSIONS OF LAW

Pursuant to CERCLA, studies are.conducted at NPL sites to characterize
the nature and extent of contamination associated with a particular
source of contamination and to determine the most feasible cleanup
approaches.  At OU No. 5,  EPA conducted a remedial investigation,
feasibility study, and risk assessment to determine the nature and
extent of site contamination.

The statutory determinations that are required for remedy selection are
in Section 121 of CERCLA,  42 U.S.C. § 9621.  Under CERCLA, EPA must
select remedies that are protective of human health and the environment,
comply with ARARs  (unless a statutory waiver is justified), are cost
effective,  and utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent
practicable.  In addition,  CERCLA includes a preference for remedies
that employ treatment that permanently and significantly reduces the-
volume, toxicity, or mobility of hazardous wastes as their principle
element.  The following sections discuss how the selected remedy meets
these statutory requirements.

Protection of Human Health and the Environment

The selected remedy protects human health and the environment by
addressing releases or threats of releases of hazardous substances by
demolition, decontamination, treatment, as necessary, and disposal of
debris and by containment of the former surface impoundment, the former
landfill and the slag burial area/other soils.

The selected remedy would  minimize the threat of exposure to the lead,
arsenic and antimony present on-site through ingestion, inhalation, and
direct contact.  By decontaminating the buildings, demolishing and
disposing of the former battery wrecking facility, and containing the
former surface impoundment, the former landfill and the slag burial
area/other soils, the cancer risks from exposure will be reduced to less
than 1X10-6, which falls within the EPA's acceptable risk range of 10-4
to 10-6.  There are no short-term threats associated with the selected
remedy that cannot be readily controlled.  In addition, no adverse
cross-media impacts are expected from the activities.

Compliance with Applicable or Relevant and Appropriate Requirements

The selected remedy will comply with ARARs.  The complete ARARs
analysis, determinations and justification for ARARs for OU No. 5 of the
RSR site is presented in Appendix E.

In addition, per comment from TNRCC.  (See Appendix F), Title 30.
Environmental Quality, Part  I., Chapter 335. Industrial Solid Waste and
Municipal Hazardous Waste  (30 T.A.C. §335) is also an ARAR'.

The following CERCLA  requirement must also be complied with as part of
the selected remedy:  All disposal off-site will be at  facilities  in
compliance with  EPA's Off-site  Policy, specifically  .all  hazardous
substances, pollutants or  contaminants removed off-site pursuant  to this
action  for  treatment, storage,  or disposal shall  be  treated,  stored, or
disposed of at a  facility  in compliance with  RCRA, as  determined  by EPA,

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pursuant to CERCLA Section 121 (d) (3), 42 U.S.C. § 9621 (d)(3),  and the
following rule:  "Amendment to the National Oil and Hazardous Substances
Pollution Contingency Plan;  Procedures for Planning and Implementing
Off-Site Response Action:  Final  Rule."  58 FR 49200  (September 22,
1993), and codified at 40 C.F.R.  § 300.440.


Cost-Effectiveness

EPA believes that this remedy would provide a significant reduction of
the risks to human health and the environment at an estimated cost of
$9,024,000.  Therefore,  the selected remedy provides an overall
effectiveness proportionate to its costs, such that it represents a
reasonable value for the money that will be spent.

Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable

EPA believes the selected remedy  represents the maximum extent to which
permanent solutions and treatment/resource recovery technologies can be
utilized in a cost-effective manner for the types of materials and
contaminants at OU No. 5 of the RSR Site.  Of those alternatives that
are protective of human health and the environment and comply with
ARARs, EPA has determined that the selected remedy provides the best
balance in considering long-term  effectiveness and permanence; reduction
in toxicity, mobility, or volume  through treatment; short-term
effectiveness; implementability;  and cost; as well as considering the
statutory preference for treatment as a principal element, and
considering State and community acceptance.

Preference for Treatment as a Principal Element

 This remedy utilizes permanent solutions and alternative treatment to
the maximum extent practicable for this Operable Unit.  However, due to
the size of the former landfill portion, slag burial  area/other soils,
it was determined impracticable to excavate and treat the chemicals of
concern effectively.  Thus, the remedy for this Operable Unit does not
satisfy the statutory preference  for treatment as a principal element of
the remedy.

Because this remedy will result  in hazardous substances remaining  on-
site  above health-based  levels,  allowing for future industrial use,
five-year reviews will be  necessary  at OU  No.  5 of the RSR Site to
ensure that the remedy continues  to  provide adequate  protection of human
health and the environment.
XII.        DOCUMENTATION  OF SIGNIFICANT  CHANGES

EPA  issued  the  Proposed  Plan for  the  RSR  Corporation  Superfund  site,
Operable Unit No.  5  for  public review and comments  on June  18,  1996.   In
the  Proposed  Plan,  EPA solicited  comments on the  disposal of
nonhazardous  material  which may be  generated from the OU No.  4  remedial
action  into the former landfill.    EPA evaluated  verbal  comments,
reviewed all  written comments and information submitted  during  the
public  comment  period  regarding this  matter.  In  addition,  EPA  received
                                    45

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ccrrjr.ents on the cap proposed for the former landfill..  EPA addressed
the comments regarding the cap in the former landfill in the Alternate
Component described for Alternative 3.  Based on this review and
evaluation, EPA has made that the following changes to the alternatives,
as originally identified in the Proposed Plan:

1.)          Remove from the' alternatives the disposal of nonhazardous
debris in the former landfill.  The basis for this change are  the
comments that were received on the Proposed Plan.  A complete  discussion
of the comments and responses regarding this matter is included in the
Appendix A. Responsiveness Summary.

2.)          Incorporate the Alternate Component in the selected remedy.
EPA has incorporated the Alternate Component in the selected remedy.
This Alternate Component,  describes other caps or covers that  may be
used in the former landfill,  in order to allow for commercial/industrial
redevelopment of that area.                                     '

3.)          Revise cost estimates for each alternative.  The revised
cost estimates that incorporate the above changes for each alternative
are included in Appendix G.

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                      RESPONSIVENESS SUMMARY
                  RSR CORPORATION SUPERFUND SITE
                     OPERABLE UNIT No.  5 AND
             GROUND WATER PORTION OPERABLE UNIT No.
                   DALLAS, DALLAS COUNTY, TEXAS
INTRODUCTION

     This Responsiveness Summary for the RSR Corporation
Superfund Site (RSR Site),  Operable Unit (OU) No. 5 and ground
water portion of OU No. 4,  documents for the Administrative
Record public comments and issues raised during the public
comment period on the Proposed Plan for OU No.  5 and- the ground
water portion of OU No. 4.   Pursuant to Section 117 of the
Comprehensive Environmental Response,  Compensation, and Liability
Act (CERCLA or Superfund),  42 U.S.C. § 9617, EPA considered all
comments received during the public comment period in making the
final decision contained in the Record of Decision (ROD)  for OU
No. 5 and ground water portion of OU No. 4.
OVERVIEW OF PUBLIC COMMENT PERIOD

     The United States Environmental Protection Agency (EPA)
issued the Proposed Plan for OU No.  5 and the ground water
portion of OU No.  4 for public review and comment on June 18,
1996.  The initial thirty-day public comment period for the
Proposed Plan ended on July 17, 1996.  At the request of a
citizen, EPA extended the public comment period to August 16,
1996.  EPA conducted a public meeting on July 9, 1996, at the
West Dallas Multipurpose Center located at 2828 Fish Trap Road,
in west Dallas, Texas to provide information and answer questions
about the Proposed Plan and to receive public comments.  A
transcript of the meeting was prepared and is available in  the
Administrative Record for OU No. 5 located at the information
repositories for the RSR Site.  This Responsiveness Summary
contains EPA's responses to verbal comments received during the
public meeting and written comments received during the comment
period.  EPA received many questions and comments during the
comment period that did not relate to the Proposed Plan for OU
No. 5, but to other matters at the RSR Site.  EPA has organized
this Responsiveness Summary to respond to comments on the
Proposed Plan for OU No. 5 first, in the section entitled
"Comments and Issues Concerning the Proposed Plan for OU No 5."
EPA is responding to the comments and questions received during

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the comment period that did not relate to the proposed plan for
OU No.  5 in the section entitled "Other Comments and Questions."

COMMENTS AND ISSUES CONCERNING THE PROPOSED PLAN FOR OU No. 5

     1.   City of Dallas Department of Environmental and Health
          Services, letter dated July 16, 1996.

     Comment:   The City of Dallas Department of Environmental and
     Health Services states the EPA's proposed clean-up
     Alternatives 3 and 4 include capping essentially all of the
     OU No. 5  site should,  in the City's opinion,  eliminate
     problems  associated with this site.  The City believes that
     little would be gained for the additional cost involved in
     soil removal as proposed in Alternative 4 and could increase
     the exposure to airborne metal emissions during the soil
     removal.  The City recommends that the EPA adopt Alternative
     3  without capping "other soils" south of the railroad right-
     of-way, unless those "other soils" exceed the City of Dallas
     Council recommended level of 250 ppm for lead.

     Response: Consistent with this comment EPA has selected
     Alternative 3 as the remedy for OU No.  5.  However,  the
     Remedial  Action Goal established for lead in the OU No.  5
     Record of Decision is 2,000 ppm.  This goal is based on the
     site specific risk assessment that was conducted for OU No.
     5.  Therefore,  the "other soils" portion of OU No.  5 will be
     capped when the concentration of lead exceeds 2,000 ppm or
     when any  of the other Remedial Action Goals established in
     Record of Decision and supported by the risk assessment are
     exceeded.

     2.   RSR  Corporation,  letter dated August 16, 1996.

     Comment:  RSR's comments focus on the Proposed Plan for OU
     No.  5, and specifically evaluate certain elements of EPA's
     preferred remedial alternative  (Alternative 3) that RSR
     believes  are inappropriate in light of site conditions and
     the requirements of the National Contingency Plan (NCP).
     RSR's comments also describe an RSR Alternative Approach,
     that RSR  says will achieve the same results as EPA's
     proposal  in a way more conducive to future development of
     the site.

     Response: Below is an itemized response  to the major
     components of the RSR Alternative Approach.

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Comment:  As to Subarea 1, the principal difference from
EPA's proposal would be to avoid unnecessary expense in
shoring up the former battery plant.  That building would be
demolished and concurrently decontaminated, not rebuilt
before decontamination and demolition.  Scrap metal and any
other reclaimable material generated from demolition
activities will be recycled rather than disposed on-site.

Response:  The EPA proposal and selected remedy for the
former battery wrecking facility portion of OU No.  5 does
not require that buildings be shored,  braced or rebuilt
prior to decontamination and demolition.  Rather,  the
relevant portion of the selected remedy simply states:

     Decontamination of the former battery wrecking building
     and the vehicle maintenance building;
     Demolition of the former battery wrecking building
     using conventional methods and offsite disposal of
     debris;

The specifics of the construction sequencing and the
decontamination and demolition methods to be used at the
former battery wrecking facility will be further defined in
the Remedial Design.  The shoring and bracing that was
described in the alternatives was for the purpose of
documenting the assumptions for purposes of estimating
costs.  EPA will consider reclamation of non-hazardous  scrap
material generated as part of demolition activities during
the Remedial Design and Remedial Action.

Comment:  The former vehicle maintenance facility would be
decontaminated in-situ with commonly employed practices.
Existing building sumps would be used to collect any fluids
generated from this decontamination.  After determination
that the fluid meets the discharge standards for the City of
Dallas's POTW,  the fluids would be discharged to the POTW.

Response:  As stated previously the specifics on the
decontamination methods will be further defined in the
Remedial Design.

Comment:  As to Subareas 2 and 3, this alternative remedy
would adopt a two-step approach.  First,  interim measures
would be put into place to prevent releases prior to
redevelopment of the property.  These would include
institutional controls, including a deed  restriction on  the
use of the site; use of dust suppressant  to control
windborne emissions; repairing existing  fencing where

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necessary; and posting warning signs.  In addition, surface
water management controls, a sediment collection and
disposal system, and storm water controls along the
perimeter of the site would be improved or, where not
currently present, installed.

     Second, EPA would define now the requirements to be
imposed on future site development.  These would be
presumptive in the sense that any future developer would
escape them only by demonstrating that an alternative was
equally protective.   These would be enumerated in the deed
restriction described above.   Among the elements to be
specified in this program would be the requirement that
metals contaminated soils outside of the former landfill be
covered with buildings or pavement meeting appropriate
standards.  If redevelopment of the site ultimately is not
feasible,  designated areas of OU No. 5 would be capped with
two feet of soil.

Response:  EPA does not agree that a two step approach to the
remedy is necessary in order to address redevelopment
options for properties associated with OU No.  5. In response
to this comment,  EPA has incorporated an Alternate
Component in Alternative 3 and in The Selected Remedy in the
Record of Decision for OU No. 5 to address the requirements
for redevelopment options that may be implemented by the
property owner or prospective purchaser.   The Alternate
Component of Alternative 3 allows for regrading of the
former landfill portion of OU No. 5 in order to support an
alternate cap consisting of asphalt or concrete that would
be constructed and monitored in accordance with State and
federal ARARs,  including, but not limited to,  State closure
and remediation requirements found in 30 T.A.C. 335
Subchapter S,  Risk Reduction Standards,  and requirements of
portions of 30 T.A.C. 335 Subchapter F,  Permitting Standards
for Owners and Operators of Hazardous Waste Storage,
Processing, or Disposal Facilities, which include closure
and post-closure care requirements for landfills.  The
scheduling and timing of the Remedial Action are not
addressed in the ROD, but can be more appropriately
addressed in implementation documents, such as work plans,
orders, or consent decrees.  Finally, in the event that
redevelopment of the former landfill portion of OU No. 5 is
not pursued, The Selected Remedy requires that the former
landfill be capped in accordance with ARARs, including
landfill closure requirements.

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Comment:  As to the former landfill area, the program would
include a hybrid closure approach.  Consistent with the
redevelopment of the site, the landfill would be graded and
covered with parking lots and/or buildings.  In the event
that redevelopment of the site ultimately does not occur, it
would be capped with 2 feet of clean, compacted soils and
vegetative cover.  In the meantime, since the topography of
the former landfill slopes by approximately 25 feet from
east to west, it could be filled with non-hazardous waste
material  from OU Nos.  4 and 5 and fenced.  Other
appropriate institutional controls also would be
implemented.  No leachate collection or leachate monitoring
would be required for this area,  however, since the material
in the landfill consists of highly insoluble and immobile
constituents.  The landfill would be inspected on a
quarterly basis, unless a parking lot or building is placed
over the landfill,  depending upon the redevelopment
approach.  Any deterioration indicating a potential for
migration of materials from the landfill would be repaired
as expeditiously as possible.

Response:  As stated above, in the event that redevelopment
does not occur on the former landfill portion of OU No. 5,
The Selected Remedy requires closure of the former landfill
in accordance with State and federal ARARs, which may
include a hybrid approach.  This includes, but is not
limited to,  ARARs such as State closure and remediation
requirements, as found in 30 T.A.C. Subchapter S.,  Risk
Reduction Standards,  and relevant portions of 30 T.A.C. 335
Subchapter F.,  Permitting Standards for Owners and Operators
of Hazardous Waste Storage, Processing, or Disposal
Facilities,  which include closure and post-closure care
requirements for landfills.    Due to the potential for
redevelopment of the former landfill portion, as well as
other comments received on the Proposed Plan regarding
disposal of the nonhazardous material generated from
Remedial Actions at OU Nos. 4 and 5, the Record of Decision
for OU No. 5 calls for the off-site disposal of the non-
hazardous material rather than disposal in the former
landfill.

Comment:  The RSR alternative approach and EPA's preferred
remedial alternative for OU No. 5 differs principally  in
three respects: the approach for decontaminating and
demolishing  the battery wrecker building;  the approach  for
capping the  former landfill area; and  timing.  In all  other
respects the remedial alternatives are virtually identical.
As noted above and discussed more  fully below, RSR believes

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the Agency's concept of shoring up the wrecker building
prior to its decontamination and demolition is unnecessary.
Further, the cap EPA would place on the former landfill is
unnecessarily complex and expensive and would interfere with
the site's future development.  Finally, by deferring work
on Subareas 2 and 3 until redevelopment occurs, some
disturbance of existing, non-threatening conditions can be
avoided and costs saved.

Response:  An itemized response to the RSR expanded critique
of certain elements of EPA's proposed alternative is
provided in the following comments and responses.

Comment:  EPA has proposed to .decontaminate the battery
wrecking building.   Prior to doing so, however, EPA would
conduct a complete structural investigation of the facility
to identify structural hazards.  EPA then assumes that
shoring and bracing will be performed at those specific
areas;  the shoring and bracing would be designed to
withstand high pressure steam cleaning.

     In lieu of this approach, it would make more sense to
demolish and concurrently decontaminate the building.  RSR
thus believes it more prudent to proactively demolish the
building while concurrently decontaminating it.

Response:  As stated previously the relevant portion of the
Record of Decision for OU No. 5 does not require that the
battery wrecking building be shored,  braced or rebuilt prior
to decontamination and demolition.  The specifics of the
construction sequencing and the decontamination and
demolition methods to be used at the former battery wrecking
facility will be further defined in the Remedial Design.
The shoring and bracing that was described in the EPA
alternatives was for the purpose of documenting the
assumptions for purposes of estimating costs.

Comment:  EPA has proposed to cap the former landfill area
with a cover system that parallels the RCRA requirements for
closure of a hazardous waste landfill.  The Agency's
apparent reasoning for requiring this extensive cover design
is that the RCRA Subtitle C landfill cover requirements are
relevant and appropriate for the site.

     This is incorrect, for two reasons.  First, the
landfill has not "actively managed" RCRA hazardous wastes;
such wastes were not placed in the landfill after the
effective date of RCRA Subtitle C requirements, nor does RSR

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propose to place hazardous waste in the landfill as part of
the alternate remedial approach.  Second the RCRA Subtitle C
cover requirements for hazardous waste landfills do not meet
the criteria set forth in the NCP that standards to be
considered relevant and appropriate.

Response: The Alternate Component described in the Record of
Decision for OU No.  5 allows for an alternate cap (i.e.
concrete or asphalt)  over the former landfill portion in
order to support redevelopment options.  This flexibility in
the final cover design for the former landfill is not
inconsistent with the proposed "hybrid closure" described in
the RSR comments.  Furthermore,  the remedial alternatives
analysis portion of the Feasibility Study for OU No.  5
describes the landfill capping design assumptions that were
made in order to estimate costs, and are as follows:

     This alternative assumes that surface preparation will
     be performed using conventional earth-moving equipment
     and methods.  In addition,  this alternative assumes the
     placement of the clay layer,  flexible membrane liner,
     drainage layer,  and cover will be performed using
     conventional methods.  The cover system in a
     nonhazardous waste landfill is a function of the bottom
     liner system and the liquid management strategy for the
     site.  Landfill closure requirements will most likely
     be established by the State of Texas.  Depending on
     site-specific considerations, designs based on natural
     soils as well as designs that resemble a multi layer
     cover may be required.   Hence, the assumption of a
     multi layer cover in this alternative is a conservative
     one.

The bases for the assumptions used in the alternatives
development are the ARARs analysis documented both in the
Feasibility Study and the Record of Decision for OU No. 5.
The principal ARARs for the former landfill portion of OU
include the State closure and remediation regulations, as
described in 30 T.A.C. 335 Subchapters F and S.  In
addition, comments received from the Texas Natural Resources
Conservation Commission  (TNRCC), recommend the use of 30
T.A.C. 335.174 for the closure and post-closure care of the
landfill portion.  This section (30 T.A.C. 335.174)
incorporates five criteria that could be considered for
landfill cover design:

      (1)  Provide long-term minimization of migration of
      liquid through the closed  landfill;

                            7

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      (2)  Function with minimum maintenance;

      (3)  Promote drainage and minimize erosion or abrasion
     of the cover;

      (4)  Accommodate settling and subsidence so that the
     cover's integrity is maintained; and

      (5)  Have a permeability less than or equal to the
     permeability of any bottom liner system or natural
     subsoils present.

Comment:  The Presumptive Remedy for a Municipal Solid Waste
Landfill (MSWLF) does not require a RCRA Subtitle C landfill
cover.  Even if the former landfill at OU No.  5 were a
MSWLF, the guidance compels the conclusion that these
closure standards to which EPA referred are not applicable.
They could be considered relevant and appropriate only after
the consideration of several factors, including the nature
of the waste,  the*date on which it was disposed in the
former landfill, and the hazardous properties  of the waste.
Furthermore,  in this instant context those factors would not
support such a finding.

     In addition, one of the primary purposes  of landfill
covers required under the RCRA Subtitle C program is to
prevent ground water contamination.  But such contamination
is not an issue at the RSR site.  EPA has stated in the RI
and the FS documents for OU No.  5 that leachate will not be
generated from the landfill and that ground water underlying
the site in the vicinity of OU No. 5 is not considered a
potential water supply aquifer.   Consequently,  the cap
design contemplated by EPA is overkill that will achieve a
degree protection substantively no greater than the cover
design proposed by RSR.   In fact,  EPA itself admits that its
assumption of a multi layer landfill cover is conservative.
Moreover, the cap would impede,  if not preclude,
redevelopment of the site.

Response: The presumptive remedy guidance for Municipal
Landfills was considered in the technology evaluation in the
Feasibility Study for OU No. 5.  -Furthermore,  the Alternate
Component described in the Record of Decision allows for an
alternate cap over the former landfill portion to support
redevelopment options and which is not inconsistent with the
proposed "hybrid closure" described  in RSR's comments.  As
stated previously, the principal ARARs for the former
landfill portion of OU No. 5 include the State closure and

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remediation regulations, as described in 30 T.A.C. 335
Subchapters F and S.  Finally, this comment takes out of
context the information cited in the OU No. 5 Feasibility
Study with regard to leachate generation.  The Feasibility
Study Report states the following with regard to leachate
generation (emphasis added):

     "Since most of the landfill material consists of highly
     insoluble and immobile industrial refuse, it has been
     assumed that for cost estimating purposes,  no leachate
     will be generated by the landfill and no monitoring
     will be required."

Comment:  The RSR alternative embodies a hybrid closure that
melds appropriate elements of the RCRA Subtitle C closure
standard with other appropriate and protective closure
standards.  Relevant EPA guidance indicated that Agency
personnel are to consider hybrid closure options for -
landfills at which the RCRA Subtitle C landfill standards
are not applicable.   The NCP clearly supports the use of
hybrid closures for the former landfill at OU No.  5.  For
example, the NCP recognizes that the Superfund program has
been using several different types of hybrid closures that
give the decision maker additional choices for the long-term
management of hazardous substances as well as treated
residuals.  Furthermore, where future brownfield development
is possible,  avoiding interfering remedies clearly is
favored.  Unlike EPA's preferred remedial approach,  the
alternative would  not put into place impediments to the
redevelopment of the property.  For example,  the RCRA cap
EPA proposes to place on the former landfill in Subarea 2
would render it virtually impossible to redevelop that
portion of the site.  Moreover,  from an economic
perspective,  the phased approach described herein makes
redevelopment a more likely prospect.

Response: The Alternate Component described in Alternative 3
and in The Selected Remedy in the Record of Decision for OU
No. 5 allows for an alternate cap over the former landfill
portion in order to support redevelopment options.  This
flexibility in the final cover design for the landfill  is
not inconsistent with the proposed "hybrid closure"
described above.  The Alternate Component of Alternative 3
allows for regrading of the former landfill portion of  OU
No. 5 in order to support an alternate cap consisting of
asphalt or concrete that would be constructed and monitored
in accordance with the  State and federal ARARs, including
those for closure and remediation, as described in  30 T.A.C.

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     335 Subchapters F and S.  As stated previously,  timing of
     implementation the Alternate Component is more appropriately
     addressed in documents other than the Record of Decision.

3.   Other Written Public Comments

     Comment:  Other separate written comments received included:
          a request that something be done to address the
          contamination soon;
          a preference for Alternative 4,  rather than 3,  because
          it provides more assurance and protection;

     Response:  The cleanup at RSR OU Nos.  4 and 5 will continue
     to be an EPA Region 6 priority and will be addressed in an
     expeditious manner.  Alternative 3 is preferred over
     Alternative 4,  because it provides a similar level of
     protection to the public and does meet the other nine
     criteria established by the National Contingency Plan.

4.   Public Meeting, July 9,  1996, West Dallas Multipurpose
     Center

     Comment:  And in this book right here I read,  we --  put us
     against animals right in this book.   Y'all said it wasn't
     that contaminated because dogs and other animals have come
     across there and they haven't died.   It's in this book.

     Response:  In accordance with the National Continency Plan
     EPA is required to conduct both a human health risk
     assessment and an ecological assessment on Superfund sites.
     As its name indicates, the human health risk assessment is
     conducted to estimate risks a Superfund site presents to
     human health.  The ecological assessment, on the other hand,
     is conducted to estimate risks to non-human life in the
     environment -- that is risks to plants and animals --
     presented by a Superfund site.  This Superfund site
     represents a risk to human health, and the risk to human
     health is what is driving EPA at this Site.  The brief
     summary of the ecological assessment for OU No.  5 is
     included in the Proposed Plan because it is required.  It is
     not intended to compare human to non-human populations.

     Comment:  One of the  things I would like to know is, talking
     about after the smelter and the area is cleaned up,  what
     kind of guarantee will we have that the contaminated debris
     or whatever will not  be stored here in West Dallas?   We
     don't want it in our  community.
                                10

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Response: One of the issues that the public was invited to
comment on was the possible disposal of the nonhazardous
waste material generated from the remedial actions on OU
Nos.  4 and 5 in the former landfill located on the southern
portion of OU No. 5.  Due to this comment, as well as other
comments received on the OU No. 5 Proposed Plan,  the Record
of Decision for OU No.  5 calls for the appropriate offsite
disposal of nonhazardous material rather than planning for
it to be disposed in the former landfill located on the
southern portion of OU No.  5.   Any hazardous material
generated as part of the OU No. 4 or 5 remedial actions must
be disposed of offsite in facility permitted and regulated
to receive hazardous materials.

Comment:  I think you better go back and look at our lawsuit
that  we have,  because that's what I stopped the trucks last
time  from doing.   They pomised us that nothing would be
placed here,  that everything would go to Illinois.

Response: Due to the comments received on the OU No.  5
Proposed Plan,  including this one,  the Record of Decision
for OU No. 5 calls for the appropriate offsite disposal of
nonhazardous material rather than planning for it to be
disposed in the former landfill located on the southern
portion of OU No. 5.  Any hazardous material generated as
part  of the OU No. 4 or 5 remedial actions must be disposed
of offsite in facility permitted and regulated to receive
hazardous materials.

Comment: When you place the cap over the top of the
landfill, what stops the lead from spreading out?

Response:  The cap/cover over the landfill will be designed
in accordance with State and Federal closure and remediation
requirements in order to minimize migration of contamination
from within the landfill.  The cap/cover will be designed to
meet  certain permeability requirements.  These permeability
requirements will minimize the infilitration of rain water
and the subsequent migration of contamination.

Comment: Who owns that property?

Response: Based on information currently available to EPA,
Murmur Corporation is the current owner of the property
where the former secondary lead smelter is located (OU No.
4) and where the former battery wrecking  facility is  located
                           11

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     (northern portion of OU No. 5).   The southern portion of OU
     No. 5, where the former landfill'is located, is curre.ntly
     owned by RSR.

     Comment: I really want to know how far back they're going to
     clean?

     Response: The area estimated to be remediated as part of the
     OU No. 5 Remedial Action is illustrated in Figure 15,
     presented in Record of Decision.

     Comment: Once y'all cap all this -- What's stopping RSR from
     coming back in here and claiming their property and building
     something else?  See,  my concern is,  we've got enough of
     these industrial areas in here.

     Response:  The remedy selected for OU No.  5, as well as the
     remedy selected for OU No.  4,  contemplates redevelopment of
     the property by current or future landowners consistent with
     city zoning requirements.   EPA does not have control over
     who owns or who might purchase or develop this property once
     the cleanup is completed.

     Comment:  When y'all say you're going to clean up so far
     back there,  what about that other area back there where they
     dumped?  RSR owns it.

     Response:  The Proposed Plan and the Record of Decision for
     OU No. 5 address the former landfill area, located in the
     southern portion and currently owned by RSR.  The remedy
     calls for containment of this area.

     Comment:  Can we get a 30-day extension to the public
     comment period?

     Response:  Yes.  A 30-day extension was granted to. extend
     the public comment period on the OU No. 5 Proposed Plan
     until August 16, 1996.
OTHER COMMENTS AND QUESTIONS

 1.  Public Meeting, July 9, 1996, West Dallas Multipurpose
     Center

     Comment: Is there a $100 million in the Superfund or
     government that you can get to help west Dallas? How much


                                12

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money is available?  How much money is in the Superfund
right now?  How much money has been spent on the inspection
and cleanup of the yards in the residential area and do you
have any receipts?

Response: At any given time since the Superfund law was
passed,  there typically has been well over one billion
dollars in the Superfund:  The total amount of money in the
Superfund is not available for EPA to spend however.  EPA
can only spend money that it is authorized to spend in the
federal budget.  The federal budget for fiscal year 1997
includes a total Superfund appropriation of approximately
$1,394,245,000.00.  That amount must be used to pay for the
operation of the Superfund program across the nation,  which
requires EPA to make many budgeting decisions.  Generally,
if there are responsible parties at a Superfund site who can
perform clean up activities or who can pay for clean up
activities,  EPA seeks to have the responsible parties do the
work rather than spend money from the Superfund.  If EPA's
efforts to get responsible parties to perform or pay for the
work are unsuccessful,  then EPA will use money from the
Superfund.  Currently EPA is engaged in efforts to have the
potentially responsible parties for the RSR Site perform or
pay for the cleanup of OU No.  4,  which is estimated to cost
$11.5 million.  EPA also plans to seek PRP funding for the
cleanup of OU No.  5,  which is estimated to cost $9.3
million.  If EPA's efforts are not successful, EPA expects
that there will be sufficient funding available from the
Superfund appropriation for EPA to do the work itself using
Superfund money.

EPA spent approximately 12 million dollars on the removal
action that was conducted in the residential area (OU No. 1)
of the RSR Site,  including the investigation and cleanup
activities.   Documentation of the money spent on the RSR
Superfund Site is located in the Site files at EPA Region 6
offices.  EPA's cost documentation can be reviewed or copies
can be obtained by submitting a request pursuant to the
Freedom of Information Act to the EPA Region 6 Freedom of
Information Officer.   The documentation is voluminous, and
there will be a charge for copying unless the requestor
qualifies for an exemption.

Comment: Don't you say that this area has been cleaned up.
We go back to the same places that you cleaned up 6 to 8
inches.   Well, we're going down a foot; and there's
contamination even higher than what you left  in there.  All
you did is just bury it.  Now you're coming in and  telling

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us that you're going to get us out of the Superfund Site,
partially.

Response: The cleanup in the residential area was not
limited to the upper 6 to 8 inches, in some cases the
excavations went down to 2 to 3 feet.   The cleanup depth was
based on sampling data. EPA welcomes information from the
community regarding areas that may still be contaminated.
The information provided to EPA can be checked against the
sampling and removal data to ensure that contamination does
not remain above cleanup goals.  Please contact Carlos
Sanchez, Remedial Project Manager,  at EPA,  Region 6,
Superfund Division,  (6SF-AT),  1445 Ross Avenue, Dallas,
Texas 75202,  or at  (214)  665-8520,  to report areas of
contamination that have not been addressed.
Comment:  The next one that I want to discuss with you is
when the smelter facility is removed, people better be moved
out of that area.  I want my parents removed.  I want the
people from the housing removed.  I do not want children at
Thomas A. Edison in the school system when this smokestack
is coming down.  Earhart, also.  All the schools in the area
need to be removed.  They need to be moved.  People in those
residences immediately within the 5-mile radius -- if you
say it's a 5-mile radius, I'll go along with you -- need to
be removed.

Response:  At the present time, EPA does not believe that it
will be necessary to relocate residents of west Dallas
during the demolition of the smelter facility.  During the
remedial action planned for OU No.  4, the former smelter
facility and stack, many safety measures will be implemented
and monitoring will be conducted to ensure that the work is
conducted in a safe manner and that contamination does not
migrate offsite and cause exposure to residents of west
Dallas.  For example, EPA has required in the OU No. 4
Record of Decision, that the 300 foot stack be removed in a
controlled manner, such as by piece by piece dismantling,
and that engineering and dust control methods be used to
protect the public.

Comment:  Will EPA help us get some money, compensation,
something out of the $2 billion  (Superfund)  that you have in
there or pass legislation, form  legislation,  to enable EPA
to compensate these folks for what's been going on, not your
fault, not our fault, but this  industry mess  they  left here
behind?

                           14

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Response:  EPA does not have the legal authority to
compensate people for damage to their persons or property
caused by or associated with the actions of private parties
which may have contributed to the existence of a Superfund
site, nor can EPA assist people crafting or promoting
legislation for a special appropriation that would provide
such compensation.

Comment:  I'm suffering from bone deterioration and
headaches and things like that.   We have been having a
problem, not only my family,  the families of west Dallas.  I
think everybody here in west Dallas should be able to have
Medicaid -- free Medicaid,  free -- any time they get sick,
they can go to the doctor.   They don't have to pay a bill,
because we have been contaminated.  We are sick.  We might
not look it,  but we are sick.

Response:  EPA does not have the ability to provide medical
care for persons affected by a Superfund site,  by using
Medicaid or other methods.   Furthermore,  EPA knows of no
government program which would provide free medical care
solely on the basis that a person has been exposed to
contamination from a Superfund site.

Comment:  They (EPA) make all these reports and tell you
they want you to come in.  Now,  if y'all are saying that
y'all want the people's input,  I would like for all these
people right here today do they want that lead smelter up
there moved down.  See,  they done already given an answer of
what they're going to do. I don't think none of these people
did ever tell you that they want that moved down and let
that contaminate these people.   So y'all are doing what you
want to do,  and then we've got to along with it.

Response: EPA has solicited community input and comments on
its remedial plans to address the former smelter facility,
including the 300 foot stack (OU No. 4 of the RSR Site).  In
addition to conducting numerous informal community open
houses on the progress of the investigation and removal
activities,  a formal public comment period was held from May
10, 1995 through July 12, 1995 on the Proposed Plan for  the
former smelter facility.  A public meeting was also held on
the proposal to dismantle the smelter on May 23, 1995 at the
West Dallas Multipurpose Center to receive verbal and
written public comments regarding the proposal. EPA
carefully considered all public comments it received during
the comment period, in addition to 'other criteria it is
required to consider by the National Contingency Plan  in

                           15

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selecting the final remedy for the smelter facility, OU No.
4 of the RSR Site,  in a Record of Decision dated February
28, 1996.

Comment:  EPA said they is a policing body.  I have never
seen a police take money out of they pocket to correct
anything.  They force other people to do it.  RS-R is
supposed to be cleaning up their own mess.

Response:  EPA has provided notice to several parties that
it believes share responsibility for the Site regarding
undertaking the cleanup activities at the former smelter
facility.  EPA is continuing to negotiate with a number of
parties about their conducting and/or financing the remedial
activities on the former smelter facility.

Comment:  I've been coming to these meetings for years,  ever
since y'all started having these meetings.  I've got a two
part question.  And y'all used to say,  wasn't nothing --
wasn't much damage up there.   The water wasn't contaminated,
this that and the other.  But now that we found out on our
own how contaminated it is, now it's coming out that it is
contaminated.  And y'all knew all along how contaminated
this premises is up here with us living out here and then
have the gall to want to t.ear down the stack and we living
out there.

Response:  EPA has attempted to provide accurate information
to the public regarding the RSR Superfund Site. As stated
previously EPA has held numerous community open house
meetings to discuss the progress and status of the
investigations and the removals.  During those meetings EPA
made available all relevant final documents.summarizing the
findings of the investigations.  Copies of all the reports
summarizing the EPA investigations on each of the OUs are
also kept in the information repositories, one which is
located in the Dallas Public Library - West Branch, 2332
Singleton Blvd., West Dallas, Texas.

Comment:  We are not getting supported for what we is -- I
want to -- this school, they said that they were digging up
lead -- lead up from around there. I was paying taxes and
things, and we can do that kind of work.  Now, it would be
nice if we could have someone out here, you know, to give
them a job.

Response:  Awarding of'the cleanup contract for the smelter
facility (OU No. 4) or  the battery wrecking facility  (OU No.

                           16

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5) will depend on who conducts the remedial action.  If the
responsible parties conduct the cleanup, they can choose any
contractor, as long as the contractor is qualified and
capable of doing the work in accordance with EPA approved
work plans.  If EPA conducts the cleanup, the contract will
be advertised and awarded to a contractor capable of
conducting the cleanup.  As with other work conducted in
west Dallas, EPA will encourage its contractors or
responsible parties to hire local workers and minority
subcontractors.

Comment.:  What are you going to do?  Because these people
are suffering from all of this lead poisoning.  And all
you're doing is talking about your big time reports and how
you're going to tear the stack down and spend 24 more
million dollars.   And these people are to continue to suffer
from lead poisoning.  They want some support.   They want
some compensation.   They want some medical attention.  They
want some help.   And it seems like all you committees are
getting all of the money.

Response:  The Superfund statute gives EPA the authority and
funding to address environmental contamination.   The law
does not authorize EPA to provide compensation to
individuals for personal injury or health problems.  EPA
intends to use its Superfund authority to the greatest
extent possible to address environmental contamination
related to the RSR Superfund Site.

Comment:  What are you going to do about compensating the
people that lived out here at that time that do .have these
health problems?  Do you know what I am saying?  It's more
than just Medicaid.  I can't go out and buy my daughter or
my son a decent pair of shoes because I can't make it on
what I'm living on.  But if I had my health -- don't call me
lazy, because my job records speak for me.  My education
speaks for me.  What would you do to help me now?

Response:  As stated previously, the Superfund statute does
not authorize EPA to provide compensation to individuals for
personal injury or health problems.  However,  EPA intends to
continue to address contamination at the smelter facility
and the battery wrecking facility as a top Region 6
priority.

Comment:   I drove my car around in different areas of the
community, you know, across Westmoreland, across Hampton,
the shopping center, and in the Spanish area, because I

                           17

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wanted to have a big turnout because I feel like this.  We
as the people of West Dallas -- I'm looking around at this
room, and I don't see all of west Dallas here.  And I wonder
why.  If you pay your county taxes and your city taxes,  no
matter what's going on in our area, everybody should know
about the meetings,  about the lawsuits.  We want to know
about the lawsuits and some people don't know.  I'm a
taxpayer.

Response:   EPA appreciates the efforts of the community in
helping to spread the word about the public meetings on the
RSR Superfund Site.   EPA attempted to get wide spread public
notice of  this meeting by publishing notice in the Dallas
Morning News,  as well as mailing out approximately 1100 Fact
Sheets and postcard meeting reminders to everyone on the RSR
Site mailing list.  EPA is not a party to and has no
information on any of the lawsuits regarding the RSR site.

Comment:   We want the lead smelter to stay standing because
it's not  hurting us  now.   We want to be given that money
that you  got to spend on the smeller and give it to us.   We
want that  money because we need it.

Response:   EPA does  not have the authority to compensate
individuals for past exposure.   EPA does not have the:option
of giving  money to the community in lieu of cleaning up the
Superfund  site.

Comment:   Lead poisoning can be diagnosed by the presence of
lead in the urine.  They have never did a urine test on us.
They do blood tests.  Why are we not getting tested by the
urine?

Response:   Blood lead levels provide the most accurate
measure of a person's exposure to lead, since lead attaches
to blood proteins.  Lead has a low solubility in water and
urine is  mostly comprised of water. Therefore, urine does
not provide an accurate measure of a person's exposure to
lead.

Comment:   We have a factory right here that's building
shingles for the roofs.  How do we know we're not being
contaminated from that now?

Response:   In addition to the Superfund statute, EPA has
under it's jurisdiction several other  statutes or laws to
protect the air, soil, and water.  Requests for information
                           18

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about an operating company in your community may be directed
to the Freedom of Information Officer, EPA Region 6, 1445
Ross Avenue, Dallas, Texas 75202.

Comment:  Can I ask you a question?  This paper here -- this
paper here that everybody's supposed to send in with you
input, if everybody's voting no to tearing down the lead
smelter, do that mean that we're going to win,  or do that
mean that you're just getting us to mail this in and
throwing them in the trash?  I want to know that,  because I
have over 200 people right now that's voting no.  We want to
know how many people said tear it down.  That's what we want
to know.

Response:  The decision concerning how the smelter would be
cleaned up was made in February 1996, and that decision is
not the subject of this comment period.  A public comment
period on the proposal to decontaminate,  dismantle and
dispose of the former smelter facility (OU No.  4)  was held
from May 10, 1995 through July 12,  1995.   A public meeting
was also held on the proposal to dismantle the smelter on
May 23, 1995 at the West Dallas Multipurpose Center to
receive verbal and written public comments regarding the
proposal.  A copy of that public meeting transcript is also
contained in the OU No. 4. Administrative Record.  EPA
carefully considered all public comments during the comment
period, as it is required to do.  EPA also considered other
evaluation criteria required by the National Contingency
Plan in selecting the final remedy for the smelter facility
in a Record of Decision dated February 28, 1996.  The other
criteria evaluated,  in addition to community acceptance, are
as follows: Overall Protection of Human Health and the
Environment; Compliance with Applicable or Relevant and
Appropriate Requirements  (ARARs); Long-Term Effectiveness
and Permanence; Reduction of Toxicity, Mobility or Volume
Through Treatment; Short-Term Effectiveness;
Implementability; Cost and State Acceptance.

Comment:  If EPA does not have the authority to compensate,
can EPA recommend that we be compensated?

Response:  EPA does not have the legal authority to give or
to recommend compensation.

Comment:  Do the City of  Dallas or the EPA have the
responsibility to notify  citizens when they're  living  in
lead contaminated areas,  especially when  they have  a plant
that's emitting over a certain amount  of  years?  Is  there  a

                           19

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time span that you have to notify us?  In other words, if
this thing starts happening, 30 days after it starts do you
supposed to notify us and say,  well, you have lead, we've
known it for about 30 days?  Do you have that
responsibility?

Response:  If EPA has identified a site where there has been
a release or threat of release of a hazardous substance that
is creating a threat to human health and the environment, it
is EPA's responsibility to contain and address the threat,
as well as conduct community relations activities.
Community relations activities may include,  but not be
limited to,  conducting open house meetings,  mailing out Fact
Sheets and conducting public meetings.

Comment:  If he is saying the stack is not contaminated,  why
is it y'all are going to tear it down?

Response:  EPA has not stated that the stack is not
contaminated. .All of the sampling data collected from the
stack does indicate that the inside refractory brick and
dust is contaminated with lead,  cadmium and arsenic.   All of
the results of the investigation of the stack and the
smelter facility (OU No. 4)  are contained in the information
repositories, including the one located at the Dallas Public
Library - West Dallas Branch,  2332 Singleton Blvd., Dallas,
Texas 75212.

Comment:  My question is once you are exposed to lead, minor
or major, you're sick right?

Response:  The amount of a person's exposure determines the
degree of health effects.   Low level exposure to lead can
have no consequences or negligible effects.

Comment:  What government entities can ya'll bring together
and sit down and talk with us?  It's only EPA.  EPA is not
the only government entity that can talk with you all
Y'all are the only one that comes out here.   Where is the
City?  Where is the State?  Y'all can never give us answers.

Response:  EPA has kept the City of Dallas and the Texas
Natural Resources Conservation Commission (TNRCC)  informed
of the activities at the RSR Site, including the public
meetings, such as this one,  and community open houses.  EPA
has provided information,  such as Fact Sheets, and conducted
briefings with interested Dallas City Council members and..
Commissions.   TNRCC has participated in the RSR Superfund

                           20

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project through review and commenting on the technical
reports, as well as attending the open houses and public
meetings, including this one.

Comment:  So you see, we're not concerned about that stack
and we're not concerned about that damn smelter because it's
done its damage, hear?  What we're concerned is, what can
you do for us to help us get some help?  If you can't give
us no money, I've been begging you to give us some medical
help.  We've got people in here falling apart.

Response:  As stated previously, it is beyond the scope and
mission of EPA to provide medical services.  However, there
are other local, State and Federal agencies that are
dedicated to health and medical services.   Some of these
agencies and contacts are listed in the Citizen's Guide to
Lead Issues, also referred to as the "Yellow Book."

Comment:  How in the world did it come up y'all talking
about $10 million to tear down the smelter.  The last
meeting we had,  the figures were -- round right $50 million.

Response:  The cost estimate for the remediation of the
former secondary lead smelter (OU No.  4)  as documented in
the OU No.  4 Record of Decision is $11.4 million.   The $50
million cost estimate that you may have heard referred to at
previous meetings,  may represent the total cost estimate to
remediate the entire RSR site (i.e.  all five OUs).

Comment:  How is it you all are so concerned about a cement
raggedy tin building that lead has been blowing out of for
50 years?  And we've got wooden frame homes right across the
street -- that lead can't penetrate them bricks up there.

Response:  Protection of human health and the environment is
EPA's main goal in addressing smelter related contamination
at the RSR Site.  EPA has been concerned about the
residential areas located near the smelter. EPA's first
focus was to address smelter related contamination in the
residential areas (i.e. RSR OU Nos. 1 and 2).  Thousands of
samples were collected by EPA in the residential areas.  In
addition, extensive research and sampling was performed to
determine the safe level of lead for the residential areas,
and 420 residential properties were cleaned up to the safe
level.

Comment:  If any of the EPA employees lived in west Dallas
when that contaminated -- when that smokestack -- even if

                           21

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 you tear it down by piece by piece, when it comes down
 contamination is sill going to go in the air.  I don't care
 how air control monitor, it's still going to go there.
 There's going to still be some contamination.  Would you and
 your kids and your family live here during that
 contamination?

 Response:  Regardless of who resides in the community, it is
 EPA's mission to protect the public during the remedial
 action planned for OU No. 4, the former smelter facility.
 Many safety measures will be implemented and monitoring will
 be conducted during all cleanup and demolition activities to
 ensure that the work is conducted in a safe manner and that
 contamination does not migrate offsite and cause exposure to
 the public.

 Comment:  So,  the only thing that we're asking you,  if it's
 not -- if it take a week to tear it down,  move us out a
 week.

 Response:  As mentioned previously, at this time EPA does
 not see a need for temporary relocation during demolition
 activities at the former smelter facility.   Engineering and
 control measures will be used to ensure that  contamination
 posing a health threat does not leave OU No.  4, the smelter
 site,  during demolition and cleanup activities.

 Comment:  I'd like for you to go back and make a memo.  You
 should make an amendment back and say that this community
 should have been and should be a Superfund Site and people
 really need to be relocated out of this community.

 Response:  The west Dallas residential areas contaminated
 with smelter related contamination were included as part of
, the National Priorities Listing of the RSR Corporation
 Superfund site.  Since those residential locations
 contaminated above health based levels have been cleaned up,
 permanent relocation is not necessary.  Furthermore, at this
 time EPA does not see a need for temporary relocation during
 demolition activities at the former smelter facility, since
 engineering and control measures will be used  to ensure that
 contamination posing a health threat does not  leave OU No.
 4, the smelter site, during cleanup activities.
                            22

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Comment:  What we want to do is, we want to get the roster
where everybody signed in today; and we also want minutes.
And we also want to make sure that you give us a plan of why
this area — or how this area becomes a Superfund site for
people to be relocated.

Response:  The roster of who attended this meeting and the
minutes for this meeting can be found in the RSR Superfund
Site files located at EPA Region 6 offices, 1445 Ross
Avenue, Dallas, Texas 75202-2733,   (214) 665-6427.  The need
for relocation is determined on a case by case basis for
Superfund Sites.

Sites are listed on the National Priorities List based on
contamination present at the site.  The need for relocation
is based on the remedy selected for the site.  For the RSR
residential locations  (OU No. 1),  it was determined that
relocation was not necessary to conduct the cleanup.  Since
the cleanup in the residential areas has been completed,
permanent relocation is not warranted at this time.  EPA
also does not see a need for temporary relocation during
demolition activities at the former smelter facility at this
time.

Comment:  We want to know when that smelter's coming down,
September or October.  We want to the date before it comes
up — before that date comes up.

Response:  EPA will ensure that a community open house
meeting is held to provide information on the schedule and
plans for the remediation of the former smelter facility,
prior to demolition activities.

Comment:  They dumped all up and down the back street
battery casings and stuff so the people could go in and out.
I come down here to be examined.  The tell me, You don't
have enough lead.  How much lead do you have to have to have
enough lead?

Response:  The concentration of lead that will produce an
adverse health affect varies whether you are an adult or a
child.  For children, the Center for Disease Control
recommends a level below 10 micrograms per deciliter of lead
in blood.  Adults can withstand much higher levels of lead,
and the occupation number is 40 micrograms per deciliter of
blood.
                           23

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Comment:  Whenever y'all decide on tearing the smelter down
up there, what steps will be taken to prevent any more
pollution?

Response:  EPA will require the contractor to develop
demolition and dust control plans, as well as air monitoring
and health and safety plans.  The purpose of the plans is to
have the contractor define how all of the steps of the
demolition activities will be conducted, including what
engineering controls will be implemented to minimize dust
and potential migration of contamination, prior to work
being initiated.   Examples of dust control measures that may
be utilized during the remedial action of the smelter
facility, include wetting down the surfaces with water prior
to demolition, and collecting and treating the water,  as
necessary.  Another dust control mechanism that may be used
is vacuum dusting the surfaces to remove contaminated dust.

Comment:  At the first meeting that I attended with EPA,  it
was last year; and there was a guy from the juvenile center
up here on the hill.  He came to express a concern about the
juvenile center being built on a mound of lead slag.  And it
was seeping into the juvenile and affecting the kids and
everything.  I haven't seen him at another meeting, you
know;  but that might be something the EPA needs to check
into.

Response:  EPA has not received information regarding the
construction of the juvenile center on a mound of lead slag.

Comment:  I understood the lady to say it was impossible for
the lead to get out.  But what about when the trucks go in?
What's getting on the tires when they come out?  The dust is
on the tires.

Response:  It is expected that dust will be generated during
remediation activities.  However, as stated earlier, EPA
will require of the construction contractor, prior to
conducting the remedial action, prepare a number of plans,
such as demolition and dust control plans.  The purpose of
the plans is to have the contractor define how all of the
steps of the remediation activities will be conducted,
including what engineering controls will be implemented to
minimize fugitive dust and potential migration of
contamination.  For example, these plans would typically
require that trucks, prior to  leaving the site, would be
washed down and decontaminated.
                           24

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     Comment:  Who has the power to get all of these government
     entities at the table at one time?  Year after year it's
     only the EPA.  There's too many questions that arise that
     the EPA cannot answer.  Who has the authority to bring to
     bring the City to the table, the State, HUD, ATSDR,
     everybody?

     Response:  There is probably no one individual or
     organization who can require all of the City,  State, and
     Federal agencies that could play a role in West Dallas to
     come together.  Coordination and cooperation of the
     different levels and agencies of government is the key.
     Even though EPA does not have the authority to require all
     of the City,  State,  and Federal agencies to come together,
     EPA does try to involve other agencies in this project.
     Several years ago EPA worked with other agencies to prepare
     the "yellow book" for the West Dallas community.  EPA met
     with 11 different agencies and jointly prepared the "yellow
     book" which gives responsibilities and contacts for each
     agency with regard to lead issues.  EPA also communicates
     regularly with the City and with the Texas Natural Resource
     Conservation Commission concerning meetings and other
     activities in West Dallas.

     Comment:  Who are the other responsible parties besides RSR?

     Response:  Several hundred Potentially Responsible Parties
     (PRPs)  have been identified for the site.   EPA has formally
     notified eleven parties which it believes have the more
     significant degrees of responsibility for the site that it
     considers them potentially responsible for the site.  The
     PRPs that received notice of liability for OU No.  4 of the
     RSR site can be found in the EPA letter dated June 5,  1996,
     located in the RSR site files.

     Comment:  Is there contamination in west Dallas?

     Response:  There is contamination present on OU Nos. 4 and 5
     of the RSR Site,  located in west Dallas, to be addressed by
     the final remedies selected for each OU.

2.    Other Written Comments

     Comment:  Approximately 21 separate letters where received
     which listed the individual family members and medical
     issues and all stated that  "My Family votes No" with regard
     to dismantling the lead smelter.  Most of these letters -also
                                25

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requested compensation for being exposed and contaminated
from the lead smelter.

Response:  The final remedy for the former smelter facility,
including the stack is documented in the Record of Decision
for OU No. 4 of the RSR Corporation Superfund Site, dated
February 28, 1996.  A formal public comment period was held
on the proposal to dismantle the former secondary lead
smelter  (OU No. 4) from May 10, 1995 through July 12, 1995.
EPA carefully considered all public comments it received
during the comment period, in addition to other criteria it
is required to consider by the National Contingency Plan, in
selecting the remedy for the former smelter facility.  EPA
has no plans to reopen that decision.

The Superfund statute does not allow EPA to provide
compensation to individuals for personal injury or health
problems.

Comment:  Other separate written comments received included:
     a request to put the demolition of the smelter on hold,
     and first consider the health of the community;
     several additional medical concerns and requests for
     compensation in lieu of cleaning up the former smelter
     facility.

Response:  EPA does not have the authority to compensate
individuals for past exposure,  nor does it have the option
to give money to the community.
                           26

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   ADULT LEAD CLEANUP MODEL
RSR CORPORATION SUPERFUND SITE
      OPERABLE UNIT No.  5
          APPENDIX B

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                    DRAFT
                Draft Region 6 Superfund Guidance

                     Adult Lead Cleanup  Level

Basic Equations:

                (PbBG-target - PbBo)
Cs =	
     BKSF x (IRs x EFs x AFs + Ksd x IRd x EFd x AFd)


PbBcytarget = PbB95thmaternal/GSDi1-645


PbB95thmaternal = PbB95thfetal/R


Input Parameters to the Model:

1.   95th Percentile PbB in fetus (PbB95thfetal)

     The EPA and CDC recommend that no more than 5% likelihood that
     a child would exceed 10 /zg/dL.   For an industrial/commercial
     setting,  the  exposed population could include pregnant women.
     The recommended PbB95thfetal is 10 /zg/dL.

2.   Mean ratio of fetal to maternal PbB (R)

     The relationship  between  fetal and  maternal  blood  lead  is
     estimated to be 0.9 (Goyer 1990).   The recommended "R value"
     is 0.9.

3.   Individual geometric standard deviation (GSDi)

     A "typical" GSDi is 1.8.

4.   Baseline blood lead value (PbBo)

     The demographic composition  of  the  site should be considered.
     The geometric mean PbB values reported for women aged 20-49
     years for African Americans was 2.2 ng/dL,  for Hispanics was
     2.0 M9/dL, and for whites was 1.7 ptg/dL.

5.   Biokinetic slope factor (BKSF)

     The recommended BKSF is 0.4 M9/dL per M9/day.

6.   Soil ingestion rate  (IRs)

     The recommended IRs is  0.025 g/day.   This assumes that one-
     half the "default"  soil/dust ingestion rate of 0.05 g/day is
     from soil.

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                     DRAFT
7.   Dust ingestion rate (IRd)

     The recommended IRd is 0.025 g/day.  This assumes that one-
     half the "default" soil/dust ingestion rate of 0.05 g/day is
     from dust.

8.   Ratio of concentration in  dust  to  that in soil (Ksd)

     The Ksd can range from 0.2 to 1.0 with a "typical" value of
     0.7.

9.   Soil exposure frequency (EFs)

     The "default"  exposure frequency for an industrial setting is
     250 days/year.  This exposure frequency is based upon 5 work
     days per week for 50 weeks/year.   The recommended EFs is 250
     days/year.

10.   Dust exposure frequency (EFd)

     The "default"  exposure frequency for an industrial setting is
     250 days/year.  This exposure frequency is based upon 5 work
     days per week for 50 weeks/year.   The recommended EFd is 250
     days/year.

11.   Absolute absorption fraction of  lead in soil (AFs)

     The absorption fractions for adults range from 0.06 to 0.2.
     The recommended AFs for most sites  is 0.1.  The  source of lead
     contamination should be considered  in selecting  the AFs value.

12.   Absolute absorption fraction of  lead in dust (AFd)

     The absorption fractions for adults range from 0.06 to 0.2.
     The recommended AFs for most sites  is 0.1.  The  source of lead
     contamination should be considered  in selecting  the AFs value.

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DRAFT
Model Parameter
95th Percentile PbB in fetus (Mg/dL)
R (Mean ratio of fetal to materal
PbB)
Individual geometric standard
deviation (GSDi)
Baseline blood lead value (PbBo)
(/ig/dL)
Biokinetic slope factor (BKSF)
(/zg/dL per Mg/day)
Soil ingestion rate (IRs) (mg/day)
Dust ingestion rate (IRd) (mg/day)
Ratio of concentration in dust to
that in soil (Ksd)
Soil ingestion frequency (EFs)
(days/year)
Dust ingestion frequency (EFd)
(days/year)
Absolute absortion fraction of lead
in soil (AFs)
Absolute absortion fraction of lead
in dust (AFd)
Resulting soil concentration (mg/kg)
Plausible
Range
5-15
0.8 - 1.0
1.6 - 2.0
1.6 - 2.2
0.3 - 0.5
10 - 25
10 - 25
0.2 - 1.0
100 - 350
100 - 350
0.06 - 0.2
0.06 - 0.2

"Typical"
Value
10
0.9
1.8
1.9
0.4
25
25
0.7
250
250
0.1
0.1
2,000

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         Results - Screening  Level  for Lead Program vl.OO
95th Percentile PbB in fetus  (PbB95  fetal)  (ug/dL)
Mean ratio of fetal to maternal  PbB  (R)
Individual geometric standard deviation  (GSDi)
Baseline blood lead value (PbBO)  (ug/dL)
Biokinetic slope factor (BKSF)  (ug/dL per ug/day)
Soil ingestion rate (IRs)  (g/day)
Dust ingestion rate (IRd)  (g/day)
Ratio of concentration in dust to that in soil (Ksd)
Soil Exposure frequency (EFs)  (days/yr)
Dust Exposure frequency (EFd)  (days/yr)
Absolute absorption fraction  of  lead in soil (AFs)
Absolute absorption fraction  of  lead in dust (AFd)
10
0.9
1.8
1.9
0.4
0.025
0.025
0.7
250
250
0.1
0.1
  Screening Level for Lead  (PRG)  (ug/g):  1997
                        DRAFT

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                   Screening Level for Lead Program vl.OO
 1.0 Starting the Program
       To start the "Screening Level for Lead Program" (PRO), enter PRG  at the DOS prompt
 of the subdirectory containing the executable file (PRG.EXE).

 2.0  Data Entry
       Figure  1 illustrates an example Data Entry Screen for PRG.





Screening Level for Lead Program vl.
J-- „•-,,. ;, - , 	 , • ,; ., ..- l"| • P > '* f ifl'lf, | Jl, J :i* ' 1 1' ' ' 	 "" ' '' ' T
. 95th Percent lie PbB 'in' fetus (PbB95 fetal) (ug/dL)
Mean ratio of fetal to maternal PbB (R)
, Individual geonetric standard deviation (GSDi)
" Baseline blood lead value (PbB6) (ug/dL)
Biokinetic slope factor (BKSF) (ug/dL per ug/day)
,Soil ingest ion rate (IBs) (g/day)
Dust ingest ion rate (IRd) (g/day)
'•• Ratio of concentration in dust to that in soil (Ksd)
, Soil Exposure frequency (EFs) (days/yr)
Dust Exposure frequency (EFd) (days/yr)
Absolute absorption fraction of lead in soil (AFs)
Absolute absorption fraction of lead in dust (AFd)

| INSTRUCT lOMS |
(1) Enter all values above.
(2) To Calculate Screening Level for Lead: Press
(3) To Exit: Press Esc key.

66
IJ9.61 t'/^Av
:;8.ei )'l'!l\'-'''i!'ij!;^'!!'i
J6.2 ''^^Uf'f,''
fzso H'vB'vcO'
i;JZ56 i^yf'^!'^'!'"1 i'
J:8.66 ,'[',1''|!3'Jj''fir
-'a 01. .'i.Vif'S^i
: , -, *!''" "N'l1'
, i:. ' ' ,'

PgDn or F5 key.






                          Figure 1. Example Data Entry Screen

When started initially, all data entry fields are zero. Some fields (such as GSDit BKSF, and R) can
not be left as zero because division by zero is prohibited. Also, this program does not allow entry of
negative numbers in any field.  After all values are entered, press either the  PgDn key or the  F5 key
to calculate the Screening Level for Lead (in ug/g).

3.0 Results
       Figure 2 illustrates an example Results Screen.

-------
                  Results  - Screening Level for Lead Progran ul.OO
         95th Percentile PbB  in fetus (PbB95 fetal)  (ug/dL)
         (lean ratio of fetal  to Maternal PbB (R)
         Individual geometric standard deviation  (GSDi)
         Baseline blood lead  value (PbBO) (ug/dL)
         Biokinetic slope factor (BKSF) (ug/dL per ug/day)
         Soil  ingest ion rate  (IRs) (g/day)
         Dust  ingest ion rate  (IRd) (g/day)
         Ratio of concentration in dust to that in soil  (Xsd)
         Soil  Exposure frequency (EFs) (days/yr)
         Dust  Exposure frequency (EFd) (daysxyr)
         Absolute absorption fraction of lead  in  soil (AFs)
         Absolute absorption fraction of lead  in  dust (AFd)
          Screening Level for Lead (PRG)  (ug/g):  13898
                                     10
                                     0.9
                                     1.7
                                     1.9
                                     0.1
                                     6.01
                                     9.01
                                     0.2
                                     250
                                     250
                                     6.06
                                     9.06
        Select
Esc: Return  to Data Entry
Ft: Save
F7: Print
                              Figure 2.  Example Results Screen

The Results Screen can be printed or saved to a file. All data entry values are retained when returning
to the Data Entry Screen.


4.0 Equation Used for Calculation
       The following equation is used to calculate The Screening Level for Lead:

                          Screening Level for Lead (PRG) (ug/g)  =

                           (PbB9S fetal / (R • (GSD;)'645)) - PbBO	
                BKSF • ((LRS • AFS • EFS / 365) +  (K,, • IRd • AFd • EFd / 365))

-------
         Results - Screening Level  for  Lead  Program vl.OO
 :5th Percentile PbB  in  fetus  (PbB95  fetal)  (ug/dL)
 ean ratio of fetal  to  maternal PbB  (R)
Individual geometric standard deviation  (GSDi)
Baseline blood lead  value  (PbBO)  (ug/dL)
Biokinetic slope factor (BKSF)  (ug/dL per ug/day)
Soil ingestion rate  (IRs)  (g/day)
Dust ingestion rate  (IRd)  (g/day)
Ratio of concentration  in dust to that in soil  (Ksd)
Soil Exposure frequency (EFs) (days/yr)
Dust Exposure frequency (EFd) (days/yr)
Absolute absorption  fraction of lead in soil  (AFs)
Absolute absorption  fraction of lead in dust  (AFd)
  Screening Level for Lead (PRG)  (ug/g):  1362
10
0.9
1.9
2
0.4
0.05
0
0
250
0
0.1
0

-------
        TECHNICAL MEMO
RSR CORPORATION SUPERFUND SITE
     OPERABLE UNIT No.  5
          APPENDIX C

-------
MEMORANDUM	CKMHILL


RSR OU NO.  5, Cost Estimate for Revised

Alternatives

T0:            Ann Schober/EPA Region 6

COPIES:         jan Walstrom/CH2M HILL/ DFW

              Ted Telisak/CH2M HILL/DFW

              Amy Lange/CH2M HILL/DEN

              Muhammad Khan/CH2M HILL/DEN

FROM:          CH2M HILL

DATE:          October 30,1996

As requested in the telephone conversation with you on September 16 and October 29,
1996, CH2M HILL has prepared this Technical Memorandum (TM) summarizing revised
alternatives for the RSR Corporation OU No. 5 Feasibility Study. The purpose of this TM is
to evaluate alternatives that would provide an asphalt or concrete surface over the former
landfill in OU No. 5.  We have prepared cost estimates so comparisons can be made for
placing an asphalt pavement or a reinforced concrete pavement to the cost of placing a
RCRA cover over the former landfill. Alternative 3 of the RSR OU No. 5 Feasibility Study
dated February 22,1996 was used for the comparison.  Cost estimates for Alternative 3 and
4 from RSR OU No. 5 Feasibility Study have also been revised  to assume offsite disposal of
OU No. 5 debris material rather than onsite disposal within the landfill.

Four variations of Alternative 3 were evaluated and are designated as Alternatives 3A
through 3D.  A brief description of the alternative variations is provided in Table 1.  Only
the elements pertaining to the former landfill cap were varied, all other components of the
alternatives are the same as presented in the February 22,1996 FS Report with the exception
that OU No. 5 debris marreial is disposed at an offsite landfill. The net present worth for
each of the alternatives is also provided in Table 1. Figure 1 depicts the final subgrade that
was used in generating the cost estimate for all alternatives. The total fill material required
based on the subgrade shown in Figure 1 is approximately 35,200 cubic yards.

The following assumptions were made in deriving these cost estimates:

       •  Heavy truck traffic (HS20) will be prevalent at the site requiring a heavy
          pavement section for Alternatives 3A and 3B. Traffic in Alternatives 3C and 3D
          will be predominantly passenger cars.

       •  All Alternatives assume that no debris material from OU No. 4 and OU No. 5  is
          placed within  the OU No. 5 landfill. Instead the debris material from OU No. 5
          is disposed in an offsite landfill.
RCRMEM.DOC                                  1                                    111433.

-------
                                                      RSR OU NO. 5. COST ESTIMATE FOR REVISED ALTERNATIVE
       •  All alternatives have assumed that slopes of up to 5% are acceptable in the
          parking areas. In several areas, grades up to 15% are present to minimize
          excavation and still allow placement of asphalt. These areas are not suitable for
          parking because of the steeper slopes (See Figure 1).

       •  No utilities such as electrical, water, or sewer hookup are included.

       •  Performance of the pavement will be similar to ones for highways and will not
          require unusual maintenance. For the alternatives using asphalt, 2 inches of
          overlay are required every 10 years.  The amount of potential settlement in the
          former landfill is unknown. We have assumed that the potential for settlement
          is low and will not damage the pavement. The asphalt surface is more flexible
          than the concrete pavement and can be repaired easily if extensive settlement
          occurs. The reinforced concrete can withstand localized settlement better than
          asphalt but repairing damaged areas of extensive settlement is more costly.

       •  The existing drainage system is adequate to handle the additional surface water
          runoff from  the paved areas.

       •  One half foot of top soil is removed and disposed offsite so consolidation issues
          are minimized.

Attachment 1 provides  the specific cost estimates for each of the alternatives presented
including the capital costs, annual operations and maintenance, and present worth.
Revised costs for Alternatives 3 and 4 assuming offsite disposal of the OU No. 5 debris are
also included.
RCRMEM.DOC

-------
                                                      RSR OU NO. 5. COST ESTIMATE FOR REVISED ALTERNATIVE
                                       Table 1

                      Summary of Alternatives for RSR OU No. 5
  Alternative
 Description of Alternative pertaining to Former Landfill at
                        OU No. 5
 Cost (Present
    Worth)
Alternative 3
Alternative presented in FS Report dated February 22,1996.
Alternative consists of capping former OU No. landfill with
clay cap.
$ 9,024,250
Alternative 3
(revised)
Alternative presented in FS Report dated February 22,1996
but revised assuming offsite disposal of OU No. 5 debris
rather than onsite disposal at the OU No. 5 landfill.
$9,343,800
Alternative 3A
Former OU No. 5 landfill is covered with asphalt capable of
handling heavy truck traffic. Assumes offsite disposal of OU
No. 5 debris material. The asphalt pavement includes a 10-
inch base course and 8 inches of asphalt.
$10,783,920
Alternative 3B
Former OU No. 5 landfill is covered with concrete capable of
handling heavy truck traffic. Assumes offsite disposal of OU
No. 5 debris material. The pavement is 10-inch reinforced
concrete.
$11,167,580
Alternative 3C
Former OU No. 5 landfill is covered with asphalt capable of
handling passenger cars only. Assumes offsite disposal of
OU No. 5 debris material. The asphalt pavement includes 6-
inch base course and 3 inches of pavement.
$9,197,190
Alternative 3D
Former OU No. 5 landfill is covered with concrete capable of
handling passenger cars only. Assumes offsite disposal of
OU No. 5 debris material. The pavement is 6-inch reinforced
concrete.
$ 10,362,430
Alternative 4
(Revised)
Alternative presented in FS Report dated February 22,1996
but revised assuming offsite disposal of OU No. 5 debris
rather than onsite disposal at the OU No. 5 landfill.
$ 22,564,906
RCSMEM DOC

-------
3 18 97

CAPITAL COSTS:
GENERAL REQUIREMENTS:
General Sltework:
Institutional Controls
F ••
$6.000
$2 000

$3.200





M*




$245.562- Based on AocuVal HBOOI852 9252
$33.480 'ECHOS 33-17-0812 Pg 374

$2.880 ECMOS33-17^ai2Pg 374

$114000
$10000
$7 000
$20000

$1400
$6 000











$1004.400 Based on AccuVal KBOOI8S2-9252
$245.973 '
$1 447

$1706450 inciudM putnu* or io> uxMon) ft r
$52 886 95 MEANS 029-304-0010

$15.000 95 MEANS 02 1-104-01 50
$276650
$558989
$279444
$139.722
$279444



•on)








$139.722 uoaMt OU*V*M of so* uyvaofg A ruarq
$18000 95 MEANS 029- 304-0010

$20 000
$50.000 IXIuM! eutrUM 0> KM WXMxq 1 »
$50000
$1550
$6030.667
SI 809 200
$7 839 867
$388 097 Based on cost of an on-site *ci>v
$543336 Based on cost of an on-sne aciiv
$8.771 299



«>••«





im
tei

$465716 Based on cost of an on-jne aa-.vi.es
MJ17.01*

$1 200
$600
$4800
S1 200
$7800
$1 560
*»MO










-------
3 18 97
Long Term Monitoring {2 wells annually)
Pavement inspection and repair
Inspection of tne cap (both landfill and surface impoundment)
SUBTOTAL
CONTINGENCY
TOTAL • Annual O A M Cotts - AKwnatlv* 3 (25 YEARS)
2 EA
1 ANNUAL
4 QUARTERLY
20%
$1 60000
560000
530000
$5.000
S3 200
$600
11 200
55000
$1 000
u.ooo

-------
3.18-97
NET PRESENT VALUE
YEARO
YEAR 1
YEAR 2
YEAR 3
YEAR 4
YEARS
YEAR 6
YEAR 7
YEARS
YEAR 9
YEAR 10
YEAR 11
YEAR 12
YEAR 13
YEAR 14
YEAR 15
YEAR 16
YEAR 17
YEAR is
YEAR 19
YEAR 20
YEAR 21
YEAR 22
YEAR 23
YEAR 24
YEAR 25
YEAR 26
YEAR 27
YEAR2B
YEAR 29
YEAR 30
NET PRESENT VALUE {»«%)- AltMTwOm 1

$9237016
$9.360
$9360
$9360
$9.360
$9360
$6 000
$6.000
$6.000 '
$6 000
$6.000
$6.000
$6000
$6 000
$6 000
$6000
$6.000
$6.000
$6.000
$6 000
$6000
$6.000
$6.000
. $6000
$6.000
$6000
.$6.000
$6000
$6.000
$6.000
$6.000 . I
St.Ml.7M I

-------
         13 97
flSft CORPORA TIOM SUPfRFUND SITE . REMEDU TJOH OfOUS
(Accuracy Range -SOS'-SO'*!
DESCRIPTION QUANTITY


CAPITAL COSTS:
GENERAL REQUIREMENTS:
General Sltework:
institutional Controls.
Fix Existing Penmeter Fence
Groundwater Well installation
Survey Well Location
Steam Clean Battery Wracking Facility (55400 SF):
Structural Inspection
Structural Modifications (50% of Building. Heavy Duty)
Steam Clean Building 2 Times, level C
Steam Clean Vehicle Maintenance Building (4.100 SF):
Steam Clean Building 2 Times. Level C
Pump Water to Frac Tank. Test I Discharge :
Frac Tanks
Pumping
Sampling
Analysis
Demolish Battery Wrecking Facility * Transport Debris to Offalte Landfill
Samples tor Battery Wrecking Facility
TCIP Analysis
Demo Battery Wrecking Facility
Transport and Disposal of Debns at Waste Facility & Tipping
Gate Fee lor Truck at Waste Facility
Cap Metals Contaminated Soil*
Cap Area with f Thick Clean Matenal
Revegetate
Cap landfill:
Top Soil Removal & Disposal (0 5')
Eicavation
Fill Matenal
Surface Preparation/ Final Grading
Base Course 110")
Asphalt PavementiB'i
Surface Drainage System
Recap Surface Impoundment:
Evaluate Enisling Cap
Recap Area wrtn 2" Thick Clay
? Thick Top Soil
Revegetate
SUBTOTAL
CONTINGENCY
SUBTOTAL - CONSTRUCTION COST
PERMITTING 4 LEGAL
SERVICES DURING CONSTRUCTION
SUBTOTAL • IMPLEMENTATION COST
ENGINEERING *. DESIGN COST
TOTAL • Capital COM • Altemattv* 3


10%


9100
2
1

32
27900
55 BOO

4800

100
1
100
100

20
20
55800
2067
103

113763
35

9.841
4548
35.189
122
16402
25981
i

t
3333
3333
I
30S

5%
7°4

5%

UNIT





LF
EA
LS

HRS
SF
SF

SF

EA
LS
EA
EA

EA
EA
SF
CY
Truck uoaos

CY
ACRE

CY
CY
CY
ACRE
CY
TON
LS

LS
CY
CY
ACRE







SAJNTT


$6 177 330


$1500
$3000
$2000

$10000
$880
$060

$060

$1 14000
$1000000
$7000
$20000

$7000
$30000
$1800
$11900
$1400

$1500
$1 50000

$1500
$500
$1500
$1 25000
$1500
$3000
$'0000000

$2000000
$1500
$1500
$• 500 DO
$6 '77 330

$7469 DIS
$'469315

$' 469 Di5

TOTAL REFERENCE
COST

$617733


$136.600 Mtu*o"4
$15250 95 MEANS 02 1-104-0150
$246 033
$779434
$100000

$20000
$50000 i««rft> ixxcn... * KM ID'.M--; l :'.:•)
$50000
$1 550
$6177330
$1 853 199
$8 030 529
$373 451 Based on cost of a" on-site ic. « ' ft
$522831 Based on cosi of an on-s.te aciiv t «»
$8 926 8 1 1
$448 '41 Bascoonoosi 0'aiion-s.ie K: . • «\
$».174.M1
ANNUAL O I H COSTS
 inspection of the Surface impoundment Cap
                                                                                         $JOOX>
                                                                                                         Si 200
        "SBQUSX

-------
3 '3 37
Pavement inspection ana Repair
Short Term Grounowater Monitoring (assumed for five years)
Snort-Term Surface water Monitoring (assumed for five years)
SUBTOTAL
CONTINGENCY
TOTAL - Annual 0 1 M Co*t» - AIMmativ* J (5 YEARS)
Long Term Monitoring (2 wells annually)
Pavement Inspeaion and repair
inspection of me cap ibotn landfill and surface impoundment)
SUBTOTAL
CONTINGENCY
TOTAL - Annual O 4 M CoM« - AHcnuttv* 1 (25 YEARS)
8 IMILE/VEAR
3 EA
2 EA
20%

2 EA
6 LMIL&YEAR
4 QUARTERLY
20%
SI 50000
$160000
S60000
$19781

SI 60000
SI 50000
$30000
$16981
$12581
$4300
SI 200
$19761
$3956
J2J.7M
$3200
$12581
$t 200
$16981
$3.396
$20,171

-------
3 1997
Ajprvjlt Overlay (every
SUBTOTAL
CONTINGENCY
TOTAL-OAMCo**-
HET PRESENT VALUE































10 years) 2'


Arttmitlv* J (mry 10 YEARS)

YEAR 0
YEAR i
YEAR 2
YEAR 3
YEAR 4
YEARS
YEAR 6
YEAR 7
YEARS
YEARS
YEAR 10
YEAR 11
YEAR 12
YEAR 13
YEAR 14
YEAR 15
YEAR 16
YEAR 17
YEAR 18
YEAR 19
YEAR 20
YEAR 21
YEAR 22
YEAR 23
YEAR 24
YEAR 25
YEAR 26
YEAR 27
YEAR 28
YEAR 29
YEAR 30
NET PRESENT VALUE (M%) - AltMiuttw 1
25981 TON $35 00 S909339
1909339
20% S909 339 1181 868
fl.091.207

$9 374 951
J23738
S23738
$23 738
J23738
$23.738
$20.378
$20378
$20 378
$20 378
$1.111 MS
$20.378
$20378
$20.378
$20378
$20378
$20378
$20378
$20 378
$20 378
$1111.585
$20 378
$20 378
$20378
$20378
$20 378
$20378
$20 378
$20 378
$20 378
$20 378
$10,781,922

-------
31337
CH2M HILL





RSK CORPORATION SUPEflFVND SITE • REMECHA TION OfOUS
(Accuracy Range -SO0* • -301*1
DESCRIPTION QUANTITY
A^HV™ ^^,^ 	 r— — .
CAPITAL COSTS:
GENERAL REQUIREMENTS: ' .
General Sltawork:
Institutional Controls
Fn Existing Penmeter Fence
Groundwater Well Installation
Survey Well Location
Steam Clean Battery Wracking Facility (5S.800 SF):
Structural Inspection
Structural Modifications (SO** of Building. Heavy Duty)
Steam Clean Building 2 Times Level C
Steam Clean Vehicle Maintenance BulMIng (4.800 SF):
Steam Clean Building 2 Times Level C
Pump Water to Frac Tank. Test & Discharge :
Frac Tanks
Pumping
Sampling
Analysis
Demolish Battery Wrecking Facility 4 Transport Debris to Offslte Landfill
Samples for Battery Wrecking Facility
TCLP Analysis
Demo Battery Wrecking Facility
Transport and Disposal of Oebns at Waste Facility ft Tipping
Gate Fee for Truck at Waste Facility
Cap Metals Contaminated Soils :
Cap Area wrtn ? Thick Clean Material
Revegetate
Cap Landfill wttfi Concrete Pavement:
Top Soil Removal ft Disposal (0 51
Excavation
Fill Matenai
Surface Preparation/ Final Grading
Reinforced Concrete Pavement 1 10")
Surface Drainage System
Recap Surface Impoundment:
Evaluate Ensting Cap
Recap Area wrtn 2' Thick Clay
? Thick Top Soil
Revegetate
SUBTOTAL
CONTINGENCY
SUBTOTAL • CONSTRUCTION COST
PERMITTING ft LEGAL
SERVICES DURING CONSTRUCTION
SUBTOTAL - IMPLEMENTATION COST
ENGINEERING ft DESIGN COST
TOTAL • Capital Cost - Alternative J
ANNUAL O AM COSTS
•nspecttoo of the cap ootn ;andMI and surface o>) tpr*«i)"e<


-------
3 13 37
Pavement inspection and repair
Short Term Groundwater Monitoring i assumed tor five years)
Snort- Term Surface water Monitoring (assumed (or five years)
SUBTOTAL
CONTINGENCY
TOTAL - Annual O ft M Cora - Altwnathn 1 (S YEARS)
Long Term Monitoring |2 wells annually)
Pavement inspection and repair
Inspection of the surface impoundment cap
SUBTOTAL
CONTINGENCY
TOTAL • Annual O ft M Cora • ANMnaOv* J (25 YEARS)
1 ANNUAL
3 EA
2 EA

20% .

-2 EA
8 LMILE/YEAR
4 QUARTERLY
20°*
$60000
51 50000
J 600 00

J7800

SI 60090
S30000
J3OOOO
$6916
1600
S4600
SI 200
57 800
SI 560
SI.MO
S3 200
S25I6
51 200
56916
SI. 383
M.JOO

-------
J  i  3  '9 7
NET PRESEHT VALUE
YEARO
YEAR t
YEAR 2
YEAR 3
YEAR 4
YEARS
YEAR 6
YEAR 7
YEARB
YEAR 9
YEAR 10
YEAR 11
YEAR 12
YEAR 13
YEAR 14
YEAR 15
YEAR 16
YEAR 17
YEAR 18
YEAR 19
YEAR 20
YEAR 21
YEAR 22
YEAR 23
YEAR 24
YEAR 25
YEAR 26
YEAR 27
YEAR 28
YEAR 29
YEAR 30
NET PRESENT VALUE (M*| • AIMnwOvt J

ill. 035 401
$9360
19360
J9360
$9360
S9360
18 300
$8300
18300
M 300
$8.300
$8.300
$8300
S8.300
S8.300
S8300
$8300
$8300
$8.300
$8300
$8.300
$8300
$8300
$8300
$8300
$8300
$8300
$8300
$8300
$8300
$8300
$11.1«7,57»

-------
9?
KSP CORPORA HOW SUPERFVHD SITE - REMEDM TJON Of Out
(Accuracy Range -50% -30%i
DESCRIPTION QUANTITY
ALTfKMt m/E )C. S«m« M-4mnuB»* « «rc«(X 
5>4
6 -

j
UNIT



UF
EA
LS
MRS
SF
SF
SF
EA
LS
EA
E*
EA
EA
SF
CY
True* Load

CV
ACRE
CY
CY
CY
ACRE
CY
TON
uS
LS
CY
CY
ACHE




1 --3"E3L •
S/UNIT


$5 526 709
$1500
13000
$2000
110000
(880
$060
$060
$1 14000
$1000000
$7000
$20000
$7000
$30000
$1600
$11900
$1400

$1500
$1 50000
$1500
$500
$1500
$1 25000
$1500
$3000
$'0030000
$2000000
$1500
$1500
$• 50000
$5 526 7Q9
$7 '06809
$' 'D6809
S--06509

S3CC 00
TOTAL REFERENCE
COST


$552671
$136500 *stum« IOCS of willing 'e«c« "«Mi •«>•«
$6000
$2000
$3.200
$245.562 Based on AccuVal 11800(852-9252
$33.480 ECMOS33-17-0812Pg 374
$2880 ECHOS33-i7-0812Pg 374
$114000
$10000
$7000
$20000
$1.400
$6.000
$1 004.400 Based on Accuval H800I852-92S2
$245.933
$1 447

$1 706 4 SO l«CJUd«» 0UICMM 0* tori uy«M*g A *»0~9
$52886 95 MEANS 029-304-00 10
$147620
$22.738
$527835 i'«auoti owtnaM o* to* tprMdfg i y«o"fl
$15250 95 MEANS 021-104-0150
$147.620
$292 288
$100000
$20000
$50000 'nCluCKt D^Cnil* 91 W« 1O»4>*"? 1 ?«J'"
$50000
$1 550
$5526709
$1 658013
$7184722
$355340 Based an cost of an on-site jovii e»
$497 477 Based an cost of an oo-s
-------
3 '9 9?
Pavement inspection ana repair
Snort Term Grounowater Monitoring (assumed for five yean)
Snort- Term Surface water Monitoring (assumed for five years)
SUBTOTAL
CONTINGENCY
TOTAL - Annual O 4 M Cora • Altenutn* J (» YEARS)
Long Term Monitoring (2 wells annually)
Pavement Inspection ana repair
Inspection of me cap (Dotn landfill and surface impoundment!
SUBTOTAL
CONTINGENCY
TOTAL • Annual O 4 M Co»B - AIMmatnm 3 1 JS YEARS)
a
3
2

20%

2
8
4

20'*

LMILE.VEAR
EA
EA



EA
LMILE/YEAR
QUARTERLY



Jl 50000
1160000
$60000

$19 781

$1 60000
J1 500 00
J30000

S16981

112581
S4BOO
11 200
$19 781
$3956
S23.7U
13200
$12581
$1 200
$16961
$3396
S20.37S

-------
3 18 97
Asphalt Overlay {every 10 yearn 2'
SUBTOTAL
CONTINGENCY
TOTAL - O ft K Coca - ANwnMtv* J (Mfy 10 YEARS)
NET PRESENT VALUE:
YEARO
YEAR 1
YEAR 2
YEAR 3
YEAR 4
YEARS
YEARS
YEAR 7
YEARS
YEARS
YEAR 10
YEAR 11
YEAR 12
YEAR 13
YEAR 14
YEAR 15
YEAR 16
YEAR 17
YEAR 18
YEAR 19
YEAR 20
YEAR 21
YEAR 22
YEAR 23
YEAR 24
YEAR 25
YEAR 26
YEAR 27
YEAR 28
YEAR 29
YEAR 30.
NET PRESENT VALUE (M%) - AMmaVv* J
9743 . TON 535 00 $341002
$341 002
20% $341 002 $68 200
MMjoa

$8463.948
$23.738
$23.738
$23.738
$23.738
$23.738
$20.378
$20.378
• $20.378
$20378
$429.580
$20.378
$20.378
$20378
$20.378
$20 378
$20378
$20.378
$20378
$20378
$429580
$20378
$20 378
$20.378
$20.378
$20.378
$20.378
$20.378
$20.378
$20 378
$20.378
S»,1*7,1M

-------
3 13 97
HSR CORPORA TIOM SUPERFUND SITE • REMEDIA TIOHOFOUt
.Accuracy Range «50% .' -30%i
DESCRIPTION
CAPITAL COSTS.
GENERAL REQUIREMENTS:
General Sltework:
institutional Controls
Fix Existing Penmeter Fence
Grounowater Well Installation
Survey Well Location
Steam Clean Battery Wracking Facility (55.800 SF):
Structural inspection
Structural Modifications (50% of Building Heavy Duty)
Steam Clean Building 2 Times. Level C
Steam Clean Venlcle Maintenance Building (4.800 SF):
Steam Clean Building 2 Times Level C
Pump Water to Frac Tank. Teat ft Discharge :
Frac Tanks
Sampling
Analysis
QUANTITY

10%
9.100
2
1
32
27900
55800
4800
100
1
100
100
Omolrtn Battery Wrecking Facility ft Transport Debris to Offslte Landfill
Samples for emery Wrecking Facility 20
TCLP Analysis 20
Demo Battery Wrecking Facility 55 800
Transport and Disposal of Debns at Waste Facility 4 Tipping .2 067
Gate Fee for Truck at Waste Facility . 103
Cap Metals Contaminated Soil* :
. Cap Area witfi z Thick Clean Maienai
Revegetate
Cap Landfill wttp Concrete Pavement
Top Soil Removal & Disposal (0 SI
Excavation •
Fill Material
Surface Preparation/ Final Grading
Reinforced Concrete Pavement (6"1
Surface Drainage System
Recap Surface Impoundment:
Evaluate Existing Cap
Recap Area vntn 2 Thick Clay
2' Thick Top Soil
Revegetate
SUBTOTAL
CONTINGENCY
SUBTOTAL - CONSTRUCTION COST
PERMITTING ft LEGAL
SERVICES DURING CONSTRUCTION
SUBTOTAL - IMPLEMENTATION COST
ENGINEERING ft DESIGN COST
TOTAL - Capital Coat • Alternative I
ANNUAL 0 ». U COSTS
inspection of me cap ibotn landfill and surface impoundment)
Pavement Inspection and repair
Snort Term Groundwater Monitoring i assumed 'or five years*

113 763
35
4548
35 189
122
59048
1
1
3333
3333
1
30%
5".
6".

4
3
UNIT


LF
EA
LS
MRS
SF
SF
SF
EA
LS
EA
EA
EA
EA
SF
CY
Truck Load

. CY
ACRE
CY
CY
CY
ACRE
SY
LS
LS
~ V
-C«E




-.(.-=• = = .•
- .>.-...
I/UNIT

$6678 145
$1500
$3.000
$2000
$10000
$880
$060
$060
$1.14000
$1000000
$7000
$20000
$7000
$30000
$1800
$11900
$1400

$1500
$1 50000
$1500
$500
$1500
$1 25000
$2500
$'0000000
$2000000
$1500
$1500
$! 50000
$6678 14$
$8603576
$8 603 576
58603676

53cc :o
$60030
5 1 60C 3C
TOTAL REFERENCE
COST

$667815
$136500 «llu"X>»  '«*•
$6.000
$2000
$3200
$245.562 Based on AccuVal K800I8S2-9252
$33.480 ECHOS 33-17-0812 Pg 374
$2880 ECHOS 33- 17-081 2 Pg 374
$114000
$10000
- $7.000
$20.000
JI400
$6000
$1 004 400 Based on AccuVal H800I852-9252
$245933
$1 447

$1 706.450 'nclud** Owtntt* o> tw to'ttd"? & ytc-"^
$52886 9S MEANS 029-304-0010
$147620
$22 738
$527.835 incJudvs eure/WM Of UW WVMfcAq 4 J'WJ-N)
$15250 95 MEANS 021 -104-0 150
$1 476200
$100.000
$20 000
550000 AowO«t o*'Cr»»« gl 10« IprtM.**; I ;••.;-)
$50000
$1 550
$6678 145
$2003444
$8681 589
$430184 Based on cost of an o"-s.
-------
3 '? 9?
Snort- Term Surface water Monitonng (assumed tor five years)
SUBTOTAL
CONTINGENCY
TOTAL - Annual O ft M Cora - AttMiuttw 3 (5 YEARS)
Long Term Monitoring (2 «eiis annually)
Pavement inspection and repair
inspection of the surface impoundment cap
SUBTOTAL
CONTINGENCY
TOTAL • Annual O » M Coma • Attamattv* 3 (25 YEARS)
2

20%

2
3
t

20%

EA



EA
IMU.E/VEAR
QUARTERLY



S 500 00

S7800

$1 600 00
S30000
$30000

S6916

SI 200
J7800
SI 560
tB.MO
S3 200
S2.S16
S1 200
$6916
S1 383
$8,300
 SSBOUSX

-------
NET PRESENT VALUE:
                         YEARO
                         YEAR i
                         YEAR 2
                         YEAR 3
                         YEAR 4
                         YEARS
                         YEAR 6
                         YEAR 7
                         YEARS
                         YEARS
                        YEAR 10
                        YEAR 1!
                        YEAR 12
                        YEAR 13
                        YEAR 14
                        YEAR 15
                        YEAR 16
                        YEAR 17
                        YEAR 18
                        YEAR 19
                        YEAR 20
                        YEAR 21
                        YEAR 22
                        YEAR 23
                        YEAR 24
                        YEAR 25
                        YEAH 26
                        YEAR 27
                        YEAR 28
                        YEAR 29
                        YEAR 30
NET PRESENT VALUE (t»»%) • Alt»m«ttv« 3
J10230251
    $9360
    $9360
    $9360
    19 360
    $9.360
    $8300
    $8300
    S8300
    (3300
    $8300
    M 300
    $8300
    $8300
    S8300
    $58300
    18 300
    S8300
    M 300
    18 300
    S8300
    SB.300
    S8.300
    M300
    18 300
    S8300
    S8300
    $8300
    $8300
    $8.300
    S8300

-------
*t.n*M*nvt 4 imm*:*iicaiiii>ftu,En*»*oii*a
OdvOMItfCMMr mmu Cam»mimM SM tocmang Try* C*~*v Com
CAPITAL COSTS.
GENERAL REQUIREMENTS:
General Sltaworv
institutional Controls
F.I Existing Perimeter Fence
Groundwater Well Installation
Survey Well Location
Steam Clean Battery Wrecking Facility (JS.80C SF):
Structural Inspection
Structural Modifications (SOS of Building Heavy Duty)
Steam Clean Building 2 Times. Level C
Steam Clean Vehicle Maintenance BulMIng (4.SOO SF):
Sieam Clean Building 2 Times. Level C
Pump Water to Frac Tank, Test 1 Discharge :
Frac Tanks
Pumpmg
Sampling
Analysis
Demolish Battery Wrecking Facility 4 Transport Debris to Offelte Landfill
Samples tor Battery Wrecking Facility
TCLP Analysis
Demo Battery Wrecking Facility
Transport and Disposal ol Debns at Waste Facility & Tipping
Gate Fee tor Truck at Easte Facility
Demolish Concrete Pavement
Transport and Disposal of Oebns at Waste Facility & Tipping
Gate Fee for True* at Waste Facility

Eicavate 7 Soil Within CHJ-S Eiceedlng Target Cleanup Goals
Eicavate Near SI and Buildings (65% of 666500 sq-ft)
Eicavate Near Landfill Are* I' 5% of 990600 sq-lt)
Eicavate Soutnem Area (10% ot me 531 100 sq-fl)
Transport & Disposal of Deens at Waste Facility & Tipping
Gate Fee for Truck at Waste Facility
Cap tne Area with 2 Clean Soil
Transport & Disposal of Delxis Eicceding Cleanup Goals (20% i
Confirmatory Sampling
Confirmatory TCLP Analysis
Cap Metals Contaminated Soils
Cap Area with Z Thick Clean Matenal
Pevegetate
Cap Landfill:
Surface Preparation
FieiiDie Membrane Liner
2' Th.ck Clay
. Drainage Layer < gravel
F.ner layer 0 5 ft sand
Protective Cover 1 soil
0 5 Thick Top Soil
Revegetate
Recap Surface Impoundment:
Evaluate Existing Cap
Recap Area with 2 hick C'ay
? Thick Top Soil
Revegetate
10%

9 100
2
1

32
27900
55800

4.800

100
1
100
100

40
40
55600
2.067

11 122
18S4
93


32091
11 007
3934
37625
1 881
47031
9406
15
15

113 763
35

12
503000
37259
18630
9315
•8630
9315
12

3^*\T
JJJ
3333
•


LF
EA
LS

MRS
SF
SF

SF

EA
LS
EA
EA

EA
EA
SF
CY

SV
CY
Truck Load


CY
CY
CY
CY
Truck Loads
CY
CY
EA
EA

CY
ACRE

ACRE
SF
* y
;y
Cy
~.<
Cv
»CRE

.3
;,
AC'E
J1495I 768

$1500
S3 000
(2000

$10000
i860
1060

1060

SI 14000
JIO 000 00
S7000
S20000

S7000
S20000
S1800
S11900 '

$1500
J1I900
S1400


S500
S500
IS 00
SH900
SH900
StSOO
S20000
$7000
$20000

$1500
$1 50000

$1 25000
$055
$1500
$1500
$1500
$1500
$1500
S< 50000

$2000000
J1 ^ Cf\
' 3 IAJ
$1500
$^50000
St 495177 '

$136500 Asiumtt 100% or ••.sting f«nc« "««0| iw
$6000
$2000

$3.200
S245.562 Based on AccuVal 1(8001852-9252
$33.480 ECHOS33-17-0812Pg 374

$2880 ECHOS 33-17-0812 Pg 374

$114000
$10000
$7000
$20 000

$2.800
sa.Doo
$1.004.400 Based on AccuVal liB0018S2-9252
$245.973

$166833 Based on 95 MEANS 020-554-1900
S220.59t
S1.298
$1 648 S9T

$160.454
$55033
$19.670
$4 477.397
$223870
$705 472
$1 881 259
$1050
$3000

$1 706.450 mauOM Ourert«i« of Mtf toraMnq s y*o<»q
$52886 95 MEANS 029- 304-00 13

$15000 95 MEANS 02 1-104-0- 50
$276 650
$558 889
$279444
$139722
$279444
$139.722 incino« pufciwt or to* tpraonq i juj.'-s
$18000 95 MEANS 029- 304-OO'0

$20000
$50000
$1 550
Cap Area where Pavement was Removed Around Battery Wrecking Facility
Cap Area «vith 2 ">'C» Oear. Matenal
•40'

$'500
$111 111 „*« &«c» "o*0«i csv :' j'ad.«g -:o \:

-------
J -337
SUBTOTAL
CONTINGENCY
SUBTOTAL • CONSTRUCTION COST
PERMITTING I LEGAL
SERVICES DURING CONSTRUCTION
SUBTOTAL • IMPLEMENTATION COST
ENGINEERING * DESIGN COST
TOTAL - Capital CON - AMMTWdv* 4
ANNUAL 0 I H COSTS
inspection of ffw oap loom landfill and surface impoundment)
Shod Term Groundwater Montonng (assumed tor rive years)
Short- Term Surface water Monitoring (assumed for five yearsi
SUBTOTAL
CONTINGENCY
TOTAL • Annual O * M Coca - AMemaOn 4 ($ yean)
Long Term Monitoring (2 wells annually)
inspection of the cap (bom landfill and surface impoundment)
SUBTOTAL
CONTINGENCY
TOTAL • Annual O t M Coata - Artamattve 4 (2S yearn)
30%
5=4
7%'

6'*


4 QUARTERLY
3 EA
2 £A
20%

2 £A
4 QUARTERLY
20'A

$14951 768 '
S16S43.8S1
$16843651

$16843851


$30000
$1.60000
$60000
$7200

$160000
$30000
$4400
-
$14951 768
$4485531
$19.437299
$842. 193 Based on cost of all on- site activities
$1 179.070 Based on cost of an orvsite activities
$21 458.561
$1010631 Based on cost of all on-site activities
S22.4M.in
I '
$1.200
$4.800
$1.200
$7.200
$1.440
M.MO
$3 200
$1 200
$4400
$880
U.2M

-------
3 1897
NET PRESENT VALUE:
YEARO
YEAR 1
YEAR 2
YEAR 3
YEAR 4
YEARS
YEAR 6
YEAR?
YEARS
YEAR 9
YEAR 10
YEAR 1 1
YEAR 12
YEAR 13
YEAR 14
YEAR 15
YEAR 16
YEAR 17
YEAR 18
YEAR 19
YEAR 20
YEAR 21
YEAR 22
YEAR 23
YEAR 24
YEAR 25
YEAR 26
YEAR 27
YEAR 28
YEAR 29
YEAR 30
NET PRESENT VALUE (M%) • AIMntMXw 4

522*69192
18640
$8.640
$8640
S8640
$8640
SS.280
$5280
15280
15.280
$5.280
$5.280
$5.280
$5 280
$5.280
$5.280
$5280
$5.280
$5280
$5280
$5280
$5280
$5280
.$5280
$5280
$5.280
$5 280
$5280
$5.280
$5.280
$5.280
122.M4.WM

-------
         TNRCC LETTER
RSR CORPORATION SUPERFUND SITE
      OPERABLE  UNIT No.  5
          APPENDIX D

-------
Barry R. McBee, Chairman
R. B. "Ralph" Marquez, Commissioner
John M. Baker. Commissioner
Dan Pearson. Executive Director
             TEXAS NATURAL RESOURCE CONSERVATION COMMISSION
                           Protecting Texas by Reducing and Preventing Pollution         '.      •
                                    December 5,  1996                         "
                                                                                  •-."3
  Mr. Myron Knudson, Director                                                      -
  Superfund Division, 6SF
  U.S. Environmental Protection Agency, Region 6
  1445 Ross Avenue, Suite 1200
  Dallas, Texas 75202-2733                                                         '-"•

  RE:   RSR/West Dallas Lead Superfund Site Operable Unit 5 (Battery Wrecking Facility and
        Ground Water Portion of OU 4 and 5) Record of Decision

  Dear Mr. Knudson:

  My staff has reviewed the proposed Record of Decision (ROD) for Operable Unit 5  (Battery
  Wrecking  Facility and Ground Water Portion of OU 4 and 5) for the RSR/West Dallas Lead
  Superfund Site.  The selected remedial action is decontamination, dismantling and offsite disposal
  of buildings, containment of the former surface impoundment, former landfill and slag burial
  area/other soils, and no action on the groundwater portions of OU 4 and OU 5.

  The no action alternative for ground water is based on EPA's documentation that the shallow
  ground water is not a likely drinking water source because of the water's low yield and slightly
  saline quality. The Texas Department of Health requirements for public water supplies and the
  City of Dallas water code requirements limit the installation of private wells in the area.

  The State  recommends that any final settlement by  EPA  with Responsible Parties include a
  requirement to establish deed notices or deed restrictions which appropriately limit the use of the
  property according to the level of remedial action conducted at the site.

  Therefore, on behalf of the  Texas Natural Resource Conservation Commission, I concur that the
  selected Remedial Alternative for OU 5  is appropriate.
     :erely,
    in Pearsoj
  Exbcuiii^-Director

  DP/JEP/ls
                      PO. Box 13087   •   Ausbn. Texas 78711-3087   •   512239-1000

-------
       ARARs EVALUATION
RSR CORPORATION SUPERFUND SITE
     OPERABLE UNIT No. 5
          APPENDIX E

-------
Table A-l
ARARs Evaluation for Soils, Buildings and Structures, and Residual Material
RSR Corporation Superfund Site
Dallas, Texas Page 1 of 14
Requirement
Potentially Pertinent Media*
Soils
Buildings and
Structures
Residual
Material

ARAR?
1 . Contaminant-Specific ARARs
Justification

Federal
Risk-based preliminary remediation goals
(PRGs) [Risk Assessment Guidance for
Superfund (RAGS), Pan B)
National Contingency Plan
40C.F.R. Pan 300.430(d)
Baseline Human Health Risk Assessment
Office of Solid Waste and Emergency
Response (OSWER)
Directive 9355.4-12
July 14. 1994
EPA -Strategy for Reducing Lead
Exposures. October 3. 1990
X
X
X
X

X

X

X

X
TBC
Yes
TBC
TBC
Risk-based PRGs calculated using RAGS Part B are TBC for OU No. 4 and
OU No. 5. PRGs are TBCs for OU No. 4 and OU No. 5.
Applicable to OU No. 4 and OU No. 5. Evaluates baseline human health risk
due (o current and potential future site exposures, and establishes contaminant
levels in environmental media at the OUs for protection of public health.
The directive establishes soil cleanup levels for lead abatement for residential
areas. These levels are TBCs for OU No. 4 and OU No. 5.
TBC for OU No. 4 and OU No. 5. The strategy was developed to reduce lead
exposures to the greatest extent possible. Goals of the strategy arc to:
(1) significantly reduce blood lead incidences above 10 jig/dL in children and
(2) reduce the amount of lead introduced into the environment.
2. Action-Specific ARARs
Federal
40 CFR 268
Universal Treatment Standards (UTS)
40C.F R Pan 264
Subpans B, C. D and G

X

X
X
X
Yes
Yes
40 CFR Pan 268 establishes restrictions on land disposal unless treatment
standards are met. Relevant and appropriate to both OU No. 4 and OU No. 5,
if the wastes are removed from the sites for subsequent disposal. Metals
wastes in soil that are hazardous by toxicily characteristic are exempt from this
rule. The UTS establish a concentration limit for 300 regulated constituents in
soil regardless of waste type.
Subpans B, C, and D establish minimum standards which define the acceptable
management of hazardous waste for owners and operators of facilities that
treat, store, or dispose of hazardous waste. Subpart G establishes standards for
closure and post-closure care for site design and operation. These requirements
are relevant and appropriate for wastes identified as RCRA hazardous wastes.
WP5

-------
Table A-l
ARARs Evaluation for Soils, Buildings and Structures, and Residual Material
RSR Corporation Superfund Site
Dallas, Texas P«g« 2 of 14
Requirement
Potentially Pertinent Media*
Soils
Buildings and
Structures
2. Action-Specific ARARs (Continued)
Residual
Material

ARAR?

Justification

Federal (Continued)
Subparts 1 and J
Subpans L and N
Subpan S
X
X
X
X
X
X
X
X
X
Yes
Yes
Yes
Subpan I sets operating and performance standards for container storage of
hazardous waste. Subpart J outlines similar standards, but applies to tanks
rather than containers. These requirements are relevant and appropriate for
RCRA hazardous wastes on OU No. 4 and OU No. 5 if containers are used
for onsite storage of liquids, soil, or other wastes as pan of the remedial
action.
Subpan L sets design and operating requirements for the storage or treatment
of wastes in piles. If the waste piles are closed with wastes left in place,
Subpan L requirements are applicable and must be met. Subpan N establishes
construction, design, performance, closure, and operation requirements
pertaining to Subtitle C landfills Subpan L and/or N are relevant and
appropriate for RCRA hazardous wastes on OU No. 4 and OU No. 5 if onsite
treatment, storage, or disposal in piles or Subtitle C landfills is included as
pan of the remedial action.
The promulgated portion of Subpan S addresses the corrective action
management unit (CAMU) and temporary unit (TU) aspects of RCRA
corrective action. A CAMU is a contiguous area within a facility in which
remedial wastes generated during corrective action are managed. A CAMU
may include uncontaminated areas where necessary to achieve overall remedial
goals. Wastes may be moved from one CAMU to another within the facility
without triggering land disposal restrictions (LDRs). Wastes can also be
removed from the CAMU, treated in a unit, and returned to the CAMU
without triggering LDRs. A TU can be used to manage wastes for up to 1
year. TUs are hot subject to the full permitting requirements of a fully
regulated RCRA unit and waste piles are not eligible for TUs. Subpan S
requirements are relevant and appropriate for RCRA hazardous wastes on OU
No. 4 and OU No. 5 if the remedial action requires wastes to be managed in
an onsite CAMU or TU.
10017#f5 WPS

-------
Table A-l
ARARs Evaluation for Soils, Buildings and Structures, and Residual Material
KSR Corporation Superfund Site
Dallas, Texas Pa8e 3 of 14
Requirement
Potentially Pertinent Media*
Soils
Buildings and
Structures
Residual
Material
ARAR?
Justification
2. Action-Specific ARARs (Continued)
Federal (Continued)
Subpan X (Miscellaneous Uniis)
40 C.I- R § 761.60
(PCB Disposal)
40C.H.R. §76l.65(c)(7)
(PCB Slur age)
OSHA Worker Protection
40C.F.R. § 300.38
X
X

X
X

X
X
X


X
Yes
Yes
No
Yes
Relates to "miscellaneous" units that treat, store, or dispose hazardous wastes.
Provides general performance standards for location, design, construction,
operation, monitoring, and closure/post -closure. This requirement is relevant
and appropriate for RCRA hazardous wastes on OU No. 4 and OU No. 5 if
the remedial action includes onsite treatment, storage, or disposal of waste in a
miscellaneous unit.
Serves as ARAR for disposal of affected materials containing concentrations of
PCBs, if affected materials are identified at OU No. 4 or OU No 5. This
requirement is relevant and appropriate.
Serves as an ARAR only to extent that it authorizes storage of liquid PCBs in
containers meeting 29 C.F.R. § 1910.106 (OSHA Standards for Flammable
and Combustible Liquids); requires preparation and implementation of Spill
Prevention Control and Countermeasures plan. Not an ARAR since liquid
PCBs were not identified at either OU No. 4 or OU No. 5
Applicable to OU No. 4 and OU No. 5 regarding protection of workers at site
(29 C.F.R. 1910.120)
VKP5

-------
Table A-l
ARARs Evaluation for Soils, Buildings and Structures, and Residual Material
RSR Corporation Superfund Site
Dallas, Texas Page 4 of 14


Requirement
Potentially Pertinent Media*

Soils
Buildings and
Structures
Residual
Material


ARAR?


Justification
2. Action-Specific ARARs (Continued)
Federal (Continued)
Surface Mining Control and Reclamation
Act of 1977
25 CSC §§ 1201 el. see.: 30 C.F.R.
Pans 816.11. .95. .97. .100. and .102











X





























State
General Prohibitions
30 TAC § 330.5



Disposal of Special Wastes
30 TAC § 330.136


















X




X














Yes














The requirements include provisions for:

• .11 -Posting signs and markers for reclamation, including top soil
markers and perimeter markers.
• .95 -Stabilization of all exposed surface areas to effectively control
erosion and air pollution attendant to erosion.
• .97 -Use of best technology currently available to minirnize
disturbances and adverse impacts on Fish, wildlife, and related
environmental values and achieve enhancement of such if possible.
• .100 -Contemporaneous reclamation including, but not limited to
backfilling, regrading, topsoil replacements and revegetation.
• .102 -Achieve a post action slope not exceeding angle of repose or such
lesser slope as is necessary to achieve a minimum long-term static
safety factor of 1.3 and to prevent slides.
These requirements are relevant and appropriate to OU No. 4 and OU No 5

X









No for
OU No.
4/Yes
forOU
No. 5
Yes




The regulation prohibits disposal of lead acid storage batteries at municipal
solid waste landfills. This requirement is not an ARAR for OU No. 4 but is
relevant and appropriate for battery casings identified on OU No. 5


Specifies that regulated asbestos-containing material (R ACM) may be accepted
at a Type 1 or Type I-AE municipal solid waste landfill (MSWLF) provided
that the MSWLF facility has been authorized to accept RACM and complies
with the provisions of § 330.136. This requirement is applicable for OU No. 4
and OU No 5.
In

-------
                                                                           Table A-l
                                          ARARs Evaluation for Soils, Buildings and Structures, and Residual Material
                                                                RSR Corporation Superfund Site
                                                                          Dallas, Texas
                                                                                                       Page 5 of 14
               Requirement
                                             Potentially Pertinent Media'
Soils
Buildings and
  Structures
Residual
Material
ARAR?
Justification
  Use of Land Over Closed Municipal
  Landfills
  Subchapier T
  30TAC §§ 330.951-330.963
                                Yes
                                    These requirements establish standards for development and construction over
                                    closed landfills. The rules apply to owners and lessees of property overlying
                                    closed landfills, registered professional engineers, local government officials
                                    with the authority  to disapprove an application for development, developers of
                                    property greater than I acre, and developers of an enclosed structure greater
                                    than 1 acre.  Some requirements do not apply to persons constructing or
                                    owning single-family homes or duplexes or other enclosed structures.
                                    Section 330.953 requires a soil test be performed on land greater than  I acre
                                    to determine if the tract overlies a closed landfill. Section 330.954 establishes
                                    permit and registration requirements, procedures and processing.
                                    Section 330.955 lists prohibitions for the development of land over a closed
                                    municipal solid waste landfill.  A developer cannot damage the final cover or
                                    the liner without written consent of the executive director unless the damage
                                    occurs constructed below the natural  grade of the land or the final cover.
                                    Sections 330.956 through 330.963 establish procedural requirements relative to
                                    permitting,  reporting, recordkeeping, and public notifications.  The
                                    requirements of these provisions are  relevant and appropriate for the OU No.  5
                                    if remedial actions undertaken at the  landfill require construction of building
                                    directly on top of  a closed landfill, with the exception of the permitting
                                    requirements which would not be  ARARs for actions implcmenied under
                                    CERCLA.
1)1

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                                                                            Table A-l
                                           AKARs Evaluation for Soils, Buildings and Structures, and Residual Material
                                                                 KSK Corporation Superfund Site
                                                                          Dallas, Texas
                                                                                                                                                Page 6 of 14
                 Requirement
                                              Potentially Pertinent Media*
                                          Soils
Buildings and
  Structures
Residual
Material
ARAR?
Justification
   2  Action-Specific ARARs (Continued)
   State (Continued)
   Closure and Remediation
   30 TAC Subchapter A
   § 335.8
                                                                         Yes
                                   These provisions apply to closure and remediation of facilities associated with
                                   contamination resulting from unauthorized discharges, either as pan of closure
                                   or at any time before or after closure.  The regulations also apply to
                                   remediation of areas that are not otherwise designated as a facility but that
                                   contain unauthorized discharges of industrial waste or municipal hazardous
                                   waste.  These requirements are relevant and appropriate for RCRA hazardous
                                   wastes on OU No. 4 and OU No. 5.
   Subpan S. Risk Reduction Standards
   30 TAC § 335.551
                                                                         Yes
                                   Establishes procedures to demonstrate compliance with the risk reduction
                                   standards for different types of contaminated media such as air, surface water,
                                   groundwater, and soil, and for cross-media contamination pathways such as
                                   soil-to-groundwaier and soil to air  Requirements apply to closure and
                                   remediation undertaken according to 30 TAC § 335.8. Numeric cleanup values
                                   are based on which of the three risk reduction  rules are appropriate. These
                                   requirements are relevant and appropriate for surface soil on OU  No.  4 and
                                   OU No. 5.
Subpan S, Risk Reduction Standard No  3
30 TAC § 335.562
                                                                            Yes
                                   Risk Reduction Standard No. 3 specifies that persons shall propose media
                                   cleanup levels in accordance with the conditions stated.  These requirements
                                   are relevant and appropriate for OU No. 4 and OU No.  5 to perform closure
                                   or remediation activities.  Cleanup levels will be based on the CERCLA risk
                                   assessments developed for OU No. 4 and OU No. 5.	
   Shipping and Reporting Procedures
   Applicable to Generators of Hazardous
   Waste or Class 1 Waste and Primary
   Exporters of Hazardous Waste
   30 TAC Subchapter A
   § 335. 10
                                                                         Yes
                                   Establishes requirements for manifesting shipments of hazardous waste to off
                                   site facilities. This requirement is relevant and appropriate to both OU No. 4
                                   and OU No.  5  if hazardous or Class 1 wastes are shipped off-site to a
                                   disposal/treatment facility.
  Shipping Requirements for Transporters of
  Hazardous Waste or Class 1 Waste
  30 TAC Subchapler A
  tj H5.I 1
                                                                         Yes
                                   Requirements specific to transporters of hazardous or class 1 wastes regarding
                                   manifesting waste shipments. These requirements are relevant and appropriate
                                   to any transporter who transports hazardous or class 1 wastes offsite from OU
                                   No. 4 or OU No. 5.
n>\ Nlllllf'755

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                                                                          Table A-l
                                          ARARs Evaluation for Soils, Buildings and Structures, and Residual Material
                                                               RSR Corporation Superfund Site
                                                                         Dallas, Texas
                                                                                                      Page 7 of 14
               Requirement
                                            Potentially Pertinent Media*
Soils
Buildings and
 Structures
Residual
Material
ARAR?
                                       Justification
 2.  Action-Specific ARARs (Continued)
 State (Continued)
 Shipping Requirements Applicable to
 Owners or Operators of Storage.
 Processing, or Disposal Facilities
 30 TAC Subchapter A § 335.12
                                No
                                   Requires owners or operators of storage, processing or disposal facilities to
                                   comply with manifest requirements upon receipt of waste shipment. This
                                   requirement is not an ARAR for OU NO. 4 or OU No. 5 because waste
                                   shipments will not be received at the RSR Site.	
 Special Definitions for Recyclable
 Materials and Nonhazardous Recyclable
 Materials
 30 TAC Subchapter § 335.17
                                Yes
                                   Specifics definition of recyclable materials including "scrap metal." This
                                   requirement is applicable to OU No. 4 and OU  No. 5 if materials (building
                                   components, etc.) are to be recycled.
  Requirements for Recyclable Materials and
  Nonhazardous Recyclable Materials
  30 TAC Subthapier A §  335.24 (c) and
  (h)
                                Yes
                                   Specifies that scrap metal is not subject to regulation under Subchapter B-l and
                                   O Chapter 335. Under § 335.24(h). the rule specifies that scrap metal, as
                                   defined in Section (c) remains subject to the requirements of § 335.4 (relating
                                   to General Prohibitions) and § 335.6 (relating to Notification Requirements).
                                   Such wasie may also be subject to the requirements of § 335.10 through
                                   8 335.15 of Title 30.

                                   These requirements are relevant and appropriate to OU  No.  4 and OU  No. 5 if
                                   materials are recycled.	
 Adoption of Appendices by Reference
 30 TAC Subchapter A
 §  335.29
                                Yes
                                   Adopts appendices contained in 40 C.F.R. Part 261  by reference; this includes
                                   Appendix Mil. Vll-X

                                   I  - Representative Sampling Methods
                                   II  - Method 1311 Toxicity Characteristic Leaching  Procedure
                                   III - Chemical  Analysis Test Methods
                                   VII   - Basis for Listing Hazardous Waste
                                   VIII  - Hazardous Constituents
                                   IX - Wastes Excluded under § 260.20 and § 260.22
                                   X  • Method of Analysis for Chlorinated Dibenzo-p dioxins and
                                        Dibenzofuram.

                                   These requirements are relevant and appropriate for  OU No. 4 and OU No. 5
                                   to determine which,  if any. media are RCRA hazardous wastes.  These
                                   requirements are  not applicable since much of the contaminated media was
                                   disposed of prior to  1980.
Ill NIUOI77.SS VSP<

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Table A-l
ARARs Evaluation for Soils, Buildings and Structures, and Residual Material
RSR Corporation Super-fund Site
Dallas, Texas Page 8 of 14
Requirement
Potentially Pertinent Media*
Soils
Buildings and
Structures
Residual
Material
ARAR?
Justification
2. Action-Specific ARARs (Continued)
Stale (Continued)
Hazardous Waste Management General
Provisions
30 TAC Subchapicr B
§335.41
Standards Applicable to Generators of
Hazardous Wastes
30 TAC Subchapter C
§ 335.61, §§ 335.65 335.70
Standards Applicable to Transporters of
Hazardous Waste
30 TAC Subchapter D
§ 335 91
Applicability of Groundwater Monitoring
and Response
30 TAC Subchapter F
§ 335.156
X
X
X
X




X
X
X
X
Yes
Yes
Yes
Yes
This Subchapter implements a state hazardous waste program which controls
from point of generation to ultimate disposal those wastes listed in 40 C.F.R.
Pan 261. These standards are relevant and appropriate for RCRA hazardous
wastes on OU No. 4 ind OU No. 5.
This subchapter establishes standards for generators of hazardous waste. These
standards include: packaging, labeling, marking, placarding, accumulation
time, and record-keeping. Requirements for packaging, labeling, marking, and
placarding are relevant and appropriate for RCRA hazardous wastes on OU
No. 4 and OU No. 5.
This subchapter establishes standards for transporters transporting hazardous
waste to offsite storage, processing, or disposal facilities. This subchapter does
not apply to onsitc transportation of hazardous waste by generators or by
owners or operators of storage, processing, or disposal facilities.
Requirements of this subchapter are relevant and appropriate for RCRA
hazardous wastes on OU No. 4 or OU No. 5 that are sent offsite for disposal.
This section outlines the rules pertaining to groundwater monitoring and
response, which apply to owners and operators of facilities that process, store,
or dispose of hazardous waste. The owner or operator must satisfy the
requirements of § 335.156 (a)(2) for all wastes (or constituents thereof)
contained in any such waste management unit at the facility, regardless of the
time at which waste was placed in the units.
These requirements are relevant and appropriate for RCRA hazardous wastes
left in place or disposed on OU No. 4 and OU No. 5.

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Table A-l
ARARs Evaluation for Soils, Buildings and Structures, and Residual Material
RSR Corporation Superfund Site
Dallas, Texas P"g« 9 of 14


Requirement
Potentially Pertinent Media*

Soils
Buildings and
Structures
Residual
Material
2. Action-Specific ARARs (Continued)


ARAR?


Justification

State (Continued)
Required programs
30 TAC Subchapter F
§335.157













Interim Standards for Owners and
Operators of Hazardous Waste Storage.
Processing, or Disposal Facilities
30 TAC Subchapter E
§335.111


Interim Standards for Owners and
Operators of Hazardous Waste Storage,
Processing, or Disposal Facilities-
Standards
30 TAC Subchapter E
§ 335 112
X















X






X


































X















X






X





Yes















Yes






Yes





Requires owners and operators subject to 30 TAC § 335. 156 to conduct a
monitoring and response program as follows:

(1) Whenever hazardous constituents from a regulated unit are detected at the
compliance point, the owner or operator must institute a compliance
monitoring program.
(2) Whenever the groundwater protection standard is exceeded, the owner or
operator must institute a corrective action program.
(3) Whenever hazardous constituents from a regulated unit exceed
concentration limit, under § 335.160 in groundwater between the compliance
point and the downgradiem facility boundary, the owner or operator must
institute a corrective action program, and
(4) In all other cases, the owner or operator must institute a detection
monitoring program.
These requirements are relevant and appropriate for RCRA hazardous wastes
left onsite at OU No. 4 and OU No. 5.
This subchapter establishes minimum requirements that define the acceptable
management of hazardous waste prior to the issuance or denial of a hazardous
waste permit and until certification of final closure or, if the facility is subject
to post-closure requirements, until post -closure responsibilities are fulfilled.

These requirements are relevant and appropriate for RCRA hazardous wastes
on OU No. 4 and OU No. 5 if wastes are left onsite.
Adopts 40 C.F.R. Pan 265, except as noted, by reference. This includes
Subparts B. C. D, E, F. G, H. 1. J. K. L. M, N, O, P. Q, R. W. AA, and
BB.

These requirements are relevant and appropriate for RCRA hazardous wastes
on OU No. 4 and OU No. 5 if wastes are left onsite.
<5 vm

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Table A-l
ARARs Evaluation for Soils, Buildings and Structures, and Residual Material
RSR Corporation Superfund Site
Dallas, Texas Page 10 of 14
Requirement
Potentially Pertinent Media*
Soils
Buildings and
Structures
Residual
Material
ARAR?
Justification
2 Action-Specific ARARs (Continued) . ,
Stale (Continued)
Containment for Waste Piles
30 TAC Subchapier E
§335.120
Permitting Standards for Owners and
Operators of Hazardous Waste Storage
Processing or Disposal Facilities
30 TAC Subchapier F
§ 335.151
Standards
30 TAC Subchapter F
§ 335.152
Corrective Action for Solid Waste
Management Units
30 TAC Subchapier F
§ 335.l67(b) and (c)
Design and Operating Requirements
(Waste Piles)
30 TAC Subchapier F
§ 335.170
location Standards tor Hazardous Waste
Storage. Processing, or Disposal
30 TAC Subchapier G

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Table A-l
ARARs Evaluation for Soils, Buildings and Structures, and Residual Material
RSR Corporation Superfund Site
Dallas, Texas P«g« 1 1 of 14
Requirement
Potentially Pertinent Media*
Soils
Buildings and
Structures
Residual
Material
ARAR?
Justification
2. Action-Specific ARARs (Continued)
State (Continued)
Prohibition on Open Dumps
30 TAC Subchapter 1
§ 335.302
Hazardous Waste Generation. Facility, and
Disposal Fees System
30 TAC Subchapier J
§ 335.321
llaurdous Substance Facilities Assessment
and Remediation
30 TAC Subchapter K
§ 335 341 (b)(4)
Specific Air Emission Requirements for
Hazardous or Solid Waste Management
Facilities
30 TAC Subchapter L
§ 335.367
Pre Application Review and Permit
Procedures
30 TAC Subchapter M
§ 335 391-335 393
Warning Signs for Contaminated Areas
30 TAC Subchapter P
§ 335 441
X
X
X
X
X
X





X
X
X
X
X
X
X
No
No
Yes
Yes
No
Yes
Prohibits open dumping of industrial solid waste. Not an ARAR for OU No. 4
or OU No. 5. as all wastes will be handled according to ARARs.
Establishes an industrial solid waste and hazardous waste fee program which is
an administrative requirement. Administrative requirements are not ARARs.
Outlines the scope and requirements associated with the State Superfund
program, including: ranking of facilities (§ 335.343). delisting and
modifications (§ 335.344). removal actions and preliminary s'te investigations
(§ 335 346), general requirements for a remedial investigation/feasibility study
(§ 335.348), and general requirements for a remedial action (§ 335.349). The
requirements set forth in the rule are relevant and appropriate However.
because the RSR Site is proposed for listing on EPA's National Priorities List
and is an EPA-lead Superfund site, the requirements are being met through the
CERCLA RI/FS process.
Requires hazardous or solid waste management facilities to use the best
available control technology to control emission of air contaminants.
considering technical practicability and economic factors. Requires the
owner/operator to demonstrate that the facility or unit will not cause or
contribute to air pollution. These requirements are relevant and appropriate to
RCRA facilities constructed onsite at OU No. 4 and OU No 5.
These requirements are administrative requirements. Administrative
requirements are not ARARs.
Provides standards and procedures for the placement of warning signs on
property contaminated with hazardous substances when such contamination
presents a danger to public health and safety. The requirements in Subchapiei
P are relevant and appropriate for RCRA hazardous wastes on OU No. 4 and
OU No 5.
|)|-NIIHII77<5

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Table A-l
AKARs Evaluation for Soils, Buildings and Structures, and Residual Material
RSR Corporation Superfund Site
Dallas, Texas Pag* 12 of 14
Requirement
Potentially Pertinent Media*
Soils
Buildings and
Structures
Residual
Material
ARAR?
Justification
2. Action-Specific ARARs (Continued)
Slate (Continued)
Pollution Prevention Source Reduction and
Waste Minimization
30 TAC Subchapter Q
§ 335.473
Waste Classification and Waste Coding
Required
30 TAC Subchapter R
§ 335.503
Hazardous Waste Determination
30 TAC Subchapter R
§ 335.504
Class 1 Waste Determination
30 TAC Subchapter R
§ 335.505
Class 2 Waste Determination
30 TAC Subchapter R
§ 335.506
Class 3 Waste Determination
30 TAC Subchapter R
§ 335.507
Classification of Spec i He Industrial Solid
Wastes
30 TAC Subchapier R
§ 335.508(1)
X
X
X
X
X
X

X
X
X
X
X
X
X
X
X
X
X
X
X

No
Yes
Yes
Yes
Yes
Yes
Yes
Applies to all large quantity generators, all generators other than large quantity
and conditionally exempt generators, and all persons subject to reporting
requirements under SARA 313 Title HI. The RSR Site is not a large-quantity
generator. Therefore, these requirements are not ARARs for OU No. 4 or
OU No. 5.
These requirements specify the classification scheme and coding for all
industrial solid and municipal hazardous waste generated, stored, processed.
transported, or disposed of in the site. These requirements are relevant and
appropriate for all waste at OU No. 4 and OU No. 5.
Requires waste generator to determine if the waste is hazardous either as a
listed or characteristic waste according to 40 C.F.R. Part 261, Subpart D or
40 C.F.R. Pan 261 Subpart C. These requirements are relevant and
appropriate for identifying RCRA hazardous waste at OU No. 4 and OU
No. 5.
Specifies the chemical/physical properties associated with a Class 1 non-
hazardous industrial solid waste. This requirement is relevant and appropriate
for OU No. 4 and OU No. 5 relative to waste determination procedures.
Requires determination of a Class 2 waste classification for industrial solid
waste that is neither a hazardous waste, a Class 1 waste, nor a Class 3 waste.
This requirement is relevant and appropriate for both OU No. 4 and OU
No. 5.
Specifies that industrial solid waste is a Class 3 waste if it is inert, essentially
insoluble, neither a Class 1 nor hazardous waste, and poses no threat to human
health and/or the environment. This requirement is relevant and appropriate for
OU No. 4 and OU No. 5.
Requires that industrial solid waste containing asbestos material identified as
Regulated Asbestos Containing Material (RACM), as defined in 40 C.F.R.
Pan 61, shall be classified as Class 1 Waste. Applicable to both OU No. 4 and
OU No. 5 due to the presence of asbestos containing material.
WPS

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                                                                              Tahlp A.I
ARARs Evaluation for Soils, Buildings and Structures, and Residual Material
RSR Corporation Super-fund Site
Dallas, Texas Page 13 of 14


Requirement
Potentially Pertinent Media*

Soils
Buildings and
Structures
Residual
Material


ARAR?


Justification
2. Action-Specific ARARs (Continued)
State (Continued)
TNRCC Demolition Debris Waste
February 23. 1994












































X













































TBC






















In an interoffice memorandum, the TNRCC defines "demolition debris" and
establishes sampling recommendations based on 30 TAC § 335 509. The
TNRCC recommends that, prior to beginning demolition or dismantling
operations, generators of demolition debris waste lake appropriate steps to:
1. .Identify the individual components/phases of the waste which have a
significant potential to be hazardous wastes (and. in the case of
industrial generators. Class 1 wastes);
2. Segregate, to the extent practical, those components/phases from the
remainder of the waste.
3. Perform any necessary sampling and analytical testing on those
components/phases to determine whether they are characteristically
hazardous as defined in 40 C.F.R. §§ 261.21 through 24 (and in the
case of generators of industrial waste, Class 1 as defined in 30 TAC
§ 335.505).
4. Manage those components/phases, as well as the remainder of the
wastes, according to standards appropriate to their classification.
If during the process of segregating hazardous or Class 1 components/phases
from the remainder of the waste, it is determined that the action may pose a
significant threat to human health and the environment, generators should use
appropriate discretion when deciding whether segregation is in the best interest
of protecting human health and the environment.
As nonpromulgaicd guidelines, these requirements are TBCs for OU No. 4 and
OU No. 5 if demolition is selected as part of the remedy.
DI.NIOUI77S5 WPi

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Table A-l
ARARs Evaluation for Soils, Buildings and Structures, and Residual Material
RSR Corporation Superfund Site
Dallas, Texas Page 14 of 14
Requirement
Potentially Pertinent Media*
Soils
Buildings and
Structures
Residual
Material
2. Action-Specific ARARs (Continued)
ARAR?
Justification

State (Continued)
TNRCC Historically Contaminated Sites:
Industrial Versus Municipal Solid Waste
July 12. 1994
X
X
3. Location-Specific ARARs
X

TBC

In an interoffice memorandum. TNRCC established requirements that, before
the final deposition of a waste is carried out. the site owner or operator must
accomplish at least the following:
1 . Waste type determination (municipal or industrial) and
2. Hazardous waste determination in accordance with 30 TAC § 335.62
Wastes from a presently inactive facility (generator) where previous industrial
activities occurred or industrial waste was generated, would he-classified as
industrial waste.
As nonpromulgated guidelines, these requirements are TBCs for OU No. 4 and
OU No. 5.

Federal
Coastal Zone Management Act
16 U.S.C. § 1451 et seq.
40 C.F.R. § 6.302(d)
40 C.F.R. § 264.18 (Location Standards)
X
X
X
X
X
X
No
No
Requires assessment of the impacts of activities on a coastal zone and the .
conduct of activities in connection with a coastal zone in accordance with a
state approved Coastal Zone Management Plan. Activities at OU No. 4 or OU
No. 5 will not impact a coastal zone; therefore this requirement is not an
ARAR.
Relates to hazardous waste treatment, storage, or disposal facilities subject to
permitting. Requires that new units where treatment, storage, or disposal of
hazardous waste will be conducted be located greater than 200 feel from a fault
with displacement in Holocene time and that facilities located in 100-year
floodplains be designed, constructed, and operated to prevent washout of
hazardous waste from active portions of the facility. Since the site is not in a
100-year floodplain, this regulation is not an ARAR. The site is not within
200 feel of a fault, thus the provisions pertaining to faults are not ARARs.
'I'oteiiiially Pertinent Media • In some cases, the evaluation of analytical results from these media is needed to determine whether a potential ARAR is applicable or relevant and
appropriate (see Appendix D for these evaluations) For example, many of the RCRA requirements are relevant and appropriate for RCRA hazardous waste A potentially
(iciiiiiciii medium may or may not be a RCRA characteristic hazardous waste, depending on its TCLP results.
PI-NIUor?7SS WPS

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Table A-2a
Numeric Contaminant-Specific ARARs/TBCs for Soils,
Buildings and Structures,
and Residual Material OU No. 4
RSR Corporation Superfund Site
Dallas, Texas
Chemical
(1)
TBC
Industrial
(rag/kg)
Inorganics
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc

818
32.T
142,476

2,044
1,577

75,628

258,711
613
40,880
10,220
10,220
164
14,308
613,200
Notes:
(1) Preliminary Remediation Goals (PRO). Calculated based on
Human Health Evaluation Manual, Part B: Development of
Risk-Based Preliminary Remediation Goals. OSWER Directive
9285.7-01 B.
TBC = To be considered.
The acceptable risk level for arsenic is set at IxlO5 since a risk
level of 1x10* results in a PRG that is at or below background
levels of arsenic.
DEN3696DOC

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Table A-2b
Numeric Contaminant - Specific ARARs/TBCs
for
Soils, Buildings, and Structures
Former Landfill, and Surface Impoundment
OU No. 5 RSR Corporation Superfund Site
Chemical
Arsenic
Antimony
Benzo(a)pyrene
Benzo(b)fluoranthene
Dibenzo( a,b)anthracene
Lead
Aroclor - 1248
Aroclor - 1260
PRG*
32.7b
818
0.784
0.784
0.784
2000
0.74
0.74
"Preliminary Remediation Goals - calculated based on Human Health Evaluation
Manual, Part B: Development of Risk-Based Preliminary Remediation Goals. OSWER
Directive 9285.7-0 IB.
bThe acceptable risk level for Arsenic is set at 1 x 10'5 since a risk level of
1 x 10"6 results in a PRO that is at or below background levels of Arsenic.
DEN 10017757 WP5

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Table A-3
ARARs for Surface Water
RSR Corporation Superfund Site
Dallas, Texas Page 1 of 10
Requirement
ARAR?
Justification
1. Contaminant-Specific ARARS
Federal
Safe Drinking Water Act
40 U.S.C. 399
Primary Drinking Water Standards (MCL)
40 C.F.R. Part 141
Secondary Drinking Water Standards
40 C.F.R. Part 143
Maximum Contaminant Level Goals
(MCLG)
40 C.F.R. § 141.50
Federal Clean Water Act
Water Quality Criteria
40 C.F.R. Part 131 U.S. EPA
Quality Criteria for Water, 1976, 1980,
and 1986
Toxic Pollutant Effluent Standards
40 C.F.R. Part 129
Hazardous Substances
40 C.F.R. § 116.3 and 116.4
No
No
No
No
No
No
There is no direct contact between the source of contaminants and surface water at the
site. Surface waters around site are not designated for public and private water supply.
MCLs are not ARARs for surface water at OU No. 4 or OU No. 5.
Secondary standards are aesthetic rather than health based and therefore are not ARARs
as surface water is unlikely to be utilized as a source of drinking water.
Not presently considered an ARAR as MCLGs are set at levels that do not take into
account cost or feasibility and MCL's are ftilly protective of human health. See 52
Fed. Reg. 32499. Further, surface waters are not utilized as a source of drinking water.
These criteria (ambient water quality criteria) apply to water classified as a fisheries
resource. The intermittent streams on OU No. 5 are not classified as such and there are
no streams on OU No. 4. Therefore, not an ARAR or TBC for OU No. 4 or OU
No. 5.
Standards are applicable to point source discharges to navigable waters from specified
facilities that discharge aldrin/dieldrin, DDT, endrin, toxaphene, benzidine, PCB's. No
point source discharges to navigable waters are associated with OU No. 4 or OU No. 5.
Establishes reporting requirements for certain discharges of reportable quantities of
hazardous substances. Creates no substantive clean up requirement. Not an ARAR.
DEN100I7759WP5/I

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                                                                                                                Appendix A, Table A-3-ARARs for Surface Water
Table A-3
ARARs for Surface Water
RSR Corporation Superfund Site
Dallas, Texas Page 2 of 10
Requirement
ARAR?
Justification
1. Contaminant-Specific ARARS (Continued)
State
Pollution Prohibition
Texas Water Code
§26.121
Texas Surface Water Quality Standards
Aesthetics
30TAC § 307.4(b)(l)
General Toxicity
30 TAC § 307.4(d)
Antidegradation
30 TAC § 307.5
Acute Toxicity
30 TAC § 307.6(b)(I)
No/Yes*
No/Yes*
No/Yes*
No/Yes*
No
Prohibits the discharge of wastes into or adjacent to any natural or artificial bodies of
surface water, inland or coastal, which in itself or in conjunction with any other
discharge or activity, causes or will cause pollution of the surface water. Not an ARAR
for OU No. 4 since discharges to surface water do not occur. May be relevant and
appropriate for OU No. 5 due to discharges to onsite drainages.
General prohibition of concentrations in surface water of taste and odor producing
substances which impart unpalatable flavor to food fish including shellfish, or otherwise
interfere with the reasonable use of the water in the state. Not an ARAR for OU No. 4
as no discharges to surface water occur; relevant and appropriate for OU No. 5 due to
discharges to onsite drainages.
Surface waters must not be toxic to man or to terrestrial or aquatic life. Not an ARAR
for OU No. 4 as no discharges to surface water occur; relevant and appropriate for OU
No. 5 due to discharges to onsite drainages.
Requires maintenance and protection of existing uses (baseline November 28, 1975)
when discharging wastewater. Not an ARAR for OU No. 4 as no discharges to surface
water occur; relevant and appropriate for OU No. 5 due to discharges to onsite
drainages.
Surface water must not be acutely toxic to aquatic life (except in small zones of initial
dilution at discharge points). This criteria applies to water classified as a fisheries
resource. The intermittent streams on OU No. 5 are not classified as such and there are
no streams on OU No. 4. Therefore, not an ARAR for OU No. 4 or OU No. 5.
10017759 WP5/2

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                                                                                                                Appendix A. Table A-3-ARARs for Surface Water
Table A-3
ARARs for Surface Water
RSR Corporation Superfund Site
Dallas, Texas Page 3 of 10
Requirement
ARAR?
Justification
I. Contaminant-Specific ARARS (Continued)
State (Continued)
Chronic Toxicity
30 TAC § 307.6(b)(2)
Human Toxicity
30 TAC § 307.6(b)(3)
No
No
Surface water with designated or existing aquatic life uses shall not be chronically toxic
to aquatic life (except in mixing zones and below critical low-flow conditions). No
surface water bodies impacted by OU No. 4 or OU No. 5 have a designated or aquatic
life use; therefore the requirement is not an ARAR.
Surface water must be maintained to preclude adverse toxic effects on human health
resulting from contact recreation, consumption of aquatic organisms, or consumption of
drinking water after reasonable treatment. This regulation is not an ARAR to the
extent that it pertains to drinking water, as surface water in the area is not a potential
source of drinking water.
DEN100I7759.WP5/3

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                                                                                                             Appendix A, Table A-3-ARARs for Surface Water
Table A-3
ARARs for Surface Water
RSR Corporation Superfund Site
Dallas, Texas Page 4 of 10
Requirement
ARAR?
Justification
1. Contaminant-Specific ARARS (Continued)
State (Continued)
Numerical Criteria for Toxics
30 TAC § 307.6(c)
LC50 Toxicity Criteria
30 TAC § 307.6(c)(8)
Yes
No/Yes*
Numerical criteria are established for certain toxic materials. These criteria are TBC
for OU No. 4 and relevant and appropriate for OU No. 5.
Notes: (1) These numerical criteria are based on ambient water quality criteria
documents published by EPA. For some chemicals, EPA criteria have been
recalculated (in accordance with procedures in the EPA guidance document entitled
"Guideline for Deriving Site-Specific Water Quality Criteria") to eliminate the effects
of toxicity data for aquatic organisms which are not known to occur in Texas. 31 TAC
§ 307.6(c)(2).
(2) Numerical Acute Criteria apply to all surface water (except in small zones of initial
dilution at discharge points). Numerical chronic criteria apply to surface water with
designated or existing aquatic life uses (except inside mixing zones and below critical
low-flow conditions.
(3) Numerical Acute Criteria are applied as 24-hour averages. Numerical Chronic
criteria are applied as seven-day averages.
Concentrations of toxic materials for which no numerical criteria have been specified
must not exceed values which are chronically toxic to representative, sensitive aquatic
organisms, as determined from appropriate chronic toxicity data or calculated as 0. 1 of
the median lethal concentration (LC50) for nonpersistent toxics (i.e., readily degrades,
half-life less than 96 hours), 0.05 of LC50 for nonbioaccumulative, persistent toxics,
and 0.01 of the completion of remediation. Not an ARAR for OU No. 4 since no
surface water sources are present or directly impacted; relevant and appropriate for OU
No. 5 due to discharges to onsite drainages.
1. Contaminant-Specific ARARS (Continued)
State (Continued)
QEN100I7759WP5/4

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                                                                                                    Appendix A. Table A-3-ARARs for Surface Water
                                                                 Table A-3
                                                         ARARs for Surface Water
                                                      RSR Corporation Superfund Site
                                                               Dallas, Texas
                                                                                Page 5 of 10
                Requirement
  ARAR?
                                  Justification
   Site-Specific Uses and Criteria
   30 TAC § 307.7(b)(5)
No/Yes*
Basic uses such as navigation, agricultural water supply, and industrial water must be
maintained and protected for all surface water in which these uses can be achieved. Not
an ARAR for OU No. 4 since no surface water sources are present or directly
impacted; relevant and appropriate for OU No. 5 due to discharges to onsite drainages.
  Oyster Waters
  30 TAC  § 307.7(b)(3)(B)(iii)
No
Oyster waters should be maintained so that concentrations of toxic materials do not
cause edible species of clams, oysters, and mussels to exceed accepted guidelines for
the protection of public health,  including the U.S. Food and Drug Administration action
levels for molluscan shellfish.  These criteria are not ARARs since no discharges to
oyster water occurs.
  Standards of Chemical Quality
  30 TAC  § 290.103(l),(3)
No
Specifies the maximum contaminant levels for inorganic and organic compounds that
apply to community and non-transient, non-community water systems.  These values are
not ARARs for OU No. 4 and OU No. 5.
  Secondary Constituent Levels
  30 TAC §290.113
No
These secondary constituent level limits, based on aesthetic and organoleptic
considerations, are applicable to all public water systems.  These levels are TBC for
OU No. 4 and OU No. 5.
  Surface Water Media Specific
  Concentration, Risk Reduction Standard
  No. 2
  30 TAC § 335.558
No/Yes*
To be applied after evaluation of 30 TAC § 307 and primary drinking water MCLs.
Relevant and appropriate for OU No. 5 due to discharges to onsite drainages; not an
ARAR for OU No. 4 since no discharges to surface water occur.
DENIOOI7759.WP5/5

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                                                                                                       Appendix A. Table A-3-ARARs for Surface Waier
                                                                  Table A-3
                                                           ARARs for Surface Water
                                                       RSR Corporation Superfund Site
                                                                 Dallas, Texas
                                                                                  Page 6 of 10
                 Requirement
  ARAR?
                                   Justification
   2. Action-Specific ARARs
   Federal
   Federal Clean Water Act
   National Pollutant Discharge Elimination
   System, Section 402
No
 A permit is not required for onsite CERCLA response actions.  Provision establishes no
 substantive cleanup requirement.
   Stormwater Regulations
   40 C.F.R. Parts 122, 125
Yes
NPDES permits are addressed relative to stormwater discharges associated with
industrial activity. These regulations require the development and implementation of a
stormwater pollution prevention plan or a stormwater best management plan.
Monitoring and reporting requirements for a variety of facilities are outlined.   Runoff
from construction activities is an ARAR depending on the nature of the remedial action
selected. Relevant and appropriate if stormwater discharge occurs as a result of the
remedial action.
   Pretreatment Standards
   40 C.F.R. § 403.5
Yes
Prohibits discharge to a POTW of pollutants that "pass-through" (exit the POTW in
quantities or concentrations that violate the POTW's NPDES permit) or cause
"interference" (inhibits or disrupts the POTW, its treatment processes or operations, or
its sludge processes, use or disposal, thereby causing a violation of the POTW's
NPDES permit). Also prohibits introduction into a POTW of:  (1) pollutants which
create a fire or explosion hazard, (2) pollutants which will cause corrosive structural
damage, (3) solid or viscous pollutants that will obstruct flow, (4) pollutants discharged
at a flow rate and/or concentration that will cause interference, and (5) heat that will
inhibit biological activity (never over 104°C).  No point source discharges have been
documented.  However, if  a remedial action results in a point source discharge to a
POTW, then the requirements will be applicable to OU No. 4 or OU No. 5.
J1ENIOOI7759 WP5/6

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                                                                                                     Appendix A. Table A-3-ARARs for Surface Water
                                                                 Table A-3
                                                         ARARs for Surface Water
                                                      RSR Corporation Superfund Site
                                                                Dallas, Texas
                                                                                 Page 7 of 10
                Requirement
 ARAR?
                                  Justification
  2. Action-Specific ARARs (Continued)
  State
  Consolidated Permits
  Standard Permit Conditions
  30TAC § 305.125
No
Specifies conditions applicable to all permits. A permit is not required for onsite
CERCLA response actions. The provisions establish no substantive cleanup
requirements.
  Consolidated Permits
  Subchapter O, Additional Conditions and
  Procedures for Wastexvater Discharge
  Permits and Sewage Sludge Permits
No
Adopts by reference 40 CFR Part 122, Subpart C, Permit Conditions and Part  124,
Subpart D,  Specific Procedures Applicable to NPDES Permits.  A permit is not
required for onsite CERCLA response actions. The provisions  establish no substantive
cleanup requirement.               	
  Texas Water Quality Act, TCA, Water
  Code, Title 2-State Water Commission
Yes
Places reporting requirements on remedial activities which may cause an accidental spill
and discharge into the state waters. Whenever an accidental discharge or spill occurs at
or from any activity or facility which causes or may cause pollution, the individual
operating, in charge of, or responsible for the activity or facility shall notify the
TNRCC as soon as possible and not later than 24 hours after the occurrence.
Activities which are inherently or potentially capable of causing or resulting in the
spillage or accidental discharge of waste or other substances and which pose serious or
significant threats of pollution are subject to reasonable rules establishing safety and
preventative measures which the commission may adopt or issue. The safety and
preventative measures which may be required shall be commensurate with the potential
harm which could result from the escape of the waste or other substances.  Applicable
to OU No. 4 and OU No. 5 during remediation.
DEN 10017759 WP5/7

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                                                                                                                Appendix A, Table A-3-ARARs for Surface Water
Table A-3
ARARs for Surface Water
RSR Corporation Superfund Site
Dallas, Texas Page 8 of 10
Requirement
ARAR?
Justification
2. Action-Specific ARARs (Continued)
State (Continued)
General Provisions
30 TAC § 335.4
Yes
Regulates the collection, handling, storage, disposal, and processing of hazardous or
deleterious materials in the vicinity of, or adjacent to, state waters. Remedial actions
must be designed with adequate measures and controls to ensure that no person may
cause, suffer, allow, or permit the collection, handling, storage, processing, or disposal
of industrial solid waste or municipal hazardous waste in such a manner to cause:
• The discharge or imminent threat of discharge of industrial solid waste or
municipal hazardous waste into or adjacent to the waters in the state without
obtaining specific authorization for such a discharge from the TNRCC.
• The creation and maintenance of a nuisance; or
• The endangerment of the public health and welfare.
Relevant and appropriate to actions taken at OU No. 4 or OU No. 5.
3. Location-Specific ARARS
Federal
Fish and Wildlife Coordination Act
16U.S.C. §661 et sea.
16 U.S.C. § 742 a
I6U.S.C. § 2901
No/Yes*
Requires consultation when a modification of a stream or other water body is proposed
or authorized and requires adequate provision for protection of fish and wildlife
resources. Not an ARAR for OU No. 4 as no surface water bodies are impacted.
Relevant and appropriate for OU No. 5 due to onsite drainages.
JJENIOOI7759 WP5/8

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                                                                                                                Appendix A. Table A-3-ARARs for Surface Water
Table A-3
ARARs for Surface Water
RSR Corporation Superfund Site
Dallas, Texas Page 9 of 10
Requirement
ARAR?
Justification
3. Location-Specific ARARS (Continued)
Federal (Continued)
Marine Protection, Research and
Sanctuaries Act
33 U.S.C. § 1401 (Title 1)
40 C.F.R. Part 220
16 U.S.C. § 1431 et sea.
(Title III)
15 C.F.R. Parts 922-941
Clean Water Act § 404
33 U.S.C. § 1344
40 C.F.R. Parts 230, 231
Rivers and Harbors Act of 1899
33 U.S.C. § 403
33 C.F.R. Parts 320-322
Protection of Wetlands Executive Order
No. 11990
40 C.F.R. § 6.302(a)
and Appendix A
No
No
No
No
Title I requires permit for dumping of wastes in U.S. ocean waters which have been
transported from U.S. or from outside U.S. Activities at site will not include dumping
of wastes into the ocean; therefore, title 1 is not an ARAR. Title HI requires
conservation and management of areas designated as National Marine Sanctuaries.
Since there is no National Marine Sanctuary in or near the site, Title III is not an
ARAR.
Requires permit for the discharge of dredge or fill material into waters of the United
States including wetlands (see 33 C.F.R. § 328.3). Not an ARAR since no discharge of
dredge or Till material into waters of the U.S. is anticipated.
Prohibits the creation of any unauthorized obstruction or work in navigable waters that
affects such navigable waters without a permit. Even if navigable waters were present
at the site, a nationwide permit is available for CERCLA site activities [see 33 C.F.R.
§ 330.5(a)(20)]. Since there are no navigable waters at the RSR Site, this requirement
is not an ARAR.
Requires federal agencies to avoid, to the extent possible, the adverse impacts
associated with the destruction or loss of wetlands and to avoid support of new
construction in wetlands if a practical alternative exists. Wetlands have not been
identified at the RSR site; this provision is not an ARAR.
DENIOOI77S9.WP5/9

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                                                                                                                 Appendix A, Table A-3-ARARs for Surface Water
Table A-3
ARARs for Surface Water
RSR Corporation Superfund Site
Dallas, Texas Page 10 of 10
Requirement
ARAR?
Justification
3. Location-Specific ARARS (Continued)
Federal (Continued)
Floodplain Management Executive Order
No. 11988
40 C.F.R. § 6.302(b)
Wild and Scenic Rivers Act
16 U.S.C. § 1271 et sea.
40 C.F.R. § 6.302(e)
Coastal Zone Management Act
16 U.S.C. § 1451 et seq.
40 C.F.R. § 6.302(d)
No
No
No
Requires federal agencies to evaluate the potential effects of actions taken in a
floodplain and to avoid or minimize impacts associated with direct and indirect
development of a floodplain. Since the site is not within a 100-year floodplain, this
Order is not an ARAR.
Prohibits adverse effects on a scenic river. Since the site does not affect a scenic river,
this Act is not an ARAR.
Requires assessment of the impacts of activities on a coastal zone and the conducting of
activities in connection with a coastal zone in accordance with a state approved Coastal
Zone Management Plan. The Act is not applicable or relevant and appropriate as OU
No. 4 and OU No. 5 have no impact on coastal areas.
QENIOOI7759.WP5/IO

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Table A-4
Numeric Contaminant-Specific ARARs for Surface Water
RSR Corporation Superfund Site
Dallas, Texas
Chemical
(1)
NA/R&A
(mg/L)
(2)
NA/R&A
(mg/L)
(3)
NA/TBC
(mg/L)
Inorganics
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
Di-n-butyl phthalate
Di-n-octyl phthalate


0.051
1.'

0.01'
0.051


0.005'

0.0000122b

o.or
0.05*














0.025

0.0000122









0.014
0.000018








0.000144
0.61


0.0017


2.7

Notes:
NA/R&A = Not an ARAR or TBC for OU No. 4; Relevant and appropriate to OU No. 5.
TBC = To be considered.
(1) = Criteria in Water for Specific Toxic Materials -Human Health Protection.
Category A -Water and Fish. 30 TAC Section 307-6 Toxic Materials.
(2) = Criteria in Water for Specific Toxic Materials -Human Health Protection.
Category B- Fresh Water Fish Only. 30 TAC Section 307-6 Toxic Materials.
(3) = Ambient Water Quality Criteria for the protection of human health. 57 FR 60847.
December 22, 1992.
'Indicates that the criteria for a specific parameter are for the dissolved portion in water. All other
criteria are for total recoverable concentrations.
"Calculations are based on USFDA Action Levels for fish tissue concentrations.
 Please Note:  There are no contaminant-specific ARARs for OU No. 4 surface water.
DEN 10017758 WP5

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Table A-5
ARARs for Air
RSR Corporation Superfund Site
Dallas, Texas Page 1 of 6
Requirement
ARAR?
Justification
1. Contaminant-Specific
Federal
National (Primary and Secondary)
Ambient Air Quality Standards
(NAAQS)
40 C.F.R. Part 50
National Emission Standards for
Hazardous Air Pollutants
(NESHAPs)
40 C.F.R. Part 61
Subpart A
Fugitive Emissions Source
Standards
40 C.F.R. Part 61
Subpart V
Mercury Standards
40 C.F.R. Part 61
Subpart E
Yes
No
No
No
The NAAQS specify the maximum concentration of a federally regulated air pollutant (i.e., SO2,
paniculate matter (PMIO), NO2, CO, ozone, and lead) in an area resulting from all sources of that
pollutant. No new construction or modification of a facility, structure or installation may emit an
amount of any criteria pollutant that will interfere with the attainment or maintenance of a NAAQS
(see 40 C.F.R. § 5 1 .160). For the federal NAAQS standards, all measurements of air quality are
corrected to a reference temperature of 25°C and to a reference pressure of 760 mm Hg (1.013.2
millibars). 40 C.F.R. § 50.3.
These provisions regulate the emissions of specified "hazardous air pollutants" [listed in 40 C.F.R.
§ 61.0l(a)] that are emitted from particular sources or processes f listed in 40 C.F.R. Part 61].
Regulates specified equipment which are potential sources of fugitive emissions because they
contain or contact fluid which is at least 10% by weight a volatile hazardous air pollutant
("VHAP"- including benzene and vinyl chloride). This requirement is not an ARAR as no fluid
containing at least 10% by weight of a VHAP is present at the site.
These provisions apply to stationary sources that process mercury ore, and incinerate or dry
wastewater treatment plant sludge. The requirement is not an ARAR as no processing of mercury
ore and/or no incineration of wastewater treatment plant sludge will occur at the site.
.DEN 10017756. WP5

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Table A-S
ARARs for Air
RSR Corporation Superfund Site
Dallas, Texas Page 2 of 6
Requirement
ARAR?
Justification
1. Contaminant-Specific (Continued)
State
Asbestos Notification Fees
30 TAC § 101.28
Particulates- Net Ground Level
30 TAC § 111.155
SOj Ground Level Concentration
30 TAC § 112.7
Hydrogen Sulfide
30 TAC § 112.31 & § 112.32
Sulfuric Acid
30 TAC § 112.41
Inorganic Fluoride
30 TAC § I13.3(a)(2)and(a)(3)
Beryllium
30 TAC § 113.3(b)
Lead Emissions from smelting
facilities
No
Yes
No
No
No
No
Yes
No
The owner/operator of a demolition or renovation activity shall remit to the TACB a fee that is
based on the amount of asbestos subject to the NESHAPS. Based on the amount of asbestos
identified may not be an ARAR.
Establishes the net ground level concentration (downwind at the property boundary minus upwind
measurements) of paniculate emissions from any source that must not be exceeded.
SOj emissions from any source must not exceed a net ground level concentration (downwind at
property boundary minus upwind). Not in ARAR since no SO, emissions are expected during or
after remediation.
Sets net ground level concentration limits for hydrogen sulfide. Not an ARAR since no hydrogen
sulfide emissions are expected during or after remediation.
Sets net ground level concentration limits for sulfuric acid. Not an ARAR since no sulfuric acid
emissions are expected during or after remediation.
Sets atmospheric and net ground level concentration limits for inorganic fluoride (as HF). Not an
ARAR since no HF emissions are expected during or after remediation.
Sets atmospheric and net ground level concentration limits for beryllium. Beryllium emissions
may be generated during or after remediation.
Rules relate to lead emissions from stationary sources in Dallas County. Sets standards for the
control of lead emissions in Dallas County. Not an ARAR because the smelter is no longer in
operation.
DEN 10017756 WPS

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Table A-5
ARARs for Air
RSR Corporation Superfund Site
Dallas, Texas Page 3 of 6
Requirement
ARAR?
Justification
2. Action-Specific
Federal
Prevention of Significant
Deterioration of Air Quality
42 U.S.C. § 7475
40 C.F.R. § 52.21
Nonattainment Areas -LAER
42 U.S.C. § 172(b)(6)and§ 173
New Source Performance Stan-
dard for Incinerators
40 C.F.R. Part 60
Subpart E
Hazardous Waste Incinerators
40 C.F.R. Part 264, Subpart O
No
No
No
No
These provisions impose various requirements (e.g. use of best available control technology) on
any new major stationary source of a federally regulated air pollutant in an area which has been
designated attainment or unclassifiable for that pollutant. A "major stationary source" is a source
listed in 40 C.F.R. § 52.21 which emits, or has the potential to emit, 100 tons per year of a
federally regulated air pollutant or any non-listed source that emits, or has the potential to emit,
250 tons per year of a federally regulated air pollutant. Activities at OU No. 4 or OU No. 5 are
not expected to constitute a major stationary source of any federally regulated air pollutant. The
requirement is not an ARAR.
A state's permit program under the federal Clean Air Act must require permits for the construction
and operation of new major stationary sources in NAAQS nonattainment areas. Such a permit may
be issued only if the proposed source complies with "lowest achievable emission rate"
requirements. Not an ARAR since activities at OU No. 4 or OU No. 5 do not constitute new
major stationary sources.
Sets a limit for paniculate emissions of 0.18g/dscm (0.08 gr/dscf) corrected to 12% CO2. Not an
ARAR since the rule applies to furnaces burning municipal waste.
Not an ARAR since a hazardous waste incinerator is not being considered as a remedial alternative
for OU No. 4 or OU No. 5.
HEN 10017756. WPS

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Table A-5
ARARs for Air
RSR Corporation Superfund Site
Dallas, Texas Page 4 of 6
Requirement
ARAR?
Justification
2. Action-Specific (Continued)
State
Control of Air Pollution by Per-
mits for New Construction or
Modification
30 TAC § 116
Requirements for Specified
Sources
30 TAC § 1 1 1 . 1 1 1
Storage of Lead Containing
Materials
30 TAC § Il3.82(a)and(b)
Transport of Materials
30 TAC § 11 3.84(1) and (2)
Yes
Yes
Yes
Yes
New non-exempt facilities which may emit air pollutants must obtain a construction permit or
special permit. To obtain such a permit, the owner or operator of the proposed facility must
provide for measuring emissions of significant air contaminants, and must demonstrate, among
other things, that the facility will utilize the "best available control technology, with consideration
given to the technical practicability and economic reasonableness of reducing or eliminating the
emissions from the facility." Applies during building decontamination or demolition activities.
May be relevant and appropriate.
Visible emissions shall not be permitted to exceed an opacity of 30% for any six-minute period
from any building, enclosed facility, or other structure. Applies during demolition or decontami-
nation of buildings, or any other activity that may generate visible emissions. Relevant and
appropriate for construction/demolition activities at Oil No. 4 or OU No. 5.
No unenclosed storage of material containing more than 1% lead by weight. All particulate matter
containing more than 1% lead by weight collected by air pollution control equipment shall be
stored in closed containers or in a structure under significant negative pressure to prevent emissions
to the atmosphere. Applies if lead content exceeds 1% by weight. Applicable to both OU No. 4
and OU No. 5.
All transport vehicles carrying materials containing more than 1% lead by weight must have
covered cargo compartments at all times on plant property except during loading and unloading,
when being washed, or inside a building. Each time a vehicle leaves a structure, all material
containing more than 1% lead by weight shall be removed from the wheels; if water is used, this
requirement is suspended during freezing weather. Applies if lead content exceeds 1% by weight.
Applicable to both OU No. 4 and OU No. 5.
DENIOOI7756.WP5

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Table A-5
ARARs for Air
RSR Corporation Superfund Site
Dallas, Texas Page 5 of 6
Requirement
ARAR?
Justification
2. Action-Specific (Continued)
State (Continued)
Control of Fugitive Dust
30TAC § Il3.9l(a), (b), (c)
Additional Measures to Reduce
Lead Emissions
30TAC § 113.92(1)
Control Requirements for Sur-
faces with Coatings Containing
Lead
30TAC § 111.135
Construction and Demolition
30TAC § 111.145
Yes
Yes
Yes
Yes
All plant roads shall be paved; parking areas and storage areas for materials containing more than
1% lead by weight shall be paved. Open unpaved areas must be vegetated or covered with rock or
crushed aggregate at least three inches deep. Applies if lead content exceeds 1% by weight.
Applicable to OU No. 4 and OU No. 5.
If they occur outside buildings, spills of dust containing more than 1% lead by weight shall be
dampened and cleaned up immediately. Applies if lead content exceeds 1% by weight. Applicable
to both OU No. 4 and OU No. 5.
Applies specifically to abrasive blasting of water storage tanks with coatings containing 2 1% lead.
Specifies emission control requirements. Applies if abrasive blasting is used to decontaminate
structures. Relevant and appropriate for OU No. 4 and OU No. 5.
Applies to properties greater than one acre in size. No person may cause, suffer, allow, or permit
a structure, road, street, alley, or parking area to be constructed, altered, repaired or demolished
without taking the following precautions:
(1) Use of water or suitable oil or chemicals for control of dust during structure demolition
(2) Use of adequate methods such as wet sandblasting and enclosure of work areas during sand-
blasting of structures or other similar operations. Applies to activities associated with building
demolition; applicable to OU No. 4 and OU No. 5 if demolition activities occur.
DEN 10017756 WP5

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Table A-5
ARARs for Air
RSR Corporation Superfund Site
Dallas, Texas
Requirement
ARAR?
Page 6 of 6
Justification
2. Location-Specific
State
General Application;
Proximity of New Construction to
Schools
30TAC § 116.1 II
No
Requires the TACB to consider, in issuing a permit for construction of a facility, any adverse
short-term or long-term side effects than an air contaminant or nuisance odor from the facility may
have on the individuals attending an elementary, junior high, or senior high school within 3,000
feet of the facility. May be TBC since a school is located within 3,000 feet of OU No. 4 facility.
DENIOOI7756 WPS

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                                                                Table A.-6
                                               Numeric Contaminant-Specific ARARs for Air
                                                     RSR Corporation Superfund Site
                                                              Dallas, Texas
              State"
                                           Level I1
                                                  (ppm)
                          Level 2"
                    0»g/m3
        (ppm)
                                                                                                          Federal"
                          Primary
0»g/m3)
(ppm)
                               Secondary
(ppm)
 PM,
     Annual arithmetic mean
                                                   50
                                                     .50
     24-hour maximum
 420
 500
     24-hour average
                                                  150°
                                                    ISO1
     3-hour net average
     concentration
2003
     1 -hour net average
     concentration
4003
 Lead
     3-month
                                                   1.5
                                                     1.5
 Beryllium
     30-day average
                                                 0.01
                                                    0.01
     24-hour average
0.01
0.01
 Notes:

 '"Control of Air Pollution Episodes.  30 TAG Section 118.1.
 "'National Ambient Air Quality Standards.
 "'Ground level Concentrations.  30 TAG Section 111.155.

 •The concentration of any air contaminants is equal to or greater than the levels specified for Level 1 and in case of all air contaminants except
 ozone, meteorological conditions conducive to high air contamination are predicted to continue for at least 12 hours.
 bLevel 2 exists if the executive director determines that an emergency reduction of emissions must be initiated to prevent the presence in the
 atmosphere of any of the air contaminants in the concentrations specified.  These levels could cause significant harm to human health.
 cMay not be exceeded more than once per year, all other NAAQS may  never be exceeded.                                             	
DhNIOOI7747.WP5

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Table A-7
Miscellaneous Location Standards
RSR Corporation Superfund Site
Dallas, Texas Page 1 of 2
Requirement
ARAR??
Justification
1. Location-Specific
Federal
National Historic
Preservation Act
16 U.S.C. § 470
40 C.F.R. § 6.30l(b)
36 C.F.R. Part 800
Archeological and Historic Preservation Act
16 U.S.C. § 469
40 C.F.R. § 6.30l(c)
Historic Sites, Buildings, and Antiquities Act
15 U.S.C. § 461 et sea.
40 C.F.R. § 6.301(a)
Endangered Species Act
16 U.S.C. § 1531 et sea.
50 C.F.R. Part 402
Wilderness Act
16 U.S.C. § 1131 et seo.
50 C.F.R. Part 35
No
Yes
No
No
No
Requires federal agencies to take into account the effect of any federally-assisted
undertaking or licensing on any district, site, building, structure, or object that is
included in or eligible for inclusion in the National Register of Historical Places.
There is no such district, site, building, structure, or object in or near the RSR site;
therefore, the Act is not an ARAR.
Establishes procedures to provide for preservation of scientific, historical, and
archeological data which might be destroyed through alteration of terrain as a result
of a federal construction project or a federally licensed activity or program. If
scientific, historical, or archaeological artifacts are discovered at the site, work in
the area of the site affected by such discovery will be halted pending the
completion of any data recovery and preservation activities required pursuant to the
Act and its implementing regulations.
Requires federal agencies to consider the existence and location of landmarks on
the National Registry of Natural Landmarks to avoid undesirable impacts on such
landmarks. There is no such landmark that will be affected by the proposed
remedy; therefore, the Ac't is not an ARAR.
Requires that proposed action minimize impacts on endangered species within
critical habitats upon which endangered species depend, including consultation with
Department of Interior. No plant or animal endangered species of "critical habitat"
will be impacted by the proposed remedy at the site; therefore, the Act is not an
ARAR.
Requires the administration of federally owned wilderness areas to leave them
unimpacted. There is no federally owned wilderness area that will be impacted by
the proposed remedy; therefore, the Act is not an ARAR.
DEN100I6CC8.WP5

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                                                                                                             Appendix A, Table A-7-Miscellaneous Location Slanda/ds
Table A-7
Miscellaneous Location Standards
RSR Corporation Superfund Site
Dallas, Texas Page 2 of 2
Requirement
ARAR??
Justification
1 . Location-Specific (Continued)
Federal (Continued)
National Wildlife Refuge System
16 U.S.C. §§ 668dd, 668ee
50 C.F.R. Part 27
No
Restricts activities within a National Wildlife Refuge. The proposed remedy will
not affect a National Wildlife Refuge; therefore, these provisions are not ARARs.
State
Antiquities Code of Texas
TEX. NAT. RES. COD. ANN.,
CH. 191
No
Prohibits the taking, altering, damaging, destroying, or excavating of a state
archeological landmark without a contract or permit. Unless a state archeological
landmark is present at the site, the Code is not an ARAR.
DENIOOI6CC8WP5

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         TNRCC LETTER
RSR CORPORATION SUPERFUND SITE
     OPERABLE UNIT No. 5
          APPENDIX F

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Barry R. McBee, Chairman
R. B. "Ralph" Marquez. Commissioner
John M. Baker. Commissioner
Dan Pearson, Executive Director
             TEXAS NATURAL RESOURCE CONSERVATION COMMISSION
                          Protecting Texas by Reducing and Preventing Pollution
                                   November 20, 1996
  Ann Schober
  United States Environmental Protection Agency
  Region 6
  1445 Ross Avenue, Suite 1200
  Dallas, Texas 75202-2733

  Re:   Comments:   Draft Record of Decision for OU 4
  Dear Ann:

  Thomas Benz and I have several minor comments on the Operable Unit 5 (OU 5) Record of
  Decision. Several of these comments are reiterations of OU 4 comments which I think are also
  applicable for OU 5.
  Comment 1:
  Comment 2:
The TNRCC Risk Reduction Rules require deed notice recordation for
Standard 3 cleanups.  The TNRCC recommends that EPA pursue deed
notices and/or deed  restrictions as  part of any  settlement with the
Responsible Parties.

The TNRCC is concerned that if contamination is left in place below 2 feet
after   the  Remedial   Action,   uncontrolled   commercial/industrial
development, (which would undoubtedly involve excavation), may result
in unrecognized exposure to contamination.  The TNRCC suggests that this
problem might be addressed through deed notices or restrictions.

TNRCC recommends limited additional sampling in excavated areas  to
document the level of contaminants remaining, after the Remedial Action.
Otherwise there  will  be no  way of knowing the concentrations  of
contaminants being left onsite below 2 feet.

-------
Ann Schober
Page 2
November 20, 1996
Comment 3:        As we discussed in our telephone conversation, TNRCC suggests that the
                   alternate component of Alternative 3, (concerning a cap that would allow
                   potential redevelopment of the former landfill area), only be implemented
                   by PRPs if they agree to conduct the remediation.  TNRCC is adverse to
                   implementing a more expensive alternative if the component is completed
                   using EPA and TNRCC funds.

Comment 4:        TNRCC recommends that EPA explore the use of property liens in the
                   event that PRPs are unwilling to conduct the remedial activities.

Comments:        The  TNRCC  recommends  the use  of 30 TAG 335 as  ARAR for
                   containment of former surface impoundment, former landfill and slag burial
                   area  located in OU 5.  The above reference State of Texas regulation
                   closure  and post closure care requirements for surface impoundments,
                   waste piles, and landfills.

Thomas and I will present our  recommendations for TNRCC's position on the  OU 5 Draft ROD
immediately. We expect a letter to be signed by the TNRCC Executive Director, which states the
TNRCC position, to be in your hands before  Thanksgiving.

If you have any questions or need further discussion you know our phone numbers.

Sincerely,                                  ^_                ^^
Jeffrey^. Patterson, Project Manager
Superfund Investigation Section
Pollution Cleanup Division
Thomas R. Benz, P.E.
Superfund Engineering Section
Pollution Cleanup Division
JEP/TRB/ls

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    REVISED COST ESTIMATES
RSR CORPORATION SUPERFUND SITE
     OPERABLE UNIT No.  5
          APPENDIX G

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CH2M HILL
RSR Corporation Superfund Sit*
PROJECT NO: TXE6SMO.FS.R4
PREPARED BY E.R.MEYER
RSR CORPORA HOW SUPERRSND SITE . REMEDtA RON OF Oil S

DESCRIPTION

U. FimunvF TO •.•xtuoon* Civma. Sfton-r«m» MoMonng
CAPITAL COSTS:
GENERAL REQUIREMENTS:
General Slteworii:
institutional Controls
Fi» Existing Perimeter Fence
Grounowater Well installation
Survey Well location
SUBTOTAL
CONTINGENCY
SUBTOTAL • CONSTRUCTION COST
PERMITTING « LEGAL
SERVICES DURING CONSTRUCTION
SUBTOTAL • IMPLEMENTATION COST
ENGINEERING • DESIGN COST-
TOTAL • Capital Cott - AlumMtv* 1b
ANNUAL O « M COSTS (FintFin Yunl
Guard Service (24 Houra/Oay. 7 Dayt/Week)
Snort Term Groundwater Momtonng (assumed for five years)
Short-Term Surface water Moratonng (assumed tor five years)
SUBTOTAL
CONTINGENCY
TOTAL • Annual O » M Co«t»<9 Yean) - AHamatN* 1b
ANNUAL OIH COSTS: (Mejrr 25 Years;
Guard Service (24 Hours/Day. 7 Oayt/Weeki
SUBTOTAL
CONTINGENCY
TOTAL • Annual 0 1 M Co«tH 25 V«an) - AKenuttm 1b
lAccixacy Range -50V, .JOSi
QUANTTTY UNIT tAJNIT TOTAL REFERENCE
COST


10% J'60522 $16052


9100 Lf JlSOO 5136500 unx<« ioo> or ••.«««•••«• '•••OIXDX
2 EA S3 000 J6000
1 LS 12000 12.000
J160552
20% J160 552 S32.110
S192.663
5% Si 92 662 66 J9 633
7% JI92 66266 S13486
S215782
6% 119266266 J11560
1227,142

12 MONTH HO 800 00 J 129 600
3 EA SI6OOOO M800
2 EA 160000 $1200
J1J5600
20% J'35600 J27120
1112.720

12 MONTHS $1080000 $129600
$129600
20% $'29600 $25920
(1SS.S20

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1
CH2MHILL
RSR Corporation Sup*rtund Sitt
PROJECT NO: TXEtUtO.FS R4
PREPARED BY E R.MEYER


DESCRIPTION

NET PRESENT VALlie.
YEARO
YEAR 1 '
YEAR 2
YEARS
YEAR 4
YEARS
YEAR 6
YEAR 7
YEAR 8
YEAR 9
YEAR 10
YEAR It
YEAR 12
YEAR 13
YEAR 14
YEAR 15
YEAR 16
YEAR 17
YEAR is
YEAR 19
YEAR 20
YEAR 21
YEAR 22
YEAR 23
YEAR 24
YEAR 25
YEAR 26
YEAR 27
YEAR 28
YEAR 29
YEAR 30
NET PRESENT VALUE (!»»%) • AIMmMIV* 1b




RSH CORPORA now SUPEOFVHD STTE • REWEWA now of ou s
.Accuracy Range •SO"* • -30%i
QUANTITY UNIT I/UNIT TOTAL REFERENCE
COST

J227 342
J 162 720
$162.720
$162.720 '
$162 720
$162.720
$155.520
$155 520
$155520
$155.520
$155.520
$155 520
$155520
$155.520
$155.520
$155520
$155520
$155.520
$155.520
$155.520
$155.520
$155520
$155520
$155520
$155520
$155520
$155520
$155.520
$155.520
$155520
$155520
>2.«4*.2M

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TIM?
CH2M HILL
RSR Corporation Superfund Site
PROJECT NO: TXE6S480 FS R4
PREPARED BY E R.MEYER
RSR CORPORA TOW SUP&VUHD SITE - ftEMEDM TOW Of OU S
(Accuracy Range »50% ' -30%|
DESCRIPTION

tLTtmumt J. B»*lu r/Mdmt o/lwMlnge < Snrara. CoranMM oflMMl
Cmiujmm«l»e Sorfft L«AdfW. 4 Suritr* mpuinimmn Snort «Kf Long- r«o»
ttvMoru*
CAPITAL COSTS.
GENERAL REQUIREMENTS:
General Sltework:
Institutional Controls
Fix Existing Penmeter Fence
Groundwater Well Installation
Survey Well Location
Steam Clean Binary Wrecking Facility (Si.800 SF):
Structural inspection
Structural Modifications 150% of Bunding. Heavy Duty)
Steam Clean Building 2 Times. Level C
Steam Clean Vehicle Maintenance Building (4.MO SF):
Steam Clean Building 2 Times Level C
Pump Water to Frac Tank. Tell & Discharge :
Frac Tanks
Pumping
Sampling
Analysis
Cover Metal* Contaminated Soils :
Cap Area with 2 Thick Clean Matenai
Revegetate
Cap Landfill:
Surface Preparation
Flexible Membrane Liner
2' Thick Clay
Drainage Layer v gravel
Finer layer OS II sand
Protective Cover r soil
0 5' Thick Top Soil
Revegelate
Recap Surface Impoundment:
Evaluate Existing Cap
Recap Area with 2' Thick Clay
2' Thick Top Soil
Pevegeiate
SUBTOTAL
CONTINGENCY
SUBTOTAL • CONSTRUCTION COST
PERMITTING ft LEGAL
SERVICES DURING CONSTRUCTION
SUBTOTAL • IMPLEMENTATION COST
ENGINEERING 4 DESIGN COST
TOTAL • Capital Cost . Attanuratre J
ANNUAL OtH COSTS. (Pint 5 rear*;
•nspection of the cap iboth landfill and surface impoundment)
Short Term Grounowater Monitoring (assumed tor 'ive yearn
Short- Term Surlace water Monitoring •assumed 'or ('ve yearsi
SUBTOTAL
CONTINGENCY
QUANTITY





lOAi


9100
2
1

32
27.900
55800

4.800

'00
1
100
100

109630
34

12
503000
37 259
18610
9315
18630
9315
12

i
3333
3333
i
JOS

5's
*S

6S


4
3
2

:cs
UNIT








LF
EA
LS

MRS
SF
SF

SF

EA
LS
EA
EA

CY
ACRE

ACRE
SF
CY
CY
CY
CY
CY
ACRE

1.S
;Y
Cv
AC9E








:.AR*E^-
£i
= i


I/UNIT





H 560 603


$15 00
S3 000
J2000

J10000
I860
$060

JO 60

Si 14000
sioooooo
S7000
S20000

JI500
SI 500 00

SI 25000
JO 55
JI500
S1SOO
SlSOO
SiSOO
11500
Si 50000

52000000 .
SISOO
515 00
Si 50000
S4 560 503

SS 928 654
SS 928 654

55 928 654


5300 00
5' 50000
WOG30

5' 200
TOTAL REFERENCE
COST




M 56 050


SI 36 500 «««fs i yao's
S50964 95 MEANS 029- 304-0010

$15000 95MEANS02M04-0150
$276650
$556889
S279 444
Si 39 722
S279444
S139.722 ^ciudvt e*xcn«M ex iM IOTMMQ t yto^9
$18000 95 MEANS 029-304-0010

120000
$50 000 -ciu
-------
CH2M HILL
RSR Corporation Superfund Sit*
PROJECT NO: TXE6MBO FS.R4
PREPARED BY E.R.MEYER
                                           RSR CORPOKA nCW SUP&tFUND STTE • REMEUA TION OF OU S
                                                        (Accuracy Range '50% .' -30*t)
DESCRIPTION QUANTITY UNIT VUNfT TOTAL REFERENCE
COST
TOTAL • Annul) O ft M Cotts • AIMmrtv* - 2 (S Y*«n) M.MO

Lonfl-Ttrm Monitoring (N«lt 2S Yiare)
Groundwater monrtonng (2 wells annually i 2
Inspection of the cap (bom landfill ana surface impoundment) '
SUBTOTAL
CONTINGENCY 20%
TOTAL . Annual O 4 M Co«a • Altamattve 2 (23 YMFI)
£A
QUARTERLY

SI 60000
J30000
$4400
S3 200
SI 200
S4400
SB80
S5,2M


-------
CH2M HILL
RSR Corporation Suptrfumt Sit*
PROJECT NO: TXE6SMO.FS.R4
PREPARED BY E.R.MEYER


DESCRIPTION

NET PRESENT VALUE:
YEARO
YEAR 1
YEAR 2
YEAR 3
YEAR 4
YEARS
YEARS
YEAR 7
YEAH 8
YEAR 9
YEAR 10
YEAR H
YEAR 12
YEAR 13
YEAR 14
YEAR 15
YEAR 16
YEAR 17
YEAR ia
YEAR 19
YEAR 20
YEAR 21
YEAR 22
YEAR 23
YEAR 24
YEAR 25
YEAR 26
YEAR 27
YEAR 28
YEAR 29
YEAR 30
NET PRESEHT VALUE 11-5X1 • AIMnwIw 2




RSR CORPORA TIOH SUPERH/WD SITE - REMEDM HOW Of OU 5
(Accuracy Range -50% ' -10%i
QUANTITY UNIT I/UNIT TOTAL REFERENCE
COST

$6995812
$8640
S8.640
18.640
M640
S8640
$5 260
$5280
$5.280
K 280
$5280
$5280
$5280
$5280
SS280
$5280
$5280
$5280
$5280
$5280
$5280
$5280
15 280
$5280
IS 280
$5280
$5280
$5280
$5280
tS.280
$5780
$7,0*1 .521

-------