VvEPA EPA Announces Proposed Plan
Eavifonmentai Protection Eagle Picher Carefree Battery Superfund Site
Afl®ncv Socorro, New Mexico
The purpose of this Proposed Plan is
to:
Identify the preferred remedial action alternative
to address contamination at the Eagle Picher Site;
Describe the other remedial alternatives consid-
ered in detail in the Feasibility Study report;
Solicit public review and comment on the reme-
dial action alternatives and supporting analysis,
as well as on information contained in the Ad-
ministrative Record File; and
• Provide information on how community mem-
bers can be involved in the remedy selection pro-
cess for the Site.
The U.S. Environmental Protection Agency has released
the Proposed Plan for addressing hazardous substance con-
tamination at the Eagle Picher Carefree Battery (Eagle
Picher) Site, Socorro, New Mexico. EPA, the lead agency
for site activity, is issuing the Proposed Plan with support
from the New Mexico Environment Department (NMED).
Following public review and discussion of the Proposed
Plan, EPA will make a final remedy selection that will be
documented in the Record of Decision (ROD).
The purpose of the Proposed Plan is to fulfill statutory re-
quirements pursuant to Sections 113(k)(2)(B), 117(a), and
121(f)(1)(G) of the Comprehensive Environmental Re-
sponse, Compensation, and Liability Act (CERCLA or
Superfund), 42 U.S.C. §§ 9613(k)(2)(B), 9617(a), and
9621(f)(1)(G). It also describes the alternatives analyzed,
identifies the preferred alternative, and solicits public in-
volvement in the selection of a remedy.
The EPA has developed this Proposed Plan. In developing
this Proposed Plan, the EPA consulted with NMED, which
concurs with this Proposed Plan.
Community Participation
The Proposed Plan fact sheet highlights key infor-
mation from the Remedial Investigation (RI) and
Feasibility Study (FS) reports for the Eagle Picher
Site, but it is not a substitute for these reports. The re-
sults of the sampling activities and an assessment of
the potential site risks are presented in the RI Report.
The development and evaluation of remedial alterna-
tives to address the contamination are presented in
the FS Report. For a complete source of information,
please refer to these reports, which are in the Admin-
istrative Record File located at the repositories listed
below. EPA encourages the public to review these
June 2014
documents in order to gain a more comprehensive
understanding of the Eagle Picher Site, the Super-
fund activities that have been conducted there, and
the various alternatives that have been developed
and evaluated to address the contamination at the
Eagle Picher Site. The EPA also encourages the public
to participate in the decision-making process for the
Eagle Picher Site by making comments on all aspects
of the Administrative Record File including the
RI/FS and the Proposed Plan. The Administrative
Record File is available at the following information
repositories:
Socorro Public Library
401 Park Street
Socorro, NM 87801
U.S. Environmental Protection Agency
12th Floor Library
1445 Ross Avenue, Suite 12D13
Dallas, Texas 75202-2733
(214) 665-2792
A public meeting to receive comments will be held at:
Socorro City Hall
111 School of Mines Road
Socorro, New Mexico
Thursday, June 26, at 6:00 PM in Socorro, New Mexico.
The public is invited to comment on this Proposed Plan.
Final decisions regarding the remediation of the Eagle
Picher Site will only be made after public comments are
considered. The official public comment period begins on
June 12, 2014 and ends on July 11, 2014. During the pub-
lic comment period, written comments may be submitted
to:
Sai Appaji
Remedial Project Manager
EPA, Region 6 (6SF-R)
1445 Ross Avenue
Dallas, Texas 75202-2733
(214) 665-3126 ortoll free (800) 533-3508
Site History
The Eagle Picher Site is located in the City of Socorro
(City), Socorro County, New Mexico (See Figure 1 below
and Figure 2 - Area Map with Well Locations on page 3).
The site encompasses two large tracts that are
approximately equal to 55 acres and located along 1-25,
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two miles north of Socorro. The area east of NM 408
contains a large structure (the manufacturing plant),
several outbuildings, and vacant land. The property to the
west of NM 408 includes the older historical facility and
contains a number of buildings in various states of decay,
along with assorted construction-type debris.
The property was initially owned by the United States
Government and was used as Civilian Conservation Corps
barracks in 1932. From 1936 to 1956, the facility was uti-
lized as a State of New Mexico tuberculosis sanitarium.
Septic waste from the sanitarium was discharged into
wastewater impoundments (Figure 2) located in the south-
east portion of the property.
After the sanitarium was closed, the facility was acquired
by the City. In 1964, the City sold the property to Eagle
Picher. From approximately 1964 to 1976, Eagle Picher
manufactured various products, including printed circuit
boards, on the property. Domestic sewage and industrial
waste from the manufacturing process was discharged into
the wastewater impoundments.
In 1976, the City obtained ownership of the property again
and leased a portion of the property to a jewelry manufac-
turing company that was in operation until 1980. No chlo-
rinated solvents were used in the jewelry manufacturing
operation.
From 1977 through 1980 the City operated a landfill in an
arroyo north of the former Eagle Picher manufacturing
building. The landfill was permitted to accept waste from
residential, commercial, institutional and recreational facil-
ities. The landfill was closed as part of a lease agreement
between the City and Eagle Picher.
In 1980, Eagle Picher leased the property from the City
and produced non-automotive lead-acid batteries at the fa-
cility until the late 1990s. Eagle Picher constructed two
lined evaporation impoundments for industrial effluent in
the 1980s. The industrial impoundments were closed in the
1990s under the Resource Conservation and Recovery Act
(RCRA) process. In 2005, the City leased approximately
11 acres of the property, including the Eagle Picher manu-
facturing building and surrounding property, to a motor-
cross track operation for recreational use. Flash flooding in
the summer of 2006 damaged the fonner building and mo-
tocross track. Because of soil erosion and exposure to lead
battery waste, motocross operations were suspended by the
City.
In 2007, the City adopted a resolution in support of listing
the site on the National Priorities List (NPL). The EPA
proposed the site on the NPL in March 2007.
Multiple investigations have been conducted at the Eagle
Picher Site from 1987 till present by NMED and its prede-
cessor agency. Site investigations have revolved around
evaluating contamination discovered in public wells (Eagle
Picher and Olson wells) near the site. Results from past in-
vestigations have indicated source of contamination ema-
nating from the former Eagle Picher facility. Contaminants
in the groundwater are primarily chlorinated solvents such
as tetrachlroethene (PCE),trichloroethene (TCE), 1,1-
dichloroethene (DCE) and 1,4 dioxane.
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Site Location
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EAGLE PICHER CAREFREE BATTERIES SUPERFUND SITE
SOCORRO, NEW MEXICO
Site Map
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rDaniel B. Stephens & Associates, Inc. ¦
3/12/2014 JN ES12 0120 00
EAGLE PICHER CAREFREE BATTERIES SUPERFUND SITE
SOCORRO, NEW MEXICO
Area Map with Well Locations
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In 2000, the Olson well located south of the Eagle Picher
site was investigated in another attempt to further delineate
the groundwater plume and identify the sources of TCE.
The source of the TCE could not be conclusively identified
during this investigation. The printed circuit board opera-
tion at the Eagle Picher site was identified as a potential
source of the TCE. Several potential sources, including the
Eagle Picher site, were identified.
In 2001/2002, NMED conducted a site investigation at the
Olson well. A total of 5 monitor wells were installed to re-
fine plume definition and source determination. Sampling
results confirmed the presence of TCE, 1,1-DCE, PCE,
and cis-l,2-DCE in groundwater at the Eagle Picher site.
From 2004 to 2006, NMED conducted an expanded site
investigation that included: (1) installation of additional
monitor wells, (2) collection of surface water, ground-
water, soil, and soil gas samples, (3) an X-ray fluorescence
(XRF) soil survey for heavy metals, and (4) off-site soil
sampling (after the 2006 floods). This investigation deter-
mined that the Eagle Picher facility was likely the source
of TCE in the aquifer in Socorro.
From 2010 to 2012, NMED conducted groundwater sam-
pling activities at monitor, domestic, and municipal wells
in the area of the Eagle Picher facility and the groundwater
plume. The sampling events were intended to provide up-
dated water quality data from the plume area and to pro-
vide further delineation of the plume extent.
In August 2012, NMED in cooperation with EPA began a
RI/FS and completed site investigation and risk characteri-
zation in early 2014.
Summary of Site Characteristics
Socorro is located in the central part of Socorro County,
New Mexico along the Rio Grande Valley. The elevation
of Socorro is 4,585 above mean sea level, where the cli-
mate is arid to semi-arid with average annual precipitation
of 9.71 inches. The population of Socorro is approximately
9000. The principal aquifer system in the Socorro Basin is
composed of the Quaternary and Tertiary Santa Fe Group
(Popotosa and Sierra Ladrones Formation) and the overly-
ing Quaternary deposits. The aquifer is divided in to three
units: (1) an unconfined aquifer comprising of the Quater-
nary deposits and the Sierra Ladrones Formations, (2) the
Popotosa confining unit consisting of playa deposits and
mudstones, and (3) the underlying Popotosa Aquifer.
Within the Socorro Basin, the unconfined aquifer is com-
monly referred to as the shallow aquifer. Most of the wells
in the Socorro Basin, including the wells impacted by
chlorinated solvents, are completed in the highly-
transmissive shallow aquifer.
Depths to groundwater vary from over 100 feet on the
higher terrain areas to less than 20 feet in low-lying areas.
The groundwater flow direction is generally to the south-
southwest in the groundwater plume area. To the west of
the Site, the groundwater flow is southeast parallel to the
Nogal Arroyo.
Although the unconfined aquifer is undifferentiated (i.e. no
laterally extensive confining units were found in the study
area), the goal of the RI was to delineate the vertical extent
of contamination. Accordingly, the upper sediments of the
unconfined aquifer were subdivided in to the three follow-
ing informal water bearing zones based on the screened
intervals of wells within the groundwater plume: (1) a
shallow water bearing zone (SWBZ) extending up to a
depth of 25 feet bgs (below ground surface) (2) the inter-
mediate water bearing zone (IWBZ) extending up to a
depth of 75 feet bgs, and (3) the deep water bearing zone
(DWBZ) extending up to 215 feet bgs.
Based on aquifer testing conducted during the RI, the
groundwater velocity in the SWBZ and IWBZ is approxi-
mately 220 ft/year, indicating plume migration downgradi-
ent.
The Eagle Picher well is currently used by the City as one
of the supply wells and is located on the Eagle Picher site.
This well is no longer impacted as the contamination has
migrated downgradient. One of the former City supply
well, Olson Well (not in use), and a number of private
wells are located within the plume area. Currently all resi-
dents have access to public water supplied by the City.
Three supply wells located to the south of the plume are
used by New Mexico Tech for irrigation of the golf course.
Based on groundwater monitoring and soil sampling data
there is no evidence of source material remaining at the
Eagle Picher site. The contaminants have migrated down-
gradient of the site. In the shallow aquifer zones (including
the SWBZ and IBWZ), the TCE plume covers an area of
360 acres and extends over 9000 feet to the south and is
2000 feet at its widest point. The shallow plume contains
two "hot spot" areas where the TCE concentrations are
above 100 parts per billion (ppb) and as high as 310 ppb.
The vast majority of the dissolved phase plume has TCE
concentrations less than 50 ppb. Smaller PCE and 1,1-
DCE plumes are within the larger TCE plume.
In the DWBZ, the plume extends for a length of approxi-
mately 4500 feet in a narrow swath under the northern part
of the shallow plume. The deep-zone plume contains both
TCE and 1,1-DCE, and is limited in depth to the upper
portion of the DWBZ. The base of the dissolved-phase
plume was identified at depth of approximately 200 ft bgs.
The highest detected concentration of TCE within the
deepest part of the plume was 230 ppb.
1,4-dioxane, an emerging contaminant was detected in low
concentrations in one private well, four monitoring wells
and one former supply well within the TCE plume. The
highest concentration of 1,4-dioxane detected was 35 ppb.
On-site soils have been impacted by lead, cadmium and
chromium contamination. Lead contamination is present in
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soils ranging in concentrations from 16 parts per million
(ppm) to 6,166 ppm. Lead concentrations exceed EPA in-
dustrial screening level of 800 ppm at the west entrance to
the manufacturing building, in the battery debris areas
southwest of the manufacturing building, wastewater im-
poundment area and south of the historical building as
shown in Figure 3. Approximately 1000 cubic yards of
soils have been impacted in these four locations.
Elevated chromium levels are present in soil but co-located
with lead contamination. Both trivalent and hexavalent
chromium forms were analyzed in soil samples. Predomi-
nantly the soil samples contain trivalent chromium that is
stable. Samples showed that hexavalent chromium was
less than one percent of the total measured chromium,
suggesting a minimal amount of chromium was present in
the hexavalent form. The highest concentration of hexava-
lent chromium observed was 16 mg/Kg.
Based on historical data and sampling conducted during
the RI, soil contamination by metals is limited to on-site
soils. VOCs not sorbed to soil materials may infiltrate to
groundwater. This process and pathway - the soil leaching
to groundwater pathway - is considered the principal mode
of transport through the vadose zone at the Eagle Picher
site.
The site contains scattered construction debris related to
structures in poor condition. The former operating build-
ings are not secure with windows and doors broken. Two
of the buildings were constructed with asbestos containing
building material (ACBM) and asbestos has been released
in to the environment as evidenced by debris on soil
around the building. Co-located with ACBM, the building
materials contain lead-based paint (LBP) that is in very
poor condition.
Scope and Role of the Response Action
The EPA expects that the site contamination will be ad-
dressed as one operable unit through the remedy selected
in the Record of Decision (ROD), which will be issued fol-
lowing this Proposed Plan. (An operable unit is a discrete
action that comprises an incremental step toward compre-
hensively addressing site contamination.) That is, the re-
sponse action, which will be detailed in the site ROD, will
address heavy metals in soils, asbestos, chlorinated sol-
vents and 1,4-dioxane in groundwater.
Summary of site risks
Chemicals of Concern (COCs)
COCs are chemicals that pose a carcinogenic risk to hu-
man health greater than 1 in 1,000,000 (1 X 10"6), have a
non-carcinogenic hazard index (HI) greater than (>) 1, or
are found in the groundwater plume at concentrations that
exceed MCLs. The following constituents are considered
to be COCs:
Soil COCs
Lead, chromium and cadmium
Construction Debris COCs
Asbestos containing building material (ACBM) and lead-
based paint (LBP)
Groundwater COCs
PCE, TCE, DCE and 1, 4-dioxane.
Land and Groundwater Use Assumptions
Currently, the City maintains and operates the Eagle Pich-
er municipal well on the site. Eagle Picher well is one of
six primary wells used for public water supply by the City.
Future land use is expected to be commercial and industri-
al development.
To the south of the site there are residential properties
within the groundwater plume boundary. These residents
are served by the City water supply. However, a number of
residential properties have private wells and some of them
use groundwater for non-drinking purposes. The Olson
Well, a former municipal supply well that is located within
the plume boundary, is no longer in use by the city. The
New Mexico Tech campus, located just south of the plume
boundary, is using three wells that are adjacent to the
plume for irrigating the golf course. The groundwater
plume extends over a part of the golf course as shown in
Figure 2.
Potentially Exposed Populations in Current and Future
Risk Scenarios
The Baseline Human Health Risk Assessment identified
primary contaminant sources, contaminant release mech-
anisms, exposure pathways, and receptors for the COCs.
The potentially exposed individuals evaluated were based
on current and potential future land use and most probable
current and future activities On-Site and Off-Site (down-
gradient plume area). The following potential receptors
were evaluated for exposure to chemicals in groundwater
and indoor air.
On-Site
• Hypothetical future commercial or industrial worker
• Hypothetical future construction worker
• Current or future intermittent visitors (trespassers and
visitors to potential future businesses at the Site)
Off-Site
• Current or future resident or farmer
• Current or future commercial/industrial worker
Exposure pathways affecting each population group
The following are the various exposure pathways and
routes that were evaluated:
5
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Soil Exposure Pathways/Route - Future commercial/
construction workers and visitors or trespassers on site can
be exposed to inhalation, ingestion and dermal routes.
Asbestos and Lead Based Paint Pathways/Route - Two
of the buildings contain ACBM and asbestos has been re-
leased in to the environment as evidenced by debris on soil
around the building. Co-located with ACBM, the building
materials contain LBP that is in very poor condition. The
inhalation pathway is currently complete for any visitor or
trespasser.
Groundwater Exposure Pathways/Route - Even though
residents have municipal water supply for consumption,
some of them are using their private well for other uses
such as irrigation. Residents using private well water for
non-potable uses are currently exposed.
Indoor Air Exposure Pathways/Route - For individual
residences, exposure to contaminants in indoor air through
inhalation of VOCs was evaluated.
Toxicity Assessment
Site contaminants were assessed for carcinogenicity and
for non-carcinogenic systemic toxicity. For carcinogens,
risks are generally expressed as the incremental probability
of an individual's developing cancer over a lifetime as a
result of exposure to the carcinogen. Excess lifetime can-
cer risk is calculated from the following equation: Cancer
Risk = CDI x CSF where: risk = a unitless probability
(e.g., 2 x 10"5) of an individual's developing cancer
CDI = Chronic daily intake averaged over 70 years [mg/kg
(milligram/kilogram)-day]
CSF = chemical and route specific cancer slope factor,
expressed as (mg/kg-day)"1.
These risks are probabilities that usually are expressed in
scientific notation (e.g., 1 x 10"6). An excess lifetime can-
cer of 1 x 10"6 indicates that an individual experiencing the
Reasonable Maximum Exposure (RME) estimate has a 1
in a 1,000,000 chance of developing cancer as a result of
site-related exposure. This is referred to as an "excess life-
time cancer risk" because it would be in addition to the
risks of cancer individuals face from other causes such as
smoking or exposure to too much sun. EPA's generally ac-
ceptable risk range for site-related exposures is 10"4 to 10"6.
The potential for non-carcinogenic effects is evaluated by
comparing an exposure level over a specified time period
(e.g., lifetime) with a reference dose (RfD) derived for a
similar exposure period. An RfD represents a level that an
individual may be exposed to that is not expected to cause
any deleterious effect. The ratio of exposure to toxicity is
called a hazard quotient (HQ). A HQ less than 1 indicates
that an individual's dose of a single contaminant is less
than the RfD, and that toxic non-carcinogenic effects from
that chemical are unlikely. The Hazard Index (HI) is gen-
erated by adding the HQs for all chemical(s) of concern
that affect that same target organ (e.g., liver) or that act
through the same mechanism within a medium or across
all media to which a given individual may reasonably be
exposed. An HI less than 1 indicates that, based on the
sum of all HQ's from different contaminants and exposure
routes, toxic non-carcinogenic effects from all contami-
nants are unlikely. An HI greater than 1 indicates that site-
related exposures may present a risk to human health. The
HQ is calculated as follows:
Non-cancer HQ = CDI/RfD where:
CDI = Chronic Daily Intake
RfD = Reference Dose
CDI and RfD are expressed in the same units and represent
the same exposure period (i.e., chronic, subchronic, or
short-term).
Human Health Risk Characterization
Risk estimates were calculated for future land use scenari-
os for hypothetical human receptors at the Eagle Picher
Site. Cancer risks were estimated as the probability of an
individual developing cancer over a lifetime as a result of
exposure to the Site's carcinogenic contaminants. Toxicity
risk estimates for non-carcinogenic toxic chemicals are
presented for COCs. The potential for non-carcinogenic
hazards due to potential exposures to chemicals was evalu-
ated by calculating an HI for the COCs at the Eagle Picher
Site.
The Baseline Risk Assessment shows the detailed calcula-
tion of risk. The Baseline Risk Assessment organized the
types of risk at the Eagle Picher Site according to various
exposure scenarios. Each exposure scenario specifies the
type of human receptor (e.g., child resident, adult industri-
al worker), the exposure pathway (e.g., inhalation, inges-
tion) and the COC. If a contaminant or exposure scenario
is found to produce a risk which will require a remedial
action (based on either the carcinogenic risk or the HI),
that contaminant or exposure scenario is said to "drive the
risk" or "drive" the need for action. A remediation goal is
set for site-related contaminants that drive risk.
The following exposure scenarios are driving the need for
action at the Site (all risks are expressed as Reasonable
Maximum Exposure or RME).
• Unacceptable levels of lead are present in soils in
some locations at the site and present a risk to human
health and the environment.
• The groundwater COCs are present at concentrations
above their MCL and EPA health risk level; therefore,
they present an unacceptable risk to human health and
the environment.
• There is evidence of asbestos release and a high poten-
tial for continued release posing a risk to human health
and the environment.
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Soil Risk
Exposure to lead in Site soils was assessed using USEPA's
Adult Lead Model (ALM). For the ALM, USEPA has se-
lected a target blood lead level (BLL) for an adult female
to protect a developing fetus. The ALM indicated that risks
from exposure to lead in Site soils, based on an average
lead concentration for all Site soils are below the BLL.
The ALM was modified to evaluate exposure to trespass-
ers, recreational visitors on-Site, and this modified ALM
also indicated that risks are below the BLL. Based on this
evaluation, current lead concentrations do not present an
elevated risk for adult workers on-Site or intermittent visi-
tors.
The ALM model is based on average soil lead concentra-
tion levels throughout the site, however, lead concentra-
tions in surface soils near the unlined wastewater
impoundments, new manufacturing plant, and southwest of
the new manufacturing plant are above levels (800 ppm)
that EPA considers safe for exposure in an industrial set-
ting.
Groundwater Risk
Drinking (ingesting) and breathing (inhaling vapors) of
groundwater (including all uses of household water, such
as showering/bathing, laundering, and dishwashing) and
dermal exposure to groundwater were evaluated for each
well individually from the plume area for both carcinogen-
ic and non-carcinogenic risks. Groundwater risk is primari-
ly from TCE. Out of eight domestic wells evaluated, three
wells had elevated risk from TCE with excess life-time
cancer risk ranging from 8xl0"6 to 4xl0"5 (within USEPA's
acceptable range of lxlO"6 to lxlO"4) and HQs ranging
from 1.2 to 7.2.
The residents are being provided with water from the mu-
nicipal water supply; however, if groundwater is used for
other non-potable uses, there is potential non-cancer risk.
There is also non-cancer risks from eating fruits and vege-
tables irrigated with contaminated groundwater.
1,4-dioxane, a COC was detected in low concentrations in
one private well, five monitor wells and one former supply
well within the groundwater plume area. Currently, there
are no federal or state standards for 1,4-dioxane. The con-
centrations found in the wells are below current EPA
Health Advisory level of 200 ug/L; however using a more
conservative approach, the concentrations found in two
wells are more than 6.7 (ig/L (EPA tap water screening
level or EPA human health risk level) associated with the
excess life-time cancer risk of lxlO"5.
Vapor Intrusion Risk
Indoor air exposure to VOCs via vapor intrusion estimated
from plume area groundwater, as well as exterior soil gas,
resulted in four of the 15 wells screened at the water table
and one exterior soil gas sample with excess life-time can-
cer risk ranging from lxlO"5 to 5xl0"5 (within USEPA's
acceptable range of lxlO"6 to lxlO"4) and noncancer HQs
greater than 1 (ranging from 2.3 to 11). For these four
wells and one exterior soil gas sample, TCE concentrations
were the primary contributors to the calculated HQs and
excess life-time cancer risks. The model used to calculate
indoor air concentrations from groundwater and exterior
soil gas relies on a number of conservative assumptions
that could over-predict the amount of VOCs migrating into
buildings. Based on ground water depths and proximity to
source vapor intrusion risk is unlikely; however, additional
evaluation will be conducted during the RD to determine if
any of the homes downgradient of these wells has the po-
tential for vapor intrusion.
Ecological Risk
The ecological risk assessment conducted indicates low
risk level that is acceptable across the site expect for the
presence of metals (chromium and lead) in surface soils
near the unlined wastewater impoundments, new manufac-
turing plant, and southwest of the new manufacturing
plant. Those identified areas could pose a potential very
low to moderate risk to hypothetical receptors (song birds
and small omnivorous mammals). None of these types of
animals were observed on the site, and it is not expected
that they would as long as the site remains industrial land
use. The risk estimates obtained in this analysis may be
overestimated due to the use of conservative exposure met-
rics and assumes 100 percent metal bioavailability.
Remedial Action Objectives
Remedial Action Objectives (RAOs) provide a general de-
scription of what a Superfund cleanup is designed to ac-
complish. The EPA proposes the following RAOs for the
site:
Soil RAOs:
• Prevent exposure to soils with lead concentrations
above the non-residential screening level of 800
mg/kg.
• Mitigate potential impacts to groundwater from
soils if present.
Construction Debris RAOs.
• Prevent exposure of asbestos.
Groundwater RAOs:
• Prevent human exposure to groundwater with con-
taminant concentrations above MCLs and above
EPA human health risk level for 1,4-dioxane.
7
-------
• Restore the aquifer in a timely manner such that
no COCs are present at concentrations above
MCLs, the EPA human health risk level for 1,4-
dioxane.
• Prevent plume migration and mitigate further
groundwater degradation.
Preliminary Remediation Goals
Preliminary Remediation Goals (PRGs) were developed
for COCs and exposure areas where the total risk for a re-
ceptor exceeded lxlO"4 or an HI of 1. The site-specific
PRGs were developed based on guidance published by the
NMED. The PRGs for the Eagle Picher Site are as follows:
Groundwater
PCE: 5 (ig/L (microgram/liter); TCE: 5 (ig/L; 1,1-DCE: 7
(ig/L; 1,4-dioxane: 6.7 (ig/L
Summary of Remedial Alternatives
The EPA has developed alternatives based on media im-
pacted. These alternatives are analyzed in more detail in
the FS, which is part of the Administrative Record File.
Figure 3 shows the extent of the plume and the areas tar-
geted for remediation using the preferred alternative.
Soil Alternatives
- Alternative S-l: No Action
- Alternative S-2: Consolidate and Cap in Place
- Alternative S-3: Excavation and off-site Disposal
The EPA will select the final remedial alternative based on
the Administrative Record File and based on comments
received during the public comment period.
Alternative S-l: No Action
Estimated Capital Cost: $0
Estimated Present Worth Annual Operation and
Maintenance (O&M): $0
Estimated Total Present Worth Cost: $0
Alternative S-l is the baseline condition against which
other remedial alternatives are compared, as required by
the National Contingency Plan (NCP). Alternative 1 would
provide no further remedial action at the Site. Alternative 1
would continue to exceed the Preliminary Remediation
Goals (PRGs) such that the RAOs for soil would not be
met.
Alternative S-2: Consolidate and Cap in Place
Estimated Capital Cost: $339,000
Estimated Present O&M Cost: $322,000
Estimated Total Present Worth Cost: $661,000
Contaminated soil would be excavated and consolidated at
a single location and covered with either a low-
permeability cap or evapotranspiration cover. Materials
would be excavated using standard earth-moving equip-
ment (backhoes, excavators, front-end loaders, etc.) and
relocated on-site. Mixing with cement would be performed
as material is placed to provide a stable final form to the
waste. A soil cap would then be installed to prevent infil-
tration to groundwater through the contaminated materials.
The approximate areas to be excavated are shown in Fig-
ure 3. Approximately 1,000 cubic yards of material would
need to be capped in place.
Alternative S-3: Excavate and Off-Site Disposal
Estimated Capital Cost: $1,601,000
Estimated Present O&M Cost: $26,000
Estimated Total Present Worth Cost: $1,627,000
This alternative includes removal of contaminated soil by
excavation and off-site disposal. As in Alternative S-2, the
volume of contaminated soil is estimated to be on the order
of 1,000 cubic yards for the entire site, including the
wastewater impoundments, building site, and battery dump
site. Materials would be excavated using standard earth-
moving equipment (backhoes, excavators, front-end load-
ers, etc.), placed in covered haul trucks, and disposed of at
a licensed out-of-state facility.
Construction Debris Alternatives
- Alternative CD-I: No Action
- Alternative CD-2: Demolition and Disposal
-------
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1 I Soil alternative
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Designation— P-37 N1
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Lead result (mg/kg)— 6,166 (0-1)-
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'6,020 (surficial soil)
Base Map Source: Aenal photograph provided by NAIP. 2011
/_
7
Daniel B. Stephens & Associates, Inc. _
3/1M14 JNES12.0120.00
EAGLE PICHER CAREFREE BATTERIES SUPERFUND SITE
SOCORRO, NEW MEXICO
Soil and Construction Debris Remedial Alternatives
Alternative CD-I: No Action
Estimated Capital Cost: $0
Estimated Present Worth O&M Cost: $0
Estimated Total Present Worth Cost: $0
No Action is a retained alternative as required by the NCP*
and is used as a baseline for comparison with other tech-
nologies. Under this alternative, none of the ACBM or
LBP materials would be moved.
Alternative CD-2: Demolition and Disposal
Estimated Capital Cost: $105,000
Estimated Present Worth O&M Cost: $0
Estimated Total Present Worth Cost: $120,000
Under this alternative, ACBM and LBP materials are re-
moved from the buildings (as opposed to building demoli-
tion) by a licensed contractor and disposed of at an
appropriate disposal facility licensed to accept special
wastes. Cost estimates are based on preliminary abatement
plans and cost estimates from licensed hazardous materials
contractors. Removal of construction debris through demo-
lition and disposal is evaluated as a remedial alternative.
Groundwater Alternatives
- Alternative GW-1: No Action
- Alternative GW-2: Monitored Natural Attenua-
tion (A4NA) - Rejected
Figure 3
- Alternative GW-3: MNA and Institutional Con-
trols (ICs) - Rejected
- Alternative GW-4: Enhanced Reductive Dechlo-
rination (ERD), MNA and ICs
- Alternative GW-5: Pump and Treat, ERD, MNA
and ICs
- Alternative GW-6: Focused Pump and Treat with
Hydraulic Containment, MNA and ICs
- Alternative GW-6A: Phased Focused Pump and
Treat with Hydraulic Containment, MNA and ICs
Alternative GW-1: No Action
Estimated Capital Cost: $0
Estimated Present Worth O&M Cost: $0
Estimated Total Present Worth Cost: $0
No Action is a retained alternative as required by the NCP,
and is used as a baseline for comparison with other tech-
nologies. Under this alternative, the contaminant plume is
allowed to expand and no monitoring is performed.
Alternative GW-2: Monitored Natural Attenuation
In final FS, standalone MNA was considered as an Alter-
native; however, after further review in a supplemental FS,
GW-2 was rejected as the time-frame required to achieve
the RAOs is not reasonable.
-------
Alternative GW-3: MNA and ICs
In final FS, MNA with ICs was considered as an alterna-
tive. However, after further review in a supplemental FS,
GW-3 was rejected as the time-frame required to achieve
the RAOs is not reasonable.
Alternative GW-4: ERD, MNA and ICs
Estimated Capital Cost: $20,208,000
Estimated Present Worth O&M Cost: $9,202,000
Estimated Total Present Worth cost: $31,208,000
Groundwater alternative GW-4 includes the Enhanced Re-
ductive Dechlorination (ERD) in situ treatment technology
in combination with MNA and ICs. Conceptually, ERD
would be implemented along 11 500-foot-long transects of
injection wells across the higher central shallow and deep
TCE plume concentrations. Preliminary locations of these
transects are shown on Figures 4a and 4b. Preliminary de-
sign assumes that injection wells are placed every 25 feet
along each transect. Implementation of this alternative, if
11 transects are installed, would require installation of 240
permanent two-inch-diameter injection wells to 110 or 210
feet bgs. No final decision of the substrate that will be in-
jected is made for this screening evaluation, but would
likely be either emulsified vegetable oil or HRC®. De-
pending on the selection, reapplication of the substrate
would be required every 24 to 36 months.
In considering this process, it is recognized that the trans-
formation of the aquifer to anaerobic conditions will likely
result in the release of odors related to the degradation of
the organics, as well as the potential release of sulfur as
sulfate degrades. Therefore, water that has been treated us-
ing ERD will not be potable until additional blending with
oxygenated water from the surrounding aquifer occurs.
This will occur over time as water migrates through the
zone of treatment; recovery to naturally occurring condi-
tions could take a number of years.
MNA includes the monitoring and evaluation of the degra-
dation processes to assess whether the contaminant plume
is stable and whether contaminant mass is decreasing over
time. MNA performance monitoring would require instal-
lation of additional monitor wells to ensure adequate
plume delineation and number of groundwater samples
collected.
Alternative GW-5: Pump and Treat, ERD, MNA and
ICs
Estimated Capital Cost: $11,059,000
Estimated Present Worth O&M Cost: $16,404,000
Estimated Total Present Worth Cost: $27,471,000
Groundwater alternative GW-5 adds groundwater extrac-
tion, treatment, and disposal to alternative GW-4. The ap-
plication of each of the other processes is targeted to
specific areas of the plume as shown on Figure 5. Mass
removal by groundwater extraction and ex situ treatment is
applied in the middle of the plume, where solute contami-
nant concentrations are the highest. This technology uses
three 6-inch-diameter extraction wells, conveyance piping
to a treatment compound, a treatment facility, site im-
provements, and disposal of treated water. The extracted
groundwater is conveyed back to a centrally located treat-
ment compound for treatment and disposition. The pipe-
lines are sized as 4-inch, 6-inch, and 8-inch polyvinyl
chloride (PVC) pipes installed 4 feet deep. Several varia-
tions of this technology will be evaluated, including forms
of ex situ treatment (air stripping and GAC), disposal
methods (surface discharge, groundwater injection), and
disposal locations (upgradient of the extracted locations
and conveyed south to the golf course).
Plume containment also uses groundwater extraction near
the leading edge of the groundwater plume. Application at
this location would limit plume migration. This technology
uses two additional 6-inch-diameter extraction wells, con-
veyance piping, and site improvements. Contaminant con-
centrations at this location are relatively low. The total
extraction from the five wells is 420 gpm. The treatment
system including the treatment skid, process pumps, and
appurtenances is sized for a design flow of 500 gpm.
Alternative GW-6: Focused Pump and Treat with Hy-
draulic Containment, MNA and ICs
Estimated Capital Cost: $2,985,000
Estimated Present Worth O&M Cost: $13,610,000
Estimated Total Present Worth Cost: $16,595,000
Alternative GW-6 applies the components described for
alternative GW-5 (without ERD), including ICs, mass re-
moval by groundwater extraction and ex situ treatment,
and plume containment by groundwater extraction. The
groundwater extraction for treatment is focused on the
highest concentrations in the groundwater plumes as de-
termined during the RI. These are shown conceptually as
inside the 50 (ig/L contours in Figure 6. With focused ex-
traction, three extraction wells are installed in the
10
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jL
m Daniel B. Stephens & Associates, Inc. ¦
3/12/2014 JN ES12.0120.00
Base Map Source: Aerial photograph provided by NAIP, 2011
EAGLE PICHER CAREFREE
BATTERIES SUPERFUND SITE
SOCORRO, NEW MEXICO
GW-4 Enhanced Reductive Dechlorination, DWBZ
11
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5.7; Field screening result
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110'total depth, and screen intervals 60-110'
WW"
Base Map Source: Aerial photograph provided by NAIP, 2011
EAGLE PICHER CAREFREE
BATTERIES SUPERFUND SITE
SOCORRO, NEW MEXICO
GW-4 Enhanced Reductive Dechlorination, SWBZ and IWBZ
'Daniel B. Stephens & Associates, Inc.
3/12/2014 JN ES12-0120.00
12
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2. 5 extraction wells
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A
'Daniel B. Stephens & Associates, Inc. ¦
3/12/2014 JN ES12.Q120.00
Map Source: Aenal photograph provided by NAIP. 2011
EAGLE PICHER CAREFREE
BATTERIES SUPERFUND SITE
SOCORRO, NEW MEXICO
GW-5 Pump and Treat with Enhanced
Reductive Dechlorination, SWBZ and IWBZ
13
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shallow zones and two extraction wells are installed in the
deep zone. The wells in both zones would be installed
2,400 apart along the flow paths. As in Alternative GW-5,
the extracted groundwater is conveyed back to a centrally
located treatment compound for treatment and disposition.
The pipelines are sized as 4-inch and 6-inch PVC pipes in-
stalled 4 feet deep. Two shallow wells would be installed
at the golf course approximately 1,000 feet apart in the low
concentration (5 to 50 (ig/L) area of the plume to hydrau-
lically contain the plume front. This water would be con-
veyed back to the treatment compound for treatment and
disposal.
Plume containment will also be included and again uses
groundwater extraction near the leading edge of the
groundwater plume. Application at this location would
limit plume migration. This technology uses two additional
6-inch-diameter extraction wells, conveyance piping, and
site improvements. Contaminant concentrations at this lo-
cation are relatively low.
The total extraction from the seven wells is 350 gpm. The
treatment system including the treatment skid, process
pumps, and appurtenances is sized for a design flow of 500
gpm.
Alternative GW-6A: Phased Focused Pump and Treat
with Hydraulic Containment, MNA and ICs
Estimated Capital Cost: $2,284,000
Estimated Present Worth O&M Cost: $12,618,458
Estimated Total Present Worth Cost: $16,490,000
Alternative GW-6A is a phased implementation of alterna-
tive GW-6 in response to plume response to the remedial
action (See Figure 7). While the complete Alternative
GW-6 addresses both the core of the plume as well as the
plume front (defined as the southern edge of the 5 |ig/L
contour), alternative GW-6A delays the installation of the
following components until the first five-year review:
• Plume front wells (shown as EWS-01 and EWS-02)
• Installation of 2,500 feet of 6-inch and 700 feet of
four-inch conveyance line
• Installation of one 250 gallon per minute (gpm) air
stripper
Initially, there will be five extraction wells, three shallow
and two deep, operating during the first 5 years with a total
capacity of 240 gpm. During the initial construction, a
building large enough to house two air strippers will be
built, but only one 250-gpm air stripper will be installed.
The remedy performance will be evaluated on an annual
basis and if conditions warrant the additional extraction
wells will be installed prior to the first five-year review.
Modification of Remedial Alternatives for 1,4-dioxane
Estimated Capital Cost: $976,000
Estimated Present Worth O&M Cost: $ 2,700,034
Estimated Total Present Worth Cost: $4,040,000
1,4-dioxane, an emerging contaminant commonly used as
a stabilizer for chlorinated solvents, was detected in
groundwater subsequent to the completion of the FS. All
detections to date are well below current health advisory
levels (which range from 1 to 0.2 milligrams per liter
[mg/L]). Additional sampling is needed to define the verti-
cal and areal extent of the 1,4-dioxane. Based on the final
extent determination, additional groundwater treatment
may be required. 1,4-dioxane is not amenable to the treat-
ment train that has been proposed. The best available tech-
nology for removal of 1,4-dioxane at low concentrations is
advanced oxidation. If required an advanced oxidation
process (AOP) system will be incorporated in to the exist-
ing treatment system. Several key assumptions are used to
develop the present worth estimate:
• The existing remedial measure has already been in-
stalled and will continue to operate pumping and con-
veyance infrastructure.
• The additional treatment skid would be installed in
year 6.
• The original building installed to house treatment
equipment is sized to accommodate the later installa-
tion of the AOP treatment skid (no new
buildings/electrical work required).
• The AOP system is operated for 24 years after
installation.
Evaluation of Alternatives
The EPA uses nine criteria to evaluate remedial alterna-
tives for the cleanup of a release. These nine criteria are
categorized into three groups: threshold, balancing, and
modifying. The threshold criteria must be met in order for
an alternative to be eligible for selection. The threshold
criteria are overall protection of human health and the en-
vironment and compliance with Applicable, Relevant and
Appropriate Requirements (ARARs). The balancing crite-
ria are used to weigh major tradeoffs among alternatives.
The five balancing criteria are long-term effectiveness and
permanence; reduction of toxicity, mobility or volume
through treatment; short-term effectiveness; implementa-
bility; and cost. The modifying criteria are state acceptance
and community acceptance, which are evaluated once the
Proposed Plan public comment period is complete. Based
on the information and the analysis presented in the FS,
EPA has identified the following
Preferred Alternative:
Soil: Alternative S-3 - Excavate and Off-Site Disposal
Construction Debris: Alternative CD-2 - Demolition and
Disposal
Groundwater: Alternative GW-6A - Phased Focused
Pump and Treat with Hydraulic Containment, MNA and
ICs
14
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The EPA may modify its position regarding site remedia-
tion based upon its assessment of community acceptance
and state acceptance, the final two criteria, which will be
described in the ROD after comments are received.
Comparative Analysis of Remedial
Technologies Relative to Impacted Media
The comparative analysis of technologies, or technology
combinations, for each media relative to the nine evalua-
tion criteria is presented below.
1. Overall Protection of Human Health and the
Environment
This criterion assesses whether each alternative provides
adequate protection of human health and the environment.
The overall assessment of protection considers the alterna-
tive's long-term effectiveness, permanence, short-term ef-
fectiveness, and compliance with ARARs. The evaluation
of protection focuses on the reduction or elimination of
site risks by the proposed remedial alternative. For the
purpose of this evaluation, an alternative is either protec-
tive or not protective.
Soil
Three technical approaches were identified pertaining to
contaminated soil. These technical approaches included
either No Action, Consolidation and Capping in Place or
Excavate and Off-Site Disposal.
Alternative S-l - The No Action approach does not protect
human health and the environment because COCs will re-
main in soils on site.
Alternative S-2 - Alternative S-2 is considered protective.
The contaminated materials remain in place, and with
proper monitoring and maintenance will be isolated from
contact with the environment. Stabilization with cement
during placement will contribute to the overall stability of
the consolidated waste. Proper grading and armoring of the
capped area and site grading will be necessary to mitigate
impacts from surface water both on and passing through
the site.
Alternative S-3 is highly protective, as the contaminated
materials are completely removed from the site.
Construction Debris
Alternative CD-1 - The No Action approach does not pro-
tect human health and the environment because COCs will
remain in soils on site.
Alternative CD-2 is considered protective because the con-
taminated material would be removed from the site and
sent to a disposal facility.
Groundwater
Alternative GW-1 provides no protection from contami-
nants in groundwater, and is not considered protective of
human health or the environment. Contaminants will con-
tinue to migrate with groundwater and will likely eventual-
ly impact drinking water wells.
Alternatives GW-2 and GW-3 have been rejected owing to
the long time-frame required for cleanup.
Alternative GW-4 is considered protective. This alterna-
tive uses in situ treatment of groundwater in combination
with MNA and ICs with a focus on the remediation of the
most contaminated portions of the plume.
Alternative GW-5 is considered protective, as pump and
treat with ex situ treatment is a proven remedial technolo-
gy. However, pump and treat of large plumes can result in
long time frames to reach remedial goals. Large-scale
pump and treat also requires removal, treatment, and dis-
posal or reuse of large volumes of groundwater. Using
pump and treat in combination with ERD, MNA, and ICs
would allow for both in situ and ex situ treatment, and
thereby likely speed the time to completion.
Alternatives GW-6 is protective and similar to GW-5 but
uses Focused pump and treat. Focused pump and treat can
provide significant mass removal and effective treatment
while extracting smaller volumes of water.
Alternative GW-6A is protective and similar to Alternative
GW-6 but the extraction wells are phased in the front end
of the plume where contaminant concentration are low
based on the remedy performance.
2. Compliance with ARARs
This criterion is used to evaluate whether each alternative
will meet all of the federal and state ARARs identified or
whether there is justification for waiving one or more
ARARs. For the purpose of this evaluation, an alternative
either complies with ARARs or does not comply with
ARARs.
Soil
With the exception of the Alternative S-l - No Action the
other two Alternatives S-2 and S-3 will comply with AR-
ARs.
15
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v 40
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S \Pro;pcts'.FS17 D170 Fag g -icrter_RI_FS»GISWXOs\Reporis\FS^epor_03_?nid\Fig1? GW-fia Focjsed_PHmp and Trest wrth Hyd-a
Notes: / /
' Treatment compound includes influentand effluent /
storage tanks, building (3*0' x 60 ).'treatment equipment,
power, and site improvements. f
S& SFSL-1
aUun„g'build^||
Manufacturing __
\\ ;
Eagle Picher property^
\\ • V '¦
Wastewaters
poun'dments „
^Lagoons ¦ t-
¦ | jfc
V \\#? . .
Length
Historical facility
PSFvSL-a
menucom
EP-UNK
NMED-1
City property
Fi~-i i-
: rv .
Sump
•i.u
\\ r
\\i;
\\ "V ' f*- ri
vXwflk. »<
0 150 300 Feet
OVVv
or. w c,
Steals*
Alice.West
OMW-9V i
EWD-02
60 GPM
EWS-05
40 GPM
Length:*2;2pO-_ Dw;6
A 4
€§aiPVCf
I
OF,".
- r-
OMW-11
EWS-04
I "" * Length:'7.50
>/6',pvE
-• - :fe, §«• E-sl
40 GPM
QlVlW;12s
-V.Tv'v .
:>/.¦ -i
City pro^ei
3QjB
<5
^ Treatmenpcorm
r . ^ 4 I @30
h. - .OMW-13* 1.^ -
' Lenath: ,1
O .I.'.-.:
Length:j.200
I; '6V RVe
EWS-03
\fe4/GPM /
r* >r i I
-QMW-10
v,
iitmu' l -'T
^Qlsen^I
500 1,000 Feet
* ^Length:-2"500
k x ?,-r:
6 ' PVC
Phase 2
BMR
Length: 700. t-
iSS'VDK/rI-1
Sedillo Park East
4'i^VC
kiaGBM
EWSiO.1
701GBM
MS®'
r 11 ¦ m .!¦'
Explanation
fS- Water supply well
^ Monitor well
• Domestic well
^ Injection well
-$¦ Extraction well
—¦ Extraction conveyance
Total TCE (trichloroethene)
above 5 pg/L
Total TCE above 50 pg/L
omw-3 Designation
6-7 TCE concentration (pg/L)
<0.5 TCE below reporting limit
fi-7) Field screening result
Notes: 1. Pumping rate 350 gpm total
2. 7 extraction wells
3. 2 Treated water injection wells
Daniel B. Stephens & Associates, Inc.-
5/30/2014 JN ES12.0120.00
X«'i
Base Map Source: Aerial photograph provided by NAIP, 2011
EAGLE PICHER CAREFREE
BATTERIES SUPERFUND SITE
SOCORRO, NEW MEXICO
GW-6A Phased Focused Pump and Treat with
Hydraulic Containment, SWBZ, IWBZ, and DWBZ
1 /
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Construction Debris
Alternative CD-1 does not comply with the ARARs, how-
ever, Alternative CD-2 complies with the ARARs.
Groundwater
Alternative GW-1 does not comply with ARARs as no ac-
tion is taken. Alternatives GW-2 and GW-3 are rejected.
Alternatives GW-4, GW-5 and GW-6 will comply with
ARARs as they all have an active remedial component.
3. Long-Term Effectiveness and Permanence
Each alternative is evaluated in terms of risk that remains
at the site after the RAOs have been met. The primary fo-
cus of this evaluation is the extent and effectiveness of
controls used to manage the risk posed by treatment resid-
uals or untreated wastes. Long-term effectiveness is one of
the balancing criteria. The following factors are considered
in evaluating this criterion:
• Adequacy of remedial controls
• Reliability of remedial controls
• Magnitude of the residual risk
For the purpose of this evaluation long-term effectiveness
is deemed low, moderate, or high. Low means that the
remedy will not be effective. Moderate means that most of
the residuals or untreated waste will not pose a risk. High
means that all risks will be mitigated.
Soil
Alternative S-l does not achieve RAOs, and offers no
mechanisms to control exposure or contact with contami-
nated soil. Long-term effectiveness is considered low.
Long-term effectiveness for Alternative S-2 is moderate,
as the cap will require long-term maintenance and moni-
toring to ensure compliance with the RAOs.
Long-term effectiveness for Alternative S-3 is high, as
once the materials are removed there is no further contam-
inated material on-site.
Construction Debris
Alternative CD-I will not meet long-term effectiveness
and permanence as ACBM and LBP material will remain
on-site. Alternative CD-2 will meet long-term effective-
ness and permanence.
Groundwater
Alternative GW-1 will not meet long-term effectiveness
and permanence as No Action is taken. Alternatives GW-2
and GW-3 are rejected. Long-term effectiveness is moder-
ate for Alternatives GW-4, GW-5, GW-6 and GW-6A.
4. Reduction of Toxicity, Mobility and Volume
(TMV) of Contaminants Through Treatment
This evaluation criterion addresses the CERCLA statutory
preference for treatment options that permanently and sig-
nificantly reduce the toxicity, mobility, or volume of the
contaminants. The preference is satisfied when treatment
reduces the principal threats through the following:
• Destruction of toxic contaminants
• Reduction in contaminant mobility
• Reduction in the total mass of toxic contaminants
• Reduction in the total volume of contaminated
media
Although CERCLA includes a statutory preference for
treatment, this criterion is not a threshold that must be met.
For the purpose of this evaluation, an alternative may be
considered to have (1) no reduction on toxicity mobility or
volume, (2) moderate reduction on toxicity mobility or
volume over time, or (3) complete reduction on toxicity
mobility or volume overtime.
Soil
Alternative S-l will not reduce toxicity, mobility, or vol-
ume, as no treatment is undertaken.
Alternative S-2 will not reduce contaminant toxicity
through treatment, but will prevent potential exposure
through capping. Mobility of contaminated materials will
be eliminated once they are capped. The overall volume of
materials will be reduced somewhat during consolidation
due to screening of the soil material.
Alternative S-3 provides no treatment, but provides an
immediate reduction in volume once materials are off-site.
There is no further potential for mobility or exposure.
Construction Debris
Alternative CD-I does not result in reduction of Toxicity,
Mobility and Volume of Contaminants as No Action is
taken. Alternative CD-2 will result in reduction of Toxici-
ty, Mobility and Volume of contaminants as materials will
be removed from site.
Groundwater
Alternatives GW-1 will not result in reduction of Toxicity,
Mobility and Volume of contaminants. Alternatives GW-2
and GW-3 are rejected. Alternatives GW-4 will be moder-
ately effective and Alternatives GW-5, GW-6 and GW-6A
will be highly effective in achieving reduction in Toxicity,
Mobility and Volume of contaminants.
5. Short-Term Effectiveness
This evaluation criterion addresses the effects of the alter-
native during the construction and implementation phase
until the RAO is met. Under this criterion, alternatives are
evaluated for their effects on human health and the envi-
ronment during implementation of the remedial action.
The following factors will be considered:
• Exposure of the community during implementation
• Exposure of workers during construction
18
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• Environmental impacts
• Time to achieve RAOs
For the purpose of this evaluation, short-term effectiveness
is deemed low, moderate, or high. Low means that the
remedy will not mitigate exposure risks. Moderate means
that there is an initial exposure risk, although it is limited
to initial implementation. High means that exposure risks
are mitigated.
Soil
Alternative S-l does not achieve RAOs, and offers no
mechanisms to control exposure or contact with contami-
nated soil.
Alternative S-2 is moderately effective, as it immediately
meets RAOs and reduces the risk to human health and the
environment through containment. There will be potential
risk in the short term to site workers during the consolida-
tion and capping process.
Alternative S-3 meets RAOs and reduces the risk to human
health and the environment through disposal. Short-term
effectiveness is considered moderate, as there will be po-
tential exposure risk to site workers during the excavation
and preparation for hauling. There is a small potential for
worker exposure during excavation activities, which is
mitigated through proper activity planning, use of personal
protective equipment (PPE), and site controls. There is al-
so a moderate increase in the environmental impact due to
the hauling distance to the disposal site.
Construction Debris
Alternative CD-I will not meet Short-Term Effectiveness
as No Action is taken. Alternative CD-2 will fully meet
Short-Term Effectiveness as material will be removed
from site.
Groundwater
Alternative GW-1 will not meet Short-Term Effectiveness.
Alternatives GW-2 and GW-3 are rejected. Alternatives
GW-4, GW-5, GW-6 and GW-6A will have moderate
Short-Term Effectiveness.
6. Implementability
This criterion addresses the technical and administrative
feasibility of implementing an alternative and the availa-
bility of various services and materials that may be re-
quired during its implementation. The following factors
were considered:
• Ability to construct the technology
• Monitoring requirements
• Availability of equipment and specialists
For the purpose of this evaluation, an alternative either
may be implemented or may not be implemented.
Soil
All Alternatives are technically and administratively easily
implementable.
Construction Debris
All Alternatives are technically and administratively im-
plementable.
Groundwater
All Alternatives are technically and administratively im-
plementable.
7. Cost
Cost includes estimated capital and operation and mainte-
nance costs as well as present worth costs. Present worth
cost is the total cost of an alternative over time in terms of
today's dollar value. Cost estimates are expected to be ac-
curate within a range of +50 to -30 percent.
The total cost for the Preferred Remedy for the site is
$18.4 million.
Soil:
There is no cost for Alternative S-l. Alternative S-3 is the
most expensive. Alternative S-2 is approximately one third
of the cost for Alternative S-3.
Construction Debris:
There is no cost for Alternative CD-I. Alternative CD-2 is
approximately $ 120,000.
Groundwater:
There is no cost for Alternative GW-1. Alternatives GW-2
and GW-3 are rejected.GW-4 and GW-5 are on the higher
end. Alternative GW-6 and GW-6A is in the middle of the
pack.
8. State Acceptance
NMED agrees with EPA's recommendations of the Pre-
ferred Remedy.
9. Community Acceptance
Community acceptance of the Preferred Alternative will be
evaluated after the public comment period ends and will be
described in the Record of Decision for the site.
Summary of EPA's Preferred Alternative
The following is the EPA's preferred alternative for the
various impacted media:
Soil: Alternative S-3 - Excavation and Off-Site Disposal
The EPA chose the Off-Site Disposal over the other alter-
natives because this alternative best meets the cleanup ob-
jectives by removing contaminated materials from the site.
This alternative reduces mobility and toxicity at the site by
removing the source materials. This alternative is expected
to be completed in relatively short period. Implementation
of this alternative will have minimum impact on the com-
19
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munity. The cost for implementation of this remedy is
more than other active alternative.
Construction Debris: Alternative CD-2 -
Demolition and Disposal
The EPA chose the Demolition and Disposal over the oth-
er alternatives because this alternative best meets the
cleanup objectives by removing contaminated materials
from the site. This alternative reduces mobility and toxici-
ty at the site by removing the source materials. This alter-
native is expected to be completed in relatively short
period. Implementation of this alternative will have mini-
mum impact on the community. The cost for implementa-
tion of this remedy is relatively small.
Groundwater: GW-6A -Phased Focused Pump
and Treat with Hydraulic Containment, MNA and
ICs
The EPA chose Alternative GW-6A because it is effective
in removing contaminants in the plume while balancing
and meeting all other criteria. Among all other active al-
ternatives considered for the site Alternative GW-6A costs
are in the middle range of costs and effective in meeting
the RAOs. EPA and the NMED believe the preferred al-
ternative would be protective of human health and the en-
vironment, would comply with ARARs, would be cost-
effective, and would utilize permanent solutions to the
maximum extent practicable.
For more information, please contact...
Sai Appaii, Remedial Project Manager
U.S. EPA Region 6
1445 Ross Avenue (6SF-R)
Dallas, TX 75202
214-665-3126
1-800-533-3508 (toll-free)
appaii. sairam@epa.gov
Jason McKinney, Community Involvement Manager
U.S. EPA Region 6
1445 Ross Avenue (6SF-VO)
Dallas, TX 75202
214-665-8132
1-800-533-3508 (toll-free)
mckinney .j ason@epa.gov
EPA Region 6 Press Office
U.S. EPA Region 6
1445 Ross Avenue
Dallas, TX 75202
214-665-2200
Sabino Rivera
New Mexico Environment Department
Superfund Oversight Section
1190 St. Francis Dr. Ste. N2300
Santa Fe, NM 87505
505-827-0387
sabino. rivera@state ,nm .us
Information Repositories
Socorro Public Library
401 Park Street
Socorro, New Mexico 87801
Tel: 575-835-1114
NMED
Harold Runnels Bldg.
1190 St. Francis Drive
Santa Fe, NM 87505
505-827 2855 or
toll-free 1-800-879-3421
U.S. EPA Region 6 Library
Seventh Floor Reception Area
1445 Ross Avenue, Ste. 12D13
Dallas, TX
214-665 6424
U.S. EPA on the Internet
U.S. EPA Headquarters
www.epa.gov
U.S. EPA Region 6
www.epa.gov/region6
U.S. EPA Region 6 Superfund
www.epa.gov/region6/superfund
20
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Glossary
Applicable, Relevant and Appropriate Requirements
(ARARs) - Generally, any Federal, State, or local re-
quirements or regulations that would apply to a remedial
action if it were not being conducted under CERCLA, or
that while not strictly applicable, are relevant in the sense
that they regulate similar situations or actions and are ap-
propriate to be followed in implementing a particular re-
medial action.
Baseline Human Health Risk Assessment - A formal
risk assessment conducted as part of the RI according to
EPA-prescribed procedures. The need for remedial action
at a site is established in part on the results of the baseline
risk assessment.
Chlorinated Solvents - An organic hydrocarbon in which
chlorine atoms substitute for one or more hydrogen atoms
in the compound's structure, for example, methylene chlo-
ride and 1,1,1-trichloromethane. Commonly used in aero-
sol spray containers, in highway paint, for grease removal
in manufacturing, dry cleaning, and other operations. The
substituted chlorine makes the compound less flammable
than the non-substituted equivalent, but more toxic.
Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA) - Also
known as Superfund. CERCLA is a federal law passed in
1980 and modified in 1986 by the Superfund Amendments
and Reauthorization Act. The Acts created a special tax
that goes into a Trust Fund, commonly known as Super-
fund, to investigate and clean up abandoned or uncon-
trolled hazardous waste sites. Under the program, U.S.
EPA can either: 1. Pay for site cleanup when parties re-
sponsible for the contamination cannot be located or are
unwilling or unable to perform the work; or 2. Take legal
action to force parties responsible for site contamination to
clean up the site or pay back the federal government for
the cost of the cleanup.
Enhanced Reductive Dechlorination (ERD) - Enhanced
Reductive Dechlorination is a process that uses a carbon
source amendment such as molasses, cheese, whey, or
vegetable oil in conjunction with native organisms in
groundwater to remove chlorine from the primary structure
of the contaminating organic chemical. The substance is
reduced in the process.
Hazard index - In the baseline risk assessment, the ration
of the dose calculated for a receptor divided by the refer-
ence dose. When the HI exceeds 1.0 (i.e., the expected
dose exceeds EPA's reference dose), a health risk is as-
sumed to exist.
Hazard quotient - The ratio of exposure to toxicity for
non-cancer endpoints. The HQ is calculated by dividing
the estimated daily intake of a chemical by the non-cancer
reference dose for that chemical. When the HQ exceeds
1.0, a possible health risk is assumed to exist.
Maximum Containment Levels (MCLs) - Set under the
Safe Drinking Water Act, a contaminant level that may not
be exceeded in a drinking water source.
National Contingency Plan (NCP) - The National Oil
and Hazardous Substances Pollution Contingency Plan is
composed of the federal regulations that guide the Super-
fund program.
National Priorities List (NPL) - EPA's list of the most
serious uncontrolled or abandoned hazardous waste sites
identified for possible long-term remedial response where
money from the Trust Fund may be used. The list is based,
primarily, on the score a site receives on the Hazard Rank-
ing System (HRS). U.S. EPA is required to update the
NPL at least once a year.
Preliminary Remediation Goals (PRGs) - Concentration
levels set for individual chemicals that, for carcinogens
corresponds to a specific cancer risk level of 1 in 1 million
and for non-carcinogens corresponds to a Hazard Quotient
of 1.
Reasonable Maximum Exposure (RME) - The maxi-
mum exposure reasonably expected to occur in a popula-
tion.
Reference Dose (RfD) - An estimate (with uncertainty
spanning perhaps an order of magnitude or greater) of a
daily exposure level for the human population, including
sensitive subpopulations, that is likely to be without an ap-
preciable risk of deleterious effects during a lifetime.
Remedial Action Objectives (RAOs) - Objectives estab-
lished for a CERCLA remedial action that define the ex-
tent to which sites require cleanup to meet the objective of
protecting human health and the environment.
21
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