Superfund Record of Decision Rsr Corp. OU 3 Dallas TX


                                    EPA/ROD/R06-97/124
                                    1997
EPA Superfund
     Record of Decision:
     RSR CORPORATION
     EPA ID: TXD079348397
     OU03
     DALLAS, TX
     09/30/1997

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RECORD OF DECISION

RSR CORPORATION SUPERFUND SITE
OPERABLE UNIT NO. 3
LANDFILLS AND SLAG FILES
DALLAS, TEXAS

Prepared by:
U. S. Environmental Protection Agency
Region 6
Dallas, Texas

DECLARATION FOR THE RECORD OF DECISION
RSR CORPORATION SUPERFUND SITE
OPERABLE UNIT NO. 3
LANDFILLS and SLAG PILES

Statutory Preference for Treatment as a Principal Element
is Not Met and Five-Year Review is Reguired

SITE NAME AND LOCATION

RSR Corporation Superfund Site, Operable Unit (OU) No. 3
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 Operable Unit (OU) No. 3, the location of the landfills and slag piles 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 seg., 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.
3. Copies of the Administrative Record for OU No. 3 are available for public review at three
repositories, one of which is located in the West Branch of the Dallas Public Library and within
the RSR site and near OU No. 3. EPA bases this decision on the results of a Remedial,
Investigation, Feasibility Study, and Human Health Risk Assessment conducted at OU No 3.

The State of Texas, through the Texas Natural Resource Conservation Commission (TNRCC), concurs
with EPA's selected remedy for OU No. 3 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. 3 is part of the five (5) operable units of the RSR Site and consists of three
(3) separate properties where slag, battery chips and/or other smelter waste have been disposed.
Site 1 of OU No. 3, also known as the Westmoreland Road Property, encompasses approximately 50
acres of privately-owned property, and was used for surface dumping of slag, battery chips and
other household and municipal debris. The area formerly designated as Site 2 was a disposal
area physically located within the OU No. 5 property and was included as part of the OU No. 5
investigation and remedy and is not addressed as part of this ROD. Site 3 of OU No. 3, also
known as the Walton Walker Property, encompasses approximately 130 acres of privately-owned
property, where three (3) separate municipal landfills were operated by the City of Dallas from
the mid-1960s through the later 1970s and early 1980s. Presently on Site 3, slag, battery
casings and battery chips are present over much of the ground surface of the landfill
properties. Site 4 of OU No. 3, also known as the Claiborne Boulevard Property, encompasses
approximately 60 acres of privately-owned land, where four (4) separate municipal landfills were
operated. Records indicate the City of Dallas leased this land during the 1950s and 1960s over
various time periods until the mid-1970s. There is evidence of uncontrolled surface dumping of
municipal type debris, along with slag and battery chips on the ground surface. The selected
remedy will address contamination at Sites 1, 3 and 4 of OU No. 3 of the RSR Corporation
Superfund Site.

The major components of the selected remedy include:

Site 1:

! Excavation and removal of slag, battery chips, metals contaminated soils and
sediments exceeding cleanup goals (up to two feet);
Off-site disposal of excavated material in an appropriate landfill;
No Action on the Ground Water Portion of Site 1 of OU No. 3
Site 3:
Containment (protective cap) of portions of the landfill where there is exposed
slag, battery chips, and metals-contaminated soil exceeding cleanup goals;
No Action on the Ground Water Portion of Site 3 of OU No. 3.
Site 4:
! Containment (protective cap) of portions of the landfill where there is exposed
slag, battery chips and metals-contaminated soil exceeding cleanup goals;
! Removal of surficial contamination in Jaycee Park and placement under the protective
cap (nonhazardous) or off-site disposal (hazardous), where cleanup goals are
exceeded;
! No Action on the Ground Water Portion of Site 4 of OU No. 3

Arsenic, antimony and lead, the primary contaminants of concern at Sites 1, 3 and 4 of OU No. 3,
are 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.

STATUTORY DETERMINATIONS

The selected remedy is protective of human health and the environment, complies with federal and
State reguirements that are legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. This remedy utilizes permanent solutions and alternative

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treatment to the maximum extent practicable for this operable Unit.  However, due to the size of
the landfills located on Sites 3 and 4 of OU No. 3, it was determined impracticable to excavate
and treat the chemicals of concern effectively.  Thus, the remedy for Sites 3 and 4 of OU No. 3
does not satisfy the statutory preference for treatment as a principal element of the remedy.

The future land use for Sites 3 and 4 may be limited to industrial use based on current zoning
and/or reasonably anticipated future zoning for Sites 3 and 4.  The current and reasonably
anticipated future land use of Site 1 is residential.  The remedy achieves cleanup levels that
allow most, if not all, of the OU No. 3 sites to be available for the reasonably anticipated
future use of industrial land use  (Sites 3 and 4)  or residential use  (Site 1).

Because this remedy will result in hazardous substances remaining on-site above health-based
levels five-year reviews will be necessary at Sites 3 and 4 of OU No. 3 of the RSR Site to
ensure that the remedy continues to provide adeguate protection of human health and the
environment.  Five year reviews will also be necessary at Site 1, because contamination may
remain at depths greater than two  (2) feet.

THE RECORD OF DECISION
RSR CORPORATION SUPERFUND SITE
OPERABLE UNIT NO. 3
LANDFILLS and SLAG PILES

SIGNATURE AND AGENCY ACCEPTANCE OF THE REMEDY

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DECISION SUMMARY
RSR CORPORATION SUPERFUND SITE
OPERABLE UNIT NO. 3
LANDFILLS and SLAG PILES

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 landfills and slag piles, Operable Unit (OU) No. 3 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 seg. (also
known as Superfund) and consistent with the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), 40 C.F.R. Part 300. The RSR Site is located in west Dallas, Texas and
encompasses an area approximately 13.6 sguare 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. See Figure 1.

For approximately 50 years, a secondary lead smelting facility, located at the southeast corner
of the intersection of Westmoreland Road and Singleton Boulevard, 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.

OU No. 3 of the RSR Site consists of three separate areas (Sites 1, 3 and 4), which include two
(2) former municipal landfills (Sites 3 and 4), and one (1) other disposal area (Site 1) where
slag and battery chips generated from the smelting and battery breaking process were disposed.

Site 1 of OU No. 3, also known as the Westmoreland Road Property, is located on the west side of
the 1000 block of Westmoreland Road, just north of Fort Worth Avenue in the south-central
portion of the RSR site (See Figure 2). Based on the information compiled by EPA, Site 1
encompasses approximately 50 acres and is comprised of five (5) privately-owned properties.
Portions of the eastern side of Site 1 have been used for surface dumping of slag, battery
chips, and other material (i.e. used tires, appliances, and municipal debris). The area where
most of the slag piles are located is partially enclosed by a chain link fence.

Site 3 of OU No. 3 is also known as the Walton Walker Property and is located northwest of Loop
12-(Walton Walker Boulevard) Davis Street intersection, in the far-western portion of the RSR
Site (See Figure 3). Site 3 encompasses approximately 130 acres of privately owned property.
Historical aerial photographs of Site 3 indicate that the area was apparently within the
floodplain of Mountain Creek prior to the creek's diversion to its present location. The
property owners leased the land comprising Site 3 to the City of Dallas, which operated three
(3) sanitary landfills at this location from the mid-1960s through the late 1970s and early
1980s. The Dahlstrom Landfill is a 33.3-acre tract of land at the northern end of Site 3 that
was in operation from 1976 to 1982. This property is now the site of an auto salvage yard.
South of the Dahlstrom Landfill is the 23.6-acre TXI Landfill, which was in operation from 1973
to 1976. The 42.4-acre West Davis Landfill comprises the southern half of Site 3 and was in
operation from 1964 to 1973. Since the TXI and West Davis landfills have closed, they have not
been developed for other uses.

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Site 4 of OU No. 3, also known as the Claibourne Boulevard Property, is located at the northern
terminus of Claibourne Boulevard and in the northwest corner of the RSR Site (See Figure 4).
Encompassing approximately 60 acres, Site 4 is bounded on the west and southwest by the Old
Channel of the West Fork of the Trinity River. Site 4 also includes a nearby property,
Jaycee-Zaragoza Park (Jaycee Park). Historical aerial photographs indicate that prior to
construction of the Trinity River Levee, what is now known as Site 4 appears to have been within
the floodplain of the Trinity River. Most of the area that is now Site 4 appeared to be used
for sand and gravel mining through approximately 1956. The City of Dallas leased this land
during the 1950s and operated four (4) sanitary landfills until the early to mid-1970s.
Landfilling operations apparently were conducted on this property at various intervals between
1956 and 1970. The 3.2-acre Nomas Landfill, located at the northern end of Claibourne Boulevard
was in operation from 1967 to the mid-1970s. The West Dallas Landfill is a 28.4-acre tract
comprising the western half of Site 4. Operation of this landfill began some time after 19S6
and ceased in 1975. In the late 1950s, the Dallas Park Board purchased the property that is now
Jaycee Park and received approval from the City to landfill the area to bring it to grade.
Historical photographs indicate that by 1964, a park, baseball field, and recreation center were
built at this location (Jaycee Park).

After landfilling activities were completed and the larger portion of land comprising Site 4 was
released back to the property owner, it was subdivided. Some of the Nomas lots were sold, but
the area was never developed. Surface dumping (mostly municipal debris) was evident on the
eastern part of Site 4, and slag and battery chips were observed on the ground surface of the
Nomas and West Dallas Landfills.

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 (e.g. battery chips). 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. Slag was generated as part of smelting
process and is made up of oxidized impurities and molten lead. Slag that was not reprocessed in
the smelter furnace and battery chips that were not also reprocessed, were both considered waste
material and reguired disposal.

An extensive review of available historical information concerning the smelter's operation
indicates that from approximately 1934 until 1971 the lead smelting facility and associated
battery wrecking operations were operated by Murph Metals, Inc. or its predecessors. In 1971,
RSR Corporation acguired the lead smelting operation and operated under the name Murph Metals.
RSR continued to operate the smelter and associated battery wrecking operations until the
acguisition 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.

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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.
Conseguently,  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).

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. 3.  The PRPs did not agree to perform or finance these
response actions.  EPA performed the RI/FS for OU No. 3 with funding from the Hazardous
Substance Superfund (Fund).

III.  HIGHLIGHTS OF COMMUNITY PARTICIPATION

EPA has performed public participation activities for OU No. 3 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, and the Baseline Human Health Risk Assessment Report and the Proposed
Plan for OU No. 3 of the RSR Site were released to the public on July 3, 1997.  On or before
July 3, 1997,  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 for Site 1,
Alternative 2 - Removal and Monitoring, for Site 3, Alternative 3 - Protective Cap and
Monitoring and for Site 4, Alternative 3 - Protective Cap, Removal and Monitoring.  These
documents were contained in an Administrative Record File for OU No. 3  (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 July 3, 1997.  The public comment period commenced on July 3,  1997 and
ended on August 4, 1997.  EPA conducted a public meeting on July 24, 1997 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 alternatives for Sites 1, 3 and 4 of OU No. 3 of the
RSR Site, located 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

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based on the Administrative Record for OU No. 3.

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 slag piles 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. 3 of the RSR Corporation Superfund Site. OU No. 3 is comprised
of the three separate properties (Sites 1, 3 and 4) where slag, battery chips and/or other
smelter waste have been disposed. Site 1 encompasses approximately 50 acres of privately-owned
property, which was used for surface dumping of slag, battery chips and other household and
municipal debris. Site 3 encompasses approximately 130 acres of privately-owned property, where
three separate municipal landfills were operated by the City of Dallas from the mid-1960s
through the later 1970s and early 1980s. Slag, battery casings and battery chips are present
over much of the ground surface of the landfill properties. Site 4 encompasses approximately 60
acres of privately-owned land. Records indicate the City of Dallas leased this land during the
1950s and 1960s and operated four separate municipal landfills over various time periods until
the mid-1970s. There is evidence of uncontrolled surface dumping of municipal type debris,
along with slag and battery chips on the ground surface.

Final Records of Decision 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.
A final Record of Decision for OU No. 5 and the ground water portion of OU No. 4 was signed on
April 3, 1997.

This ROD for OU No. 3 is EPA's final decision to address the contamination associated with the
three (3) separate sites that comprise OU No. 3. Potential ingestion, dermal contact and
inhalation of materials present on OU No. 3 of the RSR Site contaminated with lead, arsenic, and
antimony in excess of remedial action 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 present on Sites 1, 3 and 4 of
OU No. 3 of the RSR Site.

V. SITE CHARACTERISTICS

This section presents an overview of the characteristics of OU No. 3 of the RSR Site, the slag
piles/landfills (also referred to herein as the "Sites 1, 3 or 4"). In the discussion of the
Remedial Investigation findings, Sites 1, 3 and 4 will be discussed individually.

This Section contains a summary of the soils, geology, hydrogeology, ground water, topography,
surface water, climate and land use for each of the Sites, followed by a detailed description of

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all of the pertinent features of Sites 1, 3 and 4. 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. 3.

A. Soils

The soil survey of Dallas County, Texas, issued February 1980 by the USDA Soil Conservation
Service (SCS), was used to identify the major soil types on the three sites comprising OU No. 3.
The area specific complexes that were identified for each of the sites are discussed below.

1. Site 1 Soils

Four soil types are found on Site 1. The Eddy-Urban land complex, found at the southern end of
Site 1 is comprised of well-drained soils (clay loam overlying weathered limestone
inter-laminated with clay loam), typically formed at depths up to 12 inches on gently sloping
limestone surface and areas of urban land.

The Eddy-Brackett complex is found on both steep sides of the creek that flows north through the
site, near its origin and is well-drained soil (clay loam, increasing in gravel content)
typically formed at depths up to 20 inches on strongly sloping to moderately steep limestone
slopes, and usually has a dense cover of trees, shrubs, grasses, and woody plants.

The Ferris-Heiden complex is comprised of deep (up to 78 inches) well-drained soils typically
formed on gently rolling to rolling hillsides, and is found farther downstream on the creek
through Site 1. The Ferris soil is formed on the steeper slopes, whereas the Heiden soil (dark
clay grading to a mottled shale clay) is formed in valleys and on lower slopes and ridge tops.

The Trinity Clay, a deep (up to 68 inches) somewhat poorly drained soil (dark gray to grayish
brown clay) typically formed in nearly level, freguently flooded area, is found along the
northern portion of Site 1.

With distance downstream in the drainage basin, soil permeability decreases from moderately slow
(Eddy-Urban complex) to the very slow (Trinity Clay), whereas available water capacity increase
from very low to very high. All soil types except the Trinity Clay are characterized by rapid
runoff and severe erosion hazard potential.

2. Site 3 Soils

Two types of soil are found on Site 3. Ovan clays, found within the former Mountain Creek
drainage basin and near the Dahlstrom Landfill property, are deep (up to 80 inches), moderately
well drained clay soils (dark to very dark grayish brown to olive brown clay) formed in nearly
level areas that are freguently flooded. The unit is characterized by very slow permeability,
high available water capacity, slow runoff, and slight erosion hazard potential.

The Arents loamy soils formed in areas previously mined for sand and gravel (i.e., West Davis
Landfill property), where discarded overburden and/or soil have been used to fill borrow pits.
The resultant surface generally is lower than surrounding landscape, with 1 to 5 percent slopes
and no uniform soil layers. These soils may be described as sandy clay loam, clay loam, loam,
or fine sandy loam in the upper 80 inches of soil horizon; guartz pebbles are common, and
organic matter content is low. They are characterized by moderate permeability.

3. Site 4 Soils

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The entire Site 4 landfill area is characteristic of Arents loamy soils, which formed in areas
previously mined for sand and gravel, where discarded overburden and/or soil has been used to
fill borrow pits. The resultant land surface generally is lower than surrounding landscape,
with 1 to 5 percent slopes and no uniform soii layers. These soils may be described as sandy
clay loam, clay loam, loam or fine sandy loam in the upper 80 inches of soil horizon; guartz
pebbles are common, and organic matter content is low. They are characterized by moderate
permeability, and have medium potential for pasture and urban use.

B. Regional Background Soil Concentrations

Literature sources were reviewed to find the expected background concentrations of selected
inorganics in soil for comparison to concentration detected in the OU No. 3 soil and sediment
samples. Table 1 summarizes the typical regional or background concentrations. Also included
in the table is the arithmetic mean, standard deviation, number of samples on which the data was
based and a calculation of the arithmetic mean plus two standard deviations. It is the
arithmetic mean plus two standard deviations (also called the Upper Tolerance Limit or UTL)
compared with the inorganic concentrations exhibited by the soil and sediment samples.

C. Regional Geology

Throughout Dallas County the geology and landscape are interrelated. The predominant geologic
units are of the Upper Cretaceous Age. Near the RSR Site study area, the formations consist (in
descending order) of the Austin Chalk Formation, the Eagle Ford Shale Formation, the Woodbine
Formation, and the Grayson Marl and Main Street Limestone Formation. The geologic units that
make up the Cretaceous system in north-central Texas form a southeastward-thickening wedge that
extends into the East Texas Embayment. This sedimentary wedge ranges from zero thickness in the
west to nearly 7500 feet in the southeast. Regional dip is 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, in Grayson County, north of Dallas.

Geologic maps of the surface soils indicate the surface expression of the contact between the
top of the Eagle Ford Shale Formation and the overlying Austin Chalk is present within the RSR
Site study area. 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 all three
OU No. 3 sites.

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 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 aguitard overlying the
Woodbine Formation.

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Table
Comparison of OU No. 3 Soil/Sediment  Data  to  Regional
Background Data
RSR Corporation Superfund Site
Operable Unit No.  3
                            Arithmetic
                               Mean
Arsenic
Barium
Berllium
Cadmium b
Chromium
Cobalt
Copper
Lead
Manganese b
Mercury
Nickel
Silver b
Thallium
Vanadium
Zinc
1.1-
150 -
N.D.
N.D.
3.0 -
N.D.
3.0 -
N.D.
<2. 0 -
<0.01
N.D.
N.D.
—
7.0-
5.0-
18
1,000
-7.0
- 11
150
- 30
30
- 30
7, 000
- 0.6E
- 50
-5.0

200
108
                                       52           37           119          130               64.7
                                       39           22           116           83             4,300

Source:   Dragon. J. and Chasson Andrew,  1991.   Elements in North American Soils.   Hazardous  Materials  Control  Resources  Institute.

aGeometric mean

bSoil of contaminous USA, rather than  Texas  soils  only

cMaximim value

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1. Site 1 Geology

The shallow subsurface geology of Site 1 generally begins at the surface with an organic clay
soil overlying the eroded Austin Chalk Formation. The Site 1 boring locations, the Austin Chalk
is approximately 20 to 25 feet thick, and is characterized by weathered zones containing
interbedded laminations of sand, clay, and organic matter. The Austin Chalk unconformably
overlies the Eagle Ford Shale.

2. Site 3 Geology

The shallow subsurface geology of Site 3 generally consists of silty clay, ranging in thickness
from 15 to 25 feet, underlain by a gravelly clay between 1 and 6 feet thick. Underlying this
unit is a silty clay which grades into a silty sand. This interval ranges in thickness from 10
to 35 feet. At borings advanced on the far west side of Site 3 (relatively close to Mountain
Creek) a discontinuous, water-bearing sandy gravel approximately 0.5 to 1 foot thick was found
to exist unconformably over the Eagle Ford Shale. At borings advanced on the east side of Site
3 there appeared to be less alluvial deposition, and the transmissive interval described above
was either less defined or did not exist. Landfill debris was observed primarily in the shallow
subsurface on the Site 3 landfill cells and the thickness of debris varied greatly (ranging from
3 to 39 feet).

3. Site 4 Geology

At Site 4, the shallow subsurface generally begins at the surface with a sandy organic clay,
approximately 1 to 3 feet thick. The underlying unit is a silty clay to clayey silt,
approximately 10 to 25 feet thick, which grades to a silty sand, 1 to 6 feet. The silty sand
overlies a water-bearing gravelly sand, which was encountered at thickness between 0.5 feet and
3 feet. The sand and gravel unconformably overlie the Eagle Ford Shale, the top 0.5 to 3 feet
of which was observed to be weathered.

D. Hydrogeology

In north-central Texas, the two most important water-bearing stratigraphic units are the
Woodbine Group, a minor aguifer, and the Trinity Group, a major aguifer. A major aguifer is
defined as one which yields large guantities of water in a comparatively large area of the
State, and a minor aguifer is defined as one which yields large guantities of water in small
areas, or relatively small guantities of water in large areas of the State. Both aguifers
provide municipal, domestic, industrial, and some irrigation supplies to the north-central
portion of the State. It should be noted that water for Dallas residents is provided by the
City of Dallas water system, which draws its water from surface reservoirs many miles from the
RSR Site.

The Woodbine Aguifer is of Upper Cretaceous age and is composed of sand and sandstone. The
nearest outcrop of the Woodbine Formation in the vicinity of the OU No. 3 Sites is in far
northwestern Dallas County and eastern Tarrant County. Groundwater flow within the Woodbine is
generally to the east. In the vicinity of the RSR Site the depth to the Woodbine from the
ground surface is approximately 200 to 250 feet.

The Trinity Group Aguifer 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

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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 aguifer by the State. The shallow groundwater in the
vicinity of OU No. 3 is not generally considered a water supply aguifer due to its overall low
yield and slightly saline guality. The monitoring wells installed as part of the OU No. 3 RI
generally were completed in the alluvial material overlying the Eagle Ford Shale, which is not
believed to be hydraulically connected to the deeper Woodbine aguifer due to the presence of the
Eagle Ford Shale at thickness of up to 300 feet beneath the site.

E. Groundwater Quality

In the Dallas area, the general guality of groundwater from the Trinity Aguifer 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 guality (high TDS) water from this aguifer in parts of the Dallas-Ft.
Worth area in recent years has been attributed to over-pumpage of the aguifer.

Only the lower part of the Woodbine Aguifer (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 aguifer. In the Dallas area, groundwater from various units of the Woodbine Aguifer is
in the 1,000 to 3,000 mg/1 range for TDS (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 guality. The primary uses of
water derived from the Woodbine are for domestic livestock and public supply. However, due to
(1) an increasing dependance 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 aguifer 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 Aguifers is considered to be
precipitation on outcrop surfaces. Recharge from streams flowing across the outcrop, and
surface-water seepage from lakes, streams, and ponds are considered secondary sources. No
primary recharge areas are located within five miles of OU No. 3. As stated previously, the
outcrop surfaces for the Woodbine and Trinity Formations are located a minimum distance of 10
miles to the west of the RSR study area.

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.

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

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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 not
associated with a particular 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 aguifers.

G. Topography

The RSR Site is located on the margin between two physiographic provinces; the Blackland Prairie
to the east and the Eastern Cross Timbers to the west. The Blackland Prairie was formed on
sediments of the Taylor Marl, the Austin Chalk, and the Eagle Ford Shale Formation; the
physiographic province is characterized by poorly drained soil, and relatively flat to
moderately undulating surfaces that slope to the east. The Eastern Cross Timbers physiographic
province coincides with the Woodbine Formation outcrop (sandstone) and is characterized by low,
rounded, wooded hills along its western margin and gentle slopes along its eastern margin. Most
of the northeastern and northwestern portions of the RSR Site are located on a floodplain
terrace of the Trinity River, and most of western portion is located within floodplain of
Mountain Creek. The following paragraphs describe the topography of each of the three sites
comprising OU No. 3.

1. Site 1 Topography

The topography of Site 1 reflects the local geology. The site is situated near the top of the
White Rock Escarpment, which is the most western outcrop of the relatively resistant Austin
Chalk formation. The ground surface elevation of Site 1 decreases from an elevation of 580 feet
above mean sea level (MSL) in the southern portion to 560 feet MSL in the northern part (See
Figure 5).

2. Site 3 Topography

Historical aerial photographs indicate that the area that is now Site 3 was part of the Mountain
Creek floodplain prior to the creek's diversion to its present location. The diversion appears
to have been completed by the mid-1940s. The topography of the site was affected by the City of
Dallas landfilling activities conducted from the 1960s through the 1980s (illustrated in Figure
6). The ground surface of the Dahlstrom Landfill is approximately 438 to 440 feet above MSL.
The surfaces of the TXI and West Davis Landfills are slightly lower (approximately 430 to 438
feet above MSL) and characterized by moderate-gradient berms and trenches believed to be
remnants of former landfilling activities. The TXI Landfill has some standing water in some of
the trench areas. The ground surface along Mountain Creek is relatively flat (424 to 426 feet

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above MSL) and slopes steeply at the stream channel to approximately 410 above feet MSL.

3. Site 4 Topography

Site 4 appears to be part of the Trinity River floodplain, and historical aerial photographs
indicate that levee construction was in progress in 1938. The topography of Site 4 has been
affected by the City of Dallas landfilling activities conducted in this area from the 1950s
through the 1970s. The topographic features of Site 4 are shown in Figure 7. The West Dallas
Landfill ground surface is between approximately 423 and 426 feet above MSL and relatively
level, and drops sharply near each of the drainages. The elevations of the Nomas Landfill range
from approximately 424 feet to 416 feet above MSL on the southern end of the landfill.
Elevations range from 414 to 417 feet above MSL over the majority of the Vilbig Landfill. The
surface of the Jaycee Park Landfill is virtually level (approximately 416 feet above MSL).

H. Surface Water

The Trinity River and its tributaries are the only major surface water bodies in the vicinity of
the OU No. 3 sites, as shown in Figure 8. There are smaller drainage systems flowing through or
past these sites that eventually discharge to the Trinity River. 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.

1. Site 1 Surface Water

An ephemeral creek flows northern from a storm sewer outfall through Site 1 and discharges to
series of drainage ditches along 1-30 approximately 0.75 mile north of the site. These drainage
ditches transmit water generally north and to the Trinity River at the Hampton Road pumping
station.

2. Site 3 Surface Water

In addition to areas of shallow standing water on the landfills within Site 3, other surface
water bodies on this site include a series of ephemeral creeks recharged by a storm sewer
outfall at the Loop 12-Davis Street intersection. These creeks flow across the site and
discharge to Mountain Creek, which flows north along the western boundary of Site 3 and
discharges into the west Fork of the Trinity River.

3. Site 4 Surface Water

Site 4 is bounded by the Old Channel of the West Fork of the Trinity river and a drainage
channel originating at a storm sewer outfall located at the corner of Iroguois and Gallagher
Streets on the southwest/west and northeast sides. These channels flow generally north and
discharge to a drainage channel located on the south side of the Trinity River Levee, which
flows east along the north side of Site 4.

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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. Land Use and Zoning

The distribution of land uses within the RSR Site is shown on the zoning map presented in Figure
9. The land use of the areas comprising the three OU No. 3 sites are discussed below.

1. Site 1 Land Use

The southwestern portion of Site 1 is presently zoned for light industrial use, which includes
wholesale distribution and storage. The rest of the site is zoned for multi-family use.

2. Site 3 Land Use

The Dahlstrom and TXI Landfill properties located on Site 3 are zoned from agricultural use.
The West Davis Landfill property is currently zoned for light industrial use.

3. Site 4 Land Use

There are four Landfills comprising Site 4 (Vilbig, Nomas, West Dallas, and Jaycee Park). The
Vilbig and Nomas properties are zoned for mobile homes and the West Dallas and Jaycee Park
properties are zoned for single-family residential dwellings. When the City of Dallas
landfilling operations ceased in the early to mid-1970s, some of the property comprising the
Vilbig, Nomas, and West Dallas Landfills was subdivided after being released to the property
owners. These properties were never developed. EPA, in coordination with the TNRCC, is
presently working with the City of Dallas to change the zoning for the landfills on Site 4 to
non-residential use.

K. Nature and Extent of Contamination

As part of the RI, all potential sources and areas of contamination were investigated at each of
the OU No. 3 Sites. These areas included the storm sewers, the surface water and sediments,
surface and subsurface soils, 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. For purposes of discussion of the
OU No. 3 RI, surface soil is defined as the top two (2) inches of soil, and subsurface soil is
defines as the soil material below this two (2) inch horizon.

A summary of the findings of the RI 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.

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3. The RI findings for each of the three (3) OU No. 3 Sites are discussed individually.

Site 1 - Nature and Extent of Contamination

1. Site 1 Storm Sewers and Drainages

Water samples were collected from two (2) locations on Site 1 and a sediment sample was
collected from one (1) location. Figures 10 & 11, respectively, illustrate the locations of
storm water and sediment, samples, along with the concentrations of lead, arsenic and cadmium.
The highest lead concentrations, 410 micrograms per liter (Ig/L) was detected in the
Westmoreland Road inlet sample, whereas the sample from the onsite drainage channel demonstrated
a lead concentration of 32.7 Ig/L. The elevated lead concentration by the inlet sample may be
as a result of runoff from the surfaces of Westmoreland Road and Colorado Boulevard. The
highest concentration of the arsenic (61.1 Ig/L) was detected in the sample from the onsite
drainage, however cadmium was not detected in that sample. The concentration of lead, arsenic
and cadmium detected in the onsite stormwater sediment sample was 523 milligrams per kilogram
(mg/kg), 17.6 mg/kg and 7.1 mg/kg.

2. Site 1 Surface Water and Sediment Results

Surface water samples were collected from Site 1 to determine the nature and extent of any
surface water contamination. Eleven (11) sampling locations were selected on Site 1; seven (7)
were located within the creek that flows north through the site, two (2) were located at the
surface seeps along the eastern bank of the creek and one was located within the drainage
channel that flows east from the cement plant. Figures 12 & 13 illustrate the surface drainage
flow direction and the concentrations of lead, arsenic and cadmium detected in the surface water
and sediment samples, respectively. The range of lead concentrations detected in the surface
water was from 18.5 Ig/L (upgradient) to 318 Ig/L (surface seep). Lead was not detected in
drainage from the cement plant, or from samples downstream of the confluence of this drainage.
Arsenic concentrations were only detected in five (5) of the eleven (11) samples and
concentrations ranged from 27 Ig/L to 187 Ig/L. Sediment samples were also collected from these
eleven (11) surface water locations. Lead was detected in nine (9) samples at concentrations
ranging from 16 mg/kg to 3,904 mg/kg, with the highest concentration detected at a surface seep
location. The concentrations of arsenic ranged from 7.1 mg/kg to 224 mg/kg. The elevated
concentrations are likely the result of surface water runoff coming into contact with slag and
other debris prior to reaching the creek. Site 1 sediment samples were also analyzed for
organic constituents. The highest number of organic analytes were detected in three (3)
samples, two (2) of which were located at and near the seep (location 1A-A002 and 1C-A003) where
darkly discolored soil and hydrocarbon odor were observed.

3. Site 1 Surface and Subsurface Soil Results

Eighty-nine (89) X-Ray Flourescence (XRF) surface soil readings were taken at surface soil grid
locations located on Site 1 primarily in the visible slag and/or battery chip disposal areas.
The XRF lead concentrations ranged from 28 mg/kg to 22,640 mg/kg. Arsenic was detected at only
one (1) XRF location at a concentration of 1,481 mg/kg, and cadmium was detected at only six (6)
XRF locations up to 576 mg/kg. Based primarily on the XRF readings, soil samples from
twenty-five (25) grid locations were collected for laboratory analysis of Target Analyte List
(TAL) inorganics. Figure 14 illustrates the locations of these samples, along with the
concentrations of lead, arsenic, and cadmium detected in the soil samples. Four (4) samples
were also collected from background locations for TAL analysis. The highest soil sample lead

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concentrations were detected from the central and western portions, and were coincident with
areas where slag was observed over much of the ground surface. Arsenic was detected in all of
the Site 1 surface soil samples at concentrations ranging from 10 mg/kg to 7,980 mg/kg, located
in the area where most of the slag was observed. Cadmium concentrations were detected in
seventeen (17) of the samples and ranged from 0.5 mg/kg to 637 mg/kg, also in the area where the
slag was observed. Three (3) surface soils were also analyzed for TCLP inorganics. The results
for the TCLP analysis are also shown in Figure 15. Only lead and cadmium was detected above
regulatory levels (i.e. 5 mg/L for lead and 1 mg/L for cadmium) which define a waste material as
hazardous by the characteristic of toxicity (40 CFR Section 261.664).

The maximum concentrations measured in the surface soils samples located in the four (4)
background locations on Site 1 were 446 mg/kg lead, 22.1 mg/kg arsenic, and cadmium was not
detected.

A total of five (5) subsurface soil samples were collected from borings drilled on Site 1. An
illustration of the locations and range of concentrations of lead, arsenic, and cadmium is
presented in Figure 16. The detected concentrations of these contaminants were higher in the
shallow subsurface samples than in soil collected from deeper intervals. Lead concentrations
ranged from 62.4 mg/kg to 6,540 mg/kg in the 0 to 2 foot interval, and were detected at
concentrations only up to 26.1 mg/kg in samples collected from depths of eleven (11) and
twenty-two (22) feet. Similarly, arsenic and cadmium were detected at concentrations up to 309
mg/kg and 17.7 mg/kg, respectively in the shallow samples, and up to 13.7 mg/kg and 0.31 mg/kg,
respectively, in the deeper samples.

4. Site 1 Ground Water Results

Two monitoring wells were installed on Site 1 at locations relatively close to the creek bank.
These were the only locations where a saturated zone was encountered in soil borings advanced on
Site 1. The wells were screened in weathered Austin Chalk directly above the Eagle Ford Shale.
Well 1A-S022 is screened from 15 to 25 feet and is located at the southern end of Site 1. Well
1A-S083 (screened from 16 to 26 feet bgs) is located near where slag was observed on and beneath
the surface, and where relatively high concentrations of lead and arsenic were exhibited by the
surface and subsurface soil. Figure 17 illustrates the location of these wells, along with the
concentrations of lead, arsenic and cadmium.

Site 3 - Nature and Extent of Contamination

5. Site 3 Surface Water and Sediment Results

Figure 18 illustrates the locations of the surface water and sediment samples collected from
Site 3. Total lead concentrations exhibited by the surface water samples range from 1.2 Ig/L to
1,700 Ig/L. The highest total and dissolved lead concentration was exhibited by the sample
located between the drainage separating the northern and southern cells of the West Davis
Landfill. Other samples collected from this drainage, and from the eastern pond on the TXI
Landfill, a seep on the west side of the TXI Landfill, and from Mountain Creek downstream of
this seep, exhibited relatively high total lead concentrations (up to 191 Ig/L). Piles of
battery casing chips were observed near the TXI landfill pond, and along the drainage separating

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the cells of the West Davis Landfill.

Total arsenic was detected on three (3) Site 3 surface water samples at concentrations ranging
from 16.6 Ig/L to 47.1 Ig/L, and dissolved arsenic was detected in thirteen (13) samples at
concentrations up to 185 ug/L. Similar to the lead results, the higher concentrations of total
and dissolved arsenic were exhibited by the samples collected from the drainage separating the
northern and southern cells of the West Davis Landfill.

Total cadmium was detected in Site 3 surface water samples collected from Mountain Creek at
Davis Street and from a seep on west side of the West Davis Landfill at concentrations of 0.5
Ig/L and 0.98 Ig/L, respectively. Dissolved cadmium was not detected in any of the surface
water samples collected from Site 3.

The locations of the sediment samples collected on Site 3, as well as the concentrations of
lead, arsenic and cadmium detected are illustrated in Figure 19. The range of lead and arsenic
concentrations detected in the samples was 11.3 mg/kg to 2,100 mg/kg, and 4 mg/kg to 55.8 mg/kg,
respectively. For comparison purposes, the maximum lead, arsenic, and cadmium concentrations
expected in regional background soil are 30 mg/kg, 18 mg/kg, and 11 mg/kg, respectively. Other
constituents that were detected at levels higher than the maximum regional background soil
levels, were antimony and copper. Antimony was detected at concentrations up to 26.2 mg/kg
(corresponding maximum background level is 2 mg/kg) and 213 mg/kg for copper (corresponding
maximum background level is 30 mg/kg). The highest concentrations of lead and arsenic detected
in the Site 3 sediment samples were collected from the drainage separating the TXI Landfill from
the northern cell of the West Davis Landfill. Two (2) sediment samples analyzed for TCLP
demonstrated a low detection of lead (0.0165 mg/L), and were below the level used to define a
material as hazardous by the characteristic of toxicity.

6. Site 3 Surface and Subsurface Soil Results

XRF analysis was performed at three-hundred six (306) grid nodes established approximately
one-hundred (100) feet apart on Site 3, over the TXI Landfill, the northern and southern cells
of the West Davis Landfill, and an area adjacent to the West Davis Landfill where battery chips
were observed over much of the ground surface. XRF analysis was not conducted over the
Dalhstrom Landfill, due to the lack of observed evidence of battery chips or slag on the ground
surface, which is paved and covered with gravel (now an auto salvage yard). Lead was detected
at one-hundred sixty-one (161) grid nodes at concentrations ranging from 18 mg/kg to 29,260
mg/kg; arsenic was detected at ninety-six (96) grid nodes at concentrations ranging from 25
mg/kg to 141 mg/kg; and cadmium was detected at only three (3) grid nodes, where concentrations
ranged from 59 to 96 mg/kg.

Sixty-four (64) surface soil samples were also collected from Site 3 for laboratory analysis
(i.e. TAL inorganics). Figure 20 illustrates the locations of these samples, along with the
concentrations of lead, arsenic and cadmium. The concentrations of lead and arsenic detected in
all samples ranged from 16.5 mg/kg to 71,500 mg/kg, and from 5.75 mg/kg 127 mg/kg, respectively.
Cadmium was detected in thirty-two (32) samples at concentrations up to 8.4 mg/kg. The highest
lead concentrations generally coincided with locations where battery chips were observed.

A total of nine (9) Site 3 surface soil samples were analyzed for TCLP inorganics. Lead
concentrations exhibited by two (2) of these samples exceeded the 5 mg/L level used to define a
waste material as hazardous by the characteristic of toxicity.

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The maximum lead and arsenic concentrations detected from the background locations were 36.3
mg/kg and 6.1 mg/kg.

Soil vapor samples were also collected from seven (7) of the boring locations on Site 3 as part
of the landfill gas investigation at OU No. 3. The only organic analytes detected in these
samples were chlorobenzene, methane, and vinyl chloride. Chlorobenzene was detected in three
(3) samples at concentrations up to 6,700 ppm. Vinyl Chloride was detected in four (4) samples
at concentrations up to 5,000 ppm. Methane was detected in nine (9) samples at concentrations
up to 232,000 ppm (with the highest concentration detected by a sample on the east side of the
Dahlstrom Landfill). Vinyl chloride and methane concentrations generally were highest in the
area surrounding the Dahlstrom Landfill, and in the TXI Landfill.

Soil vapor samples collected from ten (10) feet and twenty (20) feet bgs at a background
location exhibited low concentrations of methane (2.8 ppm and 2.0 ppm, respectively). The
sample collected from 20 feet bgs also exhibited a chlorobenzene concentration of 6,700 ppm.

Direct push borings were advanced at sixteen (16) locations around the landfill perimeters on
Site 3, to depths between 4 and 31.5 feet bgs in order to characterize the subsurface
conditions. In addition, twenty-one (21) auger borings were advanced to depths between 13 and
72.5 feet bgs. Figure 21 shows the locations of the subsurface samples, along with the
concentrations of lead, arsenic and cadmium. Detected concentrations of lead generally were
higher in shallow subsurface samples (0 to 3 feet bgs) than in soil from deeper intervals. Lead
concentrations ranged from 7 mg/kg in samples collected from 0 to 3 feet bgs, and up to 82.6
mg/kg in samples collected from depths of 3 to 67 feet. At one (1) boring location (3B-S009),
battery casing chips were observed in soil core samples collected from depths up to 8 feet bgs.
Generally, arsenic concentrations in the shallow subsurface (up to 11 mg/kg) were nearly the
same or slightly higher than arsenic concentrations from greater depths (up to 9.7 mg/kg). In
the subsurface samples cadmium was detected up to 1.3 mg/kg. TCLP lead concentrations exhibited
by four (4) of the nine (9) samples at depths between 0 to 12 feet bgs, ranging from 20.5 mg/L
to 44.1 mg/L, significantly exceeded the 5 mg/L level used to define waste material as hazardous
by the characteristic of toxicity.

The concentration of lead and arsenic detected at the background subsurface soil location was
15.2 mg/kg and 21.5 mg/kg, respectively.

7. Site 3 Ground Water Results

During the Site 3 ground water investigation, eight (8) monitoring wells (two (2) per landfill
cell) were installed in the landfill water-bearing zone on Site 3, at depths ranging from 9 to
40.4 feet bgs. An additional ten (10) wells were installed in the alluvial water bearing zone
at depths ranging from 15 to 72 feet bgs. The locations of these wells, along with the
concentrations of lead, arsenic and cadmium detected in the monitoring wells on Site 3 are
illustrated in Figure 22.

Total lead and arsenic was detected in all seven (7) ground water samples collected from the
water-bearing landfill debris zones, at concentrations ranging from 8.2 ug/L to 20,700 ug/L, and
from 7.5 ug/L to 107 ug/L, respectively. Total cadmium was detected in four (4) of these
samples at concentrations up to 29.5 ug/L. Total Dissolved Solids (TDS) concentrations ranged
from 598,000 ug/L to 4,080,000 ug/L. The high concentrations of lead detected in several wells,
and arsenic and antimony in one (1) well, may be attributed to the presence of waste materials

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in the landfill, including battery chips (which were observed in the core samples at those
locations).

Ground water samples collected from wells screened in the water-bearing alluvial zone exhibited
total lead concentrations ranging from 6.1 ug/L to 31.6 ug/L in six (6) of the eight (8)
samples. Total arsenic was detected in seven (7) samples at concentrations ranging from 3.1
ug/L to 18.3 ug/L, and total cadmium was detected in four (4) samples at concentrations ranging
from 3.1 ug/L to 45.1 ug/L. TE concentrations of these samples ranged from 3,840,000 ug/L to
12,000,000 ug/L.

Site 4 - Nature and Extent of Contamination

8. Site 4 Storm Sewers and Drainages Results

Figures 23 & 24 show the locations of the six (6) storm sewer locations on Site 4, in addition
to the concentrations of lead, arsenic and cadmium detected in the storm water and sediment
samples, respectively. The storm water sample collected from the storm sewer inlet (location
4A-P001), located on the east side of the Vilbig Landfill, displayed elevated levels of
inorganic constituents, including lead, arsenic and cadmium at levels of 3,720 ug/L, 1.05 ug/L
and 13.3 ug/L, respectively. These elevated concentrations may be attributed to high levels of
inorganics present in stormwater runoff from Iroguois and Gallagher streets, or from
uncontrolled surface dumping in the vicinity of the inlet (which was observed during the course
of the RI investigations). The concentrations of lead detected in the other storm water samples
had concentrations that ranged up to 41.1 ug/L. Total arsenic was detected in two (2) other
storm water samples at levels up to 13.5 ug/L and cadmium was not detected in any other storm
water samples from Site 4. The sediment sample concentrations detected on Site 4 ranged from
211 mg/kg to 4,220 mg/kg of lead, 6.2 mg/kg to 7.8 mg/kg of arsenic and 0.73 mg/kg cadmium
(detected in only one sample). The arsenic and cadmium levels were below the expected regional
background levels of 18 mg/kg and 11 mg/kg, respectively.

9. Site 4 Surface Water and Sediment Results

Seven (7) surface water and sediment sampling locations were selected on Site 4; four (4)
located within the drainage that flow east between the north side of Site 4 and the south side
of the Trinity River Levee, and three (3) located within the Old Channel of the West Fork of the
Trinity River. Figures 25 & 26 illustrate the concentrations of lead, arsenic and cadmium
detected in the surface water and sediment samples, respectively. Total lead was detected in
two of the samples collected from the Old Channel of the Trinity River at concentrations of 8
ug/L and 6.1 ug/L, and in three (3) of the samples from the levee drainage at concentrations
ranging from 3.7 ug/L to 8.2 ug/L. Total arsenic was detected in nearly all of the Site 4
surface water samples at levels up to 181 ug/L. Total cadmium was not detected in any of the
Site 4 surface water samples. There was no apparent pattern to the occurrence of the lead and
arsenic in the surface water samples.

In the sediment sampling, lead was detected in four (4) samples at concentrations ranging from
41.7 mg/kg to 265 mg/kg. Arsenic was detected in three (3) samples from the levee drainage at
levels ranging from 7 mg/kg to 19.2 mg/kg and cadmium was only detected in one (1) sample at
concentration of 4.6 mg/kg. Metal concentrations were generally higher in the sediment samples
collected from the levee drainage than those from the Old Channel of the Trinity River. In
particular, lead, arsenic and zinc levels shown by the sample near the northwest corner of Site

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4 were the highest detected in the Site 4 sediment samples. Two (2) of the sediment samples
were analyzed for TCLP, and detected concentrations of lead, arsenic and cadmium were below the
corresponding levels for these constituents used to define a hazardous waste by the
characteristic of toxicity.

10. Site 4 Surface and Subsurface Soil Results

Surface soil grid nodes were established approximately 100 feet apart on Site 4, at the Vilbig
Landfill, the Nomas Landfill, and the West Dallas Landfill and approximately 50 feet apart on
the Jaycee Park for XRF analysis. Lead was detected by XRF above the detection limit up to
2,485 mg/kg and higher levels were exhibited by samples from the center of the West Dallas
Landfill. XRF arsenic was detected at concentrations up to 63 mg/kg, with higher levels shown
by samples collected primarily from the Jaycee Park Landfill and the eastern side of the Vilbig
Landfill. Cadmium was only detected by XRF at five (5) locations at levels up to 79 mg/kg.

The results of the laboratory analysis of surface soil samples for lead, arsenic and cadmium are
illustrated in Figure 27 (northern portion) and Figure 28 (southern portion). Lead detected in
these samples ranged from 9.1 mg/kg to 6,390 mg/kg and arsenic was detected up to 186 mg/kg,
with the highest levels shown by samples from the West Dallas landfill. These elevated
concentrations generally coincided with the presence of battery chips. Cadmium was detected at
concentrations up to 8.7 mg/kg. In addition, six (6) surface soils samples were submitted for
TCLP analysis. Although, inorganic constituents such as lead, arsenic and cadmium were detected
in one (1) or more of the samples for TCLP analysis, none were above regulatory levels.

Three samples were also collected from background locations on Site 4. The concentrations of
lead, arsenic and cadmium detected were 31.5 m/kg, 4.8 mg/kg and not detected, respectively.

On Site 4, nineteen (19) direct push borings were advanced at locations based on the surface
soil XRF results and the proximity of the boring to the expected landfill perimeter. "These
borings were advanced to refusal, which generally occurred at the top of the Eagle Ford Shale
formation, at depths ranging from 7 feet to 27 feet bgs. In addition, fourteen (14) auger
borings were advanced to depths between 14 and 26.5 feet bgs. During both direct push and auger
drilling activities, a total of thirty-two (32) of these samples were submitted for TAL
analysis. An illustration of the detected concentrations of lead, arsenic, and cadmium from the
TAL analysis in the subsurface soil samples is shown in Figure 29. Generally, the inorganic
concentrations were higher in the shallow subsurface samples than in soil from the deeper
intervals. Lead concentrations ranged from 12.6 mg/kg to 11,500 mg/kg in the samples collected
from 0 to 3 feet bgs, and lead detected at concentrations up to 2,060 mg/kg in the samples
collected from 3 to 26.5 feet bgs. Similarly, arsenic and cadmium concentrations were detected
at concentrations up to 114 mg/kg and 15.1 mg/kg, respectively, in samples collected from 0 to 3
feet bgs, and up to 58.5 mg/kg and 4.8 mg/kg, respectively, in samples collected from 3 to 26.5
feet bgs. Four (4) subsurface soil samples were also collected for TCLP analysis. Lead was
detected in all four samples, arsenic detected in one sample and cadmium detected in three
samples. Only one TCLP sample lead level was slightly above the regulatory level used to define
a hazardous waste and that was sample 4B-S003, with a concentration of 5.87 mg/L.

At the background location, located near the northeast corner of Jaycee Park, the levels of

-------
inorganics exhibited by the subsurface soil sample (9 to 12 feet bgs) were 10.2 mg/kg of lead,
5.7 mg/kg of arsenic and cadmium was not detected.

11. Site 4 Ground Water Results

As part of the Site 4 ground water investigation, thirteen (13) monitoring wells were installed.
Four (4) wells were installed on the Vilbig Landfill , two (2) were installed on the Nomas
landfill, five (5) were installed in the West Dallas landfill, and two (2) were installed in the
Jaycee Park landfill. One well located in the Jaycee Park area was designated as the background
well due to the lack of evidence of landfill debris, slag, battery chips or other visual signs
of contamination on the surface or subsurface. Each of the wells were screened in a
water-bearing sand and gravel (which in some locations had been displaced by or mixed with
landfill debris) directly overlying the Eagle Ford Shale, at depths ranging from 13 to 26 feet
bgs. The locations of these wells, along with the levels of lead, arsenic and cadmium detected
in the monitoring wells on Site 4 are shown in Figure 30.

Total lead was detected in all ground water monitoring samples with concentrations ranging from
7.6 ug/L to 2,010 ug/L. Total arsenic was detected in most of the samples at concentrations up
to 142 ug/L, and cadmium was detected in only one sample at 3.4 ug/L. In general, the
distribution of inorganics detected in the Site 4 ground water demonstrated no particular
pattern. Lead and arsenic concentrations were slightly higher along the southern perimeter of
Site 4. Localized elevated concentrations of lead and arsenic, may be attributable to nearby
isolated sources, such as battery chips.

The ground water sample from the background well exhibited total lead and arsenic concentrations
of 7.75 ug/L and 6.5 ug/L, respectively, and cadmium was not detected in this well.

L. Estimated Hydraulic Characteristics of Shallow Ground water at the OU No. 3 Sites

Ground water elevations measured in the Site 1 monitoring wells, combined with the information
on the surface seeps and creeks, were used to estimate that the gradient of the shallow ground
water is to the west and recharging the creek.

The geologic and hydrogeologic information from Site 3 indicates that shallow ground water is
present in both shallow water-bearing landfill debris zones and in water-bearing alluvium,
generally above bedrock. Due to the presence of landfill debris zones and surface water
drainages intercepting ground water flow in the alluvial material, ground water flow contours
for Site 3 could not be developed. However, it is likely the alluvial materials generally
migrate toward Mountain Creek and the nearby drainages.

The shallow subsurface geology and presumed depositional environment of Site 4 is similar to
that of Site 3. The ground water gradient is to the west and to the north, toward the surface
water drainages bounding Site 4.

The monitoring wells installed at Site 1 and several of the wells at Sites 3 and 4 demonstrated
relatively low yield, and several of the wells were pumped dry during well purging. The yield
of the alluvial deposits encountered in the shallow subsurface at the OU No. 3 sites is likely
to be less than one gallon per minute in most places.

The shallow ground water at each of the OU No. 3 sites is not considered a potential drinking
water supply due to the overall low yield, the slightly saline guality and the availability of
the City of Dallas water supply, as well as potable supply permitting reguirements. In

-------
addition, the expected migration pathway is the Trinity River or its tributaries and neither is
used as a drinking water supply. It is on this basis that the shallow ground water beneath the
OU No. 3 sites are not considered to be a potential drinking water supply. Therefore, further
evaluation of the ground water in the Risk Assessment and the Feasibility Study was not
conducted and no action is recommended for the ground water associated with OU No. 3.

VI. SUMMARY OF SITE RISKS

A. Risk Assessment Description

An evaluation of the potential risks to human health and the environment from OU No. 3
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. 3. 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 may be found in the baseline Human Health
Risk Assessment and Ecological Risk Assessment reports for OU No. 3, contained in the
Administrative Record for OU No. 3.

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 surface and subsurface soils and surface water and sediments. The baseline
risk assessment assumed that the reasonably anticipated future land use of OU No. 3, Site 1
would be residential, and Sites 3 and 4 would be industrial. The assumptions for Site 1 and 3
are based on the City of Dallas current zoning map (City of Dallas, 1992 - 1994). Although,
Site 4 is currently zoned as residential, EPA, in coordination with TNRCC, is presently working
with the City of Dallas to change the zoning to non-residential use. Therefore, the potential
risk to the following populations most likely to be exposed at OU No. 3 were evaluated:
site 1
! Current and future child and resident adults;
! Current and future child and adult trespasser;
! Current and future worker.

Site 3

! Current and future child and adult trespasser.
! Current and future worker.

Site 4

! Current and future child and adult trespasser;
! Current and future worker;
! Future child and resident adults (Jaycee Zaragoza Park only)

-------
The risk assessment conducted at OU No. 3 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.

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. 3. This includes data for soil, sediment, dust, and surface water. Ground water
results were not used guantitatively in the risk assessment (see rationale in Section V. (Site
Characteristics) L.5.). Not all data collected as part of the field investigation was used in
the HHRA, such as the XRF data, which is used for screening.

Concentrations of metals detected in surface soil samples 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 Sites 1, 3 and 4 of OU No. 3 are listed in Table
2.

-------
Table 2
Chemicals of Potential Concern
RSR Corporation Superfund Site
Operable Unit No.  3

Page 1 of 4
                                       Site 1
Site 3
Site 4
Surface Subsurface
Chemical Name Soil Soil
Inorganics :
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
Organics :
Acenaphthene
Acenaphthyl ene
Acetone
alpha-BHC
Aldrin
Alpha chlordane
Anthracene
Arochlor-1242

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 X

X X









Sediment

X
X

X
X

X
X
X
X
X
X
X
X
X

X

X



X
X
X

Surface
Water

X
X
X
X

X
X
X
X
X
X
X


X
X
X



X
X
X



Surface
Soil

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

X









Subsurface
Soil

X



X

X
X
X
X

X
X
X
X

X



X

X
X

X
Sediment

X
X

X
X

X
X
X
X
X
X
X
X
X

X






X


Surface Surface Subsurface
Water Soil Soil Sediment

XXX
XXX
XXX
X X
XXX
X X
XXX
XXX
XXX
XXX
XXX
XXX
X X
X X
X X
X
XXX



X
X



X

X
X

X
X

X
X
X
X
X
X
X
X
X

X

X


X
X
X
X

Surface
Water

X
X
X
X

X
X
X
X
X
X
X
X


X
X

-------
Table 2
Chemicals of Potential Concern
RSR Corporation Superfund Site
Operable Unit No,  3

Page 2 of 4
                                           Site 1                                     Site 3                                      Site 4
                         Surface    Subsurface               Surface   Surface Subsurface            Surface     Surface   Subsurface            Surface
       Chemical Name      Soil        Soil        Sediment    Water     Soil      Soil     Sediment   Water       Soil       Soil      Sediment    Water
       Arochlor-1248                                                                          x
       Arochlor-1254                                                      x                   x
       Arochlor-1260                                 x                                                              x          x            x
       Benzo(a)anthtracene                           x                              x         x                                             x
       Benzo(a)pyrene                                x                              x                                                       x
       Benzo(b)fluoranthene                          x          x                   x                               x          x            x
       Benzo(g,h,i)perylene                          x                              x                                                       x
       Benzo(k)fluoranthene                          x          x                                                                           x
       beta-BHC                                                 x                                                                           x
       Bis(2-chloroethyl)ether                                                                x
       Bis (2-ethylhexyl)phthalate                    x          x                   x         x                     x          x            x
       2-Butanone                                    x                                                    x                                 x
       Butylbenzyl phthalate                         x          x                                                                           x
       Carbazole                                     x                                                                                      x
       Carbon disulfide                              x
       Chlorobenzene                                                                                                                                  x
       Chrysene                                      x          x                   x         x                                             x
       4,4'-DDD                                      x                              xx
       4,4'-DDE                                      x                              xx                                             x
       4,4' -DDT                                      x          x                   x         x                                             x
       delta-BHC                                     x                                                    x
       Di-n-butyl-phthalate                          x          x                                                                           x         x
       Di-n-octyl-phthalate                                                         x                                                       x
       Dibenz(a,h)anthracene                         x                                                                                      x
       Dibenzofuran                                                                                                                         x
       1,3-Dichlorobenzene                                      x                                         x                                           x

-------
Site
Subsurface
Soil



1

Sediment
x

x

Surface
Water

x


Surface
Soil



Site
Subsurface
Soil
x


3



Sediment



x
x


Surface
Water
x
x
X

Surface
Soil



Site
Subsurface
Soil



4

Sediment
x



Surface
Water



Table 2
Chemicals or Potential Concern
RSR Corporation Superfund Site
Operable Unit No.  3
Page 3 of 4


                             Surface
       Chemical Name           Soil
       Dieldrin
       Diethylphthalate
       Dimethylphalate
       Endosulfan I                                         x                                            x
       Endosulfan II                                                   x
       Endosulfan sulfate                                   x                                x                                                       x
       Endrin                                                                                            x
       Endrin aldehyde                                      x
       Endrin ketone                                        x                                x                                                       x
       Ethylbenzene                                         x
       Fluoranthene                                         x          x                     x           x                    x           x          x
       Fluorene                                             x                                x                                                       x
       gamma - BHC                                                                           x
       Gamma chlordane                                      x                                x           x        x                                  x
       Heptachlor                                           x
       Heptachlor epoxide       x               x           x                                            x        x                                  x
       2-Hexanone                                           x                                                     x
       Indeno(1,2,3-cd)pyrene                               x                                                                                        x
       Methoxychlor                                                                          x                                                       x
       Methylene chloride                                                                    x                    x
       2-Methynaphthalene                                   x                                            x        x
       4-Methyl-2-pentanone                                 x
       2-Methylphenol
       Nitrobenzene                                                                                                                                  x
       N-Nitrosodiphenylamine                               x
       Phenanthrene                                         x                                            x                                           x
       phenol

-------
Table 2
Chemicals or Potential Concern
RSR Corporation Superfund Site
Operable Unit No.  3
Page 4 of 4
                                                  Site 1                                   Site 3                                      Site  4
                               Surface    Subsurface            Surface    Surface   Subsurface            Surface    Surface  Subsurface                Surface
       Chemical Name             Soil      Soil       Sediment    Water     Soil       Soil      Sediment   Water      Soil       soil        Sediment    Water
       Pyrene                                             x         x                    x           x                  x          x            x
       Tetrachloroethene                                  x
       Toluene                                            x
       Trichloroethene                                                                                                  x          x
       Xylene, mixture                                    x

-------
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, slag and battery
chips and contaminated soils 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 Sites 1, 3 and 4 of OU No. 3 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:

Site 1

! Current and future child and resident adults: incidental ingestion of soil,
inhalation of fugitive dust, and dermal contact with soil.

! Current and future child and adult trespasser: incidental ingestion of soil,
inhalation of fugitive dust, dermal contact with soil; dermal contact with surface
water; and ingestion and dermal contact with sediment.

! Current and future worker: incidental ingestion of soil, inhalation of fugitive
dust, and dermal contact with soil.
Site 3
Current and future child and adult trespasser: incidental ingestion of soil,
inhalation of fugitive dust, dermal contact with soil; dermal contact with surface
water; and ingestion and dermal contact with sediment.

Current and future worker: incidental ingestion of soil, inhalation of fugitive
dust, and dermal contact with soil.
Site 4
! Current and future child and adult trespasser: incidental ingestion of soil,
inhalation of fugitive dust, dermal contact with soil(landfills); dermal contact
with surface water; and ingestion and dermal contact with sediment.

! Future worker: incidental ingestion of soil, inhalation of fugitive dust, and
dermal contact with soil.

! Future child and resident adults (Jaycee Zaragoza Park only): incidental ingestion
of soil, inhalation of fugitive dust, and dermal contact with soil.

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.  Residential, trespasser and worker exposure scenarios evaluated
in the HHRA used standard EPA default exposure parameters for average (typical)  and RME
scenarios.  These parameters are presented in Tables 3,  4 and 5.

Estimation of Lead Intake - Children

EPA's IEUBK model estimates blood-lead levels in children exposed to environmental sources of
lead using site-specific data and/or default values in each medium.  The IEUBK model integrates
exposure to lead from air, drinking water, soil, dust, diet, and paint for each age group.  The
biokinetics section of the model uses monthly total lead uptake to estimate the amount of lead
that occurs in a number of body compartments for each month.  Age-specific mean blood lead
levels are then computed by the model based on this six-compartment biokinetics model of tissue
distribution and excretion of lead.  The IEUBK model sums predicted uptakes over time and
estimates the distribution of blood-lead levels in an exposed population.  According to the
Centers for Disease Control  (CDC),  10 ug/dL is the blood-lead level of concern for children.

-------
Table 2,
Exposure Assumptions-Residential a
RSR Corporation Superfund Site
Operable Unit No. 3

              Exposure Parameter                    Residential-Child (0-6)                            Residential-Adult

                                              Typical Exposure      Reasonable Maximum       Typical Exposure     Reasonable Maximum
                                                                        Exposure                                        Exposure
       Soil/Sediment Ingestion Rate (mg/day)         200                   200                     100                    100
       Inhalation Rate (m 3/day)                       55                      20                     20
       Skin Surface Area (cm 2)                     1,800                 1,800                   5,000                  5,000
       Soil-to-Skin Adherance Factor (mg/cm 2)          0.2                   1                       0.2                    1
       Exposure Freguency (days/year)                 350                   350                     350                    350
       Exposure Duration (years)                       2.2                   6                       9                     30
       Body Weight  (kg)                                15                    15                      70                     70
       Averaging Time-Noncancer (years)                 2.2                   6                       9                     30
       Averaging Time-Cancer (years)                  70                    70                      70                     70

       Source:
       a EPA, 1992 a, unless otherwise noted.

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Table 4
Exposure Assumptions-Trespasser a
RSR Corporation Superfund Site
Operable Unit No. 3
               Exposure Parameter

       Soil/Sediment Ingestion Rate  (mg/day)
       Inhalation Rate (m 3/hour)
       Skin Surface Area (cm 2)
       Soil-to-Skin Adherance Factor (mg/cm 2)
       Exposure Time (hours/day)
       Exposure Freguency (days/year)
       Exposure Duration (years)
       Body Weight  (kg)
       Averaging Time Noncancer  (years)
       Averaging Time Cancer(years)
        Trespasser-Child (7-16)
                    Reasonable Maximum
Typical Exposure         Exposure
        100
           1 b
        5000
          0.2
          1 b
           52
           10
           43
           10
           70
                           Trespasser-Adult
                                   Reasonable Maximum
                Typical Exposure         Exposure
 100
   1 b
5000
   1
 2 b
  52
  10
  43
  10
  70
100
  0.6
5000
 0.2
 1 b
  52
  10
  70
  10
  70
100
   0.
5000
   1
 2 b
  52
  10
  70
  10
  70
6 b
a EPA, 1992 a, unless otherwise noted.

b EPA 1989 b, The inhalation rate corresponds to an average light activity rate for the age group.

c Based on professional judgement or site-specific factors.

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Table 5
Exposure Assumptions-Worker a
RSR Corporation Superfund Site
Operable Unit No. 3
              Exposure Parameter

       Soil/Sediment Ingestion Rate  (mg/day)
       Inhalation Rate (m 3/hour)
       Skin Surface Area (cm 2)
       Soil-to-Skin Adherance Factor (mg/cm 2)
       Exposure Time (hours/day)
       Exposure Freguency (days/year)
       Exposure Duration (years)
       Body Weight  (kg)
       Averaging Time Noncancer  (years)
       Averaging Time Cancer (years)

       Source:
a EPA, 1992 a, unless otherwise noted.

b Based on professional judgement or site-specific factors.
  Current Occupational-Adult
                 Reasonable Maximum
Typical Exposure      Exposure
50
2,
5000
0,
1
52
9
70
9
70

.5

.2
b
b




50
2,
5000
1
2
52
25
70
25
70

.5


b
b




     Future Occupational-Adult
                    Reasonable Maximum
Typical Exposure          Exposure
50
2.5
5000
0.2
8
250
9
70
9
70
50
2.5
5000
1
8
250
25
70
25
70

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Estimation of Lead Intake - Adults

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 et al. (1994). This model uses a biokinetics slope
factor derived from the work of Pocock et al. (1983), who measured blood-lead levels in over
7,000 middle-aged men in 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 egual 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
association is 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

A
Meaning

Known human
carcinogen
Basis

Sufficient evidence of increased
cancer incidence in exposed humans.
Bl
Probable human
carcinogen
Sufficient evidence of increased
cancer incidence in animals, with
suggestive evidence from studies of
exposed humans.
B2
Probable human
carcinogen
Sufficient evidence of increased
cancer incidence in animals, but
lack of data or insufficient data
from humans.
Possible human
carcinogen
Suggestive evidence of
carcinogenicity in animals.
Cannot be
evaluated
No evidence or inadeguate evidence
of cancer in animals or humans.
Noncarcinogen
Evidence of noncarcinogenicity
in humans.
Toxicity values are guantitative 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 toxicity value used to describe the dose-response
relationship for noncancer health effects is the chronic reference doses (RfDs), which are
expressed in terms of mg/kg-day. Tables 6 & 7 lists the chronic RfDs for the chemicals of
concern for the OU No. 3 sites. 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. 3 site are described in Tables 8 & 9 and are expressed as the inverse of mg/kg-day.

-------
Table 6
Toxicity Values- Noncancer Health Effects
Inorganic COPCs
RSR Corporation Superfund Site
Operable Unit No. 3
   Chemical

Aluminum
Antimony
Arsenic
Barium
Beryllium

Cadmium (food)
Cadmium (water)
Chromium III
Chromium VI

Cobalt
Copper
Lead
Manganese  (food)
Manganese  (water)
Mercury
Nickel (soluble salts)
Selinium
Silver
Thallium (c)
    Vanadium
    Zinc
                                    Systemic Toxicity  (mg/kg/day)
                                        Chronic Reference Dose  (RfD)
                               Critical Effect                  Oral         Source
Blood glucose, cholesterol          0.0004        IRIS
Keratosis, hyperpigmentation        0.0003        IRIS
Increased blood pressure              0.07        IRIS
Organ changes, decreased             0.005        IRIS
body weight
Proteinuria                          0.001        IRIS
Proteinuria                         0.0005        IRIS
None observed                            1        IRIS
Increase in tissue chromium          0.005        IRIS
connection

Gastrointestinal irritation          0.037        HEAST
                                         (b)
CNS                                   0.14        IRIS
CNS                                   0.05        IRIS
CNS, kidney                         0.0003        HEAST
Decreased body/organ weight           0.02        IRIS
Hair/nail loss, dermatitis           0.005        IRIS
Argyria                              0.005        IRIS
Increased SGOT (liver),            0.00008        IRIS
increased serum LDH  (blood) ,
alopecia  (hair)
Renal                                0.007        HEAST
Anemia                                 0.3        IRIS
                                                             Inhalation  (a)
                                                                                         0.00014
                                                                                                             Source
                                                                                                               HEAST
                                                                                         0.000014
                                                                                         0.000014
                                                                                         0.000086
IRIS
IRIS
HEAST
HEAST = Health Effects Assessment Summary Tables  (1994c).
IRIS  = Integrated Risk Information System  (1995b).
      = Information not available.
CNS   = Central Nervous System.
(a)     Derived from chronic inhalation reference concentration  (RfC).
(b)     EPA work group considered it inappropriate to develop an RfD for inorganic lead.
(c)     Toxicity values correspond to thallium chloride.

-------
Table 7
Toxicity Values—Noncancer  Health Effects
Organic COPCs
RSR Corporation Superfund Site
Operable Unit No.  3
Page 1 of 3
    Chemical
                              Critical Effect
    Acenaphthene
    Acenaphthylene
    Acetone

    Aldrin
    Anthracene
    Arochlor 1016
    Arochlor 1254
    Benzene
    Benzo(a)anthracene
    Benzo(a)pyrene
    Benzo(b)fluoranthene
    Benzo(g,h,i)perylene
    Benzo(k)fluoranthene
    Bis(2-chlorethyl)ether
    Bis (2-
    ethylhexyl)phthalate
    2-Butanone

    Butylbenzylphthlate
    Carbazole

    Carbon disulfide

    Chlordane

    Chlorobenzene

    Chrysene
    4,4'-DDD
    4,4'-DDE
Increased liver  and  kidney
weights:  neprotoxicity
Liver toxicity
No observed effects
Reduced birth weight
Ocular effects;  distorted
nail growth; immune
system effects
Increased relative  liver
weight
Decreased fetal birth
weight
Significantly increased
liver/body weight and
liver/brain weight  ratios
Fetal
toxicity/malformations
Regional liver hypertrophy
in females
Histopathological  changes
in liver
IRIS

IRIS

IRIS
IRIS
IRIS(1/1/93)
IRIS (1/1/94 )
IRIS

IRIS(5/1/92

IRIS(1994 )




IRIS

IRIS

IRIS
                                                                0.002857143     HEAST

-------
Table 7
Toxicity Values--Noncancer Health Effects
Organic COPCs
RSR Corporation Superfund Site
Operable Unit No.3
Page 2 of 3
          Chemical
    4,4'-DDT
    Di-n-butyl phthalate
    Di-n-octyl phthalate
    Dibenz(a,h)anthracene
    Dibenzofuran
    1,3-Dichlorobenzene
    1,4-Dichlorobenzene
    Dieldrin
    Diethylphthalate
    Dimethylphthalate
    Endosulfan

    Endrin

    Ethylbenzene
    Fluoranthene

    Fluorene
    Heptachlor

    Heptachlor epoxide

    Indeno(1,2,3-cd)pyrene
    Lindane
    Methoxychlor
    4-Methyl-2-pentanone

    Methylene chloride
    2-Methylphenol
 Critical Effect

Liver lesions
Increased mortality
Increased liver and kidney
weights; increase
enzymatic levels
Renal and hepatic effects
Renal effects
Liver lesions
Decreased growth rate,
food consumption, and
altered organ weights
Kidney effects
Weight gain; kidney and
blood vessel effects
Mild liver lesions;
convulsion
Liver and kidney toxicity
Nephropathy; increased
liver weights
Decreased RBC
Liver weight increase in
males
Increased liver/body
weight ratio

Liver and kidney toxicity
Excessive loss of litters
Whole body and liver,
kidney effects
Liver toxicity
Decreased body weights
and neurotoxicity
Systemic Toxicity (mg/kg/day)
     Oral                Source
                                                                                                      Inhalation(a)
                                                          Source
     0.0005
     0.1
     0.02
     0.004
     0.089
     0.1
     0.00005
     0.8
     10
     0.006

     0.0003

     0.1
     0.04

     0.04
     0.0005

     0.000013
     0.0003
     0.005
     0.05

     0.06
     0.05
IRIS
IRIS
HEAST
(b)
DWHA(3/87)
DWHA(3/87)
IRIS
IRIS
HEAST
IRIS(1994)

IRIS

IRIS
IRIS

IRIS
IRIS

IRIS
IRIS
IRIS
HEAST

IRIS
IRIS
0.228571429
IRIS(l/5/94)
0.285714286
                    IRIS
0.022857143

0.857142857
  HEAST

  HEAST

-------
Table 9
Toxicity Values—Cancer Health Effects
Organic COPCs
RSR Corporation Superfund Site
Operable Unit No. 3

Page 1 of 4

         Chemical

                             Weight of
                              Evidence
       Acenapthene
       Acenaphthylene
       Acetone
       Aldrin
       Anthracene
       Arochlor 1016
       Arochlor 1254
       Benzene
       Benzo(a)anthracene
       Benzo(a)pyrene
       Benzo(b)fluoranthene
       Benzo(g,h,i)perylene
       Benzo(k)fluoranthene
       Bis(2-chloroethyl)ether
       Bis (2-
       ethylhexyl)phthalate
       2 Butanone
       Butylbenzylphthaiate
       Carbazole
Carcinogenic Potency (mg/kg-day)  -1

   Source      Oral Slope Factor     Source
NA
D
D
B2
D
NA
NA
A
B2
B2
B2
D
B2
B2
B2
D
C
B2
--
IRIS
IRIS
IRIS
IRIS
--
--
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
HE AST
                       17
                                       IRIS
0.029
0.73
7.3
0.73
0.73
1.1
0.014
IRIS
USEPA(7/93)
IRIS
USEPA(7/93)
USEPA(7/93)
IRIS
IRIS
Inhalation
Slope Factor
                                                        17.15
                                                       0.02905
Source
                                                                     Calc. from unit risk
                                                                     Calc. from unit risk
                                                        1.155
                                                                     Calc. from unit risk
                                                                0.02
                                                                                HE AST

-------
Table 9
Toxicity Values—Cancer Health Effects
Organic COPCs
RSR Corporation Superfund Site
Operable Unit No. 3

Page 2 of 4

         Chemical
       Carbon disulfide
       Chlordane
       Chlorobenzene
       Chrysene
       4,4'-DDD
       4,4'-DDE
       4,4'-DDT
       Di-n-butyl phthalate
       Di-n-octyl phthalate
       Dibenz(a,h)anthracene
       Dibenzofuran
       1,3-Dichlorobenzene
       1,4-Dichlorobenzene
       Dieldrin
       Diethylphthalate
       Dimethylphthalate
       Endosulfan
       Endrin
       Ethylbenzene
Weight of
 Evidence

     NA
     B2
     D
     B2
     B2
     B2
     B2
     D
     NA
     B2
     D
     D
     B2
     B2
     D
     D
     NA
     D
     D
       Carcinogenic Potency (mg/kg-day)  -1

Source       Oral Slope Factor      Source
  IRIS
  IRIS
  IRIS
  IRIS
  IRIS
  IRIS
  IRIS

  IRIS
  IRIS
  IRIS
  HE AST
  IRIS
  IRIS
  IRIS

  IRIS
  IRIS
 1.3

0.0073
 0.24
 0.34
 0.34
  7.3
 0.024
  16
  IRIS

USEPA(7/93)
  IRIS
  IRIS
  IRIS
USEPA(7/93)
  HE AST
  IRIS
                                                                                                      Inhalation
                                                                                                      Slope Factor
                                                       1.295
                                   0.3395
                                                     Source
                                                                    Calc. from unit risk
Calc. from unit risk
                                   16.1
Calc. from unit risk

-------
Table 9
Toxicity Values—Cancer Health Effects
Organic COPCs
RSR Corporation Superfund Site
Operable Unit No. 3

Page 3 of 4

         Chemical

                                Weight of
                                 Evidence

       Fluoranthene                  D
       Fluorene                      D
       Heptachlor                    B2
       Heptachlor epoxide            B2
       Indeno(1,2,3-cd)pyrene        B2
       Lindane                      B2-C
       Methoxychlor                  D

       4-Methyl-2-pentanone          NA
       Methylene chloride            B2
       2-Methylphenol                C
       4-methylphenol                C
       Naphthalene                   D
       Nitrobenzene                  D
       N-Nitrosodiphenylamine        B2
       Phenanthrene                  D
       Polychlorinated biphenyls     B2
       Pyrene                        D

       1,1,2,2 Tetrachloroethane     C
       Toluene                       D
Carcinogenic Potency (mg/kg-day)  -1

           Source     Oral Slope Factor
                   Source
            IRIS
            IRIS
            IRIS
            IRIS
            IRIS
            HE AST
            IRIS
            IRIS
            IRIS
            IRIS
            IRIS
            IRIS
            IRIS
            IRIS
            IRIS
            IRIS

            IRIS
            IRIS
 4.5
 9.1
 0.73
 1.3
                               0.0075
0.0049

 7.7


 0.2
   IRIS
   IRIS
USEPA(7/93)
   HE AST
                                                    IRIS
                    Inhalation
                   Slope Factor
4.55
9.1
                                                              Source
Calc. from unit risk
Calc. from unit risk
                                                                      0.001645
                                                                                       Calc.  from unit risk
   IRIS

   IRIS


   IRIS
                                         0.203
                Calc.  from unit risk

-------
Table 9
Toxicity Values—Cancer Health Effects
Organic COPCs
RSR Corporation Superfund Site
Operable Unit No. 3

Page 4 of 4

        Chemical                          Carcinogenic Potency mg/kg-day)-1

                       Weight of       SourceOral Slope FactorSource     Inhalation  Source
                       Evidence                                          Slope Factor
       Trichloroethene                   B2           HEAST(1991)               0.011             HEAST(1991)            0.00595           Calc.  from unit risk
       Xylene(mixture)                   D               IRIS

       IRIS     = Integrated Risk Information System (1995 unless otherwise noted).
       HEAST    = Health Effects Assessment Summary Tables (1994c unless otherwise noted).
                = Information not available
       USEPA 1993 = Provisional Guidance for Quantitative Risk Assessment of Polycyclic Aromatic Hydrocarbons

-------




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 eguation:

Risk = GDI x SF

where:

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

GDI = 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 70-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 guotient.  By adding the hazard
guotients 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.

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. 3 risk assessment are included in Tables 10, 11, 12, 13. The results of
the risk assessment generally indicate the following:
Site 1
Site 3
The additive estimated lifetime cancer risks for both current and future child and
adult residents related to soil ingestion, inhalation of fugitive dust, and dermal
contact fall within the 10-3 and 10-4 range. The hazard indices for current and
future child resident and the future adult all exceeded one. The hazard index for
the current adult exceeds one.

The additive estimated excess lifetime cancer risks for both current and future
trespassers (children and adults) from soil ingestion, inhalation of fugitive dust,
and dermal contact are within the 10-4 range. The hazard indices for the current
and future child and adult trespassers all exceed one.

For current and future workers at Site 1, the additive estimated excess lifetime
cancer risks related to soil ingestion, inhalation of fugitive dust, and dermal
contact with soil are within the 10-4 range. The hazard indices for both the
current and future worker exposure pathways all exceed one.
For current and future child and adult trespassers, the additive estimated excess
lifetime cancer risks related to soil ingestion, inhalation of fugitive dust, and
dermal contact are within the 10-6 range. All of the hazard indices associated with
the current and future child and adult trespasser exposure to soil are less than
one.

For current and future child and adult trespassers exposed to sediments in the
drainages that traverse Site 3, the additive estimated excess lifetime cancer risks
associated with ingestion and dermal contact are within the 10-6 range. Comparable
risks related to dermal contact with surface water are estimated to be in the 10-7
to 10-8 range. None of the hazard indices associated with exposure to surface water
or sediments exceeded one.

For current workers, the additive estimated excess lifetime cancer risk related to
soil ingestion, inhalation of fugitive dust, and dermal contact range from 10-6 to
10-7 for the RME and typical exposure setting. For future workers at Site 3, the
comparable risks are about 10-5 to 10-6. The hazard indices for both current and
future worker exposure are all less than one.

Like Site 1, the highest estimated risk associated with exposures assumed to occur
on Site 3 are due to arsenic.

-------
Table 10
Site 1 Risk Summary Table
RSR Corporation Superfund Site
Operable Unit No. 3

Page 1 of 6
            Pathway
                                    Typical Lifetime
                                     Excess Cancer
                                          Risk
               RME Lifetime
               Excess Cancer
                  Risk
               Risk Contribution
                 Typical
                 Hazard
                 Index
                RME Hazard
                Index
                  Risk Contribution
       Soil
       Current Residential - Child
       Inhalation
       Ingestion
       Dermal
2E-05
3E-03
1E-09
6E-05
8E-03
1E-08
As-95%
As-99%
1.1E+00
3.9E+02
1.4E-01
1.1E+00
3.9E+02
6.8E-01
  Mn-94%
As-57%; Sb-42%
              Total
                                          3E-03
                                                           9E-03
                                                                                                3.9E+02
                                                                                                                3.9E+02
       Soil
       Current Residential - Adult
       Inhalation
       Ingestion
       Dermal
7E-05
1E-03
2E-09
2E-04
5E-03
4E-08
As-95%
As-100?
 9.1E-01
 4.1E+01
 8.1E-02
9.1E-01
4.1E+01
4.1E-01
                                                  As-57?
                                                          Sb-42%
              Total
                                          1E-03
                                                           5E.03
                                                                                                 4.2E+01
                                                                                                                4.3E+01
       Soil
       Current Trespasser - Child

       Inhalation
       Ingestion
       Dermal
1E-06
4E-04
6E-10
2E-06
4E-04
3E-09
As-100?
 1.1E-02
 l.OE+01
 2.0E-02
2.2E-02
l.OE+01
9.8E-02
                                                  As-57?
                                                          Sb-42%
              Total
                                          4.E-04
                                                           4E-04
                                                                                                 l.OE+01
                                                                                                                l.OE+01

-------
Table 10
Site 1 Risk Summary Table
RSR Corporation Superfund Site
Operable Unit No. 3

Page 2 of 6
            Pathway
                                    Typical Lifetime
                                     Excess Cancer
                                          Risk
               RME Lifetime
               Excess Cancer
                  Risk
              Risk Contribution
                   Typical
                   Hazard
                   Index
               RME Hazard
               Index
                  Risk Contribution
       Soil
       Current Trespasser - Adult

       Inhalation
       Ingestion
       Dermal
4E-07
2E-04
4E-10
7E-07
2E-04
2E-09
As-100%
4.0E-03
6.1E+00
1.2E-02
8.1E-03
6.1E+00
6.0E-02
                                                        As-57?
                                                                Sb-42%
                  Total
                                          2E-04
                                                            2E-04
                                                                                                 6.2E+00
                                                                                                                6.2E+00
       Soil
       Current
       Commercial/Industrial
       Worker
       Inhalation
       Ingestion
       Dermal
1E-06
1E-04
4E-10
7E-06
3E-04
5E-09
As-100%
1.7E-02
3.1E+00
1.2E-02
3.4E-02
3.1E+00
6.0E-02
                                                        As-57%; Sb-42%
                  Total
                                          1E-04
                                                            3E-04
                                                                                                 3.1E+00
                                                                                                                3.2E+00

-------
Table 10
Site 1 Risk Summary Table
RSR Corporation Superfund Site
Operable Unit No. 3

Page 3 of 6
            Pathway
                                    Typical Lifetime
                                     Excess Cancer
                                          Risk
               RME Lifetime
               Excess Cancer
                  Risk
              Risk Contribution
                   Typical
                   Hazard
                   Index
               RME Hazard
               Index
                  Risk Contribution
       Soil
       Future Residential - Child
       Inhalation
       Ingestion
       Dermal
IE-OS
2E-03
1E-09
3E-05
4E-03
2E-08
As-93%
As-100%
1.1E+00
2.8E+02
7.8E-02
1.1E-00
2.8E+02
3.9E-01
   Mn-96%
As-40%; Sb-58%
                  Total
                                          2E-03
                                                            4E-03
                                                                                                 2.8E+02
                                                                                                                2.8E+02
       Soil
       Future Residential - Adult
       Inhalation
       Ingestion
       Dermal
4E-05
7E-04
3E-09
1E-04
2E-03
5E-08
As-95%
As-100%
9.5E-01
3.0E+01
4.6E-02
9.5E-01
3.0E+01
2.3E-01
                                                        As-40%; Sb-58%
                  Total
                                          7E-04
                                                            2E-03
                                                                                                 3.1E+01
                                                                                                                3.1E+01
       Soil
       Future Trespasser - Child

       Inhalation
       Ingestion
       Dermal
5E-07
2E-04
9E-10
1E-06
2E-04
4E-09
 As-100%
1.1E-02
7.2E+00
1.1E-02
2.3E-02
7.2E+00
5.6E-02
                                                         As-40%; Sb-58%
                  Total
                                          2E-04
                                                            2E-04
                                                                                                 7.2E+00
                                                                                                                7.2E+00

-------
Table 10
Site 1 Risk Summary Table
RSR Corporation Superfund Site
Operable Unit No. 3

Page 4 of 6
            Pathway
                                    Typical Lifetime
                                     Excess Cancer
                                          Risk
               RME Lifetime
               Excess Cancer
                  Risk
              Risk Contribution
                   Typical
                   Hazard
                   Index
               RME Hazard
               Index
                  Risk Contribution
       Soil
       Future Trespasser - Adult

       Inhalation
       Ingestion
       Dermal
2E-07
1E-04
5E-10
4E-07
1E-04
3E-09
As-99%
4.2E-03
4.4E+00
6.9E-03
8.4E-03
4.4E+00
3.4E-02
                                                        As-40?
                                                                Sb-58%
                  Total
                                          1E-04
                                                            1E-04
                                                                                                 4.4E+00
                                                                                                                4.4E+00
       Soil
       Future
       Commercial/Industrial
       Worker
       Inhalation
       Ingestion
       Dermal
3E-05
2E-04
2E-09
7E-05
7E-04
3E-08
As-92%
As-100%
6.8E-01
1.1E+01
3.3E-02
6.8E-01
1.1E+01
1.7E-01
                                                        As-40%; Sb-58%
                  Total
                                          3E-04
                                                            8E-04
                                                                                                 1.1E+01
                                                                                                                1.1E+01

-------
Table 10
Site 1 Risk Summary Table
RSR Corporation Superfund Site
Operable Unit No. 3

Page 5 of 6
            Pathway
                                    Typical Lifetime
                                     Excess Cancer
                                          Risk
               RME Lifetime
               Excess Cancer
                  Risk
              Risk Contribution
                         Typical
                         Hazard
                         Index
               RME Hazard
               Index
                  Risk Contribution
       Sediment
       Current/Future Trespasser
       Adult
       Inhalation
       Ingestion
       Dermal
 NA
6E-06
3E-06
 NA
6E-06
2E-05
  As-41%;BaP-30%
BaP-55%;D(a,h)A-28%
  NA
7.6E-02
4.0E-03
  NA
7.6E-02
2.0E-02
                  Total
                                          IE-OS
                                                            2E-05
                                                                                                  8E-02
                                                                                                                 1E-01
       Sediment
       Current/Future Trespasser
       Child
       Inhalation
       Ingestion
       Dermal
 NA
IE-OS
6E-06
 NA
IE-OS
3E-05
  As-41%;BaP-30
BaP-55%;D(a,h)A-28%
 NA
1.1E-01
6.5E-03
  NA
1.1E-01
3.2E-02
As-40%; Sb-58%
                  Total
                                          2E-05
                                                            4E-05
                                                                                                 1.1E-01
                                                                                                                1.4E-01
       Surface Water
       Current/Future Trespasser
       Adult
       Inhalation
       Ingestion
       Dermal
 NA
 NA
1E-06
 NA
 NA
3E-06
                                                                             B(b)F-73%
                          NA
                          NA
                         7.6E-03
                 NA
                 NA
               1.5E-02
                 Total
                                          1E-06
                                                            3E-06
                                                                                                 7.6E-03
                                                                                                                1.5E-02

-------
Table 10
Site 1 Risk Summary Table
RSR Corporation Superfund Site
Operable Unit No. 3
                                                                                            Page 6 of 6
            Pathway
                                    Typical Lifetime
                                     Excess Cancer
                                          Risk
               RME Lifetime
               Excess Cancer
                  Risk
              Risk Contribution
                         Typical
                         Hazard
                         Index
               RME Hazard
               Index
                  Risk Contribution
       Surface Water
       Current/Future Trespasser -
       Child

       Inhalation
       Ingestion
       Dermal

                  Total

As = Arsenic

Sb = Antimony

Mn = Manganese

BaP = Benzo(a)pyrene

D(a,h)A = Dibenz(a,h)Anthracene

B(b)F = Benzo(b)Fluoranthene
 NA
 NA
2E-06

2E-06
 NA
 NA
5E-06

5E-06
BaP-72%; As-26%
  NA
  NA
l.OE-02

l.OE-02
  NA
  NA
2.5E-02

2.5E-02

-------
Table 11
Site 3 Risk Summary Table
RSR Corporation Superfund Site
Operable Unit No. 3
Page 1 of 4
            Pathway
                                    Typical Lifetime
                                     Excess Cancer
                                          Risk
               RME Lifetime
               Excess Cancer
                  Risk
              Risk Contribution
                        Typical
                        Hazard
                        Index
               RME Hazard
               Index
                  Risk Contribution
       Soil
       Current Trespasser - Child
       Inhalation
       Ingestion
       Dermal
2E-08
2E-06
1E-07
5E-08
2E-06
5E-07
 As-78%; Be-15%
3.0E-03
5.6E-02
4.8E-03
5.9E-03
5.6E-02
2.4E-02
                  Total
                                          2E-06
                                                            2E-06
                                                                                                 6.4E-02
                                                                                                                4.0E-02
       Soil
       Current Trespasser - Adult
       Inhalation
       Ingestion
       Dermal
8E-09
1E-06
6E-08
2E-08
1E-06
3E-07
 As-78%; Be-155!
1.1E-03
3.4E-02
2.9E-03
2.2E-03
3.4E-02
1.5E-02
                  Total
                                          1E-06
                                                            1E-06
                                                                                                 3.8E-02
                                                                                                                5.0E-02
       Soil
       Current Commercial/Industrial
       Worker
       Inhalation
       Ingestion
       Dermal
3E-08
4E-07
6E-08
2E-07
1E-06
8E-07
As-78%;Be-15%
4.5E-03
1.7E-02
2.9E-03
9.1E-03
1.7E-02
1.5E-02
                 Total
                                          5E-07
                                                            2E-06
                                                                                                 2.4E-02
                                                                                                                4.1E-02
       Soil
       Future Trespasser - Child

-------
Table 11
Site 3 Risk Summary Table
RSR Corporation Superfund Site
Operable Unit No. 3

Page 2 of 4
            Pathway
       Inhalation
       Ingestion
       Dermal
Typical Lifetime
Excess Cancer
Risk
2E-08
2E-06
1E-07
RME Lifetime
Excess Cancer
Risk
4E-08
2E-06
5E-07
                                                                          Risk Contribution
                                  As-77%; Be-16?
Typical
Hazard
Index
2.9E-03
6E-02
4.0E-03

RME Hazard
Index
5.8E-03
6E+00
2E-02
                                                                                        Risk Contribution
                  Total
                                          2E-06
                                                            2E-06
                                                                                                 7E-02
                                                                                                                6E-00
       Soil
       Future Trespasser - Adult
       Inhalation
       Ingestion
       Dermal
8E-09
9E-07
7E-08
2E-08
9E-07
3E-07
As-77%; Be-155!
1.1E-03
3.7E-02
2.4E-03
2.2E-03
3.7E-02
1.2E-02
                  Total
                                          1E-06
                                                            1E-06
                                                                                                 4.1E-02
                                                                                                                5.1E-02

-------
Table 11
Site 3 Risk Summary Table
RSR Corporation Superfund Site
Operable Unil No.  3

Page 3 of 4
            Pathway
                                    Typical Lifetime
                                     Excess Cancer
                                          Risk
               RME Lifetime
               Excess Cancer
                  Risk
              Risk Contribution
Typical
Hazard
Index
RME Hazard
Index
Risk Contribution
       Soil
       Future Commercial/Industrial
       Worker
       Inhalation
       Ingestion
       Dermal
1E-06
2E-06
3E-07
3E-06
6E-06
4E-06
1.7E-01
8.9E-02
1.2E-02
1.7E-01
8.9E-02
5.8E-02
                  Total
                                          3E-06
                                                            IE-OS
                                                                                                 2.7E-01
                                                                                                                3.2E-01
       Sediment
       Current/Future Trespasser
       Adult
       Inhalation
       Ingestion
       Dermal
 NA
1E-06
5E-08
 NA
1E-06
2E-07
  NA
2.8E-02
1.4E-03
  NA
2.8E-02
7.1E-03
                  Total
                                          1E-06
                                                            1E-06
                                                                                                 2.0E-02
                                                                                                                3.5E-02
       Sediment
       Current/Future Trespasser
       Child
       Inhalation
       Ingestion
       Dermal
 NA
2E-06
8E-08
 NA
2E-06
4E-07
  NA
4.5E-02
2.3E-03
  NA
4.5E-02
1.2E-02
                 Total
                                          2E-06
                                                            2E-06
                                                                                                 4.7E-02
                                                                                                                5.7E-02

-------
Table 11
Site 3 Risk Summary Table
RSR Corporation Superfund Site
Operable Unit No.  3
Page 4 of 4
            Pathway
                                    Typical Lifetime
                                     Excess Cancer
                                          Risk
               RME Lifetime
               Excess Cancer
                  Risk
              Risk Contribution
Typical
Hazard
Index
RME Hazard
Index
Risk Contribution
       Surface Water
       Current/Future Trespasser
       Adult
       Inhalation
       Ingestion
       Dermal
 NA
 NA
4E-08
 NA
 NA
9E-08
 NA
 NA
9.3E-04
 NA
 NA
1.9E-03
                  Total
                                          4E-08
                                                            9E-08
                                                                                                 9.3E-02
                                                                                                                1.9E-03
       Surface Water
       Current/Future Trespasser
       Child
       Inhalation
       Ingestion
       Dermal
 NA
 NA
7E-08
 NA
 NA
1E-07
 NA
 NA
1.5E-03
 NA
 NA
3E-03
                  Total
                                          7E-08
                                                            1E-07
                                                                                                 1.5E-03
                                                                                                                3E-03

-------
Table 12
Site 3 Risk Summary I able
RSR Corporation Superfund Site
Operable Unit No. 3

Page 1 of 5
            Pathway
                                    Typical Lifetime
                                     Excess Cancer
                                          Risk
               RME Lifetime
               Excess Cancer
                  Risk
              Risk Contribution
                        Typical
                        Hazard
                        Index
               RME Hazard
               Index
                  Risk Contribution
       Soil
       Current Resident - Child
       Inhalation
       Ingestion
       Dermal
4E-07
IE-OS
3E-08
1E-06
4E-05
4E-07
 Cr-77%; As-20%
 As-85%; Be-14%
2.8E-01
1.6E+00
5.3E-03
2.8E-01
1.6E+00
2.7E-02
As-50%;Sb-22%
                  Total
                                          IE-OS
                                                            4E-05
                                                                                                 2E+00
                                                                                                                2E+00
       Soil
       Current Resident - Adult
       Inhalation
       Ingestion
       Dermal
1E-06
6E-06
7E-08
4E-06         Cr-77%; As-20%
2E-05         As-85%; Be-14%
1E-06       PCB-74%;  B(b)F-25!i
                        2.4E-01
                           E-01
                        3.2E-03
               2.4E-01
               1.7E-01
               1.6E-02
                  Total
                                          7E-06
                                                            3E-05
                                                                                                 4E-01
                                                                                                                4E-01
       Soil
       Current Trespasser - Child

       Inhalation
       Ingestion
       Dermal
2E-08
2E-06
2E-08
4E-08
2E-06
1E-07
As-85%; Be-14%
2.9E-03
4.0E-02
7.6E-04
5.9E-03
4.8E-02
3.8E-03
                 Total
                                          2E-06
                                                            2E-06
                                                                                                 4E-02
                                                                                                                5E-02
       Soil
       Current Trespasser - Adult

-------
Table 12
Site 4 Risk Summary Table
RSR Corporation Superfund Site
Operable Unit No. 3

Page 2 of 5
            Pathway
                                    Typical Lifetime
                                     Excess Cancer
                                          Risk
               RME Lifetime
               Excess Cancer
                  Risk
              Risk Contribution
                        Typical
                        Hazard
                        Index
               RME Hazard
               Index
                  Risk Contribution
       Inhalation
       Ingestion
       Dermal
7E-09
1E-06
1E-08
1E-08
1E-06
6E-08
 As-85%; Be-145!
1.1E-03
2.6E-02
4.7E-04
2.2E-03
2.6E-02
2.3E-03
                  Total
                                          1E-06
                                                            1E-06
                                                                                                 3E-02
                                                                                                                3E-02
       Soil
       Future Trespasser - Child

       Inhalation
       Ingestion
       Dermal
2E-08
2E-06
2E-08
5E-08
2E-05
1E-07
 As-86%; Be-133
3.0E-03
5E-02
8.1E-04
6.1E-03
5E-02
4.0E-03
                  Total
                                          2E-06
                                                            2E-06
                                                                                                 5E-02
                                                                                                                6E-02
       Soil
       Future Trespasser - Adult

       Inhalation
       Ingestion
       Dermal
8E-09
1E-06
IE-OS
2E-08
1E-06
6E-08
As-86%; Be-13%
1.1E-03
3.0E-02
5.0E-04
2.2E-03
3.0E-02
2.5E-03
                 Total
                                          1E-06
                                                            1E-06
                                                                                                 3E-02
                                                                                                                3E-02
       Soil
       Future Commercial/Industrial
       Worker

-------
Table 12
Site 4 Risk Summary Table
RSR Corporation Superfund Site
Operable Unit No.  3

Page 3 of 5
            Pathway
       Inhalation
       Ingestion
       Dermal
Typical Lifetime
Excess Cancer
Risk
1E-06
2E-06
5E-08
RME Lifetime
Excess Cancer
Risk
3E-06
7E-06
7E-07
                                                                          Risk Contribution
                                  Cr-80%;  As-17%
                                  As-86%;  Be-13%
Typical
Hazard
Index
1.8E-01
7.4E-02
2.4E-03

RME Hazard
Index
1.8E-01
7.4E-02
1.2E-02
                                                                                        Risk Contribution
                  Total
                                          4E-06
                                                            IE-OS
                                                                                                 3E-01
                                                                                                                3E-01
       Sediment
       Current/Future Trespasser
       Child
       Inhalation
       Ingestion
       Dermal
 NA
3E-06
9E-07
 NA
3E-06
4E-06
  As-52%; Be-16%
BaP-52%; D(a,h)A-
       26%
  NA
3.8E-02
1.9E-03
  NA
3.8E-02
9.2E-03
                  Total
                                          4E-06
                                                            7E-06
                                                                                                 4E-02
                                                                                                                5E-02

-------
Table 12
Site 4 Risk Summary Table
RSH Corporntion Superfund Site
Operable Unit No.  3

Page 4 of 5
            Pathway

       Sediment
       Current/Future Trespasser-
       Adult
                                    Typical Lifetime
                                     Excess Cancer
                                          Risk
               RME Lifetime
               Excess Cancer
                  Risk
              Risk Contribution
                       Typical
                       Hazard
                       Index
               RME Hazard
               Index
                  Risk Contribution
       Inhalation
       Ingestion
       Dermal
 NA
2E-06
5E-07
 NA
2E-06
3E-06
  As-52%; Be-16%
BaP-52%; D(a,h)A-
       26%
  NA
2.3E-02
1.1E-03
  NA
2.3E-02
5.7E-03
                  Total
                                          2E-06
                                                            4E-06
                                                                                                 2E-02
                                                                                                                3E-02
       Surface Water
       Current/Future Trespasser
       Child
       Inhalation
       Ingestion
       Dermal
 NA
 NA
6E-07
 NA
 NA
1E-06
                                                                            As-100%
                         NA
                         NA
                       1.2E-02
                 NA
                 NA
               2.4E-02
                  Total
                                          6E-07
                                                            1E-06
                                                                                                 1E-02
                                                                                                                2E-02

-------
Table 12
Site 4 Risk Summary Table
RSR Corporation Superfund Site
Operable Unit No. 3
            Pathway
                                    Typical Lifetime
                                     Excess Cancer
                                          Risk
               RME Lifetime
               Excess Cancer
                  Risk
                                Page 5 of 5
                                     Typical
                                     Hazard
              Risk Contribution      Index
                RME Hazard
                Index
                   Risk Contribution
       Surface Water
       Current/Future Trespasser -
       Adult

       Inhalation
       Ingestion
       Dermal

                  Total

As = Arsenic

Be = Beryllium

Cr = Chromium

Sb = Antimony

PCB = Polychlorinated biphenyl

BaP = Benzo(a)pyrene

B(b)F = Benzo(b)fluoranthene

D(a,h)A = Dibenzo(a,h)Anthracene
 NA
 NA
4E-07

4E-07
 NA
 NA
8E-07

8E-07
   NA
   NA
7.3E-03

7E-03
   NA
   NA
1.5E-02

2E-02

-------
Table 13
Site 4 - Jaycee Zaragoza Park Risk Summary Table
RSR Corporation Superfund Site
Operable Unit No. 3
               Pathway

       Soil
       Current Residential - Child
                                    Typical Lifetime
                                   Excess Cancer Risk
              RME Lifetime
              Excess Cancer
                  Risk
             Risk Contribution
                  Typical     RME
                  Hazard     Hazard
                   Index     Index    Risk Contribution
       Inhalation
       Ingestion
       Dermal
3E-07
2E-05
  NA
9E-07
4E-05
  NA
        Be-113
3.4E-01
2.1E+00
1.4E-03
3.4E-01
2.1E+00
7.1E-03
                                       As-477?
                                                Sb-35%
            Total
                                         2E-05
                                                          4E-05
                                                                                            2E+00
                                                                                                       2E+00
       Soil
       Current Residential - Adult
       Inhalation
       Ingestion
       Dermal
1E-06
7E-00
  NA
4E-06
2E-05
  NA
Cr-71%; As-26%
As-89%; Be-11%
2.9E-01
2.2E-01
8.5E-04
2.9E-01
2.2E-01
4.3E-03
            Total
                                         8E-06
                                                          3E-05
                                                                                           5.1E-01
                                                                                                      5.1E-01
       Surface Water
       Current/Future Trespasser
       Child
       Inhalation
       Ingestion
       Dermal
  NA
  NA
7E-09
  NA
  NA
1E-08
                     NA
                     NA
                  1.2E-04
             NA
             NA
           2.4E-04
            Total
                                         7E-09
                                                          IE-OS
                                                                                           1.2E-04
                                                                                                      2.4E-04
As = Arsenic
Be = Beryllium
Cr = Chromium
Sb - Antimony

-------
Site 4 Exclusive of Jaycee Zaragoza Park

! For the current and future child and adult trespasser within the defined exposure
are, the additive estimated excess lifetime cancer risks associated with soil
ingestion, inhalation of fugitive dust, and dermal contact fall within the 10-6
range. None of the hazard indices for this scenario exceeded one.

! For the current and future child and adult trespassers, the additive estimated
excess lifetime cancer risks related to sediment ingestion and dermal contact and
dermal contact with water, all are within the 10-6 to 10-7 range. None of the
hazard indices associated with these pathways exceeded one.

! For future workers, the additive estimated excess lifetime cancer risk due to soil
ingestion, inhalation of fugitive dust, and dermal contact are within the 10-5 to
10-6 (RME and typical, respectively). The corresponding hazard indices are less
than one.

! As for Sites 1 and 3, arsenic is the primary contributor to risk at this portion of
Site 4. However, organic compounds including PCBs, and benzopyrene also contribute
to dermal risk estimates for soil exposure.

Site 4 Jaycee Zaragoza Park

! For current adult and child residents, the additive estimated excess lifetime cancer
risks associated with soil ingestion and inhalation of fugitive dust are within the
10-5 to 10-6 range (RME and typical). The hazard indices for current resident
children exposed to soil exceed one; the hazard indices for the current adult
residents are less than one. Arsenic and antimony in surface soil are the primary
contributors leading to the hazard index greater than one for the current resident
child.

! For the current and future child trespasser exposed to surface water in storm sewers
within the exposure area, the estimated excess lifetime cancer risk associated with
dermal contact are in the 10-8 to 10-9 range. None of the hazard indices exceed
one.

-------
Exposure to Lead

Risk from exposure to lead in soil for the sites in OU No. 3 was evaluated for children in Sites
1 and 4 (Jaycee Zaragoza Park) and adult workers in Sites 3 and 4 (landfill areas). The IEUBK
model was used to estimate child exposure to lead. The adult-lead exposure was evaluated using
the Bowers model with default input parameters provided by EPA Region 8.

Child Lead Exposure

Table 14 summarizes the estimated blood-Pb concentrations that could result based on exposure to
soil at Sites 1 and 4 under current and future conditions. The input parameters to the IEUBK
model were combined with site-specific soil-lead levels to estimate values presented in Table
14. Results indicate that for Site 1 under either current or future use conditions, exposure to
lead in soil yields predicted blood-PB distributions where more than five (5) percent of the
exposed population of children ages zero to seven (7) could exhibit a blood-lead concentration
greater than 10 ug/dL.

Adult Lead Exposure

For adult exposure to lead, the data collected for each Site where adult workers were identified
as receptors were compared to a risk-based lead concentration developed using the Bowers model.
Unlike the IEUBK model which predicts a blood-lead distribution, the EPA-revised version of the
Bowers model estimates the soil-lead concentration for a worker population where no more than 5
percent exhibit a blood-lead greater than 10 ug/dL. The corresponding geometric soil-lead level
is roughly 2,000 mg/kg. Several of the soil (surface and subsurface) samples on Sites 1, 3 and
4 exceeded the 2,000 mg/kg level.

-------
Table 14
IEUBK Model Results
         Site
        Current
  Media

Surface soil
Average Soil-Pb
     (mg/kg)

    11,112
  Predicted
Geometric Mean
  Blood-Pb
  (Ig/dL)

   42.5
Percent of
Population
>10 Ig/dL

  99.79
          1
        Future
  Surface and
Subsurface soil
    10,286
                                                              40.7
                                                                               99.79
        Current
      and Future a
                     Jaycee Zaragoza Park
                    Surface soil
                                              408
                                                               4.0
                                                                                2.25
Notes:  Model default values are presented in Table 4-7.
at birth is assumed to be 2.5 Ig/dL.
                                   Air concentration - 0.055 ug/m 3.   Multi-source dust model assumes 45% soil/55% dust.   Mother's blood Pb
a Site-specific model inputs measured as part of the RSR Site OU No. 1 (Subarea 3)  RI were used in lieu of default parameters.   Siie-specific input values
included a dust-to-soil ratio of 21 percent and a water concentration of 3.0 Ig/L.   The dust-to-soil ratio was estimated based on all in-home sampling for OU No.
1; the water concentration was based on the average concentration for homes in Subarea 3.

-------
G. Uncertainties Associated with Human Health Risk Calculations

Uncertainty in the risk assessment is a function of both the "state-of-the-practice" of risk
assessment in general, and the uncertainty specific to the level of understanding of the RSR
Corporation Superfund site. The risk assessment is subject to uncertainty from a variety of
sources including the following:

! Sampling, analysis and data validation
! Fate and transport estimation
! Exposure estimation
! Toxicological data
! Blood-lead model

Table 15 summarizes the general and site-specific uncertainties in the risk assessment.

H. Ecological Risks

An ecological risk assessment (ERA) was also conducted for OU No. 3 to guantitatively 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 slag piles/landfills pose a risk to the
environment in the absence of remedial action. A summary is provided in the following
paragraphs. For a full description of the ERA, refer to the ERA report, which can be found in
the Administrative Record for OU No. 3.

OU No. 3 includes three sites that contain both terrestrial and aguatic habitat areas. In
general terrestrial habitats for all sites are disturbed in many areas by historical and/or
ongoing human activity. The majority of the aguatic areas are intermittent and can be dry
several months of every year. Many of the drainages are fed by stormwater runoff. To determine
exposure and risk conditions to aguatic receptors, an evaluation of surface water and sediment
COPC occurrence was conducted. Ground water and storm sewer media were not evaluated because it
was determined that aguatic receptors would be minimally exposed to these media.

A preliminary site investigation was conducted to determine the occurring ecological receptor
populations. The predominant populations were comprised of opportunistic mammals (i.e. rats,
deer mice and house mice) and opportunistic aguatic species (fathead minnows, mosguito fish and
crayfish). A guantitative 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 guality criteria and sediment toxicity
benchmarks (for the aguatic assessment).

-------
Table 15
Uncertainties Associated With Human Health Risk Estimations
RSR Corporation Superfund Site
Operable Unit No. 3
Page 1 of 2
            Uncertainty Factor

I.  Exposure Assessment
    Exposure assumptions
  Use of applied dose to estimate risks
   Effects of Uncertainty


May under- or overestimate risk
May over- or underestimate
risks
    Population characteristics
    Intake
    II. Toxicity Assessment
    Slope factor
    Toxicity values derived from animal
    studies
May over- or underestimate
risks
May underestimate risks
May overestimate risks
May over- or underestimate
risks
    Toxicity values derived primarily from   May over- or underestimate
    high doses; most exposures are at low    risks
    doses
        Comment
Assumptions regarding media
intake, population
characteristics, and exposure
patterns may not characterize
exposures.
Assumes that the absorption of
the chemical is the same as it
was in the study that derived the
toxicity value.  Assumes that
absorption is eguivalent across
species (animal to humans).
Absorption may vary with age
and species.
Assumes weight, lifespan, inges-
tion rate,  etc., are potentially
representative for a potentially
exposed population.
Assumes all intake of COPC is
from the exposure medium being
evaluated  (no relative source
contribution).

Slope factors are upper 95th per-
cent confidence limits derived
from a linearized model.
Considered unlikely to
underestimate risk.
Extrapolation from animal to
humans may induce error
because of differences in
pharmacokinetics, target organs,
and population variability.
Assumes linear at low doses.
Tends to have conservative
exposure assumptions.

-------
Table 15
Uncertainties Associated With Human Health Risk Estimations
RSR Corporation Superfund Site
Operable Unit No. 3
Page 2 of 2

Uncertainty Factor Effects of Uncertainty  Conunent

II. Toxicity Assessment (Continued)
    Toxicity values
    Toxicity values derived from
    homogeneous animal populations
May over- or underestimate
risks
May over- or underestimate
risks
    Not all chemicals at the site have toxicity   May underestimate risk
    values

III. Risk Estimation
    Estimation of risks across exposure
    routes
    Cancer risk estimates—no threshold as-
    sumed
    Cancer risk estimate—low dose linearity

    Adult lead exposure guantified using
    Bowers,  et al.  (1994)
May under- or overestimate risk



May overestimate risks

May overestimate risks

May under- or overestimate risk
Not all values represent the same
degree of certainty.  All are sub-
ject to change as new evidence
becomes available.

Human populations may have a
wide range of sensitivities to a
chemical.
These chemicals are not ad-
dressed guantitatively.
Some exposure routes have
greater uncertainty associated
with their risk estimates than
others.
Possibility that some thresholds
do exist.
Response at low doses is not
known.
Model used has not been
formally adopted for use by EPA
to assess adult lead exposure
Until the model is validated, the
results should be viewed as
uncertain.

-------
Inorganic COPCs were selected by comparison to regional background data for soils and sediment.
Because there were no appropriate background concentrations for surface water, this step was not
used for surface water COPC determination. All detected organic COPCs (in all media) were
retained for analysis within the ERA.

An evaluation of surface water and sediment exposure and risk to aguatic life was conducted. In
addition, an evaluation of surface water and surface soil exposure and risk to terrestrial life
was conducted. Exposure of aguatic and terrestrial receptors to ground water and storm sewer
media was not evaluated due to the high uncertainty of these exposure pathways. For the
determination of aguatic risk, the surface water and sediment exposure point concentration was
compared directly to ambient water guality criteria and sediment toxicity benchmark values,
respectively. Both the acute and chronic ambient water guality criteria were used for
comparison to COPC surface water concentrations to develop a range of hazard guotients within
the risk characterizations. Similarly, a range of sediment hazard guotients also were used to
bracket the range of risk attributable to aguatic life exposure. An evaluation of surface water
and surface soil exposure and risk to terrestrial life was conducted by comparison of the
surface water exposure point concentrations to literature-derived wildlife benchmark values, and
by comparison of a calculated exposure dose for ingested soil and contaminated food to diet
benchmark values. Observed surface water COPC and calculated diet concentrations were compared
to literature-derived, no observed adverse effect levels (NOAELs) and lowest observed adverse
effect levels (LOAEL) to determine risk.

Risk was guantified using the hazard guotient method. If the resulting guotient was greater
than one (1), the analyte was considered to contribute to potential ecological risk. Results
for the evaluation of COPC risk to aguatic and terrestrial life were as follows:
Site 1
! The presence of manganese in surface water is of concern due to the potential threat
to aguatic life.

! The presence of lead in sediment is concern due to potential threat to aguatic life.

! The presence of antimony, arsenic and lead in soil is of concern due to the
potential threat to deer mice.

! The presence of antimony, arsenic, lead, and copper, and zinc in soil is of concern
due to the potential threat to terrestrial plants.
Site 3
! The presence of lead and manganese in surface water is of concern due to the
potential threat to aguatic life.

! The presence of lead in sediment is of concern due to its potential threat to
aguatic life.

! The presence of arsenic and lead in soils are of concern due to their potential
threat to deer mice, while the presence of lead is also of concern due to its
potential threat to terrestrial plants.

-------
Site 4

! The presence of barium and manganese in surface water is of concern due to the
potential threat to aquatic life.

! The presence of manganese in sediment is of concern due to the potential threat to
aguatic life.

It should be noted that the assessment of risk to terrestrial organisms was highly conservative.
Terrestrial animals in general receive the majority of their dietary water from food sources,
not from water bodies. In addition, the majority of the drainages within OU No. 3 are
intermittent, and would therefore create an exposure pathway only during precipitation events.
In general, the possible risks to aguatic and terrestrial receptors are minimal. The
literature-derived benchmarks provided only preliminary values for the determination of possible
ecological risk. Development of ecological cleanup criteria was not conducted as part of the
ERA.

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

This section presents the Remedial Action Objectives (RAOs), the associated Remedial Action
Goals or Cleanup Levels for OU No. 3. The first step in developing remedial alternatives is to
develop RAOs, which are based on the risk assessment and the ARARs analysis.

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
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. 3 of the RSR site are to minimize exposure to the
lead, arsenic, and antimony present in the slag piles/landfills (Sites 1, 3 and 4) by direct
contact, inhalation and ingestion, and to reduce the potential for migration of these
contaminants. In order to meet these remedial objectives, remedial action goals for lead,
arsenic, antimony have been established. For the 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:

Site 1

Eliminate the potential for incidental ingestion, and/or dermal contact with contaminated soils
or sediments with arsenic in excess of 20 ppm, and/or lead in excess of 500 ppm by on-site and
off-site receptors.

Site 3

Eliminate the potential for incidental ingestion, and/or dermal contact with contaminated soils

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or sediments with arsenic in excess of 32.7 ppm , and/or lead in excess of 2,000 ppm by on-site
and off-site receptors.

Site 4 (excluding Jaycee Park)

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

Site 4 - Jaycee Park

Eliminate the potential for incidental ingestion, and/or dermal contact with contaminated soils
with arsenic in excess of 20 ppm, 108 ppm of antimony and/or lead in excess of 500 ppm by
on-site and off-site receptors.

For Site 1, the RME lifetime excess cancer risk could be as much as 9x10-3 and the HI is 390 for
the future child residential scenario (the most conservative scenario evaluated for Site 1).
The Remedial Action Goals for Site 1, of 20 ppm of arsenic and 500 ppm of lead are based on
residential risk based calculations.

For Site 3, the RME lifetime excess cancer risk could be as much as 1x10-5 and the HI is less
than 1.0 for the future worker scenario (the most conservative scenario evaluated for Site 3).
The Remedial Action Goals for Site 3, are 32.7 ppm of arsenic and 2,000 ppm of lead and are
based on the future worker exposure. The 32.7 ppm action level for arsenic is based on the
1X10-5 risk (Sites 3 and 4), since the 1X10-6 level corresponds to a level lower than
background. The 2,000 ppm cleanup goal for lead is based on an Adult Lead Model that uses the
geometric mean value for lead to predict blood-lead levels in exposed workers.

For Site 4 (excluding Jaycee Park), the RME lifetime cancer risk could be as much as 1x10-5 and
the HI is less than 1.0 for the future worker exposure scenario (the most conservative scenario
evaluated for Site 4). The Remedial Action Goals for Site 4(excluding Jaycee Park) of 32.7 ppm
of arsenic and 2,000 ppm of lead are based on the future worker exposure (same basis as Site 3).

For Jaycee Park, the RME lifetime cancer risk could be as much as 4x10-5 and the HI is 2.0 for
the child residential exposure scenario (the most conservative scenario evaluated for Jaycee
Park). The Remedial Action Goals for Jaycee Park of 20 ppm of arsenic and 500 ppm of lead and
108 ppm of antimony are based on residential risk based calculations. A cleanup goal for
antimony is included because antimony is a contributor (greater than 20 percent) to
noncarcinogenic risk in Jaycee Park. The 108 ppm action level for antimony is based on reducing
the Hazard Index to less than one.

By addressing the contamination associated with the slag piles/landfills associated with Sites
1, 3 and 4 of OU No. 3 site specific risks described in Section VI. will be reduced or
eliminated.

As stated previously, regardless of any site-related contamination, the shallow ground water in
the vicinity of OU No. 3 is not considered as a potential water supply due to its overall low
yield and slightly saline guality 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 No. 3 is
not considered to be a potential drinking water supply (i.e. a Class III aguifer) and no action
is recommended for the shallow ground water beneath OU No. 3.

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VIII. DESCRIPTION OF ALTERNATIVES

A Feasibility Study was conducted to develop and evaluate remedial alternatives for OU No. 3 of
the RSR site. This report is included in the Administrative Record for OU No. 3. 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 reguired by the
NCP. As reguired by the NCP, the no action alternative was also evaluated to serve as a point
of comparison for the other alternatives.

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. 3 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
present at Sites 1, 3 and 4 are the contaminated material (i.e. battery chips, slag and soil) in
the slag piles/landfills. The management expectations of low level threats are engineering
controls, such as containment (40 CFR Section 300.430(a) (1) (iii) .

The alternatives developed for the three OU No. 3 sites generally involve containment
alternatives.

The presumptive remedy approach was also used to streamline the evaluation of alternatives in
the Feasibility Study for OU No. 3. Containment technologies are the presumed remedy for
municipal landfills (i.e. Sites 3 and 4) because the volume of waste and the heterogeneity of
the waste generally make treatment impracticable. The components of the presumptive remedy for
landfills generally are:

! Landfill cap
! Leachate collection/treatment
! Ground water controls
! Landfill gas collection and treatment
! Institutional controls to supplement engineering controls

The EPA Guidance on Presumptive Remedy for CERCLA Municipal Landfill Sites states that the
universe of alternatives that will be analyzed in detail may be limited to components of
containment described above.

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
residential use (Site 1 and Jaycee Park) or industrial land use (Sites 3 and 4). The remedial
alternatives described herein address the contamination associated with the slag piles/landfills
present in Sites 1, 3 and 4 of OU No. 3.

As stated in Section VII. Remedial Action Goals, the shallow ground water in the vicinity of OU
No. 3 is not considered as a potential water supply due to its overall low yield and slightly
saline guality and the availability of the City of Dallas water supply, as well as potable
supply permitting reguirements. 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 No. 3 is not considered to
be a potential drinking water supply (i.e. a Class III aguifer). Therefore, the shallow ground
water beneath OU No. 3 is not considered in any of the alternatives described below, and no

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action is recommended for the shallow ground water.

1.  Remedial Action Alternatives

The remedial action alternatives for OU No. 3 of RSR site are presented below for each of the
three sites followed by a description of the common elements of each alternative.
    Sites 1, 3 and 4

    Alternative la:

    Alternative Ib:

    Site 1

    Alternative 2:

    Alternative 3:

    Alternative 4:

    Site 3

    Alternative 2:

    Alternative 3:

    Site 4

    Alternative 2:

    Alternative 3:

    Alternative 4:

2.   Common Elements
No Action

Institutional Controls; Monitoring



Removal; Offsite Disposal; Monitoring

Protective Cap; Removal; Monitoring

Composite Cap; Removal; Monitoring



Removal; Monitoring

Protective Cap; Monitoring



Removal; Monitoring

Protective Cap; Removal; Monitoring

Composite Cap; Removal; Monitoring
All of the alternatives for Site 1, with the exception of Alternative la, have the following
common elements:   (1) all general requirements associated with site preparation, such as
contractor mobilization and demobilization, bonds and insurance, decontamination facilities, a
health and safety program,  (2) for Alternatives Ib, 3 and 4, annual monitoring for a 5 year
period of two surface water locations; and  (3) deed notices and restrictions.

All of the alternatives for Site 3, with the exception of Alternative la, have the following
common elements:   (1) all general requirements associated with site preparation, such as
contractor mobilization and demobilization, bonds and insurance, decontamination facilities, a
health and safety program,  (2)annual monitoring for a 5 year period of four  (4) existing ground
water monitoring wells and four  (4) surface water locations;  (3) deed notices and restrictions.

All of the alternatives for Site 4, with the exception of Alternative la, have the following
common elements:   (1) all general requirements associated with site preparation, such as
contractor mobilization and demobilization, bonds and insurance, decontamination facilities, a
health and safety program,  (2)annual monitoring for a 5 year period of three  (3) existing ground
water monitoring wells and two (2) surface water locations;  (3) deed notices and restrictions.

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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 the three
OU No. 3 of the RSR site follows.

SITES 1, 3 and 4

Alternative la - No Action

Major Components of Alternative la:

Evaluation of the No Action alternative is reguired 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 Sites 1, 3 and 4 of OU No. 3. No institutional or operational controls
would be implemented to restrict access to the OU No. 3 sites 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

SITE 1

Alternative Ib - Institutional Controls and Monitoring

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 Site 1, OU No. 3 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 1,000 linear feet of fencing and
the posting of warning signs and annual short-term monitoring of two (2)surface water locations.

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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: $ 99,040
Annual Operation &
Maintenance: $ 2,580
Present Worth: $ 110,210

Alternative 2 - Removal; Off-site Disposal; Monitoring

Major Components of Alternative 2:

This alternative involves selective removal of (1) slag piles, surficial slag deposits and
battery casing chips, and related metals contaminated soils and sediments (exceeding cleanup
goals) to a depth of two feet; (2) large slag pieces found in open concrete drainage channel;
and (3) all tire piles and drums from the intermittent creek bed. The concrete and limestone
debris piles located in the central portion of Site 1 would also be excavated and regraded. If
slag and battery chips are unearthed in this area, they would be removed and disposed
accordingly. Excavated material would be sampled and analyzed for hazardous characteristics
(TCLP) prior to off-site disposal in an appropriate landfill. Excavations would be backfilled
and regraded using conventional eguipment and clean soil. Monitoring would be same as that
described for Alternative Ib.

Treatment Components:

Excavated contaminated material, such as soil or slag piles/deposits, that is determined to be
hazardous (i.e. exceed TCLP reguirements) would be be treated accordingly, such as through
stabilization/solidification, prior to disposal.

Containment Components:

There is no containment component of Alternative 2 for Site 1.

General Components:

The estimated time needed to implement Alternative 2 for Site 1, is less than 1 year. The
estimated costs for implementation of this alternative are provided below:

Capital Costs: $ 1,503,490
Annual Operation &
Maintenance: $ 2,580
Present Worth: $ 1,514,660

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Alternative 3 - Protective Cap; Removal; and Monitoring.

Major Components of Alternative 3:

This containment alternative includes placing a protective soil cap over the exposed battery
chips, slag, and metals-contaminated soils within the fenced area on Site 1. This 102,300
sguare foot area is currently covered with heavy vegetation, debris piles and an irregular slope
leading to the intermittent creek. The cover/capping design plan would address surface
preparation, such as clearing and regrading the hillside to a uniform slope.

It was assumed that a protective cover consisting of a 24-inch protective/topsoil cover would be
placed on the regraded slope. The cap would be vegetated with native grasses and maintained for
a period of 30 years. Sediments exceeding cleanup goals would be excavated, sampled for TCLP
and disposed off-site accordingly. Monitoring would be the same as that for Alternative Ib,
with the addition of an annual inspection of the cap.

Treatment Components:

Excavated sediments that are determined to be hazardous (i.e. exceed TCLP requirements) would be
be treated appropriately, such as through stabilization/solidification, prior to disposal.

Containment Components:

The containment component of Alternative 3 for Site 1 involves the placement of a protective
cover, consisting of a 24-inch protective/topsoil cover, as described above, over the regraded
slope.

General Components:

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

Capital Costs: $ 671,880
Annual Operation &
maintenance: $ 3,530
Present Worth: $ 726,140

Alternative 4 - Composite Cap; Removal; and Monitoring

Major Components of Alternative 4

This containment alternative is similar to Alternative 3, except that a composite barrier cap
would be constructed over the 102,300 sguare foot area of concern on Site 1. Amoung the capping
options, a composit barrier cap would provide maximum protection from exposure due to direct
contact and is very effective for reducing infiltration. It was assumed that the composite
cover would include a coarse base grade; a heavyweight nonwoven geotextile; 24 inches of
compacted clay; a flexible membrane liner (FML); a drainage layer; a lightweight geotextile; and
a 24 inch protective/topsoil cover. The cap would then be vegetated with appropriate native
grasses and maintained for a period of 30 years. Sediments exceeding cleanup goals would be
excavated, sampled for TCLP and disposed off-site accordingly. Monitoring would be the same as
that for Alternative Ib, with the addition of an annual inspection of the cap.

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Treatment Components:

The treatment components for Site 1 of Alternative 4 are identical to those in Alternative 3.

Containment Components:

The containment component of Alternative 4 for Site 1 involves the placement of a composite
cover, as described above, over the regraded slope.

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: $ 1,161,670
Annual Operation &
Maintenance: $ 3,530
Present Worth: $ 1,215,930

SITE 3

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 Site 3, OU No. 3 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 placement of approximately 4,500 linear feet of fencing
along the eastern and southern boundaries of the TXI and West Davis landfills, the placement of
3,200 linear feet of boundary fencing along the western boundary of the TXI and West Davis
landfills and the posting of warning signs. A short-term (5 year) monitoring program for the
ground water and the surface water on Site 3 would also be conducted. At the five (5) year
review, the monitoring program could discontinued, continued or modified as appropriate. For
cost estimating purposes, it was assumed that monitoring would be conducted for a period of five
(5) years.

Treatment Components:

There are no treatment components for the contaminated media for Site 3 under this Alternative
Ib.

Containment Components:

There are also no containment components for Site 3 under Alternative Ib.

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General Components:

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

Capital Costs: $ 344,350
Annual Operation &
Maintenance: $ 6,530
Present Worth: $ 372,620

Alternative 2 - Removal; Monitoring

Major Components of Alternative 2:

Under this alternative surficial slag deposits and battery chips and related metals contaminated
soils to a depth of two feet would be excavated from locations where cleanup goals are exceeded.
Based on the RI findings and for cost estimating purposes it was assumed that 166,500 sguare
feet (or 6,165 cubic feet) of contaminated material would be removed. Excavated material would
be sampled and analyzed for hazardous characteristics (TCLF) prior to off-site disposal in an
appropriate landfill. Excavations would be backfilled and regraded using conventional eguipment
and clean soil. Monitoring would be the same as that described for Alternative Ib.

Treatment Components:

Excavated contaminated material, such as soil or slag piles/deposits, that is determined to be
hazardous (i.e. exceed TCLP reguirements) would be be treated appropriately, such as through
stabilization/solidification, prior to disposal.

Containment Components:

There is no containment component of Alternative 2 for Site

General Components:

The estimated time needed to implement Alternative 2 for Site 3 is less than 1 year. The
estimated costs for implementation of this alternative are provided below:

Capital Costs: $ 1,620,810
Annual Operation
Maintenance: $ 6,540
Present Worth: $ 1,649,120

Alternative 3 - Protective Cap and Monitoring.

Major Components of Alternative 3:

This containment alternative includes placing a protective soil cap over the southern portion of
the West Davis landfill where there is exposed slag and battery chips and soil exceeding cleanup
goals and isolated areas in the northern cell of the West Davis landfill. It is assumed that an
area of approximately 275,900 sguare feet would be cleared and regraded prior to the
installation of the cover. It was assumed the protective cover would consist of a 24-inch
protective/topsoil cover and be vegetated with native grasses and maintained for a period of 30
years. Monitoring would be the same as that for Alternative Ib, with the addition of an annual
inspection of the cap.

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Treatment Components:

There is no treatment component of Alternative 3 for Site 3.

Containment Components:

The containment component of Alternative 3 for Site 3 involves the placement of a protective
cover, consisting of a 24-inch protective/topsoil cover, as described above.

General Components:

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

Capital Costs: $ 1,174,610
Annual Operation &
Maintenance: $ 4,490
Present Worth: $ 1,244,630

SITE 4

Alternative Ib - Institutional Controls

Major Components of Alternative Ib:

Fh-is alternative includes taking steps to have deed notices or a land use restriction placed in
the deed records of the Site 4, OU No. 3 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 placement of (1) approximately 4,100 linear feet of
fencing along the southern and western perimeter of the West Dallas, Nomas, and Vilbig
landfills, (2) 1,350 linear feet of boundary fencing along the northwestern perimeter, and (3)
the posting of warning signs. A short-term (5 year) monitoring program for the ground water and
the surface water on Site 4 would also be conducted. At the five (5) year review, the
monitoring program could discontinued, continued or modified as appropriate. For cost
estimating purposes, it was assumed that monitoring would be conducted for a period of five (5)
years.

Treatment Components:

There are no treatment components for the contaminated media for Site 4 under this Alternative
Ib.

Containment Components:

There are also no containment components for Site 4 under Alternative Ib.

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General Components:

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

Capital Costs: $ 311,260
Annual Operation &
Maintenance: $ 4,230
Present Worth: $ 329,570

Alternative 2 - Removal; Monitoring

Major Components of Alternative 2:

Under this alternative surficial slag deposits and battery chips and related metals contaminated
soils to a depth of two feet would be excavated from the West Dallas and Nomas landfills and
Jaycee Park at locations where cleanup goals are exceeded. Based on the RI findings and for
cost estimating purposes it was assumed that 706,270 sguare feet of contaminated material would
be removed. Excavated material would be sampled and analyzed for hazardous characteristics
(TCLP) prior to off-site disposal in an appropriate landfill. Excavations would be backfilled
and regraded using conventional eguipment and clean soil. Monitoring would be same as that
described for Alternative Ib.

Treatment Components:

Containment Components:

There is no containment component of Alternative 2 for Site 4.

General Components:

The estimated time needed to implement Alternative 2 for Site 4, is less than 1 year. The
estimated costs for implementation of this alternative are provided below:

Capital Costs: $ 5,958,810
Annual Operation &
Maintenance: $ 4,230
Present Worth: $ 5,977,120

Alternative 3 - Protective Cap; Removal and Monitoring.

Major Components of Alternative 3:

This containment alternative includes placing a protective soil cap over those areas within the
Nomas and West Dallas landfills with exposed exposed slag and battery chips and
metals-contaminated soil exceeding cleanup goals. Also included under this alternative are
isolated areas in Jaycee Park where cleanup goals are exceeded. It is assumed that an
approximate 904,300 sguare feet of the Nomas and West Dallas landfill would be cleared and
regraded prior to the installation of the cover. It was assumed that the protective cover would
consist of a 24-inch clay protective/topsoil and be vegetated with native grasses and maintained

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for a period of 30 years. Monitoring would be the same as that for Alternative Ib, with the
addition of an annual inspection of the cap.

Treatment Components:

There is no treatment component of Alternative 3 for Site 3.

Containment Components:

The containment component of Alternative 3 for Site 3 involves the placement of a protective
cover, consisting of a 24-inch protective/topsoil cover, as described above.

General Components:

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

Capital Costs: $ 3,528,600
Annual Operation &
Maintenance: $ 3,970
Present Worth: $ 3,589,630

Alternative 4 - Composite Cap; Removal; and Monitoring

Major Components of Alternative 4

This containment alternative is similar to Alternative 3, except that a composite barrier cap
would be constructed over the approximate 904,300 sguare feet area of the Nomas and West Dallas
landfills. Amoung the capping options, a composite barrier cap would provide maximum protection
from exposure due to direct contact and is very effective for reducing infiltration. It was
assumed that the composite cover would include a coarse base grade; a heavyweight nonwoven
geotextile; 24 inches of compacted clay; a flexible membrane liner (FML); a drainage layer; a
lightweight geotextile; and a 24 inch protective/topsoil cover. Because landfill gas may build
up below the barrier components, this alternative inlcudes a minimal passive gas venting system.
The cap would then be vegetated with appropriate native grasses and maintained for a period of
30 years. Monitoring would be the same as that for Alternative Ib, with the addition of an
annual inspection of the cap.

Treatment Components:

There are no treatment components for Alternative 4 for Site 4.

Containment Components:

The containment component of Alternative 4 for Site 4 involves the placement of a composite
cover, as described above, over portions of the Nomas and West Dallas landfills.

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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: $ 8,273,880
Annual Operation &
Maintenance: $ 5,910
Present Worth: $ 8,364,730

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)(1). 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 adeguate 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
protected.

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

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 guantity of contamination that will remain after treatment.

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

Implementability addresses the ease with which an alternative can be accomplished. Factors such
as availability of materials and services are considered.

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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

Tables 16, 17 & 18 provide for a comparative analysis of seven of the NCP criteria, for Site 1,
Site 3 and Site 4, respectively, against the respective remedial alternatives for each site.
The seven NCP criteria evaluated in Tables 16, 17 & 18, include (1) Overall Protection of Human
Health and the Environment, (2)  Compliance with ARARs,  (3) Long-Term Effectiveness and
Permanence,  (4)  Reduction of Toxicity, Mobility, or Volume through Treatment,  (5) Short-Term
effectiveness,  (6) Implementability and (7) Cost.  The remaining two  (2) criteria, State
Acceptance and Community Acceptance are discused below.  The discussion applies to the entire OU
No. 3 site.

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. 3.  The TNRCC on behalf of the State of
Texas concurs with EPA's selected remedial action for the Slag Piles/Landfills, OU No- 3, of the
RSR site.





Community Acceptance

Comments were received from the community during the public comment period which opened July 3,
1996, and close August 4 1997.  A public meeting was held on July 24, 1997 to receive comments.
All comments received have been addressed, and responses are included int he Responsiveness
Summary  (Appendix A) to this ROD.  EPA carefully considered all comments in making the final
decision on the selected remedial action for each of the OU No. 3 sites, Sites 1, 3, and 4.

X.           THE SEIiECTED REMEDY

Based upon consideration of the reguirements of CERCLA, the detailed analysis using the nine
cirteria, and the public comments, EPA has determined the most appropriate remedies for the OU
No. 3 sites of the RSR site are as follows:

Site 1 - Alternative 2 - Removal; Off-site Disposal; Monitoring
Site 3 - Alternative 3 - Protective Cap; Monitoring
Site 4 - Alternative 3 - Protective Cap; Removal; Monitoring

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The major componenets of the remedy for each of the OU No. 3 sites include:

Site 1 - Alternative 2

! Excavation and removal of slag, battery chips and metals-contaminated soils exceeding
cleanup goals to a depth of two feet (estimated 78,960 sguare feet);

! Excavation and removal of sediments in the intermittent creek exceeding cleanup goals
(estimated 380 cubic yards);

! Backfilling and regrading of excavated areas using clean soil;

! Off-site disposal of the excavated material (i.e. slag, battery chips, soil and sediments)
in an appropriate landfill, depending on TCLP analysis and the whether material is
classified as hazardous or nonhazardous for disposal;

! Monitoring of surface water;

! No action is recommended for the shallow ground water.

! Figure 31 illustrates the areas to be addressed under Alternative 2 for Site 1.

Site 3 - Alternative 3

! Containment (protective soil cap) of the southern portion and isolated areas the northern
cell of the West Davis landfill where there is exposed slag, battery chips and
metals-contaminated soil that exceed cleanup goals;

! Monitoring of surface water and ground water and annual inspection of the cap.

! No action is recommended for the shallow ground water.

! Figure 32 illustrates the areas to be addressed under Alternative 3 for Site 3.

Site 4 - Alternative 3

! Containment (protective soil cap) of area within the Nomas and West Dallas landfills where
there is exposed slag, battery chips and metals-contaminated soild that exceed cleanup
goals;

! Excavation of areas of surficial contamination where cleanup goals are exceeded in Jaycee
Park and placement under the protective cover in the West Dallas landfull (nonhazardous
material) or transported and disposed off-site (hazardous material);

! Monitoring of surface water and ground water and annual inspection of the cap.

! No action is recommended for the shallow ground water.

! Figure 33 illustrates the areas to be addressed under Alternative 3 for Site 4.

The shallow ground water beneath the Sites 1, 3 and 4 of OU No. 3 are not considered to be
potential drinking water supply (i.e. a Class III aguifer).

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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,and
specific ARARs for air quality durinq remediation.t Appendix B includes the ARARs analysis for
OU No. 3. In addition, all off-site disposal of material must in compliance with EPA's Off-site
Policy at the time of disposal.

The estimiated time for completion for each of the selected remedies is less than one year and
the estimated costs for each of the selected remedies is as follows:

Site 1 - Alternative 2 - Removal; Off-site Disposal; Monitorinq

Capital Costs: $ 1,503,490
Annual operation &
Maintenance: $ 2,580
Present Worth: $ 1,514,660

Site 3 - Alternative 3 - Protective Cap; Monitorinq

Capital Costs: $ 1,174,610
Annual operation &
Maintenance: $ 4,490
Present Worth: $ 1,244,630

Site 4 - Alternative 3 - Protective Cap; Removal and Monitorinq

Capital Costs: $ 3,528,600
Annual Operation &
Maintenance: $ 3,970
Present Worth: $ 3,589,630

Remedial Action Goals or Cleanup Goals

The purpose of this remedial action is to control risks posed by direct contact, inqestion, and
inhalation of the contaminated material associated with the slaq, battery chips and
metals-contaminated soils found at Sites 1, 3 and 4 of OU No. 3. The results of the baseline
risk assessment indicate that the qreatest excess lifetime cancer risk (RME) at Site 1 is
9X10-3, primarily from inqestion by the current residential child. This risk relates primarily
to inqestion of arsenic. For Site 3, the qreatest excess lifetime cancer risk (RME) is 1x10-5
from inhalation, inqestion and dermal contact (RME) by the future worker. This risk relates
siqnificantly to the exposure (inhalation and inqestion) of arsenic. The qreatest excess
lifetime cancer risk (RME) at Site 4 is 1x10-5 from inhalation, inqestion, and dermal contact of
the future worker. Arsenic also contributes siqnificantly to the risk from inhalation and
inqestion for Site 4. Exposure to lead on each of these sites was also determined to be present
at unacceptable levels. A model used to predict child and adult blood-lead levels residents
(child - Site 1) and for future workers (adult - Sites 3 and 4).

For Site 1, the remedy will address arsenic in excess of 20 ppm, and/or lead in excess of 500
ppm present in the slaq, battery chips and soils. The 20 ppm corresponds to the acceptable
level of arsenic based on current and future residential use. The 500 ppm is predicted by the
IEUBK Lead Model also for current and future residential land use.

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For Site 3, the remedy will address arsenic in excess of 32.7 ppm, and/or lead in excess of
2,000 ppm present in the slag, battery chips and soils. The 32.7 ppm corresponds to the
acceptable level of arsenic based on future industrial use. The 2,000 ppm is predicted by the
Adult Lead Model also for future industrial land use.

For Site 4, excluding Jaycee Park, the remedy will address arsenic in excess of 32.7 ppm, and/or
lead in excess of 2,000 ppm present in the slag, battery chips and soils. The 32.7 ppm
corresponds to the acceptable level of arsenic based on future industrial use. The 2,000 ppm is
predicted by the Adult Lead Model also for future industrial land use.

For Jaycee Park, the remedy will address arsenic in excess of 20 ppm, and/or 108 ppm of
antimony, and/or lead in excess of 2,000 ppm present in the slag, battery chips and soils. The
32.7 ppre corresponds to the acceptable level of arsenic based on future industrial use. The
108 ppm of antimony is based on a Hazard Index less than one. The 2,000 ppm is predicted by the
Adult Lead Model also for future industrial land use.

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. 3, EPA conducted a remedial investigation, feasibility
study, and risk assessment to determine the nature and extent of site contamination.

The statutory determinations that are reguired 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 for each of the OU No. 3 sites meets these statutory
reguirements.

Protection of Human Health and the Environment

The selected remedy for Site 1 of OU No. 3 protects human health and the enviro=ent by
addressing releases or threats of releases of hazardous substances by removal and off-site
disposal of slag, battery chips and metals-contaminated soils. The selected remedy for Site 1
will minimize the threat of exposure to the arsenic and lead present on site through ingestion,
inhalation, and direct contact. By removal and off-site disposal of the slag, battery chips and
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.

For Sites 3 and 4 of OU No. 3 the selected remedy protects human health and the environment by
addressing releases or threats of releases of hazardous substances through containment of the
slag, battery chips and metals-contaminated soils. The selected remedy for Sites 3 and 4 will
minimize the threat of exposure to the arsenic and lead present on site through ingestion,
inhalation, and direct contact. By containment of the contaminated slag, battery chips and
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.

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Compliance with Applicable or Relevant and Appropriate Requirements

The selected remedy will comply with ARAFs. The complete ARARs analysis, determinations and
justification for ARARs for OU No. 3 of the RSR site is presented in Appendix B.

The following CERCLA requirement must also be complied with as part of the selected remedy for
Site 1: 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, 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 $1,514,660 for Site 1, $1,244,63.0 for Site 3 and
$3,589,630 for Site 4. 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. 3 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 for Sites 1, 3 and 4 provide 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

The remedy for Site 1 of OU No. 3 utilizes permanent solutions and alternative treatment to the
maximum extent practicable through removal and off-site disposal of the slag, battery chips and
metals-contaminated soils. However, due to the size of the landfills present on Sites 3 and 4,
it was determined impracticable to excavate and treat the chemicals of concern effectively.
Thus, the remedy for Sites 3 and 4 of operable Unit No. 3 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. 3 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

The Proposed Plan for OU No. 3 of the RSR Site was released for public comment on July 3, 1997.
The Proposed Plan identified Alternative 2 - Removal and Monitoring for Site 1, Alternative 3 -

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Protective Cap and Monitoring for Site 3 and Alternatve 3 - Protective Cap, Removal and
Monitoring for Site 4, as the prefered alternatives.  EPA reviewed all written and verbal
comments submitted during the public comment period.  Upon review of these comments, it was
determined that no significant changes to the remedy, as originally identified in the Proposed
Plan, were necessary.

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Appendix A

Responsiveness Summary

RESPONSIVENESS SUMMARY
RSR CORPORATION SUPERFUND SITE
OPERABLE UNIT NO. 3
DALLAS, DALLAS COUNTY, TEXAS

INTRODUCTION

The United States Environmental Protection Agency  (EPA) has prepared this Responsiveness Summary
for the RSR Corporation Superfund Site  (RSR Site),  as part of the process for making final
remedial action decisions for Operable Unit No. 3  (OU No. 3).  This Responsiveness Summary
documents, for the Administrative Record, public comments and issues raised during the public
comment period on EPA's recommendations presented in the Proposed Plan for the three (3)
landfill/slag areas of the RSR Site, OU No. 3, and provides EPA's responses to those comments.
EPA's actual decisions for OU No. 3 are detailed in the Record of Decision (ROD) for OU No. 3.
Pursuant to Section 117 of the Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA),  42 U.S.C. ° 9617, EPA has considered all comments received during the public
comment period in making the final decision contained in the ROD for OU No. 3.

OVERVIEW OF PUBLIC COMMENT PERIOD

EPA issued its Proposed Plan detailing remedial action recommendations for OU No. 3 for public
review and comment on July 3, 1997.  Documents and information EPA relied on in making its
recommendations in the Proposed Plan were made available to the public on or before July 3, 1997
in three Administrative Record File locations, including the West Branch of the Dallas Public
Library located at the RSR Site.  EPA provided thirty days for public comment.  No reguests were
received by EPA to extend the comment period and it closed on August 4, 1997.

EPA held a public meeting to receive comments and answer guestions on July 24, 1997, at the
Marillac Social Center located at 2827 Lapsley Road in west Dallas, Texas.  All written comments
as well as the transcript of verbal comments received during the public comment period are
included in the Administrative Record for OU No. 3 and are available at the three Administrative
Record repositories.

COMMENTS AND ISSUES RAISED DURING THE COMMENT PERIOD

1.  Public Meeting, July 24, 1997, Marillac Social Center- Citizen's Comments at the Public
Meeting

Comment:  Why isn't the City of Dallas represented on your panel?

Response:  EPA can not speak for the city, but EPA has an open door policy for the city and
elected representatives to participate in all of our meetings.  EPA would welcome the city's
participation in the decision making process for the RSR site.

Comment:  What is the timetable for the cleanup for the OU 3 site?

Response:  Once construction activities start, the construction phase should take from six  (6)
to nine  (9) months to complete.  The work is not technically difficult to conduct and would
generally consist of earth work type construction.   The time consuming phase of the project is
to secure funds through the EPA Superfund program or sign an agreement with the Potential

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Responsible Parties to implement the selected remedial action.

Comment: What are the lead levels currently existing in OU 3, and what levels do you propose to
bring it down to? What would be the proposed uses for that property once it's cleaned up?

Response: Site 1 is currently zoned for residential land use. Since the Site 1 is not a former
landfill but a disposal area, EPA is proposing to excavate and remove the contamination to
residential levels. To be consist with the cleanup levels used at other RSR residential areas,
the lead cleanup will be to 500 parts per million (ppm), which is the level that is protective
for children and of course adults. Site 3 includes several former landfill areas operated by
the City of Dallas. Site 3 is zoned primarily for industrial/ commercial use. EPA proposes,
therefore, to implement a remedy that will provide protection for future industrial/commercial
use. The cleanup levels were based on the risk assessment conducted for the site and are
consistent with the cleanup levels selected for the former smelter facility (OU No. 4). The
cleanup level for lead will be 2,000 ppm which is protective for future industrial/commercial
use. Site 4 also includes several landfill areas operated by the City of Dallas. Most of Site
4 is zone for residential land use. EPA, TNRCC, and the City of Dallas Department of
Environmental and Human Services do not believe that these former landfill areas should be zoned
for residential use. EPA has reguested that the Dallas Planning Department change the zoning in
this area to non-residential land use. EPA's proposed remedy for Site 4 is protective for non
residential land use.

Comment: When the cleanup is being conducted, is there any chance of contaminating other areas?

Response: Various engineering control methods, such as air monitoring, adding water to reduce
dust, and silt fence construction, will be used during cleanup activities to control migration
of contaminants to other areas. In addition, where excavation activities are conducted to
remove contaminants, confirmation samples will be collected and analyzed to ensure that the
remedial action cleanup goals are met.

Comment: I would like to know, after you finish cleaning up everything, will it be safe for the
residents that live in this area? Can you say it will be safe?

Response: Yes, the residential areas will be safe from smelter related contamination once the
RSR site cleanups are completed. The purpose of the remedial action is to provide protection to
human health and the environment.

Comment: I also would like to know, with the wind carrying pollution in the air, have you
considered that there are other areas that you haven't tested that could have the same problem?

Response: EPA did take air deposition and other factors into consideration in the extensive
investigations, studies, and cleanups that have been conducted in west Dallas. Every yard
within approximately a one-half (E) mile radius of the smelter facility was sampled to determine
if contaminants above health based levels were present, if they were, cleanup activities were
conducted. In other locations outside the air deposition area, visual inspections were
conducted at 6,800 properties to determine if battery chips or slag materials were present.
Over 1,000 properties have been sampled and thousands of soil, water, dust, and paint samples
have been analyzed to determine the areas that needed cleanup. EPA's efforts have been
extensive in identifying areas that were contaminated with smelter related contaminants.

Comment: I would like to know, the lead facility up here, are you going to fence that off and
put up a danger sign or a toxic sign or something or just let it sit there? What are y'all
going to do about that?

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Response: A remedy has been selected for the smelter facility (OU No. 4), which includes
demolition in a controlled manner of the smelter stack and other buildings and off-site disposal
at permitted facilities. Also included in the selected remedy is removal of the pavement
foundation, contaminated soils, and debris and disposal off-site to a permitted facility.

Comment: I was looking at the area where you underlined where a lot of soil was buried. I
really wasn't ready to comment on this tonight, but I still would like to mention that there are
other places. I know because my father worked at the facility. Maybe they should be checked,
too.

Response: If you are referring to the area shown on the site figure as OU No. 5, EPA has
investigated this area extensively. EPA has documented areas where contaminated soils were
buried and also a landfill is located at this site. The proposed remedy for OU No. 5 has been
discussed with the community and a remedy to address OU No. 5 was signed on April 3, 1997. The
information for OU No. 5 and all the other operable units is available for public review at the
Dallas Public Library - West Branch located at 2332 Singleton Blvd.

Comment: On the area that you cleaned up before, y'all moved the stuff to Oklahoma. Some of
the people out in the city are moving stuff right over to their next-door neighbor in the yards
and the dumps. They're contaminating the whole city of Dallas. I'm puzzled by how y'all are
planning on moving this contaminated soil or moving these people. Are you planning on moving
these people out when you clean up, or are you going to go through the same thing that we went
through to clean up the west Dallas area?

Response: For all of the cleanups that EPA has conducted in west Dallas, the contaminated soils
were removed from west Dallas and disposed of at permitted facilities. The Dallas Housing
Authority also removed all building materials and contaminated soils and disposed of them
off-site.

The proposed remedies for OU No. 3 will not reguired that people be moved or relocated. People
do not live within the contaminated areas of OU No. 3. Control measures will be taken during
cleanup activities to ensure that contaminants do not move off-site.

Comment: I noticed you mentioned about you want to change one of the areas over to a commercial
place, when you can bring it up to 2,000. That's a cop-out. Whenever you feel like you can't
get something down to a certain level, then you want to raise up the lead level. That is wrong.
If you are going to do that, why don't you just move the people out, which I asked for some time
ago. Move the people out and make it commercial; but don't let part of the people stay in the
money area and put another plant in another area, contaminating the same people.

Response: EPA is not reguesting that the city change the zoning in the former landfill sites
because they can not be cleaned to residential levels. EPA recommends the zoning change because
the Agency does not believe that residences should be built on top of former landfills. EPA
does not want to condone building homes on top of these landfills by cleaning the site to
residential standards; EPA believes that it would be a waste of money to do so. Right now
people do not live on top of these landfills and therefore no relocations are reguired.

Comment: Why bring it over to 2,000 and then let these other people create a problem when it's
under 500? You're going to bring them under 500 and say it's safe when next door you're going
to have 2,000. So that is the problem I'm having.

Response: The cleanup levels at residential properties and commercial properties are based on
life time exposure and conservative assumptions. Residential levels are based on exposure to
children, the most sensitive group, and based upon assumptions that they would ingest 100

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milligrams of contaminated soil a day for 365 days a year. Since children do not live in
commercial areas, the commercial levels are based on adult ingestion of 50 milligrams of
contaminated soil for 219 days a year.

Comment: Y'all spending millions of dollars out here; and it's going into bulldozing, moving
one contaminated piece of soil over to another in the same area. You got contaminated soil up
there at RSR, and you're coming out with your demolition you got over there, and then you've
contaminated every one of the areas around here. And still y'all are promising them other
people, and you're still trying to say you're going to clean it up. So the better thing to do
is trying to get to the root of it, trying to get it all stopped, and guit trying to clean up
something you can't clean up and go and try to treat the people like they supposed to be
treated. If you can't do it right, move them out. If you can't clean up the place where a
man's staying there safe and all that, then clear them people out. And that's all anybody asked
you to do from the beginning.

Response: EPA is cleaning up the contamination in west Dallas to health based levels so people
can live and work in a healthy environment. EPA does not believe that relocating the residents
of west Dallas is necessary.

Comment: Have you made a decision on what process you're going to use, or are you going through
the alternatives that you have listed, or what? Have you made a decision?

Response: No, a decision on the alternatives that will be used to address the OU No. 3 site
contamination has not been made. This public meeting is part of the decision making process
that is used to receive comments from members of the community to determine which alternatives
they believe would do the job better or for members of the community to present their own
alternatives. EPA will evaluate all comments and suggestions made at this public meeting or
submitted in writing before making a final selection of the remedy.

Comment: The site description and history for OU 3 consisted of three separate slag piles and
landfill sites, which are labeled 1, 3, and 4, because 2 is in OU 5. This is the same waste
material and contamination that was in OU 1, the residential area. So, in effect, you used the
same criteria basically for making your selection on what procedures you want to perform, right?
And you have nine standards of evaluation that you used in your process for selecting the
alternatives? And you labeled this particular site as being a very low threat as far as human
health was concerned?

Response: The contamination identified at OU No. 3 is the same smelter type contamination that
was present in the residential areas and is present at OUs 4 and 5. EPA is applying the same
cleanup standards at OU No. 3 as have been applied in the residential areas and the smelter
facility. Extensive investigations were conducted at each operable unit to determine the full
extent of contamination and to identify the areas that exceed health base cleanup levels. Each
of the alternatives presented in the Proposed Plan was evaluated based on the nine standards
used in the selection of the remedial alternative. Based on this evaluation, EPA is presenting
it's preferred alternative. The statement in the Proposed Plan that stated that OU No. 3 is a
low level threat is based on Superfund criteria used in determining if principal and low level
treat contaminants are presant at the site. It does not mean that the site does not pose a
threat to human health or the environment or that the site contamination does not needs to be
addressed.

Comment: Basically what I'm trying to get to is, if you used the same standard for evaluating
the one site, which was OU 1, based on the same material, which was waste material, battery
chips, and slag material that was brought from the smelter to the landfill to be dumped there,
then it was the same material being dumped in OU 1, in the residential area driveways and

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landfill around their homes. And I'm saying, if you used the same standard, the same process of
evaluation of OU 1 as well as OU 3, is there a difference there somewhere in OU 3, especially at
site 4, that would raise the level of environmental contamination that would constitute you
going from a residential area to a commercial area?

Response: The same standards and criteria were used for both OU 1 and OU 3. There are
important differences between OU 3 Site and OU No. 1 which affect EPA's decision as to the
appropriate clean-up levels. The most important difference is that people actually reside in OU
1, but no people reside within OU 3 Site 4. OU 1 was cleaned up to residential standards
because people are living there. Other options can be considered in the case of OU 3 Site 4
because, while the area is zoned residential, no people actually live there. Another
significant difference between OU1 and OU 3 Site 4 is that OU 3 Site is a huge landfill that
contains many different types of materials, making it an undesirable and unlikely location for
residential development in the future. EPA believes that it would not be a wise use of money to
clean up an area to residential standards that is unlikely to be developed into a residential
area. OU 3 Site 4 should more appropriately be compared to OU 3 Site 3 which is also a huge
landfill. Site 3 was not zoned for residential use and EPA believes that Site 4 should also not
be zoned for residential use.

Comment: I'm still a little confused about a comment you made to the second speaker pertaining
to lowering the lead contamination factor down to 100 parts per million on the cleanup. He
asked you when you make this cleanup how low you're planning to bring this down in these areas.
Were you misquoted when you say 100 parts per million?

Response: My statement was that at Site 1 the cleanup level would be 500 parts per million
(ppm) , the same as was used in the residential areas of OU No. 1. However, in the process of
cleaning up areas that exceed the 500 ppm levels, typically the resulting levels are much lower
than 500 ppm; is some cases as low as 100 ppm. This is typically what EPA encountered during
the cleanup activities at OU No. 1, the high contaminant levels were in the upper 3 or 4 inches.
However, the cleanup was conducted at 6-inch intervals which results in much lower than 500 ppm
levels remaining at the site. EPA never tries to clean to exactly the 500 ppm level, if the
level is 550 ppm, EPA does not just clean 1 inch of soil, we go the full 6-inches which will
result in a much lower lead level.

Comment: But I'm still a little confused. I'm talking about, how low do you plan to bring
sites 1, 3, and 4 down to? We know you took OU 1 down to 500 parts per million. Are you going
to be able to do this on a landfill site and make a sincere effort to move all this material to
a dump site? But if it's going to be a commercial site, then lowering it to 500 parts per
million is not a requirement and spending millions of dollars per site isn't required.

Response: For site 1 of OU No. 3, EPA plans to conduct a cleanup of those areas that exceed the
500 ppm lead level and dispose of those material at permitted landfill facilities just as was
done for the residential areas of OU No. 1. For sites 3 and 4, areas which are already landfill
sites, EPA does not propose to remove materials from one landfill site and take it to another
landfill site. Therefore, at sites 3 and 4 of OU No. 3, the remedial alternative would be to
place a clean soil cap over the areas that exceed the cleanup levels of 2,000 ppm for commercial
land use and thereby prevent exposure, inhalation, and ingestion of the contaminated materials.

Comment: If you could get all the landfill sites zoned commercial, rather than residential,
then we won't have a future problem of people selling it for residential property and moving
people in on it and putting lives at risk. If you can get all four locations, even in OU 5
zoned to commercial standard, then we could eliminate the problem and go with a lesser cost,
rather than trying to bring OU 3, site 4 down to residential standard. But we need to do it for
all of the properties, not just one.

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Response: EPA agrees that those locations that at one time were commercial or industrial should
be cleaned to those standards. EPA agrees that Site 4 of OU No. 3, which is now zoned for
residential use, should be changed to commercial use. The Record of Decision for OU No. 5
called for the site to be addressed for future commercial/industrial use. So the decision for
OU No. 5 has been made. Site 1 of OU No. 3, on the other hand, has never been used for
industrial or commercial purposes and EPA believes that it can be adeguately cleaned up to
residential standards at a reasonable cost.

Comment: I'd like to know if EPA is admitting that the current cleanup standards are inadeguate
to protect all of West Dallas, since you're going to make that difference in the OU 3, which had
the same RS status evaluation that OU 1 had and the same material, the same chips, the same slag
reguires a different set of standards than it did in OU 1. OU 3 is getting preferential
treatment. Would you give us what factor specifically that OU 3 has in it that make it
different from OU 1?

Response: OU No. 3 is not getting preferential treatment. The cleanup levels for OU 3 are
higher than or egual to the cleanup levels for OU 1, which are the lowest levels used at the RSR
Site. OU No. 3 was evaluated the same way that Ous 1, 2, 4, and 5 have been evaluated. OUs 1
and 2 were evaluated as residential areas and OUs 4 and 5 were evaluated as industrial areas.
EPA is doing the same for the three sites of OU No. 3. Site 1 of OU No. 3 was evaluated as a
residential area, the same as for OUs 1 and 2. Sites 3 and 4 were evaluated as commercial
areas, the same as for OUs 4 and 5. The standards used for all of the operable units are
protective of human health and the environment and are consistent with the cleanup standards
that were used for each operable unit based on either residential use or commercial use. There
are significant differences between Sites 3 and 4 of OU No. 3 and OU 1, including the absence of
residences and the presence of landfills on Sites 3 and 4 of OU 3.

Comment: I am trying to see if you're going to zone OU 3 and its various sites as either
commercial or industrial, other than residential, what was the reason OU 1 wasn't given that
preferential treatment?

Response: First of all, EPA does not have the authority to make zoning decisions. Zoning
decisions are made by the city. Generally, EPA considers anticipated future land use in
determining clean up levels. At the RSR Site, OUs 1 and 2 are zoned residential by the City of
Dallas, and they are currently used as residential areas. EPA assumed that the residential use
of those areas would continue in selecting it remedy and cleanup levels for OUs 1 and 2. OUs 4
and 5, on the other hand, are currently zoned by the City of Dallas as commercial/industrial
areas, and they are currently occupied by commercial/industrial facilities. EPA assumed that
the commercial/industrial use of OUs 4 and 5 would continue in selecting its remedy and cleanup
levels for those OUs. OU 3 Site 1 is currently zoned by the City of Dallas as residential,
although it is not currently being used as a residential area. Since OU 3 Site 1 appears to be
suitable for future residential use consistent with its zoning, EPA assumed that it would be
used as a residential area in selecting the remedy and cleanup level for Site 1. OU 3 Site 3 is
currently zoned by the City of Dallas as commercial/industrial. Since OU 3 Site 3 appears to be
suitable for future use consistent with its zoning, EPA assumed that it would be used for
commercial/industrial purposes in selecting the remedy and cleanup levels for OU 3 Site 3. OU 3
Site 4 is currently zoned by the City of Dallas as residential. Site 4 is not currently
occupied by residences, and it does not appear to be appropriate for future use as a residential
area due to the presence of the landfill materials on the site. EPA, therefore, assumed that
the future use of OU 3 Site 4 would be non-residential (commercial/industrial) rather than
residential for purposes of selecting the remedy and cleanup levels for OU 3 Site 4. It should
be noted that EPA does not consider a cleanup to commercial/industrial standards "preferential"
over a cleanup to residential standards. The residential standards are much lower than the

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commercial/industrial levels.

Comment: I am here as a representative of a property owner in Site 1 of OU No. 3. I am here to
generally say we concur with the Preferred Alternative that EPA has dictated so far and are
waiting on public comment with one modification, not exception, but modification we would like
you to look at. And that is, because you propose to cleanup to residential standards, we know
that under the risk-based rules you're going to reguire deed recordation unless you go further
and clean it up to background. Now, that presents some stigma to the property owners and the
property value there. As a result we would like the EPA and the TNRCC to consider putting the
cleanup of Site 1 into the voluntary cleanup program. Your deed recordation then would need a
certificate of completion, and that would result in less stigma being applied to that type of
deed recordation. Future owners and lenders of that property would not be liable for the lead
and the arsenic and the other constituents on that facility. There is some precedent for this.
There's a second Superfund site in South Texas that has had a portion of it placed into the
voluntary cleanup program by the EPA with the concurrence of the TNRCC. I don't know if it
would mean that you would have to carve this out and off of the NPL list or what EPA
reguirements you might have. I would be happy to help you research those if it meant that we
could put this cleanup of Site 1 into the voluntary cleanup program and obtain as a result the
certificates of completion, rather than have to have a deed recordation and a devaluation of
that property, which is owned by innocent parties that had nothing to do with the release that's
creating the Superfund designation.

Response: EPA does not have the authority to place a site in the voluntary cleanup program
(VCP). The landowner submits a reguest to the TNRCC to be placed in the VCP. TNRCC then
decides whether to accept the site into the VCP or not. The owner would then be reguired to
submit, for approval, investigation studies, work plans for the conduct of the cleanup, and then
conduct the cleanup with TNRCC oversight. Since OU No. 3 is part of a site listed on the NPL,
cleanup of the site under the VCP would not relieve the owner of also having to comply with
CERCLA cleanup standards. The site in south Texas was accepted into the VCP before the site was
proposed to the National Priorities List. If the site makes the NPL, then cleanup of the site
under the VCP would also be reguired to meet CERCLA standards. At this stage of the NPL
process, it would not be feasible to carve this site from the rest of the RSR site. Since Site
1 is already part of the NPL, it cannot be deleted from the NPL before meeting the cleanup
standards that are selected in the Record of Decision for the site. To delete a site from the
NPL, EPA must determine, in consultation with the State, that one of the following criteria has
been met: 1) Responsible or other parties have implemented all response actions reguired; 2)
All appropriate Fund-financed response under CERCLA has been implemented, and no further
response action by responsible parties is appropriate; 3) The remedial investigation (RI) has
shown that the release poses no significant threat to public health or the environment, and
therefore, it is not appropriate to take remedial measures.

Site 1 of OU No. 3 does not meet any of the above criteria and therefore can not be removed from
the NPL at this time.

Comment: I talked to you at the Multi-purpose Center. The last time we were speaking, we had
came up to around about $5 billion. If the cleanup costs go up to maybe $5 billion, do you have
that to help the blacks and the Hispanics and the low-income people in west Dallas? Would the
EPA have this much money to help us?

Response: The amount of money the commentor is referring to may be the total amount that is in
the Superfund Trust Fund. This money is use to cleanup sites all over the country and is not
designated for one site. Superfund money can be used only to conduct the cleanup of hazardous
waste sites and certain closely related activities.

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Comment: The West Dallas site, how much money is the Superfund for the West Dallas site? How
much money?

Response: EPA has spent approximately $16 million from the Superfund program to conduct the
cleanup of the residential areas and conduct remedial investigations, feasibility studies, and
designs for future cleanups. Right now, no new money has been allocated for the cleanup of the
remaining operable units. EPA is close to an agreement with some Potentially Responsible
Parties to conduct the cleanup of the smelter facility, OU No. 4. As funds are needed in the
future, reguests will be made to EPA HQs for funding to conduct cleanup activities. EPA is
confident that there will be sufficient funds to complete the cleanup activities in west Dallas.

Comment: You don't have $50 million in the Superfund for West Dallas?

Response: No, the $50 million was an estimate of approximately how much money will ultimately
may be spent in conducting the cleanup of the five operable units. It is not money that has
been set aside for West Dallas.

Comment: You cleaned up the residential areas of West Dallas. Where did that money come from?
Do you have a receipt or something to show me?

Response: EPA spent approximately $12 million to conduct the cleanup of the residential areas.
That money came from the Superfund program and was allocated for the cleanup as needed. I do
not have the receipts with me of how that money was spent. Detailed documentation of EPA's
costs is available in our office files. Persons who want to look at those files may make a
reguest and an appointment will be set up for them look at that information. We do not carry
receipts or site files with us when we conduct public meetings. As we stated in the Proposed
Plan those files are available at three repositories for review.

Comment: Is there any blacks on the EPA board, a woman or a black man on the EPA board?

Response: Yes, EPA Region 6 has an African-American woman serving as Acting Deputy Regional
Administrator and an African-American male serving as a Division Director. There are also other
women and minorities serving in management positions at EPA Region 6.

Comment: I'm a former contaminated resident of West Dallas. I stayed on the lead plant, rather
say, not in it. I lived in the lead. I started smoking at a young age, smoking contaminated
air. I was drinking the lead-contaminated water. I done ate from the lead soil. But do the
EPA compensate or try to help me and my sick kids? No. They're trying to tear down the site,
but what about the people that was contaminated in West Dallas? What about the people that walk
around with asthma, high blood pressure, all these bad, these things, these illnesses they
wouldn't have if they hadn't been contaminated?

Response: EPA can not compensate people for health affects or provide health care. The
Superfund program is set up to cleanup hazardous waste sites.

Comment: I'm a professional biology teacher and a person that came out of this community that
knows science and a lead-contaminated person. And I applaud your efforts in cleaning up this
cosmetic, because it does look bad on the outside. And money is an important issue, but I know
something that's more important than that. It's life, the ability to live life freely, an
opportunity to succeed. Now, I realize the capacity of the EPA. It's supposed to be
Environmental Protection, that was the key word, Protection Agency. Who are you protecting?
Are you protecting the lives of people, or are you protecting the profile of certain people?

Response: There are limitations on what EPA can do. EPA is conducting cleanups to protect all

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of the people living and working in West Dallas.

2.  Letter from Mr. Luis Sepulveda, President West Dallas Coalition for Environmental Justice,
dated July 16, 1997.

Comment:  What you are doing in west Dallas lead is a joke.  Nothing but big joke.  Slag still
everywhere, dust in homes, chips still in yards.  EPA is big joke in our community, barrios.
West Dallas will always be big dump.  See you in court.

Response:  The cleanup in west Dallas is certainly not a joke to EPA.  Significant man power
resources have been dedicated to the cleanup effort in west Dallas and millions of dollars spent
since 1991.  These efforts are continuing and EPA will invest additional resources to address
the lead contamination in west Dallas attributed to the RSR smelter.  The proposed plan
presented to the public for comment and the decisions contained in this Record of Decision are
to address the slag and lead contamination at the three sites that comprise OU No. 3.  All areas
of west Dallas have benefited in some form through the efforts of EPA's actions taken to address
the lead contamination problems.  Instead of threatening to see EPA in court, we hope that
citizens work with us in addressing the remaining contaminated areas just as other community
groups have done in west Dallas in working together in the decisions affecting the cleanup
efforts.

3.  Mr. Otis Fagan, Sr., President, Friendship Homeowners Association for Environmental Justice
letter dated July 24, 1997.

Response:  Comments submitted by Mr. Fagan in a letter dated July 24, 1997, were also made at
the public meeting conducted on July 24, 1997.  Mr. Fagan's comments and EPA's response to those
comments are included above with the minutes of the public meeting

4.  Ms. Jill A. Kotvis, Chair, Environmental Practice Group, letter dated July 31, 1997.

Response:  Ms. Kotvis comments submitted in the letter dated July 31, 1997 were also made at the
public meeting conducted July 24, 1997.  Ms. Kotvis comments and EPA's response to those
comments are included above in the public meeting minutes.

5.  Mr. Keith Pate, Consultant - Representing William P. Dorfmeister, Owner of former Dahlstrom
Landfill Site, letter dated July 30, 1997

Comment:  We appreciated the opportunity to participate in the RSR Corp. Superfund Site Public
Meeting on July 24, 1997.  We commend both your agency and TNRCC for the work done to date.  EPA
is very concerned that, to date, no one has been able to get the City of Dallas to the table and
participate in the remediation work and costs.  Our belief is the City of Dallas is egually
responsible and liable along with RSR Corporation for the problem and would expect your agency
and TNRCC to immediately take any action necessary to force the City of Dallas to share in any
and all costs involved.

Response:  EPA will be pursuing potentially responsible parties (PRPs) to share in the costs
associated with EPA's activities conducted for the site.  The City of Dallas and others have
been identified as PRPs for the site.  EPA has notified the City of Dallas of its potential
liability for the Site,  but the City has thus far not been willing to perform or pay for
response actions.

6.  From Ms. Alice Coleman, letter received August 1, 1997.

Comment:  I think that they should help people with their health problems.  People are sick from

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inhaling lead, including myself. I'm on medication for the rest of my life. The Superfund
system shouldn't only go towards cleanup, but also for the people health.

Response: The EPA Superfund Program was established to cleanup abandon hazardous waste sites
that pose a risk to human health and the environment. There are other local, state, and federal
agencies that are available to assist people with health problems. EPA also can not compensate
people for past health affects.

7. Comments of the RSR Corporation on EPA's Proposed Plan for Operable Unit No. 3, "RSR
Corporation" Superfund Site, Dallas, Texas, letter dated August 4, 1997.

Comment: RSR believes that EPA has over stated or mischaracterized the risks associated with OU
3. EPA's failure to properly characterize the risks from current and future site conditions is
inconsistent with the National Contingency Plan (NCP). As such, EPA cannot support its
preferred remedial alternatives for OU No. 3.

Response: EPA did not overstate or mischaracterized the risk associated with OU No. 3. EPA's
assessment of the site is consistent with the NCP and comprehensive investigations were
conducted at each of the three (3) sites that comprise OU No. 3 to determine the risk at each
site. The remedial investigation and human health risk assessment conducted for the site are
the basis for preparing the feasibility study which evaluates alternatives to address
contaminated areas that exceed human health levels. We have numerous reports and documents to
support EPA's preferred remedial alternatives for OU No. 3 presented in the Proposed Plan for
the site.

Comment: EPA Has Mischaracterized the Risk at OU No 3.

The NCP reguires EPA to conduct a "site specific baseline risk assessment" to develop
"reasonable maximum estimates of exposure from both current land use conditions and potential
future use conditions at each site." Thus, the assessment must "characterize the current and
potential threats to human health and the environment that may be posed by contaminants
migrating to ground water or surface water, releasing to air, leaching through soil, remaining
in the soil, and bioaccumulating in the food chain," in order to "help establish acceptable
exposure levels for use in developing remedial alternatives in the FS (Feasibility Study)."

EPA's Baseline Human Health Risk Assessment for OU No. 3 (risk assessment) purportedly shows
that the existing soils, battery cases, and slags located in the landfills (Sites 1, 3, and 4)
at OU No. 3 present unacceptable risks for exposure to lead and arsenic to residents, incidental
trespassers, and workers. However, EPA's Risk Assessment significantly overstates the risk
associated with these metals.

The central flaws in EPA's risk assessment are that it is derived from inappropriate and overly
conservative estimates and assumptions on the health impacts of lead and arsenic from Sites 1,
3, and 4 at OU No. 3. EPA admits as much, when it states in the Feasibility Study that the
"HHRA (Human Health Risk Assessment) is subject to uncertainty from a variety of sources
including the following: Sampling, analysis, and data evaluation; Fate and transport
estimation; Exposure estimation; Toxicological data; and Blood-lead models."

These uncertainties (errors) and particularly apparent in EPA's estimation of the number of
children that would have blood leads exceeding 10 ug/dl at Site 1 of OU No. 3. There, EPA has
predicated the geometric mean blood-lead concentration to be 41 ug/dl with an estimated 99
percent of the exposed population expected to exhibit blood-lead concentration greater than 10
ug/dl based on soil lead concentrations measured in Site 1.

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These risk "estimates" are pure speculation. First, it is generally recognized that the
Integrated Exposure Uptake Bio-Kinetic Model (IEUBK Model) fails to accurately predict the
number of children with blood lead levels over 10 ug/dl. This is because the IEUBK Model uses
overly conservative assumptions and fails to account for non-soil exposure sources. Without the
use of accurate assumptions as well as the measurement of non-soil exposures, the IEUBK Model
cannot accurately predict children's blood lead levels from soil exposure.

Second, EPA, in this case, failed to use site specific intake absorption parameter because "site
specific values [were] not available." Thus, EPA relied upon the Model's overly conservative
default values. Given the inaccessibility of Site 1 (most of it is fenced off) as well as the
fact that much of the materials present at Site 1 (e.g., slag, battery casing chips and
municipal debris) are not readily bioavailable, EPA's estimations of the amount of soil intake
and absorption are very likely to be overstated. EPA admits as much in the Feasibility Study by
stating that "[r]isks may be overestimated ... if characteristics of the exposed population at
the site differ from these default assumptions."

Third, EPA's estimates from the IEUBK Model are clearly at odds with the results of a recent
public health assessment performed at the so-called RSR Site by the Texas Department of Health.
That assessment, performed on children living in near proximity to the so-called RSR Site, found
that the average blood lead level of children was 5.5 ug/dl. This figure is well below the
Centers for Disease Control 10 ug/dl level of concern and almost a level of magnitude less than
EPA's estimate. The Texas Department of Health study further concluded the "blood lead levels
were not substantially different among West Dallas children and children from other parts of
Dallas."

In short, it would be arbitrary and capricious for EPA to base its remedial action decision as
to this Operable Unit on default-assumption-based IEUBK model run.

EPA also overstates the risks posed by arsenic in the soils of Sites 1, 3, and 4 at OU No. 3.
This is largely because EPA's risk assessment assumes that arsenic in soils is completely (100%)
bioavailable. This is not so. The bioavailability of arsenic in soil is the product of
solubility and absorption. It is influenced by chemical species, soil particle size, associated
soil matrix materials (solubility-related factors), the mode of intake, and host factors such as
nutritional status (absorption-related factors).

Those studies that have evaluated the bioavailability of arsenic in soils from smelter sites
have concluded that arsenic in soils is not more than 20% bioavailable, depending upon the soil
matrix. For example, the attached study performed by G.B. Freeman on the bioavailability of
arsenic in soils impacted by smelter activities administered to monkeys found that arsenic was
at most 20% bioavailable. Another study performed by Greon, et al., on the bioavailability or
arsenic in soils also concluded that arsenic from soil was relatively unbioavailable. That
study found that the bioavailability of arsenic from ore-containing soil was 8.3%. In short,
arsenic risks at this Operable Unit also have been significantly overstated by EPA.

Response: The uncertainties that EPA listed in the HHRA are just that "uncertainties" which are
unknowns and not "errors" or mistakes as the commentor implies by including the word "errors"
after the word "uncertainties" in the comment. These uncertainties or unknowns could result in
the risk assessment being overestimated or underestimated. In this case, EPA chose the most
conservative results to ensure protection of human health based on long term exposure to site
contaminants, especially exposure to children who are the most sensitive population to
contaminants.

The risk estimates are just that, estimates and not speculation as the commentor states. These
estimates are based on a model (IEUBK) that is used nationally to predict blood lead levels.

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The model is widely used by other Federal and State agencies to predict blood lead levels for
children exposed to lead contaminants. The model uses site specific data (when available) for
input to the model and default parameters when site specific data is not available. This was
done for the OU No. 3 sites.

OSWER Directive # 9355.4-12. Revised Interim Soil Lead Guidance for CERCLA Sites and RCRA
Corrective Action Facilities, 1994 states "The IEUBK Model for Lead in Children was developed
to: recognize the multimedia nature of lead exposures; incorporate important absorption and
pharmacokinetic information; and allow the risk manager to consider the potential distributions
of exposure and risk likely to occur at a site (the model goes beyond providing a single point
estimate output). For these reasons, this approach is judged to be superior to the more common
method for assessing risks of non-cancer health effects which utilizes the reference dose (RfD)
methodology . . . The Agency believes that the IEUBK is the best available tool currently
available for assessing blood lead levels in children. Furthermore, use of the IEUBK allows the
risk manager to consider site-specific information that can be very important in evaluating
remediation options."

The model has received extensive peer review from both the Science Advisory Board and the
Technical Review Workgroup for Lead. In July of 1992, the Office of Solid Waste and Remedial
Response (OSWER)convened a meeting to solicit comments on the original Uptake/Biokinetic (UBK)
model from a wide range of interests, including environmental groups, citizens, and lead
industry representatives, and incorporated comments from these groups into the current IEUBK
model. In 1994, EPA outlined its strategy for IEUBK model validation. Validation was carried
out with existing data sets relating environmental and blood lead levels on a per individual
basis by using the IEUBK model to generate blood lead predictions from the measured
environmental lead levels. These predicted lead levels were then compared with the measured
blood levels, using geometric mean blood levels and proportions observed or expected to have
elevated blood lead levels. All studies used for the validation exercise had data of sufficient
guality and quantity to characterize the environmental lead levels in each residential home and
yard (i.e. , blood lead levels of residents, as well as soil, dust water, interior and exterior
lead paint levels, and demographic/behavioral survey data covering other aspects of lead
exposure). The modeled results and observed blood lead levels were reasonably concordant, with
similar geometric mean predicted and observed blood lead concentrations (5.81 Ig/dl versus 5.44
Ig/dl, respectively) and similar population proportions with elevated blood lead levels.

Although comparisons of IEUBK model output to empirical blood lead data cannot provide
conclusive "verification" of the model, they can contribute to an overall evaluation of the
credibility of model predictions. Results of EPA's validation exercises provide confidence that
the IEUBK model is a credible predictor of blood lead levels in environmentally exposed
children.

The commentor states that the IEUBK Model "fails to account for non-soil exposure sources".
That is not the case since input parameters for the model include soil, air, and water sources
and soil dust/lead paint rations. So, clearly the model takes into account other sources than
just soil. Site specific data for the other parameters was taken from the measurements made for
the OU No. 1 study conducted for the residential areas of west Dallas. OU No. 3 is located
within the west Dallas residential area.

The commentor guotes EPA's statement that "risks may be overestimazed," but the commentor left
out the additional statement that EPA made, which was that "the risk may be underestimated."
When it comes to protecting human health, especially the health of children, for whom the IEUBK
Model is used, EPA has elected to pursue a conservative course. The assumptions made in
calculating risk are based on known conditions and predicting future site conditions on best
case scenarios.

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The public health assessments conducted by the Texas Department of Health (TDK) at the RSR site
were based on site specific information for OU No. 1. As the commentor states, the health
assessment was performed for children living in near proximity to the RSR Site and was not made
for children living on Site 1 of OU No. 3. The commentor implies that the results of the OU No.
1 study would be the same for the OU No. 3 site. The health assessments conducted by TDK are
based on conditions after cleanups (conducted by EPA) had been completed. Once the cleanup is
completed at Site 1 of OU No. 3, the TDK would probably reach the same conclusion for Site 1 as
it did for OU No. 1, but only when the cleanup is completed and not with current conditions.

The arsenic risks have not been overestimated. The smelting process results in the release of
inorganic arsenic into the air and in waste forms. It has been documented that in general,
inorganic forms of arsenic are more toxic than organic forms. The bioavailability of arsenic is
dependent on many environmental factors. The bioavailability of arsenic in some animal studies
has been shown to be as much as 50% to 80%. As was the case with lead, EPA chose the most
conservative estimates to ensure that human health would be protected even in a worst case
situation.

Comment: Proper Analysis would have Resulted in the Choice of No Action Alternatives

Had EPA properly characterized the risks posed by lead and arsenic at OU No. 3, the risks
associated with Sites 1, 3, and 4 likely would have been found to be well within the NCP's
acceptable exposure levels for systemic toxicants and known or suspected carcinogens at
Superfund sites. EPA's failure to accurately characterize the risks posed at OU No. 3 thus is
inconsistent with the NCP.

Conseguently, EPA's risk assessment cannot be used to support EPA remedial action goals, the
definition of remedial alternatives, or the choice of the preferred remedial alternatives for
Sites 1, 3, and 4 of OU No. 3. Based on the information available to RSR (and referenced in the
footnotes to this letter), it seems likely that a no action alternatively would be appropriate
for Sites 1, 3, and 4. In any event, until EPA's risk assessment is revised to accurately
characterize the risk at OU No. 3, no decision on final response actions can lawfully be made.

Response: Not only is EPA risk assessment consistent with the NCP, it is also consistent with
risk assessments conducted at other similar sites through Region 6 and the rest of the country.
Therefore, it is appropriate to use this risk assessment to determine remedial action goals for
OU No. 3 and select alternatives that best meet EPA's nine criteria for selecting remedial
alternatives at Superfund sites. Additionally, EPA alternatives for the two former landfill
sites are consistent with the presumptive remedial alternatives recommended for these sites.

8. Comments written on behalf of Texas Industries, Inc. ("TXI"), submitted by Hutcheson &
Grundy, L.L.P. letter dated August 4, 1997.

Comment: These comments pertain primarily to OU No. 3, Site 3 which consists of three distinct
properties where the City of Dallas operated three separate landfills. Given the City's course
of conduct in accepting industrial solid wastes at its landfills in violation of express permit
and contractual provisions, the investigation conducted by the EPA, as reflected in the RI/FS,
may not be sufficient. The EPA has not conducted a complete investigation into the City of
Dallas landfill operations covered by OU 3. The EPA has not obtained all of the records
available from the City of Dallas related to landfill operations conducted by the City of Dallas
and encompassed in OU 3. The extent of the industrial solid wastes accepted by the City of
Dallas at the landfills is unclear. Nor does the RI/FS appear to address constituents other
than the identified constituents of concern associated with the smelter wastes. Finally, there
seems to be a lack of information justifying the parameters of the proposed cover. For
instance, the RI/FS does not appear to address the levees in the proposed remedy.

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Response: EPA conducted a complete investigation to determine the extent to which smelter
contaminants may be posing a risk to human health and the environment. It is correct that the
focus of the remedial investigations and feasibility study conducted for OU No. 3 was to
identify smelter related contaminants. The purpose of the investigations conducted at the site
were to identify smelter waste contamination that could be related to the RSR Superfund site.
Under the Superfund criteria, areas that contain site related waste become part of the site. In
this case, smelter waste materials are present at OU No. 3, and, therefore, OU No. 3 becomes
part of the RSR site. Once this was established, the focus of the investigation was conducted
to determine the nature and extent of contamination. However, in conducting the remedial
investigation at these former landfill sites, EPA used existing guidance for "Conducting
Remedial Investigations/Feasibility Studies for CERCLA Municipal Landfill Sites" dated February
1991. Because of the heterogenous nature of the landfill materials, it is almost impossible to
fully document all materials or contaminants present in the landfill. The best that can be done
is to identify areas or hot spots that pose a risk to human health and the environment. EPA
believes that the investigations EPA conducted have done that. The risk assessment conducted
for the site did not just consider smelter related contaminants, but also other contaminants
identified as a result of the remedial investigation, although the investigation and risk
assessment were focused on smelter related waste. The risk assessment indicated that other
contaminants were not present above health based levels or that complete exposure pathways
existed. The extent of the soil cover or areas to receive a soil cover are based on the risk
assessment. The soil cover will be placed over areas or hot spots that exceed health based
levels. This is to provide protection to human health and the environment based on current and
future industrial use scenarios at these properties. EPA is not sure which levees you are
referring to. EPA conducted extensive investigations at each of the three sites that comprise
OU No. 3. Old aerial maps were study to determine the approximate limits of the landfill areas,
then visual inspections were conducted to determine the presence of battery chips and slag
materials, and finally surface samples were coilected from the whole site that would be
representative of surface conditions and selected subsurface soil samples were also collected
and analyzed for contaminants. If contaminants are present below the levees, they would not
present a risk to human health since an exposure pathway would not be present.

9. Letter from Mr. Bill Dorfmeister

Comment: As a former property owner who never was detrimental in any way to either the property
or the environment I would like to see the EPA proceed with vigor against the perpetrators of
the problems of sites 1, 2 (3), and 3 (4) and all of the co-conspirators, namely the City and
County of Dallas, HB Zachary Co, and RSR Corp and all the executives of the above, both in the
criminal and civil courts.

A retaining wall should be built along the creek of Site 3 and charged to Dallas and whomever
contracted for closure of the landfill. If the city and the closing contractor don't pay, go
after them with much haste and very much vigor.

Response: EPA will select a remedial action for OU No. 3 that will be protective of human
health and the environment, that is cost effective, and that the community and State support.
EPA intends seek to have the responsible parties implement the remedial action and will pursue
all reasonable opportunities to recover costs associated with activities conducted at the site.

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Appendix B

ARARs Analysis

Table A-l
Solid Waste ARARs Evaluation
RSR Corporation Superfund Site OU No. 3

Requirement ARAR?

I. Chemical-Specific ARARs

State
Page 1 of 11
Justification
Groundwater Protection Yes
Design and Operation
Subchapter 11
30 TAG ° 330.200 (a) (1)

Constituents for Yes
Detection Monitoring
Subchapter I
30 TAAC ° 330.241

I. Action-Specific ARARs

Federal

40 C.F.R. Part 241 Yes
Guidelines for the Land
Disposal of Solid Wastes

40 C.F.R. Part 257 Yes
Criteria for
Classification of Solid
Waste Disposal Facilities
and Practices
The requirements specify that new municipal solid waste landfill facility units and lateral
expansions need to be designed such that the concentration values listed in Table 2 will not be
exceeded in the uppermost aquifer at the relevant point of compliance. The values are relevant
and appropriate to OU No. 3.

This section identifies 47 volatile organic chemicals and 15 metals for which detection
monitoring is required under 30 TAG ° 330.234. Depending on the remedial action selected
for the landfills at OU No. 3, this constituent list may be relevant and appropriate.
Establishes minimum levels of performance required of any solid waste land disposaal site
operation. Requirements are relevant and appropriate to conditions at OU No. 3 landfills.

Establishes criteria for use in determining which solid waste disposal facilities and practices
pose a reasonable probability of adverse effects on health or the environment and thereby
constitute prohibited open dumps. The landfill cover requirements stated in these regulations
are relevant and appropriate to landfills at OU No. 3.
40 C.F.R. Part 258
Regulations Concerning
Municipal Solid Waste
Landfills
Yes Established design and operational criteria for all new municipal solid waste landfills or
expansions of existing facilities. The requirements vary depending on the time frame that the
land disposal unit is used. The provisons include closure and post-closure care. Landfill
cover requirements are relevant and appropriate since waste was not received after October 9,
1991.

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Table A-l
Solid Waste ARARs Evaluation
RSR Corporation Superfund Site OU No. 3
Page 2 of 11
Requirement
ARAR?
Justification
40 C.F.R. Part 260-261 Yes
Identification and Listing
of Hazardous Waste
OSHA Worker
Protection
29 C.F.R. 1910.120
Yes
Defines those solid wastes that are subject to regulation as hazardous wastes under 40 C.F.R.
Parts 262-265, and Parts 124, 270, 271. The State of Texas has an approved delegated
program for this portion of RCRA. The regulations are applicable for purposes of determining
whether any of the materials disposed of are hazardous wastes for purposes of any remedial
actions taken under CERCLA. Materials may also be compared to the waste listings to
determine whether any of the materials are sufficiently similar such that RCRA regulations are
relevant and appropriate.

Applicable to OU No. 3 regarding protection of workers at site.
State
Applicability
Subchapter A
30 TAG ° 330.3(a) and
(b)
Yes Subsection (a) applies to all persons involved in any aspect of the management and control of
municipal solid waste including, but not limited to, storage, collection, handling,
transportation, processing and disposal. Subsection (b) notes that for municipal solid waste
landfills that stopped receiving waste before October 9, 1991 only the provisions of 30 TAG
330.251 (relating to closure reguirements) apply. Both subsections (a) and (b) are applicable.
As noted in the following, all other provisions of the regulation are either relevant and
appropriate or not ARARs except for closure reguirements established under 30 TAG 330.251,
330.254(a), and 330.255.
Permit Required
Subchapter A
30 TAG ° 330.4(a)
No Establishes requirements for permits for storage, processing, removal, or disposal of any
municipal solid waste. This requirement is not an ARAR as a permit is not required for
CERCLA actions.
General Prohibitions
Subchapter A
30 TAG ° 330.5(a)
Yes Section (a) specifies that the collection, storage, transportation, processing, or disposal of
municipal solid waste, or the use or operation of a solid waste facility to store, process, or
dispose of solid waste, in a manner that causes: (1) the discharge or imminent threat of
discharge of municipal solid waste into or adjacent to the waters in the state without obtaining
specific authorization, (2) the creation and maintenance of a nuisance, or (3) the endangerment
of human health and welfare or the environment. This requirement is relevant and
appropriate.

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Table A-l
Solid Waste ARARs Evaluation
RSR Corporation Superfund Site OU No. 3
Requirement

General Prohibitions
Subchapter A
30 TAG ° 330.5(e)(1),
(e) (4 ) , e (5) , e (7) , e (8)
ARAR?
Types of Municipal Solid
Waste Facilities;
Subchapter D
30 TAG ° 330.41
Justification
Section (e)(1) prohibits disposal of lead acid storage batteries at municipal solid waste landfills.
Section (e)(4) prohibits the disposal of whole used or scrap tires. Section (e)(5) prohibits the
disposal of refrigerators, freezers, air conditioners, and any other items containing chlorinated
fluorocarbons (CFCs), unless the CFCs have been removed and disposed of at an approved
facility. If the CFCs have not been removed, the whole item must be sent to an approved
CFC disposal facility. Section (e)(7) prohibits the disposal of regulated hazardous waste as
defined in Section 330.2 in a municipal solid waste facility. Section (e)(8) prohibits the
disposal of polychlorinated biphenyls in a municipal solid waste facility. All of these
provisions are relevant and appropriate to RSR OU No. 3.

Requires that, upon completion of the disposal operation and final closure of the facility or
site, that the owner/operator file an "Affidavit to the Public" that restricts the future use of the
land in accordance with Section 330.253(e) (8) (Closure Requirements for Municipal Solid
Waste Landfill Units that Receive Waste on or after October 9, 1993). This requirement is
relevant and appropriate to RSR OU No. 3.

This requirement outlines the classifications of municipal solid waste facilities. This provision
is not an ARAR as the landfills located within OU No. 3 are closed and unlikely to reopen.
Operational Standards
for Solid Waste Land
Disposal Sites
Subchapter F
30 TAG ° 330.100
No This subchapter outlines the permit procedures associated with legally permitting a solid waste
management facility. Because no permits are required for actions taken under CERCLA, these
provisions are not ARARs for OU No. 3.

No This subchapter establishes requirements for operational procedures including complying with a
Site Development Plan, Site Operating Plan, Final Closure Plan, Post-Closure Maintenance
Plan, Landfill Gas Management Plan, and all other documents and plans required by this
subchapter. These requirements are not ARARs for the RSR OU No. 3 site.
Large items (household appliances) should be recycled i f they cannot be incorporated into the
solid waste operation. The items should be removed from the site to prevent these items from
becoming a nuisance and to preclude the discharge of any pollutants from the area. This
requirement is relevant and appropriate i f remedial actions at the site require some action
relative to large items disposed of at the site.

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Table A-l
Solid Waste ARARs Evaluation
RSR Corporation Superfund Site OU No. 3
4 of 11
Requirement
No
Justification
Requires compliance with the State Implementation Plan regarding releases to air; also requires
that ponded water be controlled to avoid development of obj ectienable odors and requires
implementation of appropriate control measures should odors develop. These provisions are
relevant and appropriate i f remedial actions taken at the site involve disturbances resulting in
air releases or situations resulting in ponded water.

Prohibits a facility from destructing or modi fying the critical habitat of endangered or
threatened species, or cause or contribute to the taking of any endangered or threatened
species. This requirement is not an ARAR as no critical habitat of endangered or threatened
species has been identi fied at the site.

Requires that all landfill gases be monitored in accordance with an approved Landfill Gas
Management Plan. The provision is relevant and appropriate to landfills on OU No. 3. A
Management Plan would not be required under CERCLA, however, the requirements would
need to be incorporated to a remedial action.

Requires that all abandoned oil and water wells situated within the site be capped, plugged, and
closed in accordance with all applicable rules and regulations. These provisions are relevant
and appropriate i f abandoned oil and/or water wells are discovered on the OU No. 3 site in the
vicinity of the landfills.

This provision requires action be taken to mitigate ponded water over waste on a solid waste
management unit, open or closed. These requirements are relevant and appropriate i f ponded
water develops at the landfills located in OU No. 3, either before or as a result of any
remedial actions.
Disposal of Industrial
Wastes
Subchapter F
30 TAG ° 330.137
No
Allows disposal of a number of special wastes including dead animals, untreated medical
wastes, regulated asbestos-containing material, empty pesticide containers, municipal hazardous
waste from a conditionally exempt small quantity generator, used-oil filters, etc. These
provisions are not ARARs because the landfills are no longer in operation.
Operational Standards
for Solid Waste
Processing, and
Experimental Sites
Subchapter G
30 TAG ° 330.150

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Table A-l
Solid Waste ARARs Evaluation
RSR Corporation Superfund Site OU No. 3
Requirement

Groundwater Protection
Design and Operation
Subchapter H
30 TAG ° 330.201
Justification
This section establishes requirements for the use of leachate collection and associaated leachate
removal systems for landfills. The provisions specific to leachate collection and removal are
relevant and appropriate to the landfills at OU No. 3 in situations where documentation exists
to substantiate the generation of leachate.
Groundwater Protection
Design and Operation
Subchapter H
30 TAG ° 330.202
through 330.206

Groundwater Monitoring
and Corrective Action
Subchapter I
30 TAG ° 330.230
No The requirements outlined in these sections pertain to construction speci fications for liners and
location relative to geologic faults. The landfills located in OU No. 3 are no longer
operational; consequently these design specifications are not ARARs.
The requirements established for groundwater monitoring are relevant and appropriate to
landfills located in OU No. 3. Groundwater monitoring is required throughout the active li fe
and post-closure care period of the municipal solid waste landill unit.
Groundwater Monitoring
Systems
Subchapter I
30 TAG ° 330.231

Groundwater Sampling
and Analysis
Requirements
Subchapter I
30 TAG ° 330.233
These provisions require installation of a groundwater monitoring system that consists of a
sufficient number of wells at appropriate location and depth to yield representative groundwater
samples from the uppermost aqui fer. This includes installation of background wells. These
requirements are relevant and appropriate for the landfills located in OU No. 3.

Requirements in this section identi fy data needs associated with groundwater monitoring:
water level measurements, sampling and analytical methods, and the associated quality
assurance/quality control processes to be used as part of monitoring. These requirements are
relevant and appropriate for groundwater monitoring conducted for the landfills at OU No. 3.
Based on these provisions, detection monitoring is required at municipal solid waste landfill
units from all groundwater monitoring wells. Detection monitoring is required on at least a
semiannual basis during the active life of the facility and the closure and post-closure care
period. These requirements are relevant and appropriate to the landfills located in OU No. 3
Assessment Monitoring
Program
Subchapter I
30 TAG ° 330.235
Assessment of
Corrective Measures
Subchapter I
30 TAG ° 330.236
The provisions adopt 40 CFR Part 258, Appendix II by reference and indicate that if a
statistically significant change from background has been detected for one or more constituents
listed in 30 TAG ° 330.241(d) or an alternative list, that assessment monitoring is required.
Depending on the remedial action selected for the landfills located in OU No. 3, these
requirements are relevant and appropriate.

This section identi fies the need to evaluate possible corrective action measures for mitigating
statistically significant levels of constituents exceeding the groundwater protection standards.
Depending on the remedial action selected for the landfills, these requirements are relevant and
appropriate.

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Table A-l
Solid Waste ARARs Evaluation
RSR Corporation Superfund Site OU No. 3 Page 6 of 11

Requirement ARAR? Justi fication

Yes This section outlines the criteria for selecting a remedy in order to satisfy the following:
protective of human health and environment; attain groundwater protection standards; control
releases so as to reduce or eliminate further releases; and comply with standards for
management of wastes as specified in 30 TAG ° 330.238(d). These requirements are relevant
and appropriate depending on the nature and extent of groundwater contamination attributable
to the landfills and depending on the remedial action selected.

Implementation of the Yes This section outlines the criteria for initiation and completion of remedial activities. The
Corrective Action requirements are relevant and appropriate in so much that some remedial action is required to
Program address groundwater contamination resulting from the landfills located on OU No. 3.
Subchapter I
30 TAG ° 330.238

Groundwater Monitoring No Requirements included in these sections address groundwater monitoring at Type IV landfills
at Type IV Landfills which include those class!fied for the disposal of brush, construction-demolition waste, and/or
Subchapter I rubbish that are free of putrescible and household wastes, and landfills otherwise not class!fied
30 TAG ° 330.239 as Type I. These requirements are not ARARs for OU No. 3 landfills because the landfills
accepted municipal solid waste materials. Groundwater monitoring requirements included
Groundwater Monitoring elsewhere in Subchapter I are more appropriate to the situation than those specified in this
at Other Types of section.
Landfills and Facilities
Subchapter I
30 TAG ° 330.240

Monitor Well Yes Sped fications are provided by drilling; casing, screen, filter pack and seals; development;
Construction location and elevation; and plugging and abandonment. These specifications are revelant and
Specifications appropriate in so much as any remedial actions taken at the site require the installation of
Subchapter I additional monitoring wells.
30 TAG ° 330.242

Closure Requirements Yes This section establishes sped fie procedures and requirements for proper closure. Specific
for Municipal Solid requirements are included for: final cover system; final six inches of cover; side slopes of the
Waste Landfill Units final cover; and the schedule for submitting design and sped fications for the closure. These
That Stop Receiving requirements are applicable to the landfills at OU No. 3 which stopped receiving wastes prior
Waste Priorto tothestated deadline. Remedial actions which address cover requirements will need to comply
October 9, 1991, and the provisions of this section.
Municipal Solid Waste
Sites
Subchapter J
30 TAG ° 330.251

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Table A-l
Solid Waste ARARs Evaluation
RSR Corporation Superfund Site OU No. 3
Page 7 of 11
Requirement

Closure Requirements
for Municipal Solid
Waste Landfill Units
That Receive Waste on
or after October 9, 1991,
But Stop Receiving
Waste prior to
October 9, 1993 and
Closure Requirements
for Municipal Solid
Waste Landfill Units that
Receive Waste on or
after October 9, 1993,
and Municipal Solid
Waste Sites
Subchapter J
30 TAG °° 330.252 and
330.253
Justi fication
This requirements are not ARARs as the provisions sped fied in 30 TAG ° 330.251 are
applicable and address closure requirements sped fie to the landfill relative to the date of
operation and cessation of disposal activities.
Post-Closure Care
Maintenance
Requirements
Subchapter J
30 TAG ° 330.254(a)
Completion of Post-
Closure Care
Maintenance
Subchapter J
30 TAG ° 330.256
Section (a) of this provision applies sped fically to post-do sure care maintenance requirements
for municipal solid waste landfill units closing prior to October 9, 1993 and municipal solid
waste sites. Requirements of this section include: retainage of the right-of-way in for a
minimum of 5 years; correct cover material and erosion of cover material; and continue
monitoring programs implemented during operation. These requirements are applicable to the
post-closure care of the landfills located in OU No. 3.

These provisions establish limitations on proposed construction activities or structural
improvements located on closed municipal solid waste landfill units or municipal solid waste
sites. Section (b)(1) of the provisions require that any proposed construction activities or
structural improvements not disturb the integrity and function of the final cover, any liner(s),
all components of the containment system(s), and any monitoring system(s). These provisions
and others included in the citation are applicable to the landfills located in OU No. 3
depending on remedial actions that may be taken that would require disturbance of the in-place
systems.

This section specifies the requirement for submitting documentation verifying the post-do sure
care maintenance has been completed in accordance with the approved post-closure plan. This
requirement is not an ARAR for the landfills located in OU No. 3 because CERCLA actions
taken at the site would not require formal certification of completion under this section.

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Table A-l
Solid Waste ARARs Evaluation
RSR Corporation Superfund Site OU No. 3
Requirement
ARAR?
Justification
Solid Waste Technician No These provisions deal with procedures for training and certifying landfill operation employees.
Training and The requirements provide no substantive requirements relative to CERCLA activities and are
Certification Program therefore not ARARs for OU No. 3.
Subchapter M
30 TAG °° 330.381-
303.391
Guidelines for Regional
and Local Solid Waste
Management Plans
Subchapter O
30 TAG °° 330.561-
330.568
Fees and Reports for
Facilities
Subchapter P
30 TAG °° 330.601-
330.700
These provisions outline reporting requirements for municipal solid waste landfill units and
other related operations. The requirements provide no substantive requirements relative to
CERCLA activities and are therefore not ARARs for OU No. 3.
Memoranda of
Agreement and Joint
Rules with Other
Agencies
Subchapter Q
30 TAG °° 330.701-
330.733
Management of Whole
Used or Scrap Tires
Subchapter R
30 TAG °° 330.801-
330.899
Assistance Grants and
Contract
Subchapter S
30 TAG °° 330.890-
330.897
Subchapter R includes detailed regulations for whole used or scrap tires-generation, storage,
and transportation. Provisions included in Subchapter R are not ARARs as the landfills
associated with OU No. 3 were not sped fically designed nor were disposed as part of historical
facilities. Tires observed at the landfills in OU No. 3 were disposed as part of historical
practices or as illegally disposed materials (open dumping). Subchapter R does not contain
substantive requirements for handling tires disposed of under conditions present at OU No. 3.

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Table A-l
Solid Waste ARARs Evaluation
RSR Corporation Superfund Site OU No. 3
Requirement

Management of Whole
Used or Scrap Tires or
Shredded Tire Pieces
Subchapter X
30 TAG °° 330.900-
330.938
ARAR?
Justification
No Tires observed at the landfills in OU No. 3 were disposed as part of historical practices or as
illegally disposed materials (open dumping). Subchapter x does not contain substantive
requirement for handling tires disposed of under conditions present at OU No. 3.
Use of Land Over
Closed Municipal
Landfills
Subchapter T
30 TAG °° 330.951-
330.963
Generators of Medical
Waste
Subchapter Y
30 TAG ° 330.1004
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 1 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. 3 i f remedial actions undertaken at the landfills require
construction of building directly on top of a closed landfill, with the exception of the
permitting requirement requirements which would not be ARARs for actions implemented under CERCLA.

This section establishes standards for generators of medical wastes. These include: record
keeping; treatment testing procedures; disposal requirements. Requirements for disposal
[1004 (d) (4)] is relevant and appropriate for handling and disposal of sharps identi fied at the
landfills at OU No. 3.
Transporters of Medical
Waste
Subchapter Y
30 TAG ° 330.1005
This section establishes standards for transporters transporting medical wastes to offsite
storage, treatment, or disposal facilities. Requirements of this section are relevant and
appropriate for medical wastes on OU No. 3 that are sent offsite for disposal.
This section specifies that used lead-acid batteries may not be placed with mixed municipal
solid waste or otherwise disposed of except as according to these regulations. These
requirements are relevant and appropriate to the landfills at OU No. 3 if lead-acid batteries are
discovered during the course of CERCLA-related actions at the site.

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Table A-l
Solid Waste ARARs Evaluation
RSR Corporation Superfund  Site  OU No.  3
      Requirement

3 .   Location Sped fie

State
                             ARAR?
                                                               Justification
Easements and Buffer
Zones
Subchapter F
30 TAG ° 330.121
Prohibits solid waste management  activities within easements, buffer  zones,  or rights-of-way
that cross the site; prohibits  disposal within 25 feet of the center  line  of any utility line or
pipeline easement without  approval.   A minimum of 50 feet must be maintained between solid
waste processing and disposal activities and the site boundary unless  otherwise approved.
These requirements  are  relevant and appropriate i f remedial actions at  the site require
modification or construction related to the landfills.
                           No
                           No
                                    Specifies necessary actions if landfill  units  or lateral expansions are located near airport
                                    runways under sped fie operating conditions.   Subsection 300(d)  of these requirements indicate
                                    that  disposal of wastes shall not be located in  areas where the attraction of birds can  cause a
                                    signi fleant bird hazard to low-flying aircraft and that all sites within 5 miles of an airport be
                                    critically evaluated to determine if an  incompatibility exists.   These requirements are  not
                                    ARARs because airport runways are within 5 miles of OU No.  3.

                                    These provisions apply to new municipal  solid  waste landfill units, existing units, and  lateral
                                    expansions located in a 100-year floodplain.   These units must not restrict the flow of  the 100-
                                    year  flood, reduce the temporary water storage capacity of the floodplain, or result in  washout
                                    of solid waste.   These provisions are ARARs i f remedial activities result in construction  or
                                    modifications impacting a floodplain.

                                    These provisions sped fy that a municipal solid  waste landfill unit shall not cause or contribute
                                    to significant degradation of wetlands.   This  includes preventing adverse impacts on fish,
                                    wildli fe, and other aquatic resources and their  habitat from release of the solid waste.
                                    Subsection 302(2)(A)  through  (C) includes requirements that the construction and operation of
                                    the landfill unit shall not result in violations of the State  waste quality standards, toxic effluent
                                    standards of the Clean Water Act, and j eopardi ze the continued existence of endangered or
                                    threatened species or result in loss or  destruction of habitat.   The requirements under  this
                                    section are relevant and appropriate; remedial actions taken at the site that impact the wetlands
                                    will  need to address these requirements.
                           No
                                                                                                                                    This

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Table A-l
Solid Waste ARARs Evaluation
RSR Corporation Superfund Site OU No. 3
                                                 Page 11 of 11
      Requirement
 ARAR?
                                  Justification
Unstable Areas
Subchapter L
30 TAG ° 330.305
No     Specifies engineering design criteria for landfill units or expansions located in unstable areas.
       These requirements are not ARARs because unstable areas have not been documented in the
       OU No. 3 area.

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Table A-2
Solid Waste Contaminant-Specific ARARs

RSR Corporation Superfund Site OU No. 3


             Parameter

             Arsenic
             Barium
             Benzene
             Cadmium
             Carbon tetrachloride
             Chromium (hexavalent)
             2,4-D
             1,4-Dichlorobenzene
             1,2-Dichloroethane
             1,1-Dichloroethylene
             Endrin
             Fluoride
             Lindane
             Lead
             Mercury
             Methoxychlor
             Nitrate
             Selenium
             Silver
             Toxaphene
             1,1,1-Trichloroethane
             Trichloroethylene
             2,4,5-T
             Vinyl chloride
R&A 1
(mg/L)

 0.05
   1
 0.005
  0.01
 0.005
  0.05
   0.1
 0.075
 0.005
 0.007
0.0002
   4
 0.004
  0.05
 0.002
   0.1
    10
  0.01
  0.05
 0.005
   0.2
 0.005
  0.01
 0.002
             1 Design Criteria; 30 TAG 330.200; Subchapter H—Groundwater

             Protection Design and Operation

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Table A-3

Solid Waste Contaminant-Specific ARARs

Constituents for Groundwater Detection Monitoring

RSR Corporation Superfund Site OU No. 3
         R&A 1
      Inorganic a
       Parameter
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Lead
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
         R&A 1
        Organic
       Parameter

Acetone
Acrylonitrile
Benzene
Bromochloromethane
Bromodichloromethane
Bromoform
Carbon disulfide
Carbon tetrachloride
Chlorobenzene
Chloroethane
Chloroform
Dibromochloromethane
1,2-Dibromo-3-chloropropane
1,2-Dibromomethane
o-Dichlorobenzene
p-Dichlorobenzene
trans-1,2-Dichloro-2-butene
1,1-Dichloroethane
1,2-Dichloroethane
1,1-Dichloroethylene
cis-1,2-Dichloroethylene
trans-1,2-Dichloroethylene
1,2-Dichloropropane
cis-1,3-Dichloropropene
trans-1,3-Dichloropropene
Ethylbenzene
2-Hexanone
Methyl bromide
Methyl chloride
Methylene bromide
Methyl chloride
Methyl ethyl ketone
Methyl iodide
4-Methyl-2-pentanone
Styrene
1,1,1,2-Tetrachloroethane
1,1,2,2-Tetrachloroethane
Tetrachloroethylene
Toluene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Trichloroethylene
Trichlorofluoromethane
1,2,3-Trichloropropane
Vinyl acetate
Vinyl chloride
Xylenes
Total constituents.
Subchapter I—Constituents for Detection Monitoring; 30 TAG 330.241.

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Requirement
Page 1 of 11
Justi fication
TBC
Yes Applicable to OU No. 3. Evaluates baseline human health risk due to current and potential
future site exposures, and establishes contaminant levels in environmental medial at the OUs
for protection of public health.
Office of Solid Waste and Emergency Response
(OSWER)
Directive 9355.4-12
July 14, 1994
TBC
TBC for OU No. 3. The strategy was developed to reduce lead exposures to the greatest
extent possible. Goals of the strategy are to: (1) significantly reduce blood lead incidences
above 10 Ig/dL in children and (2 ) reduce the amount of lead introduced into the
environment.
Attainment of Risk Reduction Standard Number 2:
Closure/Remediation to Health/Based Standards
and Criteria Subchapter S
30 TAG ° 335.555
This section specifies the requirements for identifying if a nonhazardous industrial solid waste
is a Class 1 waste, which is defined as a waste that contains sped fie constituents which equal
or exceed the levels listed in Table 5. These provisions are applicable to OU No. 3.

These provisions specify that, to meet Risk Reduction Standard Number 1, closure and/or
remediation must meet background levels or practical quantitation limits if the practical
quantitation limit exceeds background. These provisions would be relevant and appropriate i f
Risk Reduction Standard Number 1 were the preferred standard; however, it is unlikely that
cleanup goals will be set at background levels.

Subsection (a) specifies that the concentration of a contaminant in contaminated media of
concern such as groundwater, surface water, air or soil shall not exceed the cleanup levels as
defined in ° 335.556 (relating to Determination of Cleanup Levels for Risk Reduction
Standard Number 3). If the practical quantitation limit and/or background concentration is
greater than the cleanup level, the greater of the practical quantitation limit or background
shall be used for determining compliance with the requirements of this section. These
provisions are relevant and appropriate to development of contaminant-sped fie cleanup goals
for OU No. 3.

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Table A-4
Soils or Solid Media ARARs
RSR Corporation Superfund Site OU No. 3

Requirement
Justi fication
Determination of Cleanup Levels for Risk
Reduction Standard Number 2
Subchapter S
30 TAG ° 335.556
Criteria for Selection of Non-residential Soil
Requirements for Risk Reduction Standard
Number 2
Subchapter S
30 TAG ° 335.557

Medium Sped fie Concentrations for Risk
Reduction Standard Number 2
Subchapter S
30 TAG ° 335.558

Medium Sped fie Requirements and Adj ustments
for Risk Reduction Standard Number 2
Subchapter S
30 TAG ° 335.559
Sped fies that for purposes of risk reduction, cleanup levels for individual contaminants are
represented by Texas or federal promulgated health-based standards, or when these are not
available or do not provide appropriate protection, then cleanup levels based on procedures
sped fied for determining other numeric criteria (Medium-Specific Concentration or MSC) ARE
required to be developed. These provisions are relevant and appropriate to OU No. 3.

Sped fies the conditions under which soil requirements can deviate from residential soil
requirements. Subsection (1) notes that for property located within the jurisdictional area of
zoning authority, documentation may be provided to demonstrate that the property is zoned
for commercial or industrial use. This requirement is relevant and appropriate for OU No. 3
to the extent that current zoning is relied upon to predict future land uses.

Subsections (b) through (d) of this section sped fy the methods for calculating medium sped fie
concentrations for ingestion of surface water and groundwater, and soil ingestion along with
inhalation of volatiles and particulates. These provisions are relevant and appropriate to
setting contaminant-sped fie cleanup levels/goals for OU No. 3.

Subsections (b) through (h) sped fy requirements that can define or modi fy numeric cleanup
levels such as media-specific concentrations or require non-health based criteria to be
addressed. These provisions are relevant and appropriate to establishing cleanup goals for
OU No. 3.
2. Action-Specific ARARs

Federal
40 C.F.R. Part 264
Subparts B, C, D and G
Standards for Owners and Operators of Hazardous
Waste Treatment, Storage, and Disposal Facilities
40 C.F.R. Part 268 establishes restrictions on land disposal of sped fie wastes unless
treatment standards are met. Applicable to OU No. 3, if the wastes are removed from the
site for subsequent disposal. Metals wastes in soil that are hazardous by toxicity
characteristic are exempt from this rule. The Universal Treatment Standards (UTS) establish
a concentration limit for 300 regulated constituents in soil regardless of waste type.

Subparts B, C, and D establish minimum standards which define the acceptable management
of hazardous waster 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 applicable for wastes identified as RCRA
hazardous wastes and relevant and appropriate if sufficiently similar.

-------
Requirement
Justi fication
40 C.F.R. Part 264
Subparts I and J
Standards for Container and Tank Storage of
Hazardous Waste
40 C.F.R. Part 264
Subparts L and N
Standards for Waste Piles and Landfills
Subpart 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 applicable for RCRA hazardous wastes on OU No. 3 if containers are used
for onsite storage of liquids, soil, or other wastes as part of the remedial action, or relevant
and appropriate if sufficiently similar.

Subpart 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, Subpart L requirements are
applicable and must be met. Subpart N establishes construction, design, performance, closure,
and operation requirements pertaining to Subtitle C landfills. Subpart L and/or N are
applicable for RCRA hazardous wastes on OU No. 3 if onsite treatment, storage, or disposal
in piles or Subtitle C landfills is included as part of the remedial action, and relevant and
appropriate if sufficiently similar to hazardous waste.

The promulgated portion of Subpart S address 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 not subj ect to the full permitting requirements of a
fully regulated RCRA unit and waste piles are not eligible for TUs. Subpart S requirements
are applicable for RCRA hazardous wastes on OU No. 3 if the remedial action requires
wastes to be managed in an onsite CAMU or TU, and relevant and appropriate if sufficiently
similar to hazardous waste.
40 C.F.R. Part 264
Subpart X (Miscellaneous Units
Relates to "miscellaneous" units that treat, store, or dispose hazardous wastes. Provides
general performance standards for location, design, construction, operation, monitoring, and
do sure/post-do sure. This requirement is applicable for RCRA hazardous wastes on OU No.
3 if the remedial action includes onsite treatment, storage, or disposal of waste in a
miscellaneous unit, and relevant and appropriate if sufficientlly similar to hazardous waste.

-------
Table A-4
Soils or Solid Media ARARs
RSR Corporation Superfund Site  OU No.  3

      Requirement
      Page 4 of 11
                               Justi fication
                                                              Serves as an ARAR  only to  extent that it author!zes 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 OU  No.  3.
Surface Mining Control and  Reclamation Act of
1977
25 GSC °° 1201 et. seg.;  30 C.F.R.  Parts 816.11,
.95, .97, .100, and  .102
The requirements include provisions  for:

  6  .11 - Posting signs and markers for  reclamation,  including top soil markers  and
     perimeter markers.
                                                                    .97 - Use  of  best  technology currently available to minimi ze  disturbances and adverse
                                                                    impacts  on fish, wildli fe,  and related environmentall values  and achieve enhancement of
                                                                    such if  possible.

-------
Table A-4
Soils or Solid Media ARARs
RSR Corporation Superfund Site OU No. 3

Requirement
Justi fication
2. Action-Specific ARARs (Continued)

State (Continued)
Post Closure Care and Deed Certification for Risk Yes
Reduction Standard Number 2
Subchapter S
30 TAG ° 335.560

Attainment of Risk Reduction Standard Number 3: Yes
Closure/Remediation with Controls
Subchapter S
30 TAG ° 335.561

Remedy Evaluation Factory for Risk Reduction Yes
Standard Number 3
Subchapter S
30 TAG ° 335.562

Media Cleanup Requirements for Risk Reduction Yes
Standard Number 3
Subchapter S
30 TAG ° 335.563
These provisions apply to closure and remediation of facilities associated with contamination
resulting from unauthori zed discharges, either as part 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 unauthori zed discharges of industrial waste or municipal
hazardous waste. Section (a) (2) of this citation specifies that, for remediations performed
under the State Superfund program, media cleanup levels should be based on future
residential land use unless it is demonstrated that an alternative land use is more appropriate.
These requirements are relevant and appropriate for RCRA hazardous wastes on OU No. 3.

These provisions specify that, upon attainment of Risk Reduction Standard Number 2, a deed
recordation be placed in the county using information contained in Subsections (1) through
(4). This requirement is relevant and appropriate to OU No. 3 in so much that provisions
similar to Risk Reduction Stadard Number 2 are applied.

Under Risk Reduction standard Number 3, a remedy must be permanent, or if that is not
practicable, achieve the highest degree of long-term effectiveness possible; cost-effective; and
achieve media cleanup requirement specified in 30 TAG ° 335.563. These provisions are
relevant and appropriate to OU No. 3.

These provisions outline the evaluation criteria when evaluating the relative abilities and
effectiveness of potential remedies to achieve the requirements for remedies described in
30 TAG ° 335.562. The evaluation criteria are relevant and appropriate for screening
technologies and alternatives is part of the FS for OU No. 3.

This section specifies the requirements for establishing cleanup levels for air, surface water,
groundwater, and soil, including use of media-sped fie adj ustments. The requirements of this
section are relevant and appropriate to OU No. 3.
Post closure care not required for Risk Reduction Yes
Standard Number 3
Subchapter S
30 TAG ° 335.564
Where it is determined that neither engineering nor institutional control measures are
required, no post closure care responsibilities are necessary however deed recordation is
required in accordance with 30 TAG ° 335.566. This requirement is relevant and appropriate
if the conditions are met at OU No. 3.
Shipping and Reporting Procedures Applicable to
Generators of Hazardous Waste or Class I Waste
and Primary Exporters of Hazardous Waste
Subchapter A
30 TAG ° 335.10
Establishes requirements for mani testing shipments of hazardous waste to off-site facilities.
This requirement is applicable to OU No. 3 i f hazardous or Class I wastes are shipped off-site
to a disposal/treatment facility.

-------
      Requirement
                                                                                             Justi fication
Shipping Requirements  for  Transporters of
Hazardous Waste or Class I Waste
Subchapter A
30 TAG ° 335.11
Shipping Requirements Applicable  to Owners or     No
Operators of Storage, Processing,  or Disposal
Facilities
Subchapter A
30 TAG ° 335.12
Special Definitions  for  Recyclable  Materials and  Yes
Nonhazardous Recyclable  Materials
Subchapter A
30 TAG ° 335.17
Requirements for Recyclable Materials and
Nonhazardous Recyclable Materials
Subchapter A
30 TAG ° 335.24  (c) and  (h)
Sped fies that scrap metal  is  not  subj ect to regulation under Subchapter B-I  and  Oof Chapter
335.   Under ° 335.24(h),  the rule  spedfies that scrap metal, as defined in  Section  (c)  remains
subj ect to the requirements of °  335.4  (relating to General Prohibitions) and ° 335.6 (relating
to Noti fication Requirements) .   Such  waste may also be subj ect to the requirements of
0 335.10 through  ° 335.15 of Title 30.
                                                              Adopts appendices  contained in 40 C.F.R. Part 261 by reference;  this  includes Appendix I-
                                                              III, VII-X.
                                                              I
                                                              II
                                                              III
                                                              VII
                                                              VIII
                                                              IX
                                                              X
        - Representative  Sampling  Methods
        - Method 1311 Toxicity Characteristic Leaching Procedure
        - Chemical Analysis  Test Methods
        - Basis for Listing  Hazardous  Waste
        - Hazardous Constituents
        - Wastes Excluded under °  260.20 and ° 260.22
        - Method of Analysis  for Chlorinated Dibenzo-p-dioxins and
                                                                        Dibenzofurans.

-------
Table A-4
Soils or Solid Media ARARs
RSR Corporation Superfund Site OU No. 3

Requirement

2. Action-Specific ARARs (Continued)

State (Continued)
of 11
Justi fication
Hazardous Waste Management General Provisions Yes
Subchapter B
30 TAG ° 335.41

Standards Applicable to Generators of Hazardous Yes
Wastes
Subchapter C
30 TAG ° 335.61, °° 335.65-335.70

Standards Applicable to Transporters of Hazardous Yes
Waste
Subchapter D
30 TAG ° 335.91
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. Part 261. These standards are
relevant and appropriate for RCRA hazardous wastes on OU No. 3.

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 OU No. 3.

This subchapter establishes standards for transporters transporting hazardous waste to offsite
storage, processing, or disposal facilities. This subchapter does not apply to onsite
transportation of hazardous waste by generators or by owners or operators of storage,
processing, or disposal facilities.

5 that
Applicability of Groundwater Monitoring and
Response
Subchapter F
30 TAG ° 335.156
This section outllines 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.
(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 limits under
0 335.160 in groundwater between the compliance point and the downgradient 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. 3.

-------
Table A-4
Soils or Solid Media ARARs
RSR Corporation Superfund Site OU No. 3

Requirement
Justi fication
2. Action-Specific ARARs (Continued)

State (Continued)

Interim Standards for Owners and Operators of Yes
Hazardous Waste Storage, Processing, or Disposal
Facilities
Subchapter E
30 TAG ° 335.111
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
certifi cation of final closure or, if the facility is subj ect to post-do sure requirements, until
post-do sure responsibilities are ful filled.
Interim Standards for Owners and Operators of
Hazardous Waste Storage, Processing, or Disposal
Facilities-Standards
Subchapter E
30 TAG ° 335.112
These requirements are relevant and appropriate for RCRA hazardous wastes on OU No. 3 i f
wastes are left onsite.
Establishes requirements for hazardous leachate or run-off from a pile: 1) the pile must be
placed on an impermeable base, must include a run-on control system and a run-off
management system and 2) the pile must be managed such that it must be protected from
precipitation and run-on and no liquids or wastes containing free liquids may be placed in the
pile.
Permitting Standards for Owners and Operators of
Hazardous Waste Storage Processing or Disposal
Facilities
Subchapter F
30 TAG ° 335.151
Subchapter F includes the minimum standards of operation for all aspects of the management
and control of municipal hazardous waste and industrial solid waste, including rules relating
to the siting of hazardous waste facilities. Permit not required, however, substantive portions
must be met.

These standards are relevant and appropriate for RCRA hazardous wastes on OU No. 3.
Corrective Action for Solid Waste Management No
Units
Subchapter F
Outlines requirements for corrective action at solid waste management units. No solid waste
management units have been identi fied at OU No. 3. These standards are not ARARs because
no regulated units have been established at OU No. 3.

-------
Table A-4
Soils or Solid Media ARARs
RSR Corporation Superfund Site OU No. 3

Requirement
Justi fication
2. Action-Specific ARARs (Continued)

State (Continued)
Design and Operating Requirements (Waste Piles) Yes
Subchapter F
30 TAG ° 335.170
Establishes requirements for waste piles including: 1) a liner designed, constructed, and
installed to prevent any migration of wastes out of the pile and 2) a leachate collection and
removal system immediately above the liner that is designed, constructed, maintained, and
operated to collect and remove leachate from the pile.
Location Standards for Hazardous Waste Storage
Processing, or Disposal
Subchapter G
30 TAG ° 335.201 (a) (3)
This subchapter establishes minimum standards for the location of facilities used for the
storage, processing, and disposal of hazardous waste. The requirements are applicable for
facility built onsite to store, process, or dispose of RCRA hazardous wastes.
Hazardous Waste Generation, Facility, and
Disposal Fees System
Subchapter J
30 TAG ° 335.321
Hazardous Substance Facilities Assessment and
Remediation
Subchapter K
30 TAG ° 335.341 (b)(4)
Sped fie Air Emission Requirements for Hazardous Yes
or Solid Waste Management Facilities
Subchapter L
30 TAG ° 335.367
Outlines the scope and requirements associated with the State Superfund program, including:
ranking of facilities (° 335.343), delisting and modi fications (° 335.344), removal actions and
preliminary site 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 EPA1s 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. 3.
These requirements are administrative requirements. Administrative requirements are not
ARARs.

-------
Requirement
Page 10 of 11
Justi fication
These provisions adopt 40 C.F.R. Part 268 by reference and are applicable for OU No. 3 i f
wastes are removed from the site for subsequent disposal. The Universal Treatment
Standards adopted by Subchapter O establish a concentration limit for 300 regulated
constituents in soil regardless of waster type.

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 Subchapter P are relevant and appropriate for RCRA
hazardous wastes on OU No. 3.
Pollution Prevention Source Reduction and Waste No
Minimi zation
Subchapter Q
30 TAG ° 335.473
Applies to all large quantity generators, all generators other than large quantity and
conditionally exempt generators, and all persons subj ect to reporting requirements under
SARA 313 Title III. The RSR Site is not a large quantity generator. Therefore, these
requirements are not ARARs for OU No. 3.
These requirements sped fy the class!fication scheme and coding for all industrial solid and
municipal hazardous waste generated, stored, processes, transported, or disposed of in the
site. These requirements are relevant and appropriate for all waste at OU No. 3.

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. Part 261
Subpart C. These requirments are applicable for identi fying RCRA hazardous waste at OU
No. 3.

-------
Table A-4
Soils or Solid Media ARARs
RSR Corporation Superfund Site OU No. 3

Requirement

2. Action-Specific ARARs (Continued)

State (Continued)
Page 11 of 11
Justification
TNRCC Historically Contaminated Sites:
Industrial Versus Municipal Solid Waste
July 12, 1994
TBC
Section (2) establishes requirements for empty containers; section (3) provides the
class!fication criteria for paper, cardboard, food wastes, and general plant trash; Section (4)
specifies that medical wastes subj ect to the provisions of Chapter 330 shall be designated as
Class 2 wastes; and Section (7) mandates that wastes generated by the mechanical shredding
of automobiles, appliances, or other items of scrap, used or obsolete metals shall be handled
according to the provisions set forth in Texas Solid Waste Disposal act, the Health and Safety
Code (° 361.019) until sped fie standards are developed for the class!fication of this waste and
adequate disposal capacity is assured. Applicable to OU No. 3 due to open dumping that has
occurred at OU No. 3 which includes empty containers, general trash, and medical wastes.

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:
3. Location-Specific ARARs

Federal
Coastal Zone Management Act
16 U.S.C. ° 1451 et seq.
40 C.F.R. ° 6.302(d)
No
Requires assessment of the impacts of activities on a costal 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. 3 will not impact a coastal zone; therefore this
requirement is not an ARAR.

Relates to hazardous waste treatment, storage, or disposal facilities subj ect to permitting.
Requires that new units where treatment, storage, or disposal of hazardous waste will be
conducted be located greater than 200 feet 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 feet of a
fault, thus the provisions pertaining to faults are not ARARs.

-------
Table A-5
Soils or Solid Media Waste Contaminant-Specific ARARs
Maximum Leachable Concentrations
Subchapter R Waste Determination
RSR Corporation Superfund Site OU No. 3

                                                     Concentration
                Parameter                               (mg/L)
                Acetone                                   400
                Acetonitrile                               20
                Acetophenone                              400
                Acrylamide                                0.08
                Acrylonitrile                             0.6
                Aniline                                    60
                Antimony                                   1
                Arsenic                                   1.8
                Barium                                    100
                Benzene                                   0.5
                Benzidine                                0.002
                Beryllium                                0.08
                Bis(2-chloroethyl)ether                   0.3
                Bis(2-ethylhexyl)phthalate                30
                Bromodichloromethane                      0.3
                Bromomethane                               5
                Butylbenzyl phthalate                     700
                Cadmium                                   0.5
                Carbon disulfide                          400
                Carbon tetrachloride                      0.5
                Chlordane                                 0.03
                Chlorobenzene                              70
                Chloroform                                 6
                2-Chlorophenol                             20
                Chromium                                   5
                m-Cresol                                  200
                o-Cresol                                  200
                p-Cresol                                  200
                Cyanide                                    70
                DDD                                        1
                DDE                                        1
                DDT                                        1
                Dibutyl phthalate                         400
                1,4-Dichlorobenzene                       7.5
                3,3-Dichlorobenzidine                     0.8
                1,2-Dichloroethane                        0.5
                Dichlorodifluoromethane                   700
                1,1-Dichloroethylene                       0.6
                1,3-Dichloropropene                        1
                2,4-Dichlorophenol                          10
                2,4-D                                      10
                Dieldrin                                  0.02

1 of 3

-------
Table A-5
Soils or Solid Media Waste Contaminant-Specific ARARs
Maximum Leachable Concentrations
Subchapter R Waste Determination
RSR Corporation Superfund Site OU No. 3
                Parameter
                Diethyl phthalate
                Dimethoate
                m-Dinitrobenzene
                2,4-Dinitrophenol
                2,4-Dinitrotoluene
                1,4-Dioxane
                Diphenylamine
                1,2-Diphenylhydrazine
                Disulfoton
                Endosulfan
                Endrin
                Epi chlorohydrin
                Ethylbenzene
                Ethylene dibromide
                Heptachlor
                Heptachlor epoxide
                Hexachlorobenzene
                Hexachloro-1,3-butadiene
                Hexachlorocyclopentadiene
                Hexachloroethane
                Hexachlorophene
                Isobutyl alcohol
                Isophorone
                Lead
                Lindane
                Mercury
                Methacrylonitrile
                Methorny1
                Methoxychlor
                Methyl ethyl ketone
                Methyl isobutyl ketone
                Methylene chloride
                Methyl parathion
                Nickel
                Nitrobenzene
                N-Nitroso-di-n-butylamine
                N-Ni tros odiphenylamine
                N-Nitrosomethylethylamine
                N-Nitroso-n-propylamine
                Parathion
                Pentachlorobenzene
                Pentachlorophenol
Concentration
   (mg/L)
    3,000
      70
     0.4
      7
     0.13
      30
      90
     0.4
     0.1
     0.2
     0.02
      40
     400
    0.004
    0.008
     0.04
     0.13
     0.4
      20
      3
      1
    1,000
      90
     1.5
     0.3
     0.2
     0.4
      90
      10
     200
     200
      50
     0.9
      70
      2
     0.06
      70
     0.02
     0.05
      20
      3
     100
2 of 3

-------
Table A-5
Soils or Solid Media Waste Contaminant-Specific ARARs
Maximum Leachable Concentrations
Subchapter R Waste Determination
RSR Corporation Superfund Site OU No. 3

                                                     Concentration
                Paramter                                (mg/L)
                Phenol                                   2,000
                Pyridine                                   4
                Selenium                                   1
                Silver                                     5
                Styrene                                   700
                1,1,1,2-Tetrachloroethane                  10
                1,1,2,2-Tetrachloroethane                  2
                Tetrachloroethylene                       0.7
                Toluene                                  1,000
                Toxaphene                                 0.3
                trans-1,3-Dichloropropene                  1
                1,2,4-Trichlorobenzene                     70
                1,1,1-Trichloroethane                     300
                Trichloroethylene                         0.5
                1,1,2-Trichloroethane                      6
                Trichlorofluoromethane                   1,000
                2,4,5-TP                                   1
                Vinyl chloride                            0.2
                Xylenes                                  7,000

3 of 3

-------
                       Chemical
            Inorganics
            Antimony
            Arsenic
            Barium
            Beryllium
            Cadmium
            Chromium
            Cobalt
            Copper
            Lead
            Manganese
            Mercury
            Nickel
            Selenium
            Silver
            Thallium
            Vanadium
            Zinc
            Organics
            1,1,1 Trichloroethane
            2-Butanone
            2-Methylnaphthalene
            4,4'-DDD
            4,4'-DDE
            4,4'-DDT
            2-Methyl-2-pentanone
            Acenaphthene
            Acenaphthylene
            Acetone
            Anthracene
            Arochlor-1242
            Arochlor-1248
            Arochlor-1254
            Arochlor-1260
            delta-BHC
            gamma-BHC
    1
   R&A
Industrial
 (mg/kg)
                                                             100

                                                              1
Page 1 of 3

-------
           Chemical
Benzene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g,h,i)perylene
Benzo(k)fluoranthene
bis(2-Ethylhexyl)phthalate
Carbazole
alpha-Chiordane
gamma Chiordane
Chrysene
Di-n-butyl phthalate
Di-n-octyl phthalate
Dibenz(a,h) anthracene
Dibenzofuran
Dieldrin
Diethylphthalate
Endosulfan I
Endosulfan 11
Endosulfan sulfate
Endrin
Endrin aldehyde
Endrin ketone
Ethylbenzene
Fluoranthene
Fluorene
Heptachlor epoxide
Indeno(1,2,3-ed)pyrene
Methylene chloride
N-Nitrosodiphenylamine
Naphthalene
Phenanthrene
Phenol
Pyrene
Toluene
Trichloroethene
491
                      1
                     R&A
                 Industrial
                   (mg/ kg)      a, c, d
                     1.62         g
                      4 .4
                      4 .4
    2
   TBC
Residential
  (mg/kg)
    22
    0.87
   0.087
    0.87
    2
   TBC
Industrial
  (mg/kg)
    197
    7.84
   0.784
    7.84
                                                                   784
                                                                 204,400
                                                                  40,880
                                                                   0.784
                                                                   8, 176
                                                                   0.357
                                                                1,635,200
                                                                  12,264

-------
Table A-7
Surface Water ARARs
RSR Corporation Superfund Site OU No. 3

           Requirement
1.  Contaminant-Specific ARARS
 ARAR?
                                      Page 1 of 10

                                           Justification
Federal
Safe Drinking Water Act
40 U.S.C. 399
Primary Drinking Water Standards  (MCL)
40 C.F.R. Part 141
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 or private water supply.
MCLs are not ARARs for surface water at OU No. 3.
Secondary Drinking Water Standards
40 C.F.R. Part 143

Maximum Contaminant Level Goals
(MCLG)
40 C.F.R. ° 141.50
No       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.

No       Not presently considered an ARAR as surface waters are not utilized as a source of
         drinking water.
Federal Clean Water Act
Water Quality Criteria
40 C.F.R. Part 131 U.S. EPA
Quality Criteria for Water, 1976, 1980,
and 1986
No       These criteria (ambient water quality criteria)  apply to water classified as a fisheries
         resource.  Water bodies on OU No. 3 are not classified as such.  Therefore,  not an
         ARAR or TBC for OU No. 3.
Toxic Pollutant Effluent Standards
40 C.F.R. Part 129
No       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.  3.
Hazardous Substances
40 C.F.R. ° 116.3 and 116.4
No       Establishes reporting requirements for certain discharges of reportable quantities of
         hazardous substances.  Creates no substantive clean up requirement.   Not an ARAR.

-------
Table A-7
Surface Water ARARs
RSR Corporation Superfund Site OU No. 3

Requirement ARAR?
1. Contaminant-Specific ARARS (Continued)
Page 2 of 10

Justification
State
Pollution Prohibition
Texas Water Code
0 26.121
Yes 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. May be
relevant and appropriate for OU No. 3 due to discharges to onsite drainages.
Texas Surface Wafer Quality Standards Yes
Aesthetics
30 TAG ° 307.4(b) (1)
General Toxicity Yes
30 TAG ° 307.4(d)

Antidegradation Yes
30 TAG ° 307.5
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. Relevant and appropriate for
OU No. 3 due to discharges to onsite drainages.
Surface waters must not be toxic to man or to terrestrial or aguatic life.
appropriate for OU No. 3 due to discharges to onsite drainages.
Relevant and
Requires maintenance and protection of existing uses (baseline November 28, 1975)
when discharging wastewater. Relevant and appropriate for OU No. 3 due to
discharges to onsite drainages.
Acute Toxicity
30 TAG ° 307.6(b)(1)
Chronic Toxicity
30 TAG ° 307.6(b) (2)
Human Toxicity
30 TAG ° 307.6(b) (3)
No 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 drainages and ponds on OU No. 3 are not classified as such;
therefore, not an ARAR for OU No. 3.

No Surface water with designated for 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. 3 have a designated or aquatic life use;
therefore the requirement is not an ARAR.

No 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.

-------
Table A-7
Surface Water ARARs
RSR Corporation Superfund Site OU No. 3

Requirement ARAR?
1. Contaminant-Specific ARARS (Continued)

State (Continued)
Page 3 of 10

Justification
Numerical Criteria for Toxics
30 TAG ° 307.6(c)
Yes Numerical criteria are established for certain toxic materials.
and appropriate for OU No. 3.
These criteria are relevant
Notes: (1) These numerical criteria ate 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 TAG
0 307.6(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.
LC50 Toxicity Criteria
30 TAG ° 307.6(c)(8)
(3) Numerical Acute Criteria are applied as 24-hour averages.
criteria are applied as seven-day averages.
Numerical Chronic
Yes 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. Relevant and appropriate for OU No. 3 due
to discharges to onsite drainages.

-------
Table A-7
Surface Water ARARs
RSR Corporation Superfund Site OU No. 3

Requirement ARAR?
1. Contaminant-Specific ARARS (Continued)

State (Continued)
Page 4 of 10

Justification
Site-Specific Uses and Criteria
30 TAG ° 307.7(b) (5)
Oyster Waters
30 TAG ° 307.7 (b) (3) (B) (iii)
Standards of Chemical Quality
30 TAG ° 290.103 (1) (3)
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.
Relevant and appropriate for OU No. 3 due to discharges to onsite drainages.

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 occur.

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. 3.
Secondary Constituent Levels
30 TAG ° 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. 3.
Attainment of Risk Reduction Standard No
Number 1: Closure/Remediation to
Background
Subchapter S
30 TAG ° 335.554

Attainment of Risk Reduction Standard Yes
Number 2: Closure/Remediation to
Health-Based Standards and Criteria
Subchapter S
30 TAG ° 335.555
These provisions specify that, to meet Risk Reduction Standard No. 1, closure and/or
remediation must meet background levels or practical guantitation limits if the practical
guantitation limit exceeds background. The provisions would be relevant and
appropriate if Risk Reduction Standard No. I were the preferred standard; however, it
is unlikely that cleanup goals will be set at background levels.

Subsection (d) specifies that the concentration of a contaminant in contaminated media
of concern such as groundwater, surface water, air, or soil shall not exceed the cleanup
levels as defined in ° 335.556 (relating to Determination of Cleanup Levels for Risk
Reduction Standard No. 3). If the practical guantitation limit and/or background
concentration is greater than the cleanup level, the greater of the practical guantitation
limit or background shall be used for determining compliance with the requirements of
this section. These provisions are relevant and appropriate to development of
contaminant-specific cleanup goals for OU No. 3.

-------
Table A-7
Surface Water ARARs
RSR Corporation Superfund Site OU No. 3

Requirement ARAR?
1. Contaminant-Specific ARARS (Continued)

State (Continued)

Determination of Cleanup Levels for Risk Yes
Reduction Standard Number 2
Subchapter S
30 TAG ° 335.556
Medium-Specific Concentrations for Risk Yes
Reduction Standard Number 2
Subchapter S
30 TAG ° 335.558
Page 5 of 10

Justification
Specifies that for purposes of risk reduction, cleanup levels for individual contaminants
are represented by Texas or federal promulgated health-based standards, or when these
are not available or do not provide appropriate protection, then cleanup levels based on
procedures specified for determining other numerical criteria (medium-specific
concentration or MSC) are required to be developed. These provisions are relevant and
appropriate to OU No. 3.

Subsections (b) through (d) of this section specify the methods for calculating medium-
specific concentrations for ingestion of surface water and groundwater, and for
ingestion along with inhalation of volatiles and particulates. These provisions are
relevant and appropriate to setting contaminant-specific cleanup goals for OU No. 3,
and are to be applied after evaluation of 30 TAG ° 307 and primary drinking water
MCLs.
Medium-Specific Requirements and
Adjustments for Risk Reduction Standard
Number 2
Subchapter S
30 TAG ° 335.559
Yes Subsections (b) through (d) specify requirements that can define or modify numeric
cleanup levels such as media-specific concentrations or require non-health based criteria
to be addressed. These provisions are relevant and appropriate to establishing cleanup
goals for OU No. 3.
Surface Water Media-Specific
Concentration, Risk Reduction Standard
Number 2
30 TAG ° 335.558
Yes To be applied after evaluation of 30 TAG ° 307 and primary drinking water MCLs.
Relevant and appropriate for OU No. 3 due to discharges to onsite drainages.

-------
Table A-7
Surface Water ARARs
RSR Corporation Superfund Site OU No. 3

Requirement ARAR?

2. Action-Specific ARARs

Federal

Federal Clean Water Act No
National Pollutant Discharge Elimination
System, Section 402

Stormwater Regulations Yes
40 C.F.R. Parts 122, 125
Pretreatment Standards
40 C.F.R. ° 403.5
Page 6 of 10

Justification
A permit is not required for onsite CERCLA response actions.
substantive cleanup requirement.
Provision establishes no
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.

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 1045C). 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. 3.

-------
Table A-7
Surface Water ARARs
RSR Corporation Superfund Site OU No. 3

           Requirement                      ARAR?

2.  Action-Specific ARARs (Continued)

State

Consolidated Permits                      No
Standard Permit Conditions
30 TAG ° 305.125

Consolidated Permits                      No
Subchapter 0, Additional Conditions and
Procedures for Wastewater Discharge
Permits and Sewage Sludge Permits

Texas Water Quality Act, TCA,  Water       Yes
Code, Title 2 - State Water Commission
                             Page 7 of 10

                                   Justification
Specifies conditions applicable to all permits.  A permit is not required for onsite
CERCLA response actions.  The provisions establish no substantive cleanup
requirements.

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.

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. 3. during remediation.

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Table A-7
Surface Water ARARs
RSR Corporation Superfund Site OU No. 3

Requirement

2. Action-Specific ARARs (Continued)

State
ARAR?
Page 8 of 10

Justification
General Provisions
30 TAG ° 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
Post-Closure Care and Deed Certification Yes
for Risk Reduction Standard Number 2
Subchapter S
30 TAG ° 335.560

Attainment of Risk Reduction Standard Yes
Number 3: Closure/Remediation with
Controls
Subchapter S
30 TAG ° 335.561
The endangerment of the public health and welfare.

Relevant and appropriate to actions taken at OU No. 3.

These provisions specify that, upon attainment of Risk Reduction Standard Number 2, a
deed recordation be placed in the County using information contained in subsections (1)
through (4). This requirement is relevant and appropriate to OU No. 3 insomuch that
provisions similar to Risk Reduction Standard Number 2 are applied.

Under Risk Reduction Standard Number 3, a remedy must be permanent, or if that is
not practicable, achieve the highest degree of long-term effectiveness possible; cost-
effective; and achieve media cleanup requirements specified in 30 TAG ° 335.563.
These provisions are relevant and appropriate to OU No. 3.
Remedy Evaluation Factors for Risk
Reduction Standard Number 3
Subchapter S
30 TAG ° 335.562
Yes These provisions outline the evaluation criteria when evaluating the relative abilities and
effectiveness of potential remedies to achieve the requirements for remedies described
in 30 TAG ° 335.564. The evaluation criteria are relevant and appropriate for
screening technologies and alternatives as part of the FS for OU No. 3.

-------
Table A-7
Surface Water ARARs
RSR Corporation Superfund Site OU No. 3

Requirement

2. Action-Specific ARARs (Continued)

State
ARAR?
Page 9 of 10

Justification
Media Cleanup Requirements for Risk
Reduction Standard Number 3
Subchapter S
30 TAG ° 335.563

Post-Closure Care Not Required for Risk
Reduction Standard Number 3
Subchapter S
30 TAG ° 335.564

3. Location-Specific ARARS

Federal
Yes
Yes
This section specifies the requirements for establishing cleanup levels for air,
water, groundwater, and soil, including use of media-specific adjustments. The
requirements of this section are relevant and appropriate to OU No. 3.
surface
Where it is determined that neither engineering nor institutional control measures are
required, no post-closure care responsibilities are necessary; however, deed recordation
is required in accordance with 30 TAG ° 335.566. This requirement is relevant and
appropriate if the conditions are met at OU No. 3.
Fish and Wildlife Coordination Act
16 U.S.C. ° 661 et seq.
16 U.S.C. ° 742 a
16 U.S.C. ° 2901
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. Relevant and appropriate for OU No. 3 due to onsite drainages.
Marine Protection, Research and
Sanctuaries Act
33 U.S.C. ° 1401 (Title I)
40 C.F.R. Part 220
16 U.S.C. ° 1431 et seq.
(Title III)
15 C.F.R. Parts 922-941
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 I is not an ARAR. Title III 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.
Clean Water Act ° 404
33 U.S.C. ° 1344
40 C.F.R. Parts 230, 231
No 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 fill material into waters of the U.S. is anticipated.

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Table A- 7
Surface Water ARARs
RSR Corporation Superfund Site OU No. 3

Requirement

3. Location-Specific ARARs (Continued)

Federal (continued)
ARAR?
Page 10 of 10

Justification
Rivers and Harbors Act of 1899
33 U.S.C. ° 403
33 C.F.R. Parts 320-322
No 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.
Protection of Wetlands Executive Order Yes
No. 11990
40 C.F.R. ° 6.302(a)
and Appendix A

Floodplain Management Executive Order Yes
No. 11988
40 C.F.R. ° 6.302(b)
Wild and Scenic Rivers Act No
16 U.S.C. ° 1271 et seq.
40 C.F.R. ° 6.302 (c)
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.
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 portions of the site are within a 100-year
floodplain, this Order is applicable, depending on location.
Prohibits adverse effects on a scenic river.
this Act is not an ARAR.
Since the site does not affect a scenic river,
Coastal Zone Management Act
16 U.S.C. ° 1451 et seq.
40 C.F.R. ° 6.302(d)
No 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. 3 has no impact on coastal areas.

-------
Table A-E
Surface Water Contaminant-Specific ARARs
RSR Corporation Superfund Site OU No. 3
           Chemical
           Inorganics
           Antimony
           Arsenic
           Barium
           Beryllium
           Cadmium
           Chromium
           Cobalt
           Copper
           Lead
           Manganese
           Mercury
           Nickel
           Selenium
           Silver
           Thallium
           Vanadium
           Zinc
           Organics
           1,1,1-Trichloroethane
           2-Butanone
           2-Methylnaphthalene
           4,4'-DDD
           4,4'-DDE
           4,4'-DDT
           2-Methyl-4-pentanone
           Acenaphthene
           Acenaphthylene
           Acetone
           Anthracene
           Arochlor-1242
           Arochlor-1248
           Arochlor 1254
           Arochlor-1260
           delta-BHC
   1
  R&A
 (mg/L)
  0.05
   1

  0.01
  0.05
  0.2
0.000297
0.0000544
0.0000527
  2
 R&A
(mg/L)
0.005
0.0000122
0.01
0.05
a
b
a
a
0.025
0.0000122


0.000299
0.0000545
0.0000528
  3
 R&A
(mg/L)
                                     0.36
                                  113.0*
  4
 R&A
(mg/L)
                                                   0.19
                                                  102.4**
                                  0.0011
                                                 0.000001
  9
 R&A
(mg/L)

0.006
0.05
  2
0.004
32.2*
1, 679.4*
18.5*
77.5*
0.0024
1,370.1*
0.02
0.00092
a
a
a
a
a
a

a
1.1**
200.2**
12.4**
3.0**
0.0013
152.3**
0.005
0.00049
0.005
0.1


0.002
0.1
0.05

                                                                0.002
                                                                0.2
0.0000013
0.0000013
0.0000013
0.0000013
0.0000013
0.0000013
0.0000013
0.0000013
0.002
0.002
0.002
0.002
0.000014
0.000014
0.000014
0.000014
0.0005
0.0005
0.0005
0.0005
 10
 R&A
(mg/L)
                                                                            0.05

-------
Table A-8
           Chemical
           gamma-BHC
           Benzene
           Benzo(a)anthracene
           Benzo(a)pyrene
           Benzo(b)fluoranthene
           Benzo(g,h,i)perylene
           Benzo(k)fluoranthene
           bis(2-ethylhexyl)phthalate
           Carbazole
           alpha-Chiordane
           gamma-Chiordane
           Chrysene
           Di-n-butyl phthalate
           Di-n-octyl phthalate
           Dibenz(a,h) anthracene
           Dibenzofuran
           Dieldrin
           Diethylphthalate
           Endosulfan I
           Endosulfan II
           Endosulfan sulfate
           Endrin
           Endrin  aldehyde
           Endrin  ketone
           Ethylbenzene
           Fluoranthene
           Fluorene
           Heptachlor epoxide
           Indeno(1,2,3-cd)pyrene
           Methylene  chloride
           N-Nitrosodiphenylamine
           Naphthalene
           Phenanthrene
           Phenol
           Pyrene

-------
Table A-9
Air ARARs
RSR Corporation Superfund Site OU No. 3

Requirement

1. Contaminant-Specific

Federal
ARAR?
Page 1 of 6

Justification
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

State
Yes The NAAQS specify the maximum concentration of a federally regulated air pollutant (i.e.,
SO 2, particulate matter (PM 10), NO 2, CO, ozone, 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. ° 51.160). For the federal NAAQS standards, all
measurements of air quality are corrected to a reference temperature of 255C and to a refer-
ence pressure of 760mm Hg (1,013.2 millibars). 40 C.F.R. ° 50.3

No These provisions regulate the emissions of specified "hazardous air pollutants" [listed in 40
C.F.R. ° 61.01(a)] that are emitted from particular sources or processes [listed in 40 C.F.R.
Part 61].

No 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.

No 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 witl occur at the site.
Particulates - Net Ground Level
30 TAG ° 111.155

SO 2 Ground Level Concentration
30 TAG ° 112.7
Hydrogen Sulfide
30 IAC ° 11231 & 11232
Yes Establishes the net ground level concentration (downwind at the property boundary minus
upwind measurements) of particulate emissions from any source that must not be exceeded.

No SO 2 emissions from any source must not exceed a net ground level concentration (downwind
at property boundary minus upwind). Not in ARAR since no SO 2 emissions are expected
during or after remediation.

No Sets net ground level concentration limits for hydrogen sulfide. Not an ARAR since no
hydrogen sulfide emissions are expected during or after remediation

-------
Table A-9
Air ARARs
RSR Corporation Superfund Site OU No. 3

Requirement ARAR?

Sulfuric Acid No
30 TAG ° 112.41

Inorganic Fluoride No
30 TAG ° 113.3(a)(2) and (a)(3)

Beryllium No
30 TAG ° 113.3(b)

Lead Emissions from smelting No
facilities
Attainment of Risk Reduction No
Standard Number 1:
Closure/Remediation to Background
Subchapter S
30 TAG ° 335.554
Page 2 of 6

Justification

Sets net ground level concentration limits for sulfuric acid.
acid emissions are expected during or after remediation.
Not an ARAR since no sulfuric
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.
that beryllium emissions will be generated during or after remediation.
It is not expected
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 smelter emissions as a
result of an operating facility do not exist.

These provisions specify that, to meet Risk Reduction Standard Number 1, closure and/or
remediation must meet background levels or practical guantitation limits if the practical
quantitation limit exceeds background. These provisions would be relevant and appropriate if
Risk Reduction Standard Number 1 were the preferred standard; however, it is unlikely that
cleanup goals will be set at background levels.
Attainment of Risk Reduction
Standard Number 2:
Closure/Remediation to Health/Based
Standards and Criteria
Subchapter S
30 TAG ° 335.555
Determination of Cleanup Levels for
Risk Reduction Standard
Number 2
Subchapter S
30 TAG ° 335.556
Yes Subsection (d) specifies that the concentration of a contaminant in contaminated media of
concern such as groundwater, surface water, air or soil shall not exceed the cleanup levels as
defined in
° 335.556 (relating to Determination of Cleanup Levels for Risk Reduction Standard Number
3). If the practical quantitation limit and/or background concentration is greater than the
cleanup level, the greater of the practical quantitation limit or background shall be used for
determining compliance with the requirements of this section. These provisions are relevant
and appropriate to development of contaminant - specific cleanup goals for OU No. 3.

Yes Specifies that for purposes of risk reduction, cleanup levels for individual contaminants are
represented by Texas or federal promulgated health-based standards, or when these are not
available or do not provide appropriate protection, then cleanup levels based on procedures
specified for determining other numeric criteria (medium - specific concentration or MSC) are
required to be developed. These provisions are relevant and appropriate to OU No. 3.

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Table A-9
Air ARARs
RSR Corporation Superfund Site OU No. 3

Requirement

Criteria for Selection of Non-
residential Soil Requirements for Risk
Reduction Standard
Number 2
Subchapter S
30 TAG ° 335.557
Paqe 3 of 6

ARAR? Justification

Yes Specifies the conditions under which soil requirements can deviate from residential soil
requirements. Subsection (1) notes that for property located within the jurisdictional area of a
zoninq authority, documentation may be provided to demonstrate that the property is zoned for
commercial or industrial use. These provisions are relevant and appropriate as they pertain to
particulates qenerated from contaminated soil.
Medium Specific Concentrations for
Risk Reduction Standard Number 2
Subchapter S
30 TAG ° 335.558
Medium Specific Requirements
and Adjustments for Risk Reduction
Standard Number 2
Subchapter S
30 TAG ° 335.559
Yes Subsections (b) throuqh (d) of this section specify the methods for calculatinq medium specific
concentrations for inqestion of surface water and qroundwater, and soil inqestion alonq with
inhalation of volatiles and particulates. These provisions are relevant and appropriate to
settinq contaminant - specific cleanup qoals for OU No. 3, and are to be applied after
evaluation of the National Ambient Air Quality Standards and NESHAPs, and other applicable
federal standards. Texas Air Control Board standards also apply accordinq to these provisions.

Yes Subsections (b) throuqh (h) specify requirements that can define or modify numeric cleanup
levels such as media - specific concentrations or require non-health based criteria to be
addressed. These provisions are relevant and appropriate to establishinq cleanup qoals for OU
No. 3.

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Table A-9
Air ARARs
RSR Corporation Superfund Site OU No. 3

Requirement

2. Action-Specific
Federal

Prevention of Significant Deterioration
of Air Quality
42 U.S.C. ° 7475
40 C.F.R. ° 52.21
ARAR?
No
Nonattainment Areas - LAER
42 U.S.C. ° 172(b)(6) and °
No
173
New Source Performance Standard for
Incinerators
40 C.F.R. Part 60
Subpart E

Hazardous Waste Incinerators
40 C.F.R. Part 264, Subpart 0

State
No
No
Page 4 of 6

Justification
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.
3 are not expected to constitute a major stationary source of any federally regulared 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. 3 do not constitute new
major stationary sources.

Sets a limit for particulate emissions of 0.18g/dscm (0.08 gr/dscf) corrected to 12% CO 2. Not
an ARAR since the rule applies to furnaces burning municipal waste.
Not an ARAR since a hazardous waste incinerator is unlikely to be used at OU No. 3.
Control of Air Pollution by Permits
for New Construction or Modification
30 TAG ° 116
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 Ilic technical practicability and economic reasonableness of reducing or
eliminating the emissions from the facility. " Applies during construction activities. May be
relevant and appropriate.

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Table A-9
Air ARARs
RSR Corporation Superfund Site OU No. 3

Requirement

Requirements for Specified Sources
30 TAG ° 111.111
Paqe 5 of 6

ARAR? Justification

Yes Visible emissions shall not be permitted to exceed an opacity of 30% for any six-minute
period from any buildinq, enclosed facility, or other structure. Applies durinq any activity that
may qenerate visible emissions. Relevant and appropriate for construction activities at OU
No. 3.
Storaqe of Lead Containinq Materials
30 TAG ° 113.82(a) and (b)
Transport of Materials
30 TAG ° 113.84 (1) and (2)
Control of Fuqitive Dust
30 TAG ° 113.91 (a) , (b) , (c)
Additional Measures to Reduce Lead
Emissions
30 TAG ° 113.92 (1)

Post Closure Care and Deed
Certification for Risk Reduction
Standard Number 2
Subchapter S
30 TAG ° 335.560
Yes No unenclosed storaqe of material containinq more than 1% lead by weiqht. All particulate
matter containinq more than 1% lead by weiqht collected by air pollution control equipment
shall be stored in closed containers or in a structure under siqnificant neqative pressure to
prevent emissions to the atmosphere. Applies if lead content exceeds 1% by weiqht.
Applicable to OU No. 3.

Yes All transport vehicles carryinq materials containinq more than 1% lead by weiqht must have
covered carqo compartments at all times on plant properly except durinq loadinq and
unloadinq, when beinq washed, or inside a buildinq. Each time a vehicle leaves a structure, all
material containinq more than 1% lead by weiqht shall be removed from the wheels; if water
is used, this requirement is suspended durinq freezinq weather. Applies if lead content exceeds
1% by weiqht. Applicable to OU No. 3.

Yes All plant roads shall be paved; parkinq areas and storaqe areas for materials containinq more
than 1% lead by weiqht shall be paved. Open unpaved areas must be veqetated or covered
with rock or crushed aqqreqate at least three inches deep. Applies if lead content exceeds 1%
by weiqht. Applicable to OU No. 3.

Yes If they occur outside buildinqs, spills of dust containinq more than 1% lead by weiqht shall be
dampened and cleaned up immediately. Applies if lead content exceeds 1% by weiqht.
Applicable to OU No. 3.

Yes These provisions specify that, upon attainment of Risk Reduction Standard Number 2, a deed
recordation be placed in the county usinq information contained in Subsections (1) throuqh (4).
This requirement is relevant and appropriate to OU No. 3 in so much that provisions similar to
Risk Reduction Standard Number 2 are applied.

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Table A-9
Air ARARs
RSR Corporation Superfund Site OU No. 3

Requirement

Attainment of Risk Reduction
Standard Number 3:
Closure/Remediation with Controls
Subchapter S
30 TAG ° 335.561
Page 6 of 6

ARAR? Justification

Yes Under Risk Reduction Standard Number 3, a remedy must be permanent, or if that is not
practicable, achieve the highest degree of long-term effectiveness possible; cost-effective; and
achieve media cleanup requirements specified in 30 TAG ° 335.563. These provisions are
relevant and appropriate to OU No. 3.
Remedy Evaluation Factor for Risk
Reduction Standard
Number 3
Subchapter S
30 TAG ° 335.562
Yes These provisions outline the evaluation criteria when evaluating the relative abilities and
effectiveness of potential remedies to achieve the requirements for remedies described in 30
TAG ° 335.561. The evaluation criteria are relevant and appropriate for screening
technologies and alternatives as part of the FS for OU No. 3.
Media Cleanup Requirements for Risk
Reduction Standard
Number 3
Subchapter S
30 TAG ° 335.563
Yes This section specifies the requirements for establishing cleanup levels for air, surface water,
groundwater, and soil, including use of media - specific adjustments. The requirements of this
section are relevant and appropriate to OU No. 3.
Post Closure Care Not Required for
Risk Reduction Standard Number 3
Subchapter S
30 TAG ° 335.564
Yes Where it is determined that neither engineering nor institutional control measures are required,
no post closure care responsibilities are necessary; however, deed recordation is required in
accordance with 30 TAG ° 335.566. This requirement is relevant and appropriate if the
conditions are met at OU No. 3.
2. Location-Specific

State
General Application;
Proximity of New Construction to
Schools
30 TAG ° 116.111
Yes Requires the Texas Air Control Board to consider, in issuing a permit for construction of a
facility, any adverse short-term or long-term side effects that 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. Since a school is located within 3,000 feet
of Site No. 4 of OU No. 3, the requirements is relevant and appropriate.

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Table A-ll
Miscellaneous Location-Specific ARARs
RSR Corporation Superfund Site OU No. 3

Requirement

1. Location-Specific

Federal
Page 1 of 2
ARAR??
Justification
National Historic
Preservation Act
16 U.S.C. ° 470
40 C.F.R. ° 6.301(b)
36 C.F.R. Part 800
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.
Archeological and Historic Preservation Act
16 U.S.C. ° 469
40 C.F.R. ° 6.301(c)
Yes 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.
Historic Sites, Buildings, and Antiquities Act No
15 U.S.C. ° 461 et seq.
40 C.F.R. ° 6.301(a)
Endangered Species Act No
16 U.S.C. ° 1531 et seq.
50 C.F.R. Part 402
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 Act 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.
Wilderness Act
16 U.S.C. ° 1131 et seq.
50 C.F.R Part 35
No 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.

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Table A-ll
Miscellaneous Location-Specific ARARs
RSR Corporation Superfund Site OU No. 3

           Requirement                      ARAR??

Federal  (Continued)

National Wildlife Refuge System            No
16 U.S.C. °° 668dd, 668ee
50 C.F.R. Part 27

State

Antiquities Code of Texas                  No
TEX. NAT. RES. COD. ANN.,
CH. 191
                            Paqe 2 of 2

                                   Justification
Restricts activities within a National Wildlife Refuqe.  The proposed remedy will
not affect a National Wildlife Refuqe; therefore, these provisions are not ARARs.
Prohibits the takinq, alterinq, damaqinq, destroyinq, or excavatinq of a state
archeoloqical landmark without a contract or permit.  Unless a state archeoloqical
landmark is present at the site, the Code is not an ARAR.

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