EPA/ROD/R09-85/009
1985
EPA Superfund
Record of Decision:
CELTOR CHEMICAL WORKS
EPA ID: CAD980638860
OUOl
HOOPA, CA
09/30/1985
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CELTOR CHEMICAL WORKS, HOOPA, CALIFORNIA.
#DR
DOCUMENTS REVIEWED
MY DECISION IS PRIMARILY BASED ON THE FOLLOWING DOCUMENTS THAT DESCRIBE THE COST-EFFECTIVENESS
OF REMEDIAL ALTERNATIVES FOR THE CELTOR CHEMICAL WORKS:
CELTOR CHEMICAL WORKS REMEDIAL INVESTIGATION
CELTOR CHEMICAL WORKS FEASIBILITY STUDY
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
COMMUNITY RELATIONS RESPONSIVENESS SUMMARY.
#DE
DECLARATIONS
CONSISTENT WITH THE COMPREHENSIVE ENVIRONMENTAL RESPONSE COMPENSATION, AND LIABILITY ACT OF 1980
(CERCLA), AND THE NATIONAL OIL AND HAZARDOUS SUBSTANCES CONTINGENCY PLAN (40 C.F.R. PART 300), I
HAVE DETERMINED THAT EXCAVATION AND OFF-SITE DISPOSAL OF ALL SOILS CONTAMINATED ABOVE
SITE-SPECIFIC ACTION LEVELS AT THE CELTOR CHEMICAL WORKS IS A COST-EFFECTIVE REMEDY WHICH
PROVIDES ADEQUATE PROTECTION OF PUBLIC HEALTH, WELFARE, AND THE ENVIRONMENT. THE STATE OF
CALIFORNIA AGREES WITH THE SELECTED ALTERNATIVE.
THE REMEDIAL ACTION I HAVE CHOSEN WILL REQUIRE FUTURE OPERATION AND MAINTENANCE TO ENSURE ITS
CONTINUED EFFECTIVENESS. THESE OPERATIONS AND MAINTENANCE ACTIVITIES ARE PART OF THE APPROVED
ACTION AND ARE ELIGIBLE FOR TRUST FUND MONIES FOR A PERIOD OF ONE YEAR.
I HAVE ALSO DETERMINED THAT THE REMEDIAL ACTION SELECTED IS APPROPRIATE WHEN BALANCED AGAINST
THE AVAILABILITY OF TRUST FUND MONIES FOR USE AT OTHER SITES. FINALLY, THE OFF-SITE TRANSPORT
AND SECURE DISPOSITION OF THE HAZARDOUS SUBSTANCES IS MORE COST-EFFECTIVE THAN OTHER REMEDIAL
ACTIONS AND IS NECESSARY TO PROTECT PUBLIC HEALTH, WELFARE AND THE ENVIRONMENT.
9/30/85
DATE
JUDITH E. AYRES
REGIONAL ADMINISTRATOR
EPA REGION 9.
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
CELTOR CHEMICAL WORKS
HOOPA, CALIFORNIA
SEPTEMBER 30, 1985
PREPARED BY NICHOLAS MORGAN
FEDERAL RESPONSE SECTION, SUPERFUND PROGRAMS BRANCH
TOXICS AND WASTE MANAGEMENT DIVISION
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
215 FREMONT STREET
SAN FRANCISCO, CALIFORNIA 94105
#SLD
I. SITE LOCATION AND DESCRIPTION
THE CELTOR CHEMICAL WORKS SITE IS LOCATED IN THE NORTHERN END OF THE HOOPA VALLEY IN HUMBOLDT
COUNTY, CALIFORNIA, (SEE FIGURE 1). THE 2.5 ACRE SITE IS ON RESERVATION LAND OF THE HOOPA
VALLEY INDIAN TRIBE, ABOUT 2 MILES NORTH OF THE TOWN OF HOOPA. THE MAIN FEATURES OF THE SITE
ARE THE PLANTSITE, A PRIVATELY OWNED PASTURE USED FOR LIVESTOCK GRAZING TO THE WEST OF THE
PLANTSITE, AND A SHALLOW GULLY THAT RUNS NORTHWARD FROM THE PLANTSITE TO THE TRINITY RIVER (SEE
FIGURE 2). SULFIDE ORES WERE HAULED TO THE CELTOR MILL FROM THE NEARBY COPPER BLUFF MINE FOR
COPPER, ZINC, AND PRECIOUS METAL EXTRACTION. THE PLANTSITE CURRENTLY CONTAINS A NUMBER OF
CONCRETE WALLS AND SLAB FLOORS AS REMNANTS OF THE FORMER ORE PROCESSING OPERATIONS.
SURROUNDING THE MILL ARE BARE TO PARTIALLY VEGETATED SLOPES THAT CONSIST OF NATIVE SOIL
CONTAMINATED BY ORE AND TAILINGS DIRT ROADS CROSS THE SITE, AND A GRAVEL FISHING-ACCESS ROAD
PASSES THROUGH THE LOWER (WESTERN) PART OF THE PLANTSITE AREA SEPARATING THE PLANTSITE FROM THE
PASTURE. THE GRASS COVERED PASTURE, LOCATED BELOW AND WEST OF THE FISHING-ACCESS ROAD AND THE
PLANTSITE, IS USED TO GRAZE CATTLE. THE 500 FOOT LONG GULLY, WHICH RUNS TO THE NORTH OF THE
PLANTSITE, IS HEAVILY WOODED AND CONTAINS THICK BRUSH. THIS GULLY DISCHARGES INTO THE TRINITY
RIVER, WHICH, IN THIS AREA, IS CLASSIFIED AS A SCENIC RIVER AREA UNDER THE NATIONAL WILD AND
SCENIC RIVER SYSTEM. THE TRINITY IS ALSO CONSIDERED AN IMPORTANT FISH RESOURCE, INCLUDING
SALMON AND TROUT SPAWNING GROUNDS.
IN DECEMBER, 1964 THE MAXIMUM HISTORIC FLOOD FOR THIS AREA WAS RECORDED. UNITED STATES
GEOLOGICAL SURVEY (USGS) AND THE UNITED STATES ARMY CORPS OF ENGINEERS (USACE) RECORDS CLASSIFY
THE 1964 FLOOD AS GREATER THAN A 100-YEAR EVENT. AERIAL PHOTOGRAPHS, DISCUSSIONS WITH LOCAL
RESIDENTS, AND A HIGH WATER MARK INDICATE THAT IN THE SITE AREA THE FLOOD REACHED A HEIGHT OF
321 FEET ABOVE MEAN SEA LEVEL. THE LOWEST ELEVATION OF THE PLANTSITE IS 330 FEET. THUS, ALL
AREAS LOWER THAN THE PLANTSITE, SUCH AS THE PASTURE, AT ELEVATION 320 FEET, AND ALL OF THE
GULLY, MAY BE IMPACTED BY A 100-YEAR FLOOD.
THE PREDOMINANT WATER BEARING AQUIFER BENEATH THE SITE IS A THREE TO FIVE FOOT THICK BED OF
SANDY GRAVEL WHICH RESTS ATOP RELATIVELY IMPERMEABLE UNWEATHERED PHYLLITE BEDROCK. THIS HIGHLY
PERMEABLE AND TRANSMISSIVE AQUIFER IS LOCATED BETWEEN 20 FEET (AT THE PLANTSITE) AND 60 FEET (IN
THE MIDDLE OF THE GULLY) BELOW THE GROUND SURFACE. A SUBSTANTIAL AMOUNT OF WATER, PERHAPS
GREATER THAN 10 CUBIC FEET PER SECOND, FLOWS IN THIS AQUIFER IN A NORTHERLY DIRECTION INTO THE
TRINITY RIVER.
THE STRUCTURE NEAREST TO THE SITE IS A HOME SITUATED APPROXIMATELY 500 FEET TO THE SOUTH. ONE
THOUSAND TWO HUNDRED TWENTY (1,220) FEET SOUTH OF THE SITE ARE APPROXIMATELY ONE HUNDRED HOMES
WHICH ARE PART OF THE NORTON FIELD DEVELOPMENT. ALTOGETHER, APPROXIMATELY 900 RESIDENCES ARE
WITHIN THREE MILES OF THE SITE. UNTIL AS RECENTLY AS 1985, RESIDENTS OF THE NORTON FIELD
DEVELOPMENT, AND OTHER NEARBY HOMES, DRANK WATER FROM A COMMUNITY WELL WHICH TAPPED INTO THE
SAME GROUND WATER WHICH FLOWS BENEATH THE SITE. THE WELL, WHICH IS LOCATED UPGRADIENT (SOUTH)
OF THE SITE WAS SAMPLED BY THE UNITED STATES INDIAN HEALTH SERVICE (IHS), AND WAS FOUND TO BE
FREE OF INORGANIC CONTAMINATION, EXCEPT FOR IRON, WHICH IS BELIEVED TO BE A LOCAL PHENOMENON.
ALL RESIDENTS IN THE VICINITY OF THE SITE NOW DRINK WATER SUPPLIED FROM AN UPSTREAM SURFACE
WATER SOURCE, EXCEPT FOR A CLUSTER OF SIX TO TEN HOMES WHICH DRAW FROM PRIVATE WELLS LOCATED
FURTHER UPGRADIENT OF THE SITE THAN THE NORTON FIELD COMMUNITY WELL.
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#SH
II. SITE HISTORY
THE HOOPA VALLEY INDIAN TRIBE IS THE OWNER OF THE CELTOR SITE. THE TRIBE'S LAND IS HELD IN
TRUST BY THE UNITED STATES. THE TRIBE LEASED THE LAND IN 1958 TO THE CELTOR CHEMICAL
CORPORATION WHICH PROCESSED SULFIDE ORE TAKEN FROM THE NEARBY COPPER BLUFF MINE. A RESPONSIBLE
PARTY SEARCH CONDUCTED FOR EPA IN NOVEMBER, 1984 INDICATED THAT ORE PROCESSING MAY HAVE OCCURRED
AT THE SITE PRIOR TO 1958, BUT THERE IS NO RELIABLE DOCUMENTATION TO SUPPORT THIS CONTENTION.
THE PLANT, KNOWN AS THE CELTOR CHEMICAL WORKS MILL, IS BELIEVED TO HAVE USED DISSOLVED AIR
FLOTATION TO EXTRACT COPPER, ZINC, AND PRECIOUS METALS FROM THE ORE. THE ORE CONCENTRATES WERE
THEN TRUCKED OFF-SITE FOR FURTHER PROCESSING. SOME MINE TAILINGS WERE STOCKPILED IN THE
PLANTSITE AREA. HOWEVER, MOST WERE PRESUMABLY SLUICED DOWN THE GULLY TO THE TRINITY RIVER. THE
TAILINGS MAY HAVE BEEN THE CAUSE OF THE NUMEROUS FISH KILLS FOR WHICH THE CALIFORNIA DEPARTMENT
OF FISH AND GAME CITED THE CELTOR CHEMICAL CORPORATION.
BEGINNING IN 1960, THE COMPANY BECAME DELINQUENT IN ITS ROYALTY PAYMENTS TO THE HOOPA VALLEY
INDIAN TRIBE. BY 1962, CELTOR'S INDEBTEDNESS TO THE TRIBE HAD INCREASED TO $23,592.87.
ACCORDING TO RECORDS FROM THE UNITED STATES BUREAU OF INDIAN AFFAIRS (BIA) , MINING AND MILLING
OPERATIONS ACTUALLY CEASED ON JUNE 2, 1962 AND JUNE 5, 1962, RESPECTIVELY. FINALLY, IN MARCH OF
1963, THE BIA, AS THE TRUSTEE FOR THE HOOPA VALLEY INDIAN TRIBE, CANCELLED THE LEASES OF BOTH
THE COPPER BLUFF MINE AND THE CELTOR CHEMICAL WORKS MILL.
AFTER MILLING OPERATIONS CEASED, A VERY LARGE PILE OF TAILINGS WAS REPORTED TO HAVE BEEN LEFT
STANDING ON A SAND AND GRAVEL BAR BETWEEN THE GULLY AND THE TRINITY RIVER, ALONG WITH THE
TAILINGS THAT ARE KNOWN TO HAVE BEEN LEFT AT THE PLANTSITE AREA. THE AFOREMENTIONED FLOOD OF
1964 REMOVED ALL TRACES OF ANY TAILINGS THAT MAY HAVE BEEN ON THE SAND AND GRAVEL BAR.
THE REMAINING TAILINGS IN THE PLANT AREA, ALONG WITH NONSPECIFIC RELEASES OF ORE OR TAILINGS
THROUGHOUT THE PLANTSITE AREA, ARE BELIEVED TO BE THE CAUSE OF THE ACIDIC SURFACE WATER RUNOFF
AND VERY ELEVATED METALS CONCENTRATIONS IN THE SOILS THROUGHOUT THE PLANTSITE AREA. THESE
CONDITIONS WERE IDENTIFIED BY SAMPLING PERFORMED BY THE STATE OF CALIFORNIA DEPARTMENT OF HEALTH
SERVICES (DOHS) IN JULY, 1981. THE SAMPLING OCCURRED IN THE SAME MONTH THAT DOHS FIRST
DISCOVERED THE SITE THROUGH AN ONGOING CALIFORNIA STATEWIDE ABANDONED INDUSTRIAL WASTE FACILITY
SURVEY. IN AUGUST OF THAT SAME YEAR, THE IHS SUBMITTED TO THE UNITED STATES ENVIRONMENTAL
PROTECTION AGENCY (EPA) A NOTIFICATION OF HAZARDOUS WASTE SITE UNDER THE COMPREHENSIVE
ENVIRONMENTAL RESPONSE, COMPENSATION AND LIABILITY ACT OF 1980 (CERCLA). IN FEBRUARY, 1982 THE
EPA FIELD INVESTIGATION TEAM PERFORMED ADDITIONAL SAMPLING AT THE SITE.
IN APRIL, 1982 THE SITE WAS PLACED ON THE CALIFORNIA STATE PRIORITY LIST, AND ON DECEMBER 30,
1982, THE SITE WAS PROPOSED FOR INCLUSION ON THE NATIONAL PRIORITIES LIST (NPL).
ON AUGUST 29, 1983, EPA WROTE TO THE BIA, STATING OUR INTENT TO PERFORM AN INITIAL REMEDIAL
MEASURE (IRM) AT THE SITE AND REQUESTING BIA TO EITHER PERFORM OR SPONSOR THE ACTION. THIS
LETTER EXPLAINED THAT EPA CONSIDERED BIA A POTENTIAL RESPONSIBLE PARTY AT THE SITE DUE TO ITS
ROLE AS TRUSTEE FOR THE HOOPA VALLEY INDIAN TRIBE. THE MILL LEASE STATED THAT THE SITE WAS TO
BE LEFT IN A CONDITION THAT WOULD NOT BE HAZARDOUS TO PUBLIC HEALTH OR SAFETY, A CONDITION THAT
CELTOR HAD NOT COMPLIED WITH. THE BIA RESPONSE STATED THAT THE MATTER SHOULD BE ELEVATED TO A
HIGHER LEVEL FOR RESOLUTION. DUE TO THE IMPENDING WINTER RAINS, WHICH WOULD HAVE CAUSED
CONTINUED ACIDIC SURFACE RUNOFF AND HEALTH THREATS, EPA PERFORMED THE IRM ACTION IN DECEMBER,
1983, PRIOR TO THE RESOLUTION OF THE RESPONSIBLE PARTY ISSUE.
DURING THE IRM, ALL VISIBLY CONTAMINATED MATERIAL WAS REMOVED FROM THE SITE. THIS MATERIAL
INCLUDED ALL TAILINGS, NON-CONCRETE STRUCTURES, AND A PORTION OF THE ADJACENT PASTURE (SEE
FIGURE 3). IN ALL, APPROXIMATELY 1,400 CUBIC YARDS OF CONTAMINATED MATERIAL WERE TAKEN TO THE
IT CORPORATION CLASS I HAZARDOUS LANDFILL IN BENICIA, CALIFORNIA. THE TOTAL COST OF THIS ACTION
WAS APPROXIMATELY $337,000. AFTER THE CONTAMINATED SOIL WAS REMOVED, THE FISHING-ACCESS ROAD
WAS REGRADED AND COVERED WITH FRESH GRAVEL. FINALLY, A DRAINAGE CULVERT WAS INSTALLED AT THE
NORTH END OF THE SITE, AND THE SITE WAS FENCED. ALL IRM ACTIVITIES WERE COMPLETED ON DECEMBER
18, 1983. PLANS WERE MADE TO RETURN TO THE SITE DURING THE NEXT RAINY SEASON TO PERFORM THE
SAMPLING NECESSARY TO DETERMINE IF RUN-OFF OR SOILS FROM THE SITE OR ADJACENT AREAS STILL POSED
A HEALTH THREAT.
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#css
III. CURRENT SITE STATUS
ON OCTOBER 10, 1984, THE FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY WORK PLAN RECEIVED EPA
APPROVAL. REMEDIAL INVESTIGATION FIELD WORK WAS COMPLETE ON FEBRUARY 9, 1985, AND THE FINAL
REMEDIAL INVESTIGATION REPORT WAS RELEASED ON APRIL 29, 1985. THE RESULTS OF THE 177 SURFACE
AND SUBSURFACE SOIL SAMPLES, 32 SURFACE WATER AND GROUND WATER SAMPLES, AND 16 AIR SAMPLES ARE
DISCUSSED BELOW.
IN ORDER TO HAVE A BASIS ON WHICH TO EVALUATE THE RESULTS OF THE REMEDIAL INVESTIGATION,
CRITERIA FOR EVALUATING THE HAZARDS AT THE SITE HAD TO BE DETERMINED. BECAUSE NO FEDERAL ACTION
LEVELS EXIST FOR DEFINING HAZARDOUS CONCENTRATIONS OF METALS IN SOIL, THE STATE OF CALIFORNIA,
CALIFORNIA ASSESSMENT MANUAL (CAM) TOTAL THRESHOLD LIMIT CONCENTRATIONS (TTLC) CRITERIA FOR
DEFINING HAZARDOUS MATERIALS WERE USED. WATER QUALITY WAS EVALUATED ON THE BASIS OF THE EPA ONE
HOUR NATIONAL AMBIENT WATER QUALITY CRITERIA FOR PROTECTION OF FRESHWATER AQUATIC LIFE, 45
FEDERAL REGISTER 79318 ET SEQ., NOVEMBER 28, 1980 AND 50 FEDERAL REGISTER 30784 ET SEQ., JULY
29, 1985 (WQCAL), AS PROMULGATED UNDER THE CLEAN WATER ACT AS AMENDED IN 1977 (CWA) AND THE EPA
MAXIMUM CONTAMINANT LEVELS (MCLS) OR PRIMARY AND SECONDARY DRINKING WATER REGULATIONS, 40 C.F.R.
PART 141 AND 49 FEDERAL REGISTER 24330 ET SEQ., JUNE 12, 1984 (DWRS), AS PROMULGATED UNDER THE
SAFE DRINKING WATER ACT AS AMENDED IN 1977 (SDWA) .
THE SOIL SAMPLES TAKEN FROM THE MAIN PLANTSITE TO A DEPTH OF 20 FEET CONTAINED CADMIUM, COPPER,
LEAD AND ZINC IN CONCENTRATIONS GREATER THAN THE CAM TTLC CRITERIA TO DEPTHS OF 2.5 FEET.
ELEVATED CONCENTRATIONS OF ARSENIC, COPPER, AND ZINC WERE ALSO FOUND TO DEPTHS OF 11.5 FEET.
THESE DEEPER CONCENTRATIONS WERE ABOVE BACKGROUND LEVELS, BUT WERE NOT NECESSARILY GREATER THAN
THE CAM TTLC CRITERIA. THE MOST SIGNIFICANT ELEVATED METALS CONCENTRATIONS IN THE PLANTSITE
WERE 124,000 MILLIGRAMS PER KILOGRAM (MG/KG), OR PARTS PER MILLION (PPM), COPPER AT THE SURFACE,
23,330 MG/KG ZINC ON THE FISHING ACCESS ROAD SURFACE, AND 1,040 MG/KG LEAD, ALSO ON THE SURFACE.
THE GULLY WAS ALSO FOUND TO BE CONTAMINATED. THE REMEDIAL INVESTIGATION FIELD PERSONNEL
OBSERVED A VEIN OF TAILINGS WHICH WAS APPROXIMATELY FOUR FEET WIDE AND FIVE FEET DEEP. AGAIN,
ARSENIC, CADMIUM, COPPER, LEAD, AND ZINC WERE FOUND AT CONCENTRATIONS EXCEEDING THE CAM TTLC
CRITERIA. ALTHOUGH CONCENTRATIONS ABOVE BACKGROUND WERE FOUND AT DEPTHS UP TO 4.5 FEET, MAXIMUM
CONCENTRATIONS WERE ONLY FOUND BETWEEN THE SURFACE AND 2.5 FEET. THESE MAXIMUM CONCENTRATIONS
WERE 600 MG/KG FOR ARSENIC, 310 MG/KG FOR CADMIUM, 25,500 MG/KG FOR COPPER, 1,680 MG/KG FOR
LEAD, AND 62,100 MG/KG FOR ZINC.
A THIN LENS OF CONTAMINATED MATERIAL WAS FOUND BENEATH THE CLEAN FILL THAT HAD BEEN PLACED IN
THE ADJACENT PASTURE AFTER THE IRM. IN THIS LENS, 1.25 FEET BELOW THE SURFACE, ARSENIC,
CADMIUM, COPPER, LEAD, AND ZINC WERE FOUND IN ELEVATED CONCENTRATIONS, HOWEVER, ONLY LEAD, AT
2,650 MG/KG, AND ZINC, AT 11,200 MG/KG, WERE ABOVE THE CAM TTLC CRITERIA.
DURING THE WINTER MONTHS, WATER FROM MANY SPRINGS AND SEEPS TRAVEL THROUGH OR BENEATH THE
PLANTSITE. THESE SPRINGS EITHER EMERGE SOMEWHERE IN THE PLANTSITE AREA AND EVENTUALLY COLLECT
IN THE GULLY, OR CONTINUE TO TRAVEL BENEATH THE PLANTSITE FOR EVENTUAL DISCHARGE INTO THE
TRINITY RIVER.
SAMPLING SHOWED THAT THESE WATERS BECOME CONTAMINATED AS THEY PASS THROUGH OR ON TOP OF THE
SITE. WATER LEAVING THE SITE AND IN THE GULLY WAS CONTAMINATED WITH CADMIUM, COPPER, LEAD,
IRON, AND ZINC ABOVE THE MCLS, AS WELL AS, IN SOME CASES, THE MORE STRINGENT WQCAL. NO WQCAL
FOR LEAD HAS BEEN ESTABLISHED. MAXIMUM CONCENTRATIONS FOUND ON THE PLANTSITE OR IN THE GULLY
WERE 241 MICROGRAMS PER LITER (UG/L), OR PARTS PER BILLION (PPB), OF CADMIUM, 9,920 UG/L OF
COPPER, 16,600 UG/L OF IRON, 7 UG/L OF LEAD, AND 48,300 UG/L OF ZINC. THE PH OF THE WATER WAS
AS LOW AS 3.6. THAT VALUE, HOWEVER, IS NOT LOWER THAN THE CAM TTLC AND THE RESOURCE
CONSERVATION AND RECOVERY ACT AS AMENDED IN 1984 (RCRA) CRITERIA FOR DEFINITION OF A HAZARDOUS
MATERIAL, WHICH IS PH EQUAL TO OR LESS THAN 2.
SAMPLING UPSTREAM AND DOWNSTREAM OF THE GULLY'S DISCHARGE POINT INTO THE TRINITY RIVER SHOWED
THAT THE RIVER WAS NOT DETECTABLY IMPACTED BY WATER DISCHARGES FROM THE GULLY. A WORST CASE
ANALYSIS OF THE POTENTIAL IMPACT WAS CONDUCTED IN THE REMEDIAL INVESTIGATION REPORT. ASSUMING A
FIRST FLUSH OF CONTAMINANTS FROM THE SITE ENTERED THE RIVER DURING LOW FLOW, THIS ANALYSIS
SHOWED THAT RIVER IMPACT WOULD BE UNLIKELY BECAUSE THE PROJECTED DILUTION OF 1:500 (NORMAL
DILUTION IS BETWEEN 1:1000 AND 1:5000) WOULD PREVENT THE WATER QUALITY IN THE TRINITY RIVER FROM
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RISING ABOVE THE WQCAL FOR MORE THAN A FEW HOURS.
SAMPLING DURING THE REMEDIAL INVESTIGATION SHOWED THAT GROUND WATER BENEATH, AND IN THE VICINITY
OF THE SITE WAS NOT CONTAMINATED. THERE WERE, HOWEVER, ELEVATED LEVELS OF IRON IN SOME OF THE
SAMPLES, BUT DISCUSSIONS WITH THE ENVIRONMENTAL DIRECTOR OF THE HOOPA VALLEY BUSINESS COUNCIL
(HVBC), THE REPRESENTATIVES OF THE HOOPA VALLEY INDIAN TRIBE, AND THE IHS, INDICATED THAT THIS
IS DUE TO NATURALLY ELEVATED LEVELS OF IRON IN THE LOCAL SOILS. IN SUMMATION, THERE DOES NOT
APPEAR TO BE A GROUND WATER CONTAMINATION PROBLEM ASSOCIATED WITH THE SITE.
ON JUNE 18 AND 19, 1985, IN RESPONSE TO COMMUNITY CONCERNS ABOUT NOXIOUS ODORS IN THE VICINITY
OF THE SITE, THE EPA TECHNICAL ASSISTANCE TEAM PERFORMED AIR SAMPLING AT THE SITE. NO
DETECTABLE CONCENTRATIONS OF AIR POLLUTANTS RELATING TO THE REPORTED SULFUR ODOR COULD BE FOUND.
HOWEVER, THERE IS A NOTICEABLE SULFUR ODOR IN THE AREA AT TIMES. IF THE ODORS ARE CAUSED BY THE
CONTAMINANTS AT THE SITE, IMPLEMENTATION OF THE RECOMMENDED ALTERNATIVE SHOULD ELIMINATE THIS
ODOR NUISANCE.
IN SUMMATION, THE REMEDIAL INVESTIGATION FOUND THAT THE SITE POSES A THREAT TO HUMAN HEALTH AND
THE ENVIRONMENT FROM HIGH LEVELS OF ARSENIC, CADMIUM, COPPER, LEAD, AND ZINC IN THE SOIL.
DIRECT CONTACT, ESPECIALLY INGESTION OF GREATER THAN 2 LITERS PER DAY, WITH CONTAMINATED WATER
IN THE PLANTSITE, ROADWAY, OR GULLY AREAS ALSO POSES A HUMAN HEALTH AND ENVIRONMENTAL THREAT.
#ENE
IV. ENFORCEMENT ANALYSIS
A POTENTIAL RESPONSIBLE PARTY SEARCH COMPLETED FOR THE EPA IN NOVEMBER, 1984 CONCLUDED THAT THE
CELTOR CHEMICAL CORPORATION WAS A DEFUNCT COMPANY WITH NO REMAINING ASSETS OR INTERESTS THAT
COULD BE PURSUED FOR COST RECOVERY. THE BIA, AS TRUSTEE FOR THE HOOPA VALLEY INDIAN TRIBE AND
THE UNITED STATES DEPARTMENT OF THE INTERIOR (DOI), THE PARENT AGENCY OF THE BIA, ARE THE ONLY
OTHER POTENTIAL RESPONSIBLE PARTIES.
ON AUGUST 29, 1983, PRIOR TO THE IRM, EPA SENT TO BIA A 3007/104 NOTICE LETTER WHICH IDENTIFIED
THE BIA AS A POTENTIAL RESPONSIBLE PARTY AND REQUESTED BIA TO FUND OR PERFORM THE IRM. ON
OCTOBER 24, 1983, BIA RESPONDED AND SUGGESTED THAT THE MATTER BE ELEVATED TO BIA HEADQUARTERS.
AFTER EPA CONDUCTED THE IRM, A SECOND NOTICE LETTER WAS SENT TO THE DOI IN AUGUST, 1985
SPECIFYING OUR INTENT TO TAKE REMEDIAL ACTION AND REQUESTING DOI TO FUND OR PERFORM THE REMEDIAL
ACTION. A MEETING WAS HELD IN WASHINGTON, D.C. ON SEPTEMBER 19, 1985 TO DISCUSS THE DOI'S
STATUS AS A POTENTIAL RESPONSIBLE PARTY. AT THE MEETING, THE DOI REFUSED TO CONTRIBUTE TO OR
CONDUCT THE REMEDIAL ACTION. HOWEVER, DOI AGREED TO DISCUSS THE MATTER FURTHER WITH EPA AFTER
THE CLEANUP WAS COMPLETED DURING COST RECOVERY NEGOTIATIONS. RESULTS OF ONGOING DISCUSSIONS AT
THE HEADQUARTERS LEVEL REGARDING DOI'S LIABILITY FOR SITES ON INDIAN LANDS THAT ARE HELD IN
TRUST BY DOI WILL BE A KEY ELEMENT IN THE RESOLUTION OF DOI'S STATUS AT THIS SITE.
#AE
V. ALTERNATIVES EVALUATION
THE FOLLOWING SECTION SUMMARIZES THE ALTERNATIVES EVALUATION AND RECOMMENDED ALTERNATIVE
SELECTION PROCESS AS DOCUMENTED IN THE FEASIBILITY STUDY. ALL PROCEDURES ARE CONSISTENT WITH
THE NATIONAL OIL AND HAZARDOUS SUBSTANCES CONTINGENCY PLAN, 47 FEDERAL REGISTER 31180 ET SEQ.,
JULY 16, 1982 (NCP) AND THE GUIDANCE ON FEASIBILITY STUDIES CONDUCTED UNDER CERCLA, EPA, JUNE,
1985. THIS SECTION BEGINS WITH THE DEFINITIONS OF THE REMEDIAL ACTIONS THAT WERE EVALUATED THEN
DESCRIBES THE SITE-SPECIFIC ACTION LEVELS THAT WERE SELECTED FOR THE SITE. AN ALTERNATIVE,
CONSISTENT WITH ALL RELEVANT GUIDANCE, IS THEN CHOSEN. THE STEPS IN THIS EVALUATION ARE
TECHNOLOGY DEVELOPMENT, INITIAL ALTERNATIVE SCREENING, AND DETAILED ANALYSIS OF ALTERNATIVES.
FINALLY, THE RESULTS OF ALTERNATIVES EVALUATION IS DOCUMENTED.
V.A. REMEDIAL ACTION DEFINITION
THE NCP, SECTION 300.68(E) (2) STATES THAT SOURCE CONTROL REMEDIAL ACTIONS ARE APPROPRIATE WHEN A
SUBSTANTIAL CONCENTRATION OF HAZARDOUS SUBSTANCES REMAIN AT OR NEAR THE AREAS WHERE THEY WERE
ORIGINALLY LOCATED. BECAUSE ALL OF THE CONTAMINATION IN THE PLANTSITE AND GULLY ARE PRESUMED TO
BE LEFT FROM OPERATIONS OF THE CELTOR CHEMICAL WORKS, AND NOT FROM OFF-SITE MIGRATION, THE
MEASURES UNDER CONSIDERATION FOR THE PLANTSITE AND GULLY ARE CONSIDERED SOURCE CONTROL. BECAUSE
CONTAMINANTS IN THE FIELD ARE PRESUMED TO HAVE MIGRATED FROM THE PLANTSITE, THE REMEDIAL ACTION
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IN THE PASTURE AREA, ACCORDING TO THE NCP SECTION 300.68(E) (3), IS CONSIDERED AN OFF-SITE, OR
MANAGEMENT OF MIGRATION, REMEDIAL ACTION.
V.B. SITE-SPECIFIC ACTION LEVEL DEVELOPMENT
IN THE JUNE 28, 1985 PUBLIC COMMENT DRAFT FEASIBILITY STUDY REPORT, SITE-SPECIFIC OBJECTIVES FOR
REMEDIAL ACTION WERE DEVELOPED. ACCORDING TO THE PUBLIC HEALTH ASSESSMENT PREPARED FOR THE
REPORT, UNDER THE WORST CASE SCENARIO OF NO RESPONSE ACTION AND UNRESTRICTED RESIDENTIAL SITE
USE, THE PRIMARY HEALTH THREATS ARE:
DIRECT CONTACT WITH SOILS CONTAMINATED WITH ARSENIC, CADMIUM, COPPER AND LEAD.
CONSUMPTION OF SURFACE WATER RUNNING OFF THE SITE OR IN THE GULLY. THIS WATER
SOMETIMES EXCEEDS THE MCLS FOR COPPER, IRON, LEAD, AND ZINC. THE ELEVATED
CONCENTRATIONS OF IRON ARE BELIEVED TO BE A NATURAL CONDITION.
AS DESCRIBED IN THE NCP, SECTION 300.68(J), THE OBJECTIVE OF EVERY REMEDIAL ACTION IS TO
"...MITIGATE(S) AND MINIMIZE DAMAGE TO AND PROVIDE(S) ADEQUATE PROTECTION OF PUBLIC HEALTH,
WELFARE, OR THE ENVIRONMENT....". FOR THE CELTOR SITE, THE GENERAL REMEDIAL GOALS ARE TO
PREVENT HUMAN EXPOSURE TO SOIL AND WATER THAT IS CONTAMINATED AT CONCENTRATIONS THAT MAY POSE A
PUBLIC HEALTH OR ENVIRONMENTAL THREAT. TO IMPLEMENT THESE GOALS, SITE-SPECIFIC ACTION LEVELS
WERE DEVELOPED AS SHOWN IN TABLE 1.
THE ACTION LEVELS FOR WATER WERE ESTABLISHED AS DISCUSSED BELOW. WATER FLOWS IN THE GULLY ARE
INTERMITTENT AND ARE INSUFFICIENT TO SUPPORT MOST AQUATIC LIFE. ACCORDINGLY, WATER QUALITY
CRITERIA FOR THE GULLY, FOR SURFACE WATER RUNNING INTO THE GULLY, AND FOR GROUND WATER, WHICH IS
A KNOWN DRINKING WATER RESOURCE, ARE BASED ON ACTION LEVELS NECESSARY TO PROTECT HUMAN HEALTH.
THEREFORE, THE SURFACE WATER AND GROUND WATER SITE-SPECIFIC ACTION LEVELS SELECTED FOR THE SITE
ARE THE MCLS, OR DWRS. THESE ACTIONS LEVELS FULLY PROTECT PUBLIC HEALTH IN ALL SCENARIOS.
ACTION LEVELS FOR THE TRINITY RIVER WERE BASED ON THE MOST STRINGENT FEDERAL STANDARDS FOR
PROTECTION OF AQUATIC LIFE. THESE ARE THE WQCAL, AS BASED ON A HARDNESS OF 75 MG/L AS CAC03.
FOR ARSENIC AND LEAD, HOWEVER, THE MORE STRINGENT MCL OF 50 UG/L WAS USED INSTEAD OF THE WQCAL
OF 440 UG/L AND 57.4 UG/L, RESPECTIVELY. THESE ACTION LEVELS FOR THE TRINITY RIVER FULLY
PROTECT HUMAN HEALTH AND MOST AQUATIC ORGANISMS.
IN ADDITION TO THE CONCERNS REGARDING METALS CONTAMINATION, LOW PH SURFACE WATER MAY ALSO POSE A
HEALTH HAZARD. THEREFORE, AN ADDITIONAL ACTION LEVEL FOR SURFACE WATER OR SOIL OF PH = 2 OR
LOWER WAS DEVELOPED. THIS IS BASED ON THE RCRA CORROSIVITY REQUIREMENTS FOUND IN 40 C.F.R.
2 61.22, WHICH IS THE DEFINITION FOR A HAZARDOUS WASTE UNDER RCRA.
ACTION LEVELS FOR CONTAMINANTS IN SOIL WERE BASED PRIMARILY ON THE ACCEPTABLE RANGE OF
CONTAMINANT LEVELS IN SOIL AS DERIVED FROM THE EPA NATIONAL AMBIENT WATER QUALITY CRITERIA FOR
PROTECTION OF HUMAN HEALTH, 45 FEDERAL REGISTER 79318 ET SEQ., NOVEMBER 28, 1980 (WQCHH), AS
PROMULGATED UNDER THE CWA, AND THE MCLS, OR DWRS, AS PROMULGATED UNDER THE SDWA. FIRST, AN
ACCEPTABLE DAILY DOSE WAS COMPUTED BY MULTIPLYING THE WQCHH OR MCL FOR A GIVEN CONTAMINANT BY
TWO LITERS, WHICH IS THE MAXIMUM DAILY INGESTION RATE FOR THE WQCHH OR MCL TO PROTECT HUMAN
HEALTH. THIS COMPUTED DAILY DOSE IS THEN DIVIDED BY 10 GRAMS OR 0.1 GRAMS, WHICH IS THE UNITED
STATES CENTERS FOR DISEASE CONTROL (CDC) MAXIMUM ESTIMATED INGESTION RATE OF SOIL FOR A CHILD OR
AN ADULT, RESPECTIVELY. THE RESULT IS A RANGE OF CONTAMINANT CONCENTRATIONS IN SOIL WHICH WILL
FULLY PROTECT HUMAN HEALTH. THESE ACCEPTABLE CONTAMINANT CONCENTRATIONS ARE: ARSENIC 10-1,000
MG/KG, CADMIUM 2-200 MG/KG; COPPER 200-20,000 MG/KG; LEAD 10-1,000 MG/KG; AND ZINC 1,000-100,000
MG/KG.
OTHER CONSIDERATIONS WERE ALSO EVALUATED IN SETTING THE ACTION LEVELS. THE ACTION LEVEL FOR
ARSENIC OF 100 MG/KG IS BASED ON AN ADVISORY FROM THE CDC FOR ANOTHER CERCLA SITE. THIS LEVEL
IS MUCH STRICTER THAN THE CAM TTLC OF 500 MG/KG. THE ACTION LEVEL FOR CADMIUM OF 25 MG/KG IS
CONSISTENT WITH THE ACTION LEVEL SET FOR THE CAPRI PUMPING SERVICE SITE (A STATE OF CALIFORNIA
SUPERFUND SITE), AND IS BASED ON CLEANUP FOR UNRESTRICTED RESIDENTIAL USE. IT IS ONE-QUARTER OF
THE CAM TTLC OF 100 MG/KG. THE ACTION LEVEL FOR LEAD OF 500 MG/KG IS ALSO CONSISTENT WITH THE
CAPRI SITE, IS ONE-HALF THE CAM TTLC OF 1,000 MG/KG, AND IS ALSO CONSISTENT WITH OTHER CERCLA
SITES. ACTION LEVELS AT THESE OTHER SUPERFUND SITES RANGED FROM 300 MG/KG TO 1,000 MG/KG. THE
ACTION LEVELS FOR COPPER AND ZINC WERE ESTABLISHED AT THE CAM TTLC LEVELS OF 2,500 MG/KG AND
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5,000 MG/KG, RESPECTIVELY, BECAUSE THESE LEVELS ARE SUFFICIENT TO PROTECT HUMAN HEALTH. TOXIC
EFFECTS FROM THESE METALS ARE NOT FOUND EXCEPT FOR MATERIALS WITH VERY HIGH CONCENTRATIONS
(20,000 TO 100,000 MG/KG RANGE) AS THESE METALS ARE PRIMARILY REGULATED FOR TASTE AND ODOR
CONSIDERATIONS. THE COPPER AND ZINC ACTION LEVELS ARE ALSO CONSISTENT WITH THE LEVELS SET FOR
THE CAPRI SITE, AND PROVIDE A WIDE MARGIN OF SAFETY EVEN IN WORST CASE SCENARIOS.
V.C. TECHNOLOGY DEVELOPMENT
IN ORDER TO MEET THESE ACTION LEVELS, SEVERAL GENERAL RESPONSE ACTIONS WERE DEVELOPED. THE
GENERAL RESPONSE ACTIONS, AND SOME OF THE ASSOCIATED TECHNOLOGIES THAT WERE CONSIDERED IN THE
FEASIBILITY STUDY WERE:
CONTAINMENT: CAPPING, GROUND WATER CONTAINMENT BARRIER WALLS, BULKHEADS, AND
GAS BARRIERS.
ON-SITE DISPOSAL: ENCAPSULATION AND LAND APPLICATION.
OFF-SITE DISPOSAL: EXCAVATION AND OFF-SITE DISPOSAL.
ON-SITE TREATMENT: INCINERATION, SOLIDIFICATION, BIOLOGICAL TREATMENT, CHEMICAL
TREATMENT, IN-SITU SOIL FLUSHING AND SOIL FLUSHING.
OFF-SITE TREATMENT: SAME AS ON-SITE TREATMENT, EXCEPT FOR IN-SITU SOIL FLUSHING.
NO ACTION: NO REMEDIAL ACTION.
ACCORDING TO THE GUIDANCE ON FEASIBILITY STUDIES UNDER CERCLA, THE SECOND STEP IN THE
DEVELOPMENT OR REMEDIAL ALTERNATIVES IS TO DEFINE AND SCREEN TECHNOLOGIES THAT ARE APPLICABLE TO
THE GENERAL RESPONSE ACTIONS LISTED ABOVE. INAPPLICABLE, INFEASIBLE, OR UNRELIABLE TECHNOLOGIES
ARE ASSEMBLED AND SCREENED PRIMARILY THROUGH THE USE OF ENGINEERING JUDGMENT AND QUALITATIVE
COMPARISONS.
AFTER DEVELOPING AN EXTENSIVE LIST OF TECHNOLOGIES, BASED ON THE GENERAL RESPONSE ACTIONS LISTED
ABOVE, AND SCREENING, BASED ON SUCH FACTORS AS SITE CONDITIONS, WASTE CHARACTERISTICS, AND
TECHNOLOGY EFFECTIVENESS, THE TECHNOLOGIES PRESENTED IN TABLE 2 REMAINED.
V.D. INITIAL ALTERNATIVE SCREENING
ONCE THE TECHNOLOGIES IDENTIFIED ABOVE HAVE BEEN SCREENED, MORE DEFINITE ALTERNATIVES CAN BE
DEVELOPED. AT LEAST ONE ALTERNATIVE FOR EACH OF THE FIVE FOLLOWING CATEGORIES MUST BE EVALUATED
PER THE FEASIBILITY STUDY GUIDANCE. THESE FIVE CATEGORIES, AND THE CORRESPONDING ALTERNATIVES,
ARE PRESENTED BELOW:
1. ALTERNATIVES SPECIFYING OFF-SITE STORAGE, DESTRUCTION, TREATMENT, OR SECURE DISPOSAL OF
HAZARDOUS SUBSTANCES AT A FACILITY APPROVED UNDER RCRA. SUCH A FACILITY MUST ALSO BE IN
COMPLIANCE WITH ALL OTHER APPLICABLE EPA STANDARDS (E.G., CLEAN WATER ACT, CLEAN AIR ACT,
TOXIC SUBSTANCES CONTROL ACT) - REMOVAL AND TREATMENT ARE IN THIS CATEGORY.
2. ALTERNATIVES THAT ATTAIN ALL APPLICABLE OR RELEVANT FEDERAL PUBLIC HEALTH OR ENVIRONMENTAL
STANDARDS, GUIDANCE, OR ADVISORIES. REMOVAL, ENCAPSULATION, AND TREATMENT ALL FALL INTO
THIS CATEGORY.
3. ALTERNATIVES THAT EXCEED ALL APPLICABLE OR RELEVANT FEDERAL PUBLIC HEALTH AND
ENVIRONMENTAL STANDARDS, GUIDANCE, AND ADVISORIES. NO ALTERNATIVES ARE IN COMPLIANCE WITH
THIS CATEGORY BECAUSE IT WAS NOT FEASIBLE TO DEVELOP AN ALTERNATIVE THAT WOULD EXCEED ALL
APPLICABLE ENVIRONMENTAL STANDARDS.
4. ALTERNATIVES THAT MEET THE CERCLA GOALS OF PREVENTING OR MINIMIZING PRESENT OR FUTURE
MIGRATION OF HAZARDOUS SUBSTANCES AND PROTECT HUMAN HEALTH AND THE ENVIRONMENT, BUT DO NOT
ATTAIN THE APPLICABLE OR RELEVANT STANDARDS. THIS CATEGORY MAY INCLUDE AN ALTERNATIVE
THAT CLOSELY APPROACHES THE LEVEL OF PROTECTION PROVIDED BY THE APPLICABLE OR RELEVANT
STANDARDS. CAPPING FALLS INTO THIS CATEGORY.
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5. A NO-ACTION ALTERNATIVE MUST BE INCLUDED.
A MORE DETAILED DESCRIPTION OF THE ALTERNATIVES MENTIONED ABOVE IS PROVIDED BELOW:
1. NO-ACTION
2. CAPPING - PARTIALLY DEMOLISH CONCRETE STRUCTURES (TO FACILITATE CAPPING).
EXCAVATE SOILS CONTAMINATED ABOVE ACTION LEVELS FROM THE PASTURE AND GULLY,
DEPOSIT IN PLANTSITE AREA, AND BACKFILL PASTURE AND GULLY WITH CLEAN SOIL.
REGRADE ALL AREAS.
INSTALL SURFACE AND SUBSURFACE DRAINAGE SYSTEMS.
INSTALL MULTILAYER SYSTEM OF CLAY, SYNTHETIC COVER, AND NATIVE SOIL OVER
CONTAMINATED MATERIAL IN PLANT AREA.
VEGETATE SITE.
INSTALL SECURITY FENCING TO PROTECT CAP AND NEW VEGETATION.
3. REMOVAL - DEMOLISH AND REMOVE STRUCTURES.
EXCAVATE SOILS CONTAMINATED ABOVE ACTION LEVELS FROM ALL SITE AREAS.
REMOVE ALL SOILS TO A RCRA-APPROVED CLASS I LANDFILL.
IMPORT CLEAN FILL AS NECESSARY.
REGRADE AND VEGETATE SITE.
INSTALL SECURITY FENCING TO PROTECT NEW VEGETATION.
4. ENCAPSULATION
DEMOLISH CONCRETE STRUCTURES AND BURY ON-SITE.
EXCAVATE SOILS CONTAMINATED ABOVE ACTION LEVELS FROM ALL SITE AREAS.
BACKFILL PASTURE AND GULLY WITH CLEAN SOIL.
ENCAPSULATE CONTAMINATED SOILS ON-SITE.
INSTALL SURFACE AND SUBSURFACE DRAINAGE SYSTEMS.
IMPORT CLEAN FILL AS NECESSARY.
REGRADE AND VEGETATE SITE.
INSTALL SECURITY FENCE TO PROTECT NEW VEGETATION.
5. TREATMENT
DEMOLISH AND BURY STRUCTURES ON-SITE.
PREPARE THE SITE FOR A TREATMENT FACILITY.
EXCAVATE SOILS CONTAMINATED ABOVE ACTION LEVELS.
PROCESS SOILS CONTAMINATED ABOVE ACTION LEVELS THROUGH THE EPA MOBILE SOILS
FLUSHING UNIT.
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RETURN CLEAN MATERIAL TO EXCAVATED AREAS.
ADD CLEAN FILL AS NECESSARY.
REMOVE CONTAMINATED SLUDGES/"WASTE TO A RCRA-APPROVED CLASS I LANDFILL.
REMOVE TREATMENT FACILITY.
REGRADE AND VEGETATE SITE.
INSTALL SECURITY FENCE TO PROTECT NEW VEGETATION.
AN INITIAL SCREENING OF ALTERNATIVES IS PERFORMED ACCORDING TO THE NCP, SECTION 300.68. PUBLIC
HEALTH, ENVIRONMENTAL, AND COST FACTORS, INCLUDING POTENTIAL ADVERSE ENVIRONMENTAL IMPACTS AND
ENGINEERING FEASIBILITY ARE FIGURED INTO THE SCREENING PROCESS.
NO-ACTION WAS ELIMINATED AT THIS TIME BECAUSE IT WOULD NOT PROTECT HUMAN HEALTH OR THE
ENVIRONMENT. HOWEVER, NO-ACTION WAS CARRIED THROUGH THE DETAILED ANALYSIS FOR THE PURPOSE OF
COMPARISON WITH OTHER ALTERNATIVES. THE RESULTS OF A BENCH SCALE SOILS FLUSHING TREATABILITY
STUDY, METALS EXTRACTION STUDY FOR THE CELTOR CHEMICAL WORKS, EPA, OCTOBER, 1985, INDICATED THAT
TREATMENT WOULD NOT BE EFFECTIVE. NONE OF THE FLUSHING SOLUTIONS TESTED WAS ABLE TO EXTRACT
SUFFICIENT CONTAMINANTS TO ATTAIN THE ACTION LEVELS. WHILE TREATMENT WAS CARRIED THROUGH THE
DETAILED ALTERNATIVES ANALYSIS IN THE DRAFT FEASIBILITY STUDY REPORT, IT IS NOW BEING DROPPED
FROM FURTHER CONSIDERATION ON THE BASIS OF THE TEST DATA.
V.E. DETAILED ANALYSIS OF ALTERNATIVES
A DETAILED ANALYSIS OF THE REMAINING ALTERNATIVES WAS PERFORMED ACCORDING TO THE NCP, SECTION
300.68. FIVE FACTORS ARE EVALUATED IN THIS ANALYSIS: TECHNICAL, INSTITUTIONAL, PUBLIC HEALTH,
ENVIRONMENTAL, AND COST. CHAPTERS 3, 4, 5, 6, AND 7 OF THE GUIDANCE ON FEASIBILITY STUDIES
CONDUCTED UNDER CERCLA PROVIDE AN IN-DEPTH DISCUSSION OF THE COMPONENTS OF EACH FACTOR REQUIRING
FURTHER EVALUATION.
V.E.I. TECHNICAL EVALUATION
THERE ARE FOUR PRIMARY FACTORS IN THE TECHNICAL EVALUATION: PERFORMANCE (INCLUDING EFFECTIVENESS
AND USEFUL LIFE), RELIABILITY (INCLUDING OPERATIONS AND MAINTENANCE (O&M) REQUIREMENTS AND
DEMONSTRATED PERFORMANCE), IMPLEMENTABILITY (INCLUDING ON- AND OFF-SITE CONDITIONS, TIME TO
IMPLEMENT, AND TIME TO ACHIEVE BENEFICIAL RESULTS), AND SAFETY.
V.E.I.A. PERFORMANCE: EFFECTIVENESS: THE REMOVAL ALTERNATIVE WOULD PROVIDE THE HIGHEST LEVEL OF
PROTECTION TO HUMAN HEALTH AND THE ENVIRONMENT BECAUSE IT WOULD PERMANENTLY REMOVE ALL
CONTAMINANTS FROM THE SITE. ENCAPSULATION AND CAPPING MAY PROVIDE AN ACCEPTABLE LEVEL OF
PROTECTION, IF ALL OF THEIR COMPONENTS (THE LINERS, CAP, AND DRAINAGE FACILITIES) WERE PROPERLY
MAINTAINED. HOWEVER, THE EFFECTIVENESS OF THE ENCAPSULATION CELL, AND ESPECIALLY THE CAP, MAY
BE SERIOUSLY COMPROMISED BY THE NATURAL SPRINGS IN THE AREA. THERE IS NO ASSURANCE THAT THE
INTERCEPTOR TRENCHES AND SUBSURFACE DRAINS COULD EFFECTIVELY PREVENT GROUND WATER (ESPECIALLY
THE SPRINGS) FROM COMING INTO CONTACT WITH THE CONTAMINATED SOIL. THE CERTAINTY WITH WHICH THIS
OBJECTIVE COULD BE ACHIEVED IS GREATER FOR ENCAPSULATION THAN FOR CAPPING. NO-ACTION IS
COMPLETELY INEFFECTIVE IN PREVENTING DIRECT CONTACT WITH CONTAMINATED SOILS OR THE FORMATION OF
CONTAMINATED RUNOFF.
USEFUL LIFE: REMOVAL WOULD HAVE AN INFINITE USEFUL LIFE. THE USEFUL LIFE OF ENCAPSULATION AND
CAPPING IS ESTIMATED TO BE THIRTY YEARS, BASED ON THE LIFE OF THE MATERIALS. AT THAT TIME, THE
ENTIRE ENCAPSULATION CELL OR CAP MIGHT HAVE TO BE REPLACED. THE CONCEPT OF USEFUL LIFE DOES NOT
APPLY TO THE NO-ACTION ALTERNATIVE.
V.E.l.B. RELIABILITY: OPERATION AND MAINTENANCE: EXCEPT FOR NO-ACTION, EACH OF THE
ALTERNATIVES WILL REQUIRE GROUNDS MAINTENANCE FOR AN INITIAL PERIOD OF ONE YEAR. THIS WOULD
INCLUDE CARING FOR SURFACE VEGETATION, DOING PREVENTATIVE WORK ON ANY SURFACE WATER DRAINAGE
SYSTEMS, AND TAKING CARE OF EROSION PROBLEMS IN ORDER TO ASSURE THAT REVEGETATED AREAS BECOME
PROPERLY ESTABLISHED. AFTER THE FIRST YEAR, VEGETATION OR SURFACE DRAINAGE MAINTENANCE WOULD
NOT BE REQUIRED FOR THE REMOVAL ALTERNATIVE. CAPPING AND ENCAPSULATION BOTH REQUIRE LONG TERM
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(THIRTY YEARS AND GREATER) MAINTENANCE OF VEGETATION AND SURFACE DRAINAGE FEATURES TO ENSURE THE
EFFECTIVENESS OF THE TECHNOLOGY.
A FENCE WILL BE REQUIRED THE FIRST YEAR FOR ALL ALTERNATIVES. THEREAFTER, CAPPING,
ENCAPSULATION, AND NO-ACTION WILL ALL REQUIRE A FENCE. THIS IS NOT A LEGAL REQUIREMENT.
HOWEVER, GOOD ENGINEERING JUDGEMENT INDICATES THAT MAINTAINING A FENCE AROUND THE SITE FOR THOSE
ALTERNATIVES WHICH LEAVE HAZARDOUS MATERIALS AT THE SITE IS A SOUND METHOD TO ENSURE THAT THE
VEGETATION, THE REMEDIAL TECHNOLOGY, AND THE CONTAMINANTS ARE NOT DISTURBED.
DEMONSTRATED PERFORMANCE: ALL OF THE COMPONENT TECHNOLOGIES UTILIZED IN THE REMOVAL, CAPPING,
AND ENCAPSULATION ALTERNATIVES HAVE BEEN WIDELY USED AND PROVEN IN SIMILAR APPLICATIONS.
BECAUSE ALL CONTAMINANTS WILL BE REMOVED FROM THE SITE WITH THE REMOVAL ALTERNATIVE, THERE IS NO
CHANCE OF FAILURE OF THIS TECHNOLOGY. AT THIS SITE, ENCAPSULATION IS LESS LIKELY TO BE
EFFECTIVE THAN REMOVAL BECAUSE THERE ARE MANY SPRINGS AND SEEPS IN THE AREA. FURTHERMORE, IT IS
IMPOSSIBLE TO PREDICT THE LOCATION OF ALL SURFACE WATER IN THE AREA. IT IS UNLIKELY, THEREFORE,
THAT INTERCEPTOR TRENCHES AND SUBSURFACE DRAINS COULD PREVENT ALL THE SUBSURFACE WATER FROM
COMING INTO CONTACT WITH THE ENCAPSULATION CELL. IN TIME, THIS WATER COULD DAMAGE THE
ENCAPSULATION CELL AND COMPROMISE THE EFFECTIVENESS OF THIS ALTERNATIVE. THE CAPPING
ALTERNATIVE, WHICH HAS NO BOTTOM OR SIDE LINER, HAS A GREATER PROBABILITY OF FAILURE THAN THE
ENCAPSULATION ALTERNATIVE ALSO BECAUSE THE INTERCEPTOR TRENCHES AND SUBSURFACE DRAINS MAY NOT
DIVERT ALL WATER WHICH MAY CONTACT THE CONTAMINATED MATERIAL BENEATH THE CAP.
THE ENCAPSULATION AND CAPPING ALTERNATIVES MAY ALSO FAIL BECAUSE OF DEGRADATION OF THEIR SURFACE
FEATURES. IF VEGETATION IS NOT PROPERLY MAINTAINED, IF EROSION IS NOT PREVENTED, OR IF ANY
HEAVY OBJECTS FALL OR ARE PLACED ON THE SURFACE, THE INTEGRITY OF THE TOP CAP WILL BE
COMPROMISED. CAREFUL MAINTENANCE CAN HELP PREVENT SUCH A FAILURE.
V.E.l.C. IMPLEMENTABILITY: CONSTRUCTABILITY: NONE OF THE ALTERNATIVES PRESENT EXCEPTIONAL
PROBLEMS FOR CONSTRUCTION, GIVEN A REASONABLE SCHEDULE, FAVORABLE WEATHER, AND GOOD GROUND
CONDITIONS. BECAUSE SEVERAL SPRINGS ARE PRESENT ON THE SITE, CONSTRUCTION OF ANY OF THE
ALTERNATIVES WOULD BE UNADVISABLE DURING THE WET WINTER MONTHS. FOR THE ENCAPSULATION AND
CAPPING ALTERNATIVES, THERE MUST BE CONTROLLED MOISTURE CONDITIONS FOR THE PLACEMENT OF THE CLAY
LAYERS. NO OTHER ON-SITE CONDITIONS SHOULD BE SIGNIFICANT TO THE CONSTRUCTION OF ANY
ALTERNATIVE.
THERE ARE MANY QUALIFIED CONTRACTORS WITH EXTENSIVE EXPERIENCE IN PERFORMING REMOVAL WORK.
CURRENTLY NO RESTRICTIONS EXIST ON THE OFF-SITE TRANSPORTATION OR DISPOSAL OF HAZARDOUS WASTES
THAT WOULD PREVENT THE IMPLEMENTATION OF THE REMOVAL ALTERNATIVE (SEE THE CONSISTENCY WITH OTHER
ENVIRONMENTAL LAWS SECTION).
THERE ARE FEWER QUALIFIED CONTRACTORS WHO COULD PERFORM THE ENCAPSULATION OR CAPPING WORK. OF
THE TWO ALTERNATIVES, CAPPING IS MUCH SIMPLER TO PERFORM AND HAS HAD WIDER FIELD USE.
ENCAPSULATION IS A COMPLEX TECHNOLOGY WITH MANY COMPONENTS WHICH WOULD REQUIRE CAREFUL
CONSTRUCTION. SEALING THE SEAMS BETWEEN THE SECTIONS OF FABRIC IS THE MOST CRITICAL ASPECT OF
THE CONSTRUCTION, BUT THERE ARE MANY PORTIONS OF CONSTRUCTION WHICH MUST BE PROPERLY PERFORMED
IN ORDER FOR THIS ALTERNATIVE TO PERFORM ADEQUATELY.
TIME TO IMPLEMENT AND TIME TO ACHIEVE BENEFICIAL RESULTS: ALL OF THE ALTERNATIVES HAVE
RELATIVELY SHORT CONSTRUCTION SCHEDULES AND COULD BE IMPLEMENTED OVER ONE DRY SEASON, FOR
EXAMPLE, FROM APRIL THROUGH OCTOBER. THE FOLLOWING CONSTRUCTION TIMES DO NOT INCLUDE THE DESIGN
OR BID AND AWARD PERIOD.
- REMOVAL AND DISPOSAL 3 MONTHS
- CAPPING 2 MONTHS
- ENCAPSULATION 4 MONTHS
- TREATMENT 6 MONTHS
- NO-ACTION 0 MONTHS.
THE DIFFERENCES BETWEEN CONSTRUCTION TIMES FOR THE ALTERNATIVES (EXCEPT FOR NO-ACTION) ARE
MINOR. ONCE CONSTRUCTED, EACH ALTERNATIVE WOULD IMMEDIATELY BEGIN PROVIDING THE BENEFITS
ASSOCIATED WITH THE COMPONENT TECHNOLOGIES.
V.E.l.D. SAFETY: EXPOSURE TO HAZARDOUS MATERIALS DURING CONSTRUCTION WOULD BE MOST LIKELY TO
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OCCUR THROUGH INHALATION OF AIRBORNE DUST SINCE ALL ALTERNATIVES (EXCEPT NO-ACTION) INVOLVE
EARTHWORK OPERATIONS. WITHOUT STRICT DUST CONTROL MEASURES, THIS EXPOSURE COULD AFFECT THE
PUBLIC AS WELL AS CONSTRUCTION WORKERS. DIRECT CONTACT AND INGESTION BY WORKERS IS ALSO A
POSSIBILITY.
THE REMOVAL ALTERNATIVE PRESENTS THE ADDITIONAL POSSIBILITY OF EXPOSURE DURING OFF-SITE
TRANSPORTATION. DEPENDING ON THE TRUCK CAPACITY AND THE TOTAL VOLUME OF CONTAMINATED SOIL
HAULED, THIS MAY INVOLVE UP TO 600 TRUCKLOADS, POSSIBLY INCLUDING UP TO 20 TRIPS PER DAY. HEALTH
AND SAFETY CONSIDERATIONS DURING CONSTRUCTION ARE NOT APPLICABLE TO THE NO-ACTION ALTERNATIVE.
THE CAPPING ALTERNATIVE REQUIRES THE LEAST AMOUNT OF EARTHWORK, HAS THE SHORTEST CONSTRUCTION
PERIOD, AND DOES NOT INVOLVE ANY OFF-SITE TRANSPORT OF CONTAMINATED MATERIALS. THEREFORE, IT IS
THE MOST FAVORABLE IN TERMS OF POTENTIAL EXPOSURE DURING CONSTRUCTION. THE ENCAPSULATION,
REMOVAL, AND TREATMENT ALTERNATIVES ALL REQUIRE ABOUT THE SAME AMOUNT OF EXCAVATION OF
CONTAMINATED MATERIAL, ALTHOUGH ENCAPSULATION MAY INVOLVE MORE HANDLING BECAUSE OF THE
STOCKPILING OF CONTAMINATED SOILS REQUIRED DURING THE CONSTRUCTION OF THE CELL LINER. THE
REMOVAL ALTERNATIVE INVOLVES OFF-SITE TRANSPORTATION OF HAZARDOUS MATERIALS, WHILE ENCAPSULATION
DOES NOT. THEREFORE, THE OVERALL POTENTIAL FOR EXPOSURE TO CONTAMINATED MATERIAL IS
APPROXIMATELY EQUAL FOR THE ALTERNATIVES, ALTHOUGH SOMEWHAT DIFFERENT IN TYPES.
TO HELP PREVENT POTENTIAL HEALTH RISKS, STRINGENT HEALTH AND SAFETY REQUIREMENTS WILL BE
IMPLEMENTED DURING ON-SITE WORK AND WHEN CONTAMINANTS ARE BEING HAULED OFF-SITE.
V.E.2. INSTITUTIONAL EVALUATION
THERE ARE THREE PRIMARY FACTORS IN THE INSTITUTIONAL EVALUATION: COMPLIANCE WITH APPLICABLE OR
RELEVANT FEDERAL ENVIRONMENTAL AND PUBLIC HEALTH STANDARDS, AGENCY COORDINATION, AND COMMUNITY
RELATIONS. THE FIRST FACTOR IS DISCUSSED IN DETAIL IN THE CONSISTENCY WITH OTHER ENVIRONMENTAL
LAWS SECTION, COMMUNITY RELATIONS ARE DISCUSSED IN THE ACCOMPANYING COMMUNITY RELATIONS
RESPONSIVENESS SUMMARY, AND AGENCY COORDINATION IS SUMMARIZED BELOW.
V.E.2.A. AGENCY COORDINATION: THE FOLLOWING AGENCIES HAVE BEEN KEPT INFORMED OR HAVE BEEN
COORDINATED WITH IN THE PAST, AND WE WILL CONTINUE TO SO FOR ALL FUTURE SITE ACTIVITIES:
HOOPA VALLEY INDIAN TRIBE
BIA
DOI
DOHS
RWQCB
U.S. ARMY CORPS OF ENGINEERS
CALIFORNIA DEPARTMENT OF FISH AND GAME
U.S. FISH AND WILDLIFE SERVICE.
THE HOOPA VALLEY INDIAN TRIBE, THE BIA, THE DOI, AND THE DOHS HAVE ALL EXPRESSED A STRONG
PREFERENCE FOR THE REMOVAL ALTERNATIVE.
V.E.3. PUBLIC HEALTH EVALUATION
AN EXTENSIVE PUBLIC HEALTH ASSESSMENT WAS CONDUCTED FOR THE FEASIBILITY STUDY. THE CURRENT SITE
STATUS SECTION OF THIS DOCUMENT DESCRIBES THE RESULTS OF THE ASSESSMENT WHILE THE EVALUATION AND
SELECTION OF SITE-SPECIFIC ACTION LEVELS NECESSARY TO PROTECT HUMAN HEALTH AND THE ENVIRONMENT
ARE DESCRIBED PREVIOUSLY IN THIS SECTION.
V.E.4. ENVIRONMENTAL EVALUATION
A DETAILED EVALUATION OF THE SHORT AND LONG-TERM ADVERSE AND BENEFICIAL EFFECTS OF THE RESPONSE
ON THE RESOURCES PEOPLE USE (AIR, WATER, LAND, ETC.) AND ON THE BIOLOGICAL ENVIRONMENT WERE
CONDUCTED IN THE FEASIBILITY STUDY. IT WAS DETERMINED THAT ALL OF THE ALTERNATIVES, EXCEPT
NO-ACTION, WOULD HAVE SIMILAR SHORT-TERM IMPACTS RELATED TO CONSTRUCTION ACTIVITIES. THESE
IMPACTS WOULD BE LIMITED TO THE CONSTRUCTION TIME AND WOULD INCLUDE ELIMINATION OF WILDLIFE
HABITATS OR PASSAGE WAYS, AND EXTREMELY LIMITED USE OF THE FISHING-ACCESS ROAD.
SURFACE WATER LEAVING THE SITE IS NOT CURRENTLY USED BY PEOPLE OR AQUATIC LIFE AND IS LIKELY TO
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REMAIN UNUSED DUE TO LOW AND INTERMITTENT FLOW. REMOVAL WILL IMPROVE SURFACE WATER QUALITY THE
GREATEST, SINCE NO CONTAMINANTS WILL REMAIN AT THE SITE. THE IMPROVEMENT IN SURFACE WATER
QUALITY WILL BE PERMANENT AND WITHOUT REGARD TO SITE OR MAINTENANCE CONDITIONS. ENCAPSULATION,
GIVEN PROPER CONSTRUCTION AND MAINTENANCE, SHOULD PROVIDE FOR THE NEXT GREATEST IMPROVEMENT IN
SURFACE WATER QUALITY, SINCE CONTAMINANTS SHOULD REMAIN COMPLETELY ISOLATED FROM SUBSURFACE
WATER WHICH COULD CARRY CONTAMINANTS UP TO THE SURFACE. CAPPING MAY IMPROVE SURFACE WATER
QUALITY TO THE SAME DEGREE AS ENCAPSULATION, BUT IT IS UNLIKELY, DUE TO THE INCREASED
POSSIBILITY OF SUBSURFACE WATER MIXING WITH THE CONTAMINANTS. NO-ACTION WILL NOT IMPROVE
SURFACE WATER QUALITY AND, UNLIKE THE OTHER ALTERNATIVES, WILL CONTINUE TO ALLOW OFF-SITE
MIGRATION OF WATER CONTAINING CONCENTRATIONS OF CONTAMINANTS WHICH ARE HAZARDOUS TO PUBLIC
HEALTH.
REMOVAL PROVIDES FOR THE MOST BENEFICIAL LONG-TERM USE OF THE LAND, AS THERE WOULD BE NO DEED
RESTRICTIONS AND THE LAND COULD BE USED FOR ANY FUTURE USES. ENCAPSULATION AND CAPPING WOULD
BOTH REQUIRE PERMANENT DEED RESTRICTIONS ON THE SITE, BUT WOULD ALLOW FOR SUCH LIMITED USES AS A
PARK OR WILDLIFE AREA. NO-ACTION WOULD REQUIRE A PERMANENT DEED RESTRICTION, PREVENTING ALMOST
ALL FUTURE ACTIVITIES.
IF THE NOXIOUS ODOR DESCRIBED IN CURRENT SITE STATUS IS COMING FROM THE SITE, REMOVAL WOULD BE
THE MOST EFFECTIVE IN ELIMINATING THE PROBLEM. ENCAPSULATION AND CAPPING MIGHT BE EFFECTIVE IN
REDUCING THE ODOR, AND NO-ACTION WOULD HAVE NO EFFECT ON THE ODOR.
GROUND WATER AND THE TRINITY RIVER CURRENTLY DO NOT APPEAR TO BE IMPACTED BY THE SITE, AND NONE
OF THE ALTERNATIVES ARE LIKELY TO HAVE ANY LONG-TERM EFFECTS ON EITHER RESOURCE.
V.E.5. COST EVALUATION
THE COSTS DEVELOPED FOR THIS EVALUATION ARE ORDER-OF-MAGNITUDE ESTIMATES WITH AN ACCURACY OF +50
AND -30 PERCENT. THESE ESTIMATES REFLECT JANUARY 1985 PRICE LEVELS AND INCLUDE THIRTY YEARS OF
OPERATION AND MAINTENANCE. THE COSTS ARE SHOWN IN PRESENT WORTH UTILIZING A 10 PERCENT DISCOUNT
RATE AS OUTLINED IN THE OFFICE OF MANAGEMENT AND BUDGET CIRCULAR NO. A-94.
ALTERNATIVE
TOTAL
COST
CAPITAL
O&M
NO-ACTION
CAPPING
REMOVAL
ENCAPSULATION
0
$
$ 921,705
$ 3,072,338
$ 1,201,837
0
$
$ 889,702
$ 3,065,338
$ 1,169,837
0
32,000
7, 000
32,000.
#CR
VI. COMMUNITY RELATIONS
THE PRIMARY INTERESTED PARTIES IN THIS SITE ARE THE HOOPA VALLEY INDIAN TRIBE, THE BIA, AND THE
DOI. BOTH THE HVBC AND THE BIA SUBMITTED WRITTEN COMMENTS ON THE DRAFT FEASIBILITY STUDY DURING
THE OFFICIAL COMMENT PERIOD WHICH RAN FROM JUNE 28, 1985 TO JULY 19, 1985. BOTH COMMENTORS
STATED A STRONG PREFERENCE FOR REMOVAL, WHICH IS CONSISTENT WITH WHAT BOTH AGENCIES HAVE BEEN
REQUESTING SINCE EPA FIRST BECAME INVOLVED IN THE SITE IN 1981. DURING THE PUBLIC MEETING TO
DISCUSS THE FEASIBILITY STUDY, WHICH WAS HELD ON JULY 11, 1985, AT THE HOOPA VALLEY BUSINESS
COUNCIL CHAMBERS, SOME OF THE COMMENTORS EXPRESSED OBJECTIONS WITH THE TREATMENT ALTERNATIVE AND
SOME EXPRESSED A PREFERENCE FOR THE REMOVAL ALTERNATIVE. ALL OF THE COMMENTS AND CONCERNS ARE
DISCUSSED IN THE ATTACHED COMMUNITY RELATIONS RESPONSIVENESS SUMMARY.
THE PUBLIC COMMENT PERIOD WAS EXTENDED UNTIL AUGUST 16, 1985, FOR THE DOI. THEY RECEIVED THE
EXTENSION BECAUSE OF THEIR STATUS AS A POTENTIAL RESPONSIBLE PARTY AND BECAUSE THEY DID NOT
RECEIVE A COPY OF THE DRAFT FEASIBILITY STUDY UNTIL JULY 23, 1985. DOI HAS NOT SUBMITTED
WRITTEN COMMENTS AS OF THE DATE OF THIS DOCUMENT, BUT WHEN SOLICITED OVER THE PHONE, DOI ALSO
PREFERRED THE REMOVAL ALTERNATIVE.
THE ONLY OTHER COMMENT RECEIVED ON THE REMEDIAL ACTION ALTERNATIVES WAS ON A PROPOSED
ALTERNATIVE THAT WAS NOT DEVELOPED. THE HVBC SUGGESTED THAT EPA CONSIDER PARTIAL TREATMENT
COMBINED WITH REMOVAL. BECAUSE TREATMENT WAS SHOWN TO BE INEFFECTIVE DURING BENCH SCALE STUDIES,
THE HVBC'S PROPOSED ALTERNATIVE WOULD BE A MORE EXPENSIVE VARIATION OF THE REMOVAL ALTERNATIVE
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WITH NO ADDITIONAL BENEFITS, SUCH AS REDUCED AMOUNTS OF HAZARDOUS MATERIAL REQUIRING OFF-SITE
DISPOSAL.
A FULL DISCUSSION OF ALL COMMUNITY RELATIONS ACTIVITIES, COMMUNITY CONCERNS, COMMENTS, AND THE
EPA RESPONSE TO THE COMMENTS IS INCLUDED IN THE ATTACHED COMMUNITY RELATIONS RESPONSIVENESS
SUMMARY.
#OEL
VII. CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
IT IS EPA POLICY TO GIVE PRIMARY CONSIDERATION TO REMEDIAL ACTIONS THAT ATTAIN OR EXCEED
APPLICABLE OR RELEVANT FEDERAL ENVIRONMENTAL OR PUBLIC HEALTH STANDARDS. STATE AND LOCAL
STANDARDS SHOULD ALSO BE CONSIDERED; HOWEVER, STATE STANDARDS THAT ARE MORE STRINGENT THAN
FEDERAL STANDARDS MAY FORM THE BASIS FOR THE REMEDY ONLY IF THE RESULT IS CONSISTENT WITH THE
COST-EFFECTIVE REMEDY BASED ON FEDERAL STANDARDS. THE STATE MAY ALSO PAY THE ADDITIONAL COST
NECESSARY TO ATTAIN THE STATE STANDARD(S). THE ENVIRONMENTAL OR PUBLIC HEALTH LAWS WHICH ARE
RELEVANT OR APPLICABLE TO THE CELTOR SITE ARE:
RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
FLOODPLAIN MANAGEMENT EXECUTIVE ORDER 11988 (E.0.11988)
CLEAN WATER ACT (CWA)
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) REQUIREMENTS
DEPARTMENT OF TRANSPORTATION (DOT) HAZARDOUS MATERIALS TRANSPORT RULES
GROUND WATER PROTECTION STRATEGY (GWPS).
VII.A. RCRA
RCRA SUBTITLE C, 40 C.F.R. PARTS 2 64 AND 2 65 CONTAIN CLOSURE REQUIREMENTS FOR LANDFILLS AND
SURFACE IMPOUNDMENTS THAT ARE RELEVANT TO THIS SITE. THIS LAW REQUIRES THAT ALL CONTAMINANTS BE
PREVENTED FROM MIGRATING OFF-SITE, AND IF OFF-SITE MIGRATION HAS OCCURRED, IT MUST BE CLEANED
UP. CONSOLIDATION OF ALL WASTES INTO THE PLANTSITE AREA AND SUBSEQUENT CAPPING OR ENCAPSULATION
OF THE WASTES WITH LONG TERM SURFACE AND GROUNDWATER MONITORING MAY MEET THESE REQUIREMENTS.
HOWEVER, SIGNIFICANT UNCERTAINTY EXISTS REGARDING THE ABILITY OF THE INTERCEPTOR TRENCHES AND
SUBSURFACE DRAINS TO DIVERT ALL SUBSURFACE WATER FROM ENTERING THE WASTE MANAGEMENT AREA. ALSO,
A HIGH LIKELIHOOD EXISTS FOR OFF-SITE MIGRATION OF CONTAMINANTS IN THE CAPPING SCENARIO IF
SUBSURFACE WATER ENTERS THE WASTE MANAGEMENT AREA. GIVEN THE SIGNIFICANT, YET UNPREDICTABLE
AMOUNT OF SUBSURFACE WATER FLOWS IN THE AREA, THE INTEGRITY OF THE ENCAPSULATION CELL MAY, OVER
TIME, BE COMPROMISED. OFF-SITE MIGRATION OF WASTES WOULD THEN BE JUST AS PROBABLE AS WITH THE
CAPPING ALTERNATIVE. THEREFORE, WHILE CAPPING AND ENCAPSULATION MAY, AT THE TIME OF
CONSTRUCTION, MEET THE REQUIREMENTS OF RCRA, THEY ARE UNLIKELY TO REMAIN IN COMPLIANCE.
REMOVAL ENSURES THAT ALL RCRA REQUIREMENTS WILL BE MET. ON JUNE 19, 1985 THE ACTING ASSISTANT
ADMINISTRATOR, THE OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE AND THE OFFICE OF GENERAL
COUNSEL AGREED TO A NEW INTERPRETATION OF THE LANDFILL AND SURFACE IMPOUNDMENT CLOSURE
REQUIREMENTS DESCRIBED IN 40 C.F.R. PART 264.111. "CLEAN CLOSURE" (I.E. NO NEED FOR LONG-TERM
MONITORING) NO LONGER REQUIRES REMOVAL OF ALL CONTAMINANTS TO BACKGROUND LEVELS. CLEAN CLOSURE
MAY NOW BE ACHIEVED BY REMOVING ALL CONTAMINANTS WHICH MAY POSE A THREAT TO HUMAN HEALTH OR THE
ENVIRONMENT OR WHICH MAY MIGRATE OFF-SITE. THE SITE-SPECIFIC ACTION LEVELS FOR THIS SITE WILL
PROTECT HUMAN HEALTH AND THE ENVIRONMENT AND ASSURE THAT REMOVAL WILL BE IN FULL COMPLIANCE WITH
THIS REQUIREMENT, HENCE, FULL COMPLIANCE WITH RCRA.
SINCE THE NO-ACTION ALTERNATIVE WOULD ALLOW CONTAMINANTS TO CONTINUE TO MIGRATE OFF-SITE IN
CONCENTRATIONS THAT POSE A HAZARD TO HUMAN HEALTH AND THE ENVIRONMENT, NO-ACTION IS NOT RCRA
COMPLIANT.
VII.B. E.O. 11988
BECAUSE PORTIONS OF THE SITE, THE PASTURE AND THE GULLY ARE PRESUMED TO LIE WITHIN THE 100-YEAR
FLOODPLAIN, E.O. 11988 REQUIRES THAT A FLOODPLAIN ASSESSMENT BE CONDUCTED. THE ASSESSMENT
REQUIRES CONSIDERATION OF ALL ENVIRONMENTAL EFFECTS, COMMUNITY WELFARE, COSTS, AND ALL POSSIBLE
ALTERNATIVES. THE ASSESSMENT CONCLUDED THAT THE BEST COURSE OF ACTION TO ENSURE PROTECTION OF
THE ENVIRONMENT, THE PREVENTION OF OFF-SITE CONTAMINANT MIGRATION, AND STABILIZATION AND
PRESERVATION OF THE FLOODPLAIN, WOULD BE TO REMOVE ALL CONTAMINANTS FROM THE FLOODPLAIN THEN
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REGRADE AND REVEGETATE THE AFFECTED AREAS TO NATURAL CONDITIONS. THIS WILL ENSURE THAT AREAS IN
THE FLOODPLAIN (THE GULLY) WILL BE AS RESISTANT TO THE DAMAGING EFFECTS OF FLOODS, WITHOUT THE
ADDED POSSIBILITY OF CONTAMINANTS MIGRATING OFF-SITE, AS IF NO CONSTRUCTION IN THE FLOODPLAIN
HAD EVER OCCURRED. THEREFORE, CAPPING, ENCAPSULATION, AND REMOVAL ALL MEET THE SUBSTANTIVE
REQUIREMENTS OF E.O. 11988. SINCE NO-ACTION DOES NOT PROTECT AGAINST THE RELEASE OF
CONTAMINANTS INTO THE ENVIRONMENT DURING A 100-YEAR FLOOD IT DOES NOT MEET THE SUBSTANTIVE
REQUIREMENTS OF E.O. 11988.
VI I.C. CWA
UNDER THE CWA, DISCHARGES FROM A FACILITY WHICH ENTER INTO A WATER BODY OF THE UNITED STATES
MUST MEET CALIFORNIA WATER QUALITY STANDARDS, BASED ON THE DESIGNATED USES OF THE RECEIVING
WATER. HOWEVER, BECAUSE THIS SITE IS ON INDIAN RESERVATION LAND, STATE ENVIRONMENTAL LAWS OR
REGULATIONS APPLY AS STATE LAW. THEY ARE, HOWEVER, INCORPORATED INTO THE FEDERAL LAW, THE CWA,
AND THUS APPLY.
DISCHARGES FROM THE GULLY ENTER THE SOUTH FORK OF THE TRINITY RIVER WITHIN THE KLAMATH RIVER
BASIN 1-A. THE STATE OF CALIFORNIA HAS NOT DESIGNATED ANY SPECIFIC DISCHARGE LIMITS FOR
INORGANIC CONTAMINANTS FOR THIS RIVER BASIN. HOWEVER, THERE DOES EXIST, UNDER CALIFORNIA WATER
QUALITY STANDARDS, A NON-DEGRADATION POLICY FOR ALL HIGH QUALITY WATERS IN THE STATE. WHILE IN
THEORY THIS MEANS THAT THE RWQCB REQUIRES ZERO DISCHARGE OF CONTAMINANTS FROM ANY SITE OR
FACILITY, IN PRACTICE THE RWQCB RECOGNIZES THAT ZERO DISCHARGE MAY BE IMPRACTICAL OR UNFEASIBLE.
DISCUSSIONS WITH THE RWQCB HAVE CONFIRMED THAT SHOULD UP AND DOWNSTREAM SAMPLING CONFIRM THAT
DISCHARGES FROM THE GULLY DO NOT IMPACT THE TRINITY, AN ACTION LEVEL MEETING THE DWRS FOR WATER
QUALITY IN THE GULLY WOULD BE ACCEPTABLE.
CAPPING, ENCAPSULATION, AND REMOVAL, WOULD ALL ENSURE THAT WATER QUALITY IN THE GULLY IS AT
LEAST EQUAL TO DWRS AND WOULD ALL COMPLY WITH THE CWA AND CALIFORNIA WATER QUALITY STANDARDS
BECAUSE DISCHARGES FROM THE SITE ARE NOT CURRENTLY IMPACTING THE TRINITY, NO-ACTION MAY ALSO
COMPLY WITH THESE REQUIREMENTS.
VI I.D. OSHA
ANY APPLICABLE OSHA REQUIREMENTS WILL BE ADDRESSED DURING THE DETAILED DESIGN PHASE OF THE
SELECTED ALTERNATIVE. OSHA REQUIREMENTS ADDRESS SUCH CONCERNS AS ON-SITE WORKER SAFETY AND
HEALTH. ALL ALTERNATIVES CAN BE DESIGNED TO BE IN FULL COMPLIANCE WITH ALL OSHA REQUIREMENTS.
VI I.E. DOT
DOT HAZARDOUS MATERIAL TRANSPORT RULES APPLY ONLY TO THE OFF-SITE TRANSPORTATION OF HAZARDOUS
MATERIALS. THE REMOVAL ALTERNATIVE CAN BE DESIGNED TO BE FULLY COMPLIANT WITH ALL DOT RULES AND
REGULATIONS.
VI I.F. GWPS
THE GWPS IS NOT A RELEVANT OR APPLICABLE STANDARD AT THIS TIME, BUT IS TO BE CONSIDERED DURING
REMEDIAL ALTERNATIVE SELECTION. THE GROUND WATER BENEATH THE SITE IS DESIGNATED AS A CLASS II
GROUND WATER UNDER THE GWPS SINCE IT HAS BEEN USED IN THE PAST AND COULD BE USED IN THE FUTURE
AS A DRINKING WATER SOURCE. FOR THESE WATERS, THE GWPS STATES THAT THE GOAL OF CERCLA CLEANUPS
WILL BE DRINKING WATER QUALITY OR RCRA APPROVED ALTERNATIVE CONCENTRATION LIMITS. CURRENTLY,
THE SITE IS NOT IMPACTING GROUND WATER, AND IMPLEMENTATION OF ANY ALTERNATIVE IS NOT EXPECTED TO
CAUSE AN IMPACT ON GROUND WATER. ALL ALTERNATIVES WOULD BE IN FULL COMPLIANCE WITH THE GWPS.
VII.G OTHER
AS MENTIONED ABOVE, STATE LAWS AND REGULATIONS DO NOT APPLY TO THIS SITE AS IT IS LOCATED
ENTIRELY ON INDIAN RESERVATION LAND. THERE ARE NO OTHER KNOWN APPLICABLE OR RELEVANT FEDERAL
LAWS OR REGULATIONS WHICH APPLY TO THIS SITE.
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#RA
VIII. RECOMMENDED ALTERNATIVE
SECTION 300.68(J) OF THE NCP STATES THAT "THE APPROPRIATE EXTENT OF REMEDY SHALL BE DETERMINED
BY THE LEAD AGENCY'S SELECTION OF THE REMEDIAL ALTERNATIVE WHICH THE AGENCY DETERMINES IS
COST-EFFECTIVE (I.E. THE LOWEST COST ALTERNATIVE THAT IS TECHNOLOGICALLY FEASIBLE AND RELIABLE
AND WHICH EFFECTIVELY MITIGATES AND MINIMIZES DAMAGE TO AND PROVIDES ADEQUATE PROTECTION OF
PUBLIC HEALTH, WELFARE, OR THE ENVIRONMENT)". BASED UPON THE REMEDIAL INVESTIGATION AND
FEASIBILITY STUDY, EPA REGION 9, THE STATE OF CALIFORNIA, THE HOOPA VALLEY INDIAN TRIBE, THE
BUREAU OF INDIAN AFFAIRS, AND THE DEPARTMENT OF THE INTERIOR AGREE THAT EXCAVATION AND OFF-SITE
REMOVAL OF ALL SOIL CONTAMINATED ABOVE SITE-SPECIFIC ACTION LEVELS IS THE MOST COST-EFFECTIVE
LONG-TERM REMEDIAL ACTION NECESSARY TO PROTECT HUMAN HEALTH AND THE ENVIRONMENT. THIS
ALTERNATIVE FULLY COMPLIES WITH ALL RELEVANT OR APPLICABLE LAWS AND REGULATIONS.
NO-ACTION WAS ELIMINATED AS A POTENTIAL ALTERNATIVE BECAUSE IT WOULD NOT PROTECT HUMAN HEALTH
AND THE ENVIRONMENT, BASED ON THE PUBLIC HEALTH ASSESSMENT CONDUCTED FOR THE FEASIBILITY STUDY.
CAPPING WAS ELIMINATED BECAUSE OF THE HIGH PROBABILITY OF SUBSURFACE WATER MIGRATION THROUGH THE
CONTAMINATED SOIL AND OFF-SITE MIGRATION OF CONTAMINANTS. THESE CONTAMINANTS COULD BE CARRIED TO
THE SURFACE VIA THE MANY SPRINGS IN THE AREA WHERE THEY WOULD POSE A HUMAN HEALTH THREAT.
ENCAPSULATION WAS ALSO ELIMINATED BECAUSE OF PROBABILITY THAT, OVER TIME, THE MANY SPRINGS IN
THE AREA COULD DAMAGE THE INTEGRITY OF THE ENCAPSULATION CELL, THEREBY PERMITTING CONTAMINANTS
TO MIGRATE TO THE SURFACE AND OFF-SITE.
CAPPING AND ENCAPSULATION HAVE THE ADDED DISADVANTAGE OF REQUIRING A PERMANENT DEED RESTRICTION
ON THE PROPERTY, SINCE THE INORGANIC CONTAMINANTS PRESENT AT THE SITE DO NOT DEGRADE WITH TIME.
IN ADDITION, THE ENTIRE CAP OR ENCAPSULATION CELL MAY REQUIRE COMPLETE REPLACEMENT EVERY 30
YEARS, THE PROJECTED LIFE OF THE TECHNOLOGY. FOR THESE REASONS, REMOVAL IS SELECTED AS THE ONLY
REMEDIAL ACTION WHICH IS COST-EFFECTIVE AND WILL ASSURE LONG-TERM PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT. TABLE 3 SUMMARIZES THE INFORMATION PRESENTED IN THIS DOCUMENT REGARDING THE
VARIOUS ALTERNATIVES.
#OM
IX. OPERATION AND MAINTENANCE
PROJECTED O&M FOR REMOVAL, AS FOR ALL OF THE ALTERNATIVES, IS AN INITIAL ONE YEAR PERIOD OF
GROUNDS MAINTENANCE. THIS WOULD INCLUDE CARING FOR SURFACE VEGETATION, DOING PREVENTATIVE WORK
ON ANY SURFACE WATER DRAINAGE SYSTEMS, AND TAKING CARE OF EROSION PROBLEMS TO ASSURE THAT
REVEGETATED AREAS BECOME PROPERLY ESTABLISHED. A FENCE WILL ALSO BE UTILIZED FOR THE FIRST YEAR
AFTER REMEDIAL ALTERNATIVE IMPLEMENTATION. THE FENCE WILL HELP TO ENSURE THAT THE VEGETATION IS
NOT DISTURBED WHILE BECOMING ESTABLISHED. THE TOTAL PRESENT WORTH OF THESE O&M ACTIVITIES IS
$7,000.
#SCH
X. SCHEDULE
APPROVE REMEDIAL ACTION (ROD)
START REMEDIAL DESIGN
COMPLETE REMEDIAL DESIGN
ENTER STATE SUPERFUND CONTRACT
START REMEDIAL CONSTRUCTION
COMPLETE REMEDIAL CONSTRUCTION
START DELISTING PROCESS
DELIST SITE FROM NPL
#FA
XI. FUTURE ACTIONS
ONCE A REMEDIAL ACTION IS SELECTED AND SUFFICIENT FUNDING IS AVAILABLE, EPA WILL ENTER INTO
INTERAGENCY AGREEMENTS WITH THE USACE FOR DESIGN AND CONSTRUCTION OF THE SELECTED ALTERNATIVE.
REMEDIAL DESIGN SHOULD TAKE APPROXIMATELY FOUR MONTHS AND SHOULD BE COMPLETED IN MARCH, 198 6.
CONSTRUCTION OF THE SELECTED ALTERNATIVE WILL TAKE APPROXIMATELY THREE MONTHS AND SHOULD BE
COMPLETED IN JULY, 198 6. WHEN CONSTRUCTION OF THE SELECTED ALTERNATIVE IS COMPLETED, THE
DELISTING PROCESS WILL BE COMMENCED. DELISTING OF THE SITE FROM THE NPL IS ANTICIPATED TO OCCUR
IN DECEMBER, 198 6.
SEPTEMBER 1985
NOVEMBER 1985
MARCH 1986
MARCH 1986
APRIL 1986
JULY 198 6
JULY 198 6
DECEMBER 1986.
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#TMA
TABIiES, MEMORANDA, ATTACHMENTS
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
DATE: SEPTEMBER 30, 1985
SUBJECT: RECORD OF DECISION FOR REMEDIAL ACTION AT
THE CELTOR CHEMICAL WORKS SUPERFUND SITE
FROM: HARRY SERAYDARIAN
DIRECTOR, TOXICS AND WASTE MANAGEMENT DIVISION
TO: JUDITH E. AYRES
REGIONAL ADMINISTRATOR
A RECORD OF DECISION TO SELECT A REMEDIAL ACTION FOR THE CELTOR CHEMICAL WORKS SITE IS ATTACHED
FOR YOUR SIGNATURE. ALSO ATTACHED ARE THE BRIEFING DOCUMENTS DESCRIBING THE SELECTION PROCESS
AND THE BASIS FOR OUR DETERMINATION THAT EXCAVATION AND OFF-SITE DISPOSAL IS THE MOST
COST-EFFECTIVE REMEDIAL ACTION FOR THE SITE.
AS YOU KNOW, EPA HEADQUARTERS HAS BEEN DELEGATING THE AUTHORITY TO SIGN CERTAIN RECORDS OF
DECISION FOR REMEDIAL ACTIONS FROM THE ASSISTANT ADMINISTRATOR FOR SOLID WASTE AND
EMERGENCY RESPONSE TO THE REGIONAL ADMINISTRATOR. THE AUTHORITY TO SIGN THIS RECORD OF DECISION
WAS DELEGATED TO YOU ON JUNE 17, 1985 IN THE THIRD REMEDY DELEGATION REPORT.
THE RECORD OF DECISION FOR THE CELTOR CHEMICAL WORKS SITE IS A FOURTH QUARTER, FY-85, SPMS
COMMITMENT FOR REGION 9. HOWEVER, DUE TO THE CURRENT SUPERFUND SLOWDOWN INITIATED BY
HEADQUARTERS IN AUGUST, 1985, FUNDING FOR THE REMEDIAL DESIGN HAS BEEN WITHDRAWN PENDING CERCLA
REAUTHORIZATION.
UPON YOUR SIGNATURE, AND PENDING AVAILABLE FUNDING, THE U.S. ARMY CORPS OF ENGINEERS WILL BE
GIVEN AUTHORIZATION TO BEGIN DESIGN OF THE SELECTED REMEDY. PROVIDED WE OBTAIN FUNDING IN
OCTOBER, 1985, WE EXPECT CONSTRUCTION TO BEGIN IN APRIL, 1986 AND TO BE COMPLETED BY JULY, 1986,
AT WHICH TIME THE SITE WILL BE ELIGIBLE FOR DELISTING FROM THE NATIONAL PRIORITIES LIST.
BASED ON THE REMEDIAL INVESTIGATION REPORT, THE FEASIBILITY STUDY REPORT, AND THE ATTACHED
BRIEFING DOCUMENTS, I REQUEST THAT YOU SIGN THE RECORD OF DECISION SELECTING EXCAVATION AND
OFF-SITE DISPOSAL AS THE COST-EFFECTIVE REMEDIAL ACTION FOR THE CELTOR CHEMICAL WORKS SITE. WE
HAVE COORDINATED THIS RECORD OF DECISION PACKAGE WITH EPA HEADQUARTERS AND THE STATE OF
CALIFORNIA AND WE HAVE RECEIVED CONCURRENCE FROM REGION 9'S OFFICE OF REGIONAL COUNSEL, WATER
MANAGEMENT DIVISION, AND AIR MANAGEMENT DIVISION. I AM AVAILABLE TO DISCUSS THIS MATTER IN
MORE DETAIL IF YOU HAVE ANY QUESTIONS CONCERNING THE ATTACHED RECORD OF DECISION PACKAGE.
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ATTACHMENT.
GLOSSARY
BIA - UNITED STATES BUREAU OF INDIAN AFFAIRS
CAM - CALIFORNIA ASSESSMENT MANUAL
CDC - UNITED STATES CENTERS FOR DISEASE CONTROL
CERCLA - COMPREHENSIVE ENVIRONMENTAL RESPONSE CONSERVATION AND
LIABILITY ACT OF 1980 ("THE SUPERFUND")
C.F.R - CODE OF FEDERAL REGULATIONS
CWA - CLEAN WATER ACT, AS AMENDED IN 1977
DOI - UNITED STATES DEPARTMENT OF INTERIOR
DOHS - STATE OF CALIFORNIA DEPARTMENT OF HEALTH SERVICE
DOT - UNITED STATES DEPARTMENT OF TRANSPORTATION
DWRS - PRIMARY OR SECONDARY DRINKING WATER REGULATIONS (OR MCLS) OF THE SDWA
GWPS - EPA GROUND WATER PROTECTION STRATEGY
HVBC - HOOPA VALLEY BUSINESS COUNCIL
IHS - UNITED STATES INDIAN HEALTH SERVICE
IRM - INITIAL REMEDIAL MEASURE
MCLS - MAXIMUM CONTAMINANT LEVELS (OR DWRS) OF THE SDWA
MG/KG - MILLIGRAMS PER KILOGRAM (OR PPM)
NCP - NATIONAL OIL AND HAZARDOUS SUBSTANCES CONTINGENCY PLAN
NPL - NATIONAL PRIORITIES LIST
O&M - OPERATIONS AND MAINTENANCE
OSHA - UNITED STATES OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION
PPB - PARTS PER BILLION (OR UG/L)
PPM - PARTS PER MILLION (OR MG/KG)
RCRA - RESOURCE CONSERVATION AND RECOVERY ACT, AS AMENDED IN 1984
ROD - RECORD OF DECISION
RWQCB - STATE OF CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
SDWA - SAFE DRINKING WATER ACT, AS AMENDED IN 1977
TTLC - CAM TOTAL THRESHOLD LIMIT CONCENTRATION
UG/L - MICROGRAMS PER LITER (OR PPB)
USACE - UNITED STATES ARMY CORPS OF ENGINEERS
WQCAL - EPA ONE HOUR NATIONAL AMBIENT WATER QUALITY CRITERIA FOR PROTECTION OF FRESHWATER
AQUATIC LIFE, AS PROMULGATED UNDER THE CWA
WQCHH - EPA NATIONAL AMBIENT WATER QUALITY CRITERIA FOR PROTECTION OF HUMAN HEALTH, AS
PROMULGATED UNDER THE CWA.
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#RS
COMMUNITY RELATIONS
RESPONSIVENESS SUMMARY
CELTOR CHEMICAL WORKS SITE
HOOPA, CALIFORNIA
SEPTEMBER 1985
INTRODUCTION
THE PURPOSE OF THIS RESPONSIVENESS SUMMARY IS TO DOCUMENT THE FOLLOWING ITEMS FOR THE PUBLIC
RECORD: (1) THE CONCERNS AND ISSUES RAISED BY PRIVATE CITIZENS AND GOVERNMENTAL AGENCIES DURING
THE REMEDIAL PLANNING PROCESS, (2) COMMENTS AND QUESTIONS RAISED DURING THE PUBLIC COMMENT
PERIOD ON THE FEASIBILITY STUDY, AND (3) THE RESPONSE OF EPA TO THESE COMMENTS AND CONCERNS.
COMMUNITY RELATIONS ACTIVITIES
THE COMMUNITY RELATIONS ACTIVITIES THAT WERE UNDERTAKEN TO INFORM INTERESTED PARTIES AND SOLICIT
THEIR COMMENTS THROUGHOUT THE REMEDIAL INVESTIGATION (RI) AND FEASIBILITY STUDY (FS) ARE
SUMMARIZED BELOW.
THE PRIMARY INTERESTED PARTY HAS BEEN THE HOOPA VALLEY BUSINESS COUNCIL, WHICH REPRESENTS THE
HOOPA VALLEY INDIAN TRIBE. THE COUNCIL HAS HAD ONGOING COMMUNICATIONS WITH THE INVOLVED
GOVERNMENT AGENCIES SINCE THE SITE WAS FIRST IDENTIFIED IN 1981. THESE AGENCIES INCLUDE THE
INDIAN HEALTH SERVICE (IHS), HUMBOLDT-DEL NORTE COUNTY HEALTH DEPARTMENT, CALIFORNIA DEPARTMENT
OF HEALTH SERVICES (DOHS), AND EPA. IN ADDITION TO THE MEETINGS LISTED BELOW, THE HOOPA VALLEY
BUSINESS COUNCIL HAS BEEN IN CONTACT WITH DOHS, EPA, AND EPA'S CONTRACTOR BY TELEPHONE AND
LETTER.
APRIL 1, 1982: DOHS NOTIFIED HOOPA VALLEY BUSINESS COUNCIL THAT THE CELTOR SITE WAS
A CANDIDATE STATE SUPERFUND SITE.
JULY 6, 1982: EPA MET WITH HOOPA VALLEY BUSINESS COUNCIL STAFF TO DISCUSS THE
STATUS OF SEVERAL HAZARDOUS WASTE DISPOSAL SITES ON THE INDIAN RESERVATION.
APRIL-SEPTEMBER 1982: NUMEROUS MEETINGS WERE HELD AMONG HOOPA VALLEY BUSINESS
COUNCIL STAFF, DOHS, AND EPA TO DISCUSS APPLICABILITY OF THE FEDERAL SUPERFUND TO
INDIAN LANDS.
SEPTEMBER 1982: DOHS NOTIFIED HOOPA VALLEY BUSINESS COUNCIL THAT THE SITE WAS BEING
CONSIDERED FOR THE FEDERAL SUPERFUND LIST.
NOVEMBER 3, 1982: DOHS AND EPA MET WITH THE HOOPA VALLEY BUSINESS COUNCIL TO
PROPOSE A JOINT FEDERAL AND STATE ENFORCEMENT APPROACH TO GET A VOLUNTARY
RESPONSIBLE PARTY CLEANUP AT THE SITE. IHS AND THE NORTH COAST REGIONAL WATER
QUALITY CONTROL BOARD ALSO ATTENDED THE MEETING.
APRIL 28, 1983: EPA, DOHS, IHS, AND HUMBOLDT-DEL NORTE COUNTY HEALTH DEPARTMENT
ATTENDED A MEETING WITH THE HOOPA VALLEY BUSINESS COUNCIL TO DISCUSS POSSIBLE SITE
RESPONSE ALTERNATIVES.
JUNE 1983: A MEETING WAS HELD AMONG EPA, DOHS, AND THE HOOPA VALLEY BUSINESS
COUNCIL TO DISCUSS THE INITIAL REMEDIAL MEASURE (IRM) FEASIBILITY STUDY.
JUNE 1983: INTERVIEWS WERE CONDUCTED WITH INVOLVED AGENCIES AND REPRESENTATIVES OF
THE HOOPA VALLEY BUSINESS COUNCIL. THE PURPOSE OF THE INTERVIEWS WAS TO IDENTIFY
CONCERNS AND INFORMATION NEEDS FOR USE IN DESIGNING THE COMMUNITY RELATIONS PLAN.
AUGUST 1983: EPA HELD A PUBLIC MEETING TO DISCUSS THE IRM FEASIBILITY STUDY; ISSUED
A PRESS RELEASE; SENT A SUMMARY OF THE IRM FEASIBILITY STUDY AND A MEETING
NOTIFICATION TO THE PROJECT MAILING LIST; AND ESTABLISHED INFORMATION REPOSITORIES
WHERE THE IRM FEASIBILITY STUDY REPORT AND FUTURE DOCUMENTS COULD BE REVIEWED.
APPROXIMATELY 17 PEOPLE ATTENDED THE PUBLIC MEETING.
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NOVEMBER 1983: EPA ISSUED A PRESS RELEASE ANNOUNCING APPROVAL OF THE IRM.
DECEMBER 1983: TRIBAL REPRESENTATIVES REVIEWED THE COMPLETED ONSITE IRM WORK.
SEPTEMBER 1984: EPA MET WITH HOOPA VALLEY BUSINESS COUNCIL STAFF TO DISCUSS THE
PROPOSED RI/FS WORKPLAN AND COMMUNITY RELATIONS ACTIVITIES. REPRESENTATIVES FROM
THE BUREAU OF INDIAN AFFAIRS (IN HOOPA) AND THE HUMBOLDT-DEL NORTE COUNTY HEALTH
DEPARTMENT ALSO ATTENDED THE MEETING.
NOVEMBER 1984: EPA SENT A FACT SHEET TO THE PROJECT MAILING LIST TO PRESENT THE
CONTENT AND SCHEDULE OF THE RI/FS. THE RI/FS WORK PLAN WAS MADE AVAILABLE FOR
REVIEW AT THE INFORMATION REPOSITORIES.
NOVEMBER 1984: COMMUNITY RELATIONS STAFF CONDUCTED FOLLOWUP INTERVIEWS FOR USE IN
UPDATING THE COMMUNITY RELATIONS PLAN. HOOPA VALLEY BUSINESS COUNCIL STAFF REVIEWED
THE DRAFT PLAN BEFORE IT WAS MADE FINAL.
MAY 1985: EPA MET WITH THE HOOPA VALLEY BUSINESS COUNCIL CHAIRPERSON AND STAFF TO
DISCUSS THE REMEDIAL INVESTIGATION REPORT (APRIL 1985) AND DISCUSS PRELIMINARY
ALTERNATIVES TO BE CONSIDERED IN THE FEASIBILITY STUDY.
JUNE 1985: EPA SENT A FACT SHEET TO THE PROJECT MAILING LIST TO SUMMARIZE THE
FINDINGS OF THE RI, PRESENT THE FINAL ALTERNATIVES INCLUDED IN THE FS, AND ANNOUNCE
THE FS PUBLIC COMMENT PERIOD AND PUBLIC MEETING. A NOTICE OF THE FS COMMENT PERIOD
AND MEETING WAS PLACED IN THE EUREKA TIMES AND THE KLAMATH COURIER.
JUNE 28-JULY 19, 1985: THE PUBLIC COMMENT PERIOD FOR THE FEASIBILITY STUDY WAS
HELD. A PUBLIC MEETING TO DISCUSS THE FS WAS HELD ON JULY 11, 1985.
CONCERNS RAISED PRIOR TO THE FEASIBILITY STUDY COMMENT PERIOD
A NUMBER OF COMMON ISSUES AND CONCERNS WERE RAISED PRIOR TO THE FEASIBILITY STUDY COMMENT PERIOD
BY THE HOOPA VALLEY BUSINESS COUNCIL, THE IHS, AND THE HUMBOLDT-DEL NORTE COUNTY HEALTH
DEPARTMENT. THESE ARE SUMMARIZED BELOW, FOLLOWED BY THE EPA RESPONSE.
1) HEALTH EFFECTS FROM DIRECT HUMAN EXPOSURE TO CONTAMINANTS: CONCERN WAS RAISED ABOUT OPEN
ACCESS TO THE SITE. CHILDREN AND MOTOR BIKERS WERE USING THE SITE, AND SOME PEOPLE WERE USING
IT AS A WASTE DUMP. IN ADDITION, THE ACCESS ROAD WAS COMMONLY USED TO REACH A FISHING SPOT ON
THE TRINITY RIVER.
RESPONSE: DIRECT EXPOSURE TO CONTAMINATED SOIL IN THE ROAD AND PASTURE AREA WAS REDUCED BY
IMPLEMENTATION OF THE INITIAL REMEDIAL MEASURE (IRM). THE MAIN PLANT AREA HAS BEEN FENCED AND
POSTED TO LIMIT ACCESS TO REMAINING CONTAMINATED SOILS. IMPLEMENTATION OF THE REMEDIAL ACTION
WILL FURTHER REDUCE POSSIBLE EXPOSURE TO CONTAMINATION.
2) IMPACT ON NEARBY AREAS: CONCERNS ABOUT POSSIBLE IMPACTS OF THE SITE ON NEARBY AREAS HAVE
INCLUDED:
CONTAMINATED DUST BLOWING FROM THE SITE AND THE ACCESS ROAD ONTO AN ADJACENT HUD
HOUSING DEVELOPMENT KNOWN AS NORTON FIELD.
RESPONSE: SEE RESPONSE NO. 7 UNDER CONCERNS RAISED DURING THE FEASIBILITY STUDY COMMENT PERIOD.
IMPACTS ON GRAZING CATTLE IN AN ADJACENT FIELD FROM CONTAMINATED SOIL, POSSIBLE
OFFSITE MIGRATION OF CONTAMINATED SURFACE WATER, AND INGESTION OF POTENTIALLY
CONTAMINATED GRASSES.
RESPONSE: SEE RESPONSE NO. 12 UNDER CONCERNS RAISED DURING THE FEASIBILITY STUDY COMMENT
PERIOD.
USE OF CONTAMINATED SOIL FROM THE CELTOR SITE AS FILL ON HUD HOUSING DEVELOPMENTS.
RESPONSE:
SEE RESPONSE NO. 8 UNDER CONCERNS RAISED DURING THE FEASIBILITY STUDY COMMENT PERIOD.
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3) IMPACTS ON DRINKING WATER: CONCERN WAS EXPRESSED THAT CONTAMINANTS FROM THE SITE MIGHT BE
ENTERING AREA GROUNDWATER AND CONTAMINATING LOCAL WELLS.
RESPONSE: THE HOOPA PUBLIC WATER SYSTEM IS UPGRADIENT OF THE SITE. NO PRIVATE WELLS ARE LOCATED
DOWNGRADIENT. FURTHERMORE, BASED ON THE FINDINGS OF THE REMEDIAL INVESTIGATION, LOCAL
GROUNDWATER IS NOT CONTAMINATED.
4) IMPACTS ON THE TRINITY RIVER: THERE WAS CONCERN THAT CONTAMINATED SURFACE WATER RUNOFF OR
GROUNDWATER COULD REACH THE TRINITY RIVER. THIS WAS OF PARTICULAR CONCERN TO THE HOOPA TRIBE
BECAUSE THE RIVER IS THE TRIBE'S ONLY FISH RESOURCE.
RESPONSE: THE PRIMARY GROUNDWATER RESOURCE IN THE AREA IS A GRAVEL
AQUIFER THAT LIES BETWEEN 20 AND 60 FEET BELOW THE GROUND SURFACE OF THE SITE TESTING DURING THE
REMEDIAL INVESTIGATION SHOWED THAT THE GRAVEL AQUIFER IS FREE FROM CONTAMINATION. THUS,
CONTAMINATION DOES NOT APPEAR TO BE ENTERING THE TRINITY RIVER VIA GROUNDWATER.
RESULTS OF THE REMEDIAL INVESTIGATION INDICATE THAT CONTAMINATED SURFACE WATER IS LEAVING THE
SITE AND ENTERING THE TRINITY RIVER. HOWEVER, THE DILUTION FACTOR IS SO HIGH — ANYWHERE FROM A
RATIO OF 500:1 (PARTS RIVER WATER: PART GULLY WATER) TO A RATIO OF 5,000:1 — THAT CONTAMINANTS
ARE DILUTED BELOW DETECTABLE CONCENTRATIONS AND APPEAR TO HAVE NO IMPACT ON THE RIVER'S WATER
QUALITY. EVEN IN A "WORST CASE" SCENARIO (WHERE RIVER DILUTION WAS AT ITS LOWEST EXTREME AND A
"FIRST FLUSH" OF THE GULLY BY A LOCALIZED STORM CAUSED A CONCENTRATED CONTAMINANT DISCHARGE INTO
THE RIVER), RIVER WATER QUALITY WOULD BE UNLIKELY TO EXCEED EPA 24-HOUR NATIONAL AMBIENT WATER
QUALITY CRITERIA FOR PROTECTION OF FRESHWATER AQUATIC LIFE.
5) LOCATION OF THE SITE IN THE FLOODPLAIN: CONCERN WAS EXPRESSED THAT THE SITE IS LOCATED IN
THE FLOODPLAIN OF THE TRINITY RIVER. IF FLOODING OCCURRED DURING THE RAINY SEASON, CONTAMINANTS
COULD BE CARRIED INTO THE RIVER AND DOWNSTREAM AREAS.
RESPONSE: IT WAS DETERMINED DURING THE FEASIBILITY STUDY THAT THE MAIN PLANT SITE AREA IS ABOVE
THE 100YEAR FLOODPLAIN. A MINOR PORTION OF THE SITE (THE PASTURE AND LOWER GULLY AREA) IS
LOCATED WITHIN THE 100-YEAR FLOODPLAIN. THE REMEDIAL ACTION FOR THE SITE WILL ADDRESS THIS
CONCERN BY REDUCING ALL SOURCES OF CONTAMINATION WITHIN THE 100-YEAR FLOODPLAIN. FOR FURTHER
DISCUSSION OF THIS ISSUE, SEE THE SECTION TITLED "SUMMARY OF REMEDIAL ALTERNATIVE SELECTION:
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS" IN THE RECORD OF DECISION (SEPTEMBER 1985).
6) ONSITE VERSUS OFFSITE REMEDIAL ACTIONS: DURING THE IRM FEASIBILITY STUDY, HOOPA VALLEY
BUSINESS COUNCIL REPRESENTATIVES INDICATED A GENERAL TRIBAL PREFERENCE FOR OFFSITE DISPOSAL
RATHER THAN ENCAPSULATION OR DISPOSAL ON RESERVATION LANDS. THE HOOPA VALLEY BUSINESS COUNCIL
ALSO STATED ITS PREFERENCE FOR OFFSITE DISPOSAL AS THE PERMANENT REMEDIAL ACTION.
RESPONSE: EXCAVATION AND OFFSITE DISPOSAL OF CONTAMINATED SOILS WAS IMPLEMENTED AS THE IRM, AND
IS ALSO THE RECOMMENDED FINAL REMEDIAL ACTION.
7) ADDITIONAL SAMPLING AND TESTING: THE HOOPA VALLEY BUSINESS COUNCIL REQUESTED IN FEBRUARY
1984 THAT EPA INCLUDE SPECIFIED SAMPLING LOCATIONS IN THE POST-IRM SITE TESTING. THE COUNCIL
HAS ALSO REQUESTED THAT TESTING BE PERFORMED TO IDENTIFY THE WHITE PRECIPITATE THAT HAS FORMED
IN SOME LOCATIONS FOLLOWING THE IRM AND TO DETERMINE THE COMPOSITION OF ODORS THAT ARE SOMETIMES
PRESENT AT THE SITE.
RESPONSE: IN RESPONSE TO THE FEBRUARY 1984 REQUEST, ADDITIONAL SAMPLING LOCATIONS WERE INCLUDED
IN THE REMEDIAL INVESTIGATION.
TESTING HAS BEEN CONDUCTED TO DETERMINE THE COMPOSITION OF THE PRECIPITATE AND OF SITE ODORS.
(SEE RESPONSE NUMBERS 5 AND 6 UNDER CONCERNS RAISED DURING THE FEASIBILITY STUDY COMMENT
PERIOD).
8) EMPLOYMENT OPPORTUNITIES FOR TRIBAL MEMBERS: THE HOOPA VALLEY BUSINESS COUNCIL WAS
CONCERNED THAT EMPLOYMENT OPPORTUNITIES BE PROVIDED FOR TRIBAL MEMBERS WHERE POSSIBLE DURING
ONSITE WORK. IF EMPLOYMENT RESTRICTIONS EXIST, THE REASONS SHOULD BE PROVIDED.
RESPONSE: BECAUSE OF SUPERFUND PROGRAM REQUIREMENTS, ONLY SUBCONTRACTORS WHO HAVE COMPLETED AN
EXTENSIVE HEALTH AND SAFETY TRAINING PROGRAM CAN WORK ONSITE WHERE CONTAMINATION IS PRESENT.
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FOR THIS REASON, JOBS SUCH AS DRILLING CANNOT BE SUBCONTRACTED TO THE TRIBE. HOWEVER, THE
SECURITY WORK DURING THE ONSITE REMEDIAL INVESTIGATION WORK WAS SUBCONTRACTED TO THE TRIBE, AND
WILL ALSO BE SUBCONTRACTED TO THE TRIBE DURING IMPLEMENTATION OF THE REMEDIAL ACTION.
AN EXPLANATION OF EMPLOYMENT RESTRICTIONS BECAUSE OF HEALTH AND SAFETY REQUIREMENTS WAS INCLUDED
IN THE NOVEMBER 1984 FACT SHEET DISTRIBUTED TO THE PROJECT MAILING LIST.
CONCERNS RAISED DURING THE FEASIBILITY STUDY COMMENT PERIOD
THE PUBLIC COMMENT PERIOD ON THE DRAFT FEASIBILITY STUDY REPORT BEGAN JUNE 28, 1985, AND ENDED
JULY 19, 1985. A PUBLIC MEETING WAS HELD ON JULY 11, 1985, AND WAS ATTENDED BY TEN PERSONS.
NINE INDIVIDUALS OR AGENCIES SUBMITTED COMMENTS OR QUESTIONS AT THE PUBLIC MEETING OR IN
WRITING. A LIST OF THOSE WHO COMMENTED IS ATTACHED.
THE COMMENTS AND QUESTIONS ARE SUMMARIZED BELOW BY SUBJECT AND ARE FOLLOWED BY THE RESPONSE FROM
EPA.
COMMENTS CONCERNING THE CLEANUP CRITERIA
1) COMMENT/QUESTION: THE HOOPA VALLEY BUSINESS COUNCIL SUBMITTED THE FOLLOWING COMMENTS
CONCERNING THE CLEANUP CRITERIA FOR THE SITE:
"THE CLEANUP CRITERIA ESTABLISHED FOR CADMIUM AND ARSENIC SOIL CONCENTRATIONS ARE BASED ON
INFORMATION FROM THE CENTERS FOR DISEASE CONTROL AND OTHER SUPERFUND SITES. THE EFFECTS OF
LONG-TERM, LOW-LEVEL EXPOSURE ON HUMANS OF SUCH CARCINOGENS HAVE NOT BEEN SUFFICIENTLY
DETERMINED. TO INSURE ADEQUATE PROTECTION, CLEANUP LEVELS FOR THESE SUBSTANCES SHOULD BE SET AT
BACKGROUND LEVELS.
"THE FEASIBILITY STUDY REPORT INDICATES THAT ADEQUATE PROTECTION OF THE ENVIRONMENT WILL BE
ACHIEVED IN PART BY INSURING THAT SURFACE WATER DISCHARGES DO NOT EXCEED THE FEDERAL DRINKING
WATER STANDARDS. THE DRAINAGE LEAVING THE PLANT AREA MAY SUPPORT AMPHIBIANS AND OTHER
FRESHWATER LIFE IF RESTORED TO ITS ORIGINAL CONDITION. WATER QUALITY CRITERIA FOR AQUATIC LIFE
SHOULD THEREFORE BE USED AS A STANDARD WHEN STRICTER THAN THE DRINKING WATER STANDARD.".
RESPONSE: THE CLEANUP CRITERION FOR IN-SOIL ARSENIC (100 PPM) IS BASED ON STUDIES CONDUCTED BY
THE CENTERS FOR DISEASE CONTROL EVALUATING THE LONG-TERM EFFECTS OF ARSENIC EXPOSURE IN A
RESIDENTIAL AREA, AND ON THE EPA PRIMARY DRINKING WATER REGULATIONS. THE CRITERION FOR IN-SOIL
CADMIUM (25 PPM) WAS EXTRAPOLATED FROM THE EPA PRIMARY DRINKING WATER REGULATIONS AND WAS BASED
ON CLEANUP LEVELS AT OTHER SUPERFUND SITES. THESE CRITERIA ARE CONSERVATIVE, BASED ON AN
INGESTION RATE OF UP TO 10 GRAMS OF SOIL PER DAY FOR CHILDREN AND UP TO 0.1 GRAM PER DAY FOR
ADULTS OVER A PERIOD OF 70 YEARS. THE CLEANUP CRITERIA FOR ALL CONTAMINANTS FOUND AT THE SITE
ARE EQUIVALENT TO OR STRICTER THAN THE CALIFORNIA ASSESSMENT MANUAL (CAM) STANDARDS, AND ARE
CONSISTENT WITH CLEANUP LEVELS USED AT OTHER SUPERFUND SITES. EPA CONSIDERS CLEANUP OF THE
CELTOR SITE TO THESE CRITERIA TO BE SUFFICIENT FOR THE PROTECTION OF PUBLIC HEALTH AND THE
ENVIRONMENT.
WATER FLOW IN THE DRAINAGE CHANNEL LEAVING THE SITE IS SPORADIC AND PROBABLY CANNOT SUPPORT FISH
OR OTHER AQUATIC LIFE. THERE ARE NO EXISTING GUIDELINES SPECIFYING THE ALLOWABLE METAL INTAKE
LEVELS FOR OTHER ANIMALS THAT MAY DRINK THE WATER. REMOVAL OF THE CONTAMINATED SOIL WILL REDUCE
THE SOURCE OF METALS TO ESTABLISHED CLEANUP LEVELS, AND THE RUNOFF WATER QUALITY WILL BE
SUBSTANTIALLY IMPROVED, PROBABLY APPROACHING THE PRE-MINING WATER QUALITY.
2) COMMENT/QUESTION: ONE PERSON ASKED IF THE SITE COULD BE USED FOR RECREATIONAL OR OTHER
ACTIVITIES AFTER CLEANUP TO THE ACTION LEVELS.
RESPONSE: WITH TREATMENT OR REMOVAL TO THE ACTION LEVELS, THE SITE WOULD BE SAFE FOR ALL USES,
INCLUDING RESIDENTIAL. WITH ENCAPSULATION, FUTURE USES OF THE LAND WOULD BE RESTRICTED. FOR
EXAMPLE, IT WOULD NOT BE POSSIBLE TO BUILD STRUCTURES THAT REQUIRE FOUNDATION WORK OR ANY OTHER
SUBSURFACE DISTURBANCE. HOWEVER, THE SITE WOULD BE COVERED WITH CLEAN SOIL AND REGRASSED, AND
RECREATIONAL USES WOULD BE POSSIBLE.
COMMENTS CONCERNING THE REMEDIAL ALTERNATIVES
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3) COMMENT/QUESTION: THREE COMMENTS CONCERNED THE PREFERRED REMEDIAL ACTION.
A HOOPA RESIDENT EXPRESSED CONCERN THAT THE TREATMENT ALTERNATIVE HAS NOT BEEN SUFFICIENTLY
TESTED. THE SITE AREA PROVIDES THE ONLY ACCESS TO THE RIVER AND HAS THE POTENTIAL FOR HIGH
RECREATIONAL USE. HE BELIEVES THAT PEOPLE WILL HAVE DOUBTS ABOUT THE AREA'S SAFETY IF TREATED
SOIL IS REDISPOSED ONSITE; THIS PSYCHOLOGICAL FACTOR IS IMPORTANT TO CONSIDER.
THE BUREAU OF INDIAN AFFAIRS, SACRAMENTO AREA OFFICE, SUBMITTED A WRITTEN COMMENT SUPPORTING THE
REMOVAL ALTERNATIVE.
THE HOOPA VALLEY BUSINESS COUNCIL SUBMITTED THE FOLLOWING COMMENTS, INCLUDING A PROPOSED
ALTERNATIVE THAT WAS NOT INCLUDED IN THE FEASIBILITY STUDY REPORT:
"WHILE THE TREATMENT ALTERNATIVE WILL REDUCE THE THREAT TO HUMAN HEALTH AND THE ENVIRONMENT AND
REDUCE THE VOLUME OF MATERIAL SENT TO A CLASS I LANDFILL, THE EXPERIMENTAL NATURE OF THE PROCESS
AND THE PRESENCE OF RESIDUAL CONTAMINANTS IN TREATED SOIL MAKE THE ALTERNATIVE LESS DESIRABLE
THAN REMOVAL. THIS PROCESS HAS BEEN UTILIZED AT ONLY TWO OTHER SITES AND CELTOR IS NOT
CONSIDERED AN APPROPRIATE LOCATION FOR FURTHER DEVELOPMENT OF THE METHOD. IN ADDITION, AS WITH
ANY SUCH PROCESS, SOME CONTAMINANTS AND EXTRACTION MATERIAL RESIDUES WILL REMAIN IN THE TREATED
SOIL THAT WOULD BE RETURNED TO THE SITE.
"THE REMOVAL ALTERNATIVE WILL INVOLVE REPLACEMENT OF CONTAMINATED MATERIAL WITH CLEAN SOIL
CONTAINING ONLY BACKGROUND LEVELS OF HEAVY METALS AND NO BY-PRODUCTS OF THE TREATMENT PROCESS.
THERE ARE NO UNCERTAINTIES INVOLVED WITH THE REMOVAL ALTERNATIVE SUCH AS UNFORESEEN PROBLEMS
WHICH COULD OCCUR WITH THE STILL EXPERIMENTAL TREATMENT METHOD. COMPARED TO TREATMENT, REMOVAL
WOULD MINIMIZE THE THREAT TO HUMAN HEALTH AND THE ENVIRONMENT, TAKE LESS TIME TO IMPLEMENT AND
BE LESS COSTLY. OUR PREFERRED ALTERNATIVE IS, THEREFORE, REMOVAL AND REPLACEMENT.
"ALTHOUGH NOT CONSIDERED IN THE FEASIBILITY REPORT, AN ALTERNATIVE THAT REMOVES THE CONTAMINATED
SOIL AND REPLACES IT WITH CLEAN FILL COULD BE COMBINED WITH LIMITED TREATMENT. ONCE REMOVED
FROM THE CELTOR AREA, CONTAMINATED SOILS COULD BE SUBJECTED TO A LIMITED TREATMENT TO BRING
HEAVY METAL CONCENTRATIONS BELOW HAZARDOUS LEVELS. ALL TREATED SOILS COULD THEN BE HAULED TO A
CLASS II LANDFILL WITH HAZARDOUS WASTE OR SLUDGE REMOVED TO A CLASS I SITE AS IN THE TREATMENT
ALTERNATIVE. THIS APPROACH WOULD ADDRESS CONCERNS REGARDING THE EXPERIMENTAL NATURE OF THE
PROCESS AND RESIDUAL SOIL CONTAMINANTS AS WELL AS REDUCE THE VOLUME OF MATERIAL TO BE SENT TO A
CLASS I LANDFILL.".
RESPONSE: FURTHER LABORATORY AND FIELD TESTING HAS BEEN CONDUCTED TO DETERMINE THE FEASIBILITY
AND COST OF IMPLEMENTING THE TREATMENT ALTERNATIVE AT THE CELTOR SITE. RESULTS OF THE TESTING
SHOWED THAT TREATMENT WOULD NOT BE ADEQUATELY EFFECTIVE AT THIS SITE. THEREFORE EXCAVATION AND
OFF-SITE DISPOSAL IS THE RECOMMENDED REMEDIAL ALTERNATIVE.
TREATMENT, WHICH HAS BEEN SHOWN TO BE INEFFECTIVE, COMBINED WITH REMOVAL WOULD BE MORE COSTLY
THAN REMOVAL ALONE. THIS COMBINED ALTERNATIVE COULD THEREFORE NOT BECOME THE COST-EFFECTIVE
REMEDIAL ACTION.
4) COMMENT/QUESTION: THE HOOPA VALLEY BUSINESS COUNCIL ALSO SUBMITTED THE FOLLOWING COMMENT
CONCERNING SITE CLEANUP:
"SINCE NEITHER THE CONCRETE PADS NOR THE SOILS BENEATH THE CONCRETE HAVE BEEN TESTED,
CONCENTRATION OF CONTAMINANTS SHOULD BE DETERMINED FOR EACH PRIOR TO FINAL ACTION IN THESE
AREAS. MATERIAL NOT MEETING THE CRITERIA IDENTIFIED ABOVE (SEE COMMENT NO.l) SHOULD BE REMOVED
WITH OTHER HAZARDOUS SOILS.".
RESPONSE: BOTH THE CONCRETE AND THE UNDERLYING SOILS WILL BE TESTED TO ENSURE THAT ALL
CONTAMINATED MATERIAL ABOVE THE SITE-SPECIFIC ACTION LEVELS IS REMOVED.
COMMENTS CONCERNING SITE CONDITIONS
5) COMMENT/QUESTION: ONE COMMENTOR EXPRESSED CONCERN ABOUT THE FORMATION OF A WHITE
CRYSTALLINE SUBSTANCE IN THE FIELD NEXT TO THE PLANT SITE AREA. IT APPEARS THAT THIS SUBSTANCE
APPEARED ONLY AFTER THE SOIL EXCAVATION PERFORMED DURING THE INITIAL REMEDIAL MEASURE (IRM).
WHAT IS THIS SUBSTANCE; WILL IT BE TESTED? IS IT PREVENTING VEGETATION FROM GROWING IN THE
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FIELD? IF NOT ALL THE CONTAMINATION IS REMOVED FROM THE SITE DURING THE REMEDIAL ACTION,
WON'T THIS SUBSTANCE CONTINUE TO FORM AND RECONTAMINATE THE CLEAN SOIL?
RESPONSE: THE WHITE PRECIPITATE SEEN IN THE FIELD WAS NOT PRESENT WHEN ONSITE SAMPLING WAS
PERFORMED DURING THE REMEDIAL INVESTIGATION. AT THE TIME OF THE PUBLIC MEETING, ITS COMPOSITION
WAS UNKNOWN. TESTS HAD BEEN TAKEN OF A SIMILAR WHITE PRECIPITATE THAT HAD FORMED ON THE ROAD.
THIS WAS FOUND TO CONTAIN HIGH LEVELS OF COPPER, ZINC, CADMIUM, ARSENIC, AND IRON, SIMILAR TO
THE LEVELS FOUND IN SOIL SAMPLES FROM THE SITE.
EPA HAS SINCE SAMPLED AND TESTED THE PRECIPITATE IN THE FIELD TO DETERMINE ITS COMPOSITION.
TEST RESULTS ARE NOT YET AVAILABLE.
WHEN CONTAMINATED SOIL WAS EXCAVATED AND REPLACED WITH CLEAN SOIL DURING THE IRM, PROVISION WAS
MADE FOR THE PROPERTY OWNER TO RESEED THE FIELD. HOWEVER, RESEEDING HAS NOT YET BEEN DONE. THE
ABSENCE OF GRASS DOES NOT NECESSARILY MEAN THAT THE FIELD IS INCAPABLE OF SUPPORTING VEGETATION;
IT MAY BE BECAUSE THE FIELD HAS NOT BEEN RESEEDED. ALSO, THE PORTION OF THE FIELD THAT IS
DENUDED IS IN A LOW-LYING AREA THAT IS OFTEN FLOODED DURING THE WINTER MONTHS. THIS FLOODING MAY
ALSO BE PREVENTING VEGETATION FROM GROWING.
FURTHER FORMATION OF THE WHITE PRECIPITATE SHOULD BE CONTROLLED BY THE CLEANUP ACTION. IF IT
SHOULD OCCUR AFTER THE CLEANUP ACTION IS IMPLEMENTED, EPA WILL DETERMINE IF FURTHER RESPONSE IS
NEEDED.
6) COMMENT/QUESTION: TWO COMMENTORS WERE CONCERNED ABOUT THE ODORS THAT PERIODICALLY OCCUR AT
THE SITE. ALTHOUGH EPA'S AIR SAMPLING DETECTED NOTHING, IT WAS CONDUCTED WHEN ODOR WAS AT A
VERY LOW LEVEL. ONE OF THE COMMENTORS ASKED IF THE ODOR IS TOXIC.
RESPONSE: EPA CONDUCTED EXTENSIVE ONSITE AIR SAMPLING OVER A 2-DAY PERIOD DURING CONDITIONS
WHEN ODORS ARE NORMALLY PRESENT. NOTHING WAS DETECTED DURING THIS PERIOD. BECAUSE OF RESOURCE
LIMITATIONS, IT WAS NOT POSSIBLE TO WAIT AT THE SITE UNTIL ODORS RETURNED. IF THE ODORS ARE
COMING FROM CONTAMINANTS AT THE SITE, THEY SHOULD BE SIGNIFICANTLY REDUCED AFTER SITE CLEANUP.
IT IS NOT POSSIBLE TO TELL AT THIS TIME IF THE ODOR IS TOXIC. NORMALLY, SULFUR ODORS ARE NOT
HAZARDOUS UNLESS THEY ARE VERY STRONG AND EXPOSURE IS LONG-TERM.
COMMENTS CONCERNING EXPOSURE TO CONTAMINANTS
7) COMMENT/QUESTION: ONE COMMENTOR ASKED IF PEOPLE HAVE BEEN EXPOSED TO CONTAMINATED DUST
RAISED BY TRAFFIC ALONG THE ROAD. ARE PEOPLE LIVING NEAR THE SITE STILL BEING EXPOSED TO
CONTAMINATED DUST FROM THE SITE OR THE ROAD, OR TO CONTAMINATION THAT HAS BEEN CARRIED TO THE
HOUSING AREAS BY DRAINAGE FROM THE SITE? IS THIS POSSIBLE EXPOSURE A HEALTH THREAT?
RESPONSE: BEFORE THE IRM WAS IMPLEMENTED, IT IS POSSIBLE THAT PEOPLE WERE EXPOSED TO
CONTAMINATED DUST RAISED BY TRAFFIC ALONG THE ROAD. HOWEVER, LIMITED EXPOSURE TO THE LEVELS AND
TYPES OF CONTAMINANTS FOUND ON THE ROAD IS NOT LIKELY TO HAVE PRESENTED A HEALTH HAZARD. THE
PLACEMENT OF GRAVEL ON THE ROAD DURING THE IRM HAS REDUCED THIS SOURCE OF EXPOSURE.
SOIL SAMPLING AND TESTING HAS INDICATED THAT CONTAMINANTS ARE NOT PRESENT FURTHER UP THE ROAD.
DRAINAGE PATTERNS CARRY RUNOFF FROM THE SITE AWAY FROM THE HOUSING AREAS. IT IS UNLIKELY THAT
CONTAMINATION ORIGINATING ON THE SITE MIGRATES INTO THESE AREAS. DURING IMPLEMENTATION OF THE
CLEANUP ALTERNATIVE, TESTING WILL CONTINUE TO ENSURE THAT ALL CONTAMINATED SOILS ABOVE THE
SITE-SPECIFIC ACTION LEVELS ARE IDENTIFIED AND REMOVED.
IT IS UNLIKELY THAT PEOPLE LIVING NEAR THE SITE ARE CURRENTLY BEING
EXPOSED TO LEVELS OF CONTAMINATED DUST THAT WOULD PRESENT A HEALTH
HAZARD. PREDOMINANT WIND PATTERNS ARE TO THE NORTH, AWAY FROM THE HOUSING AREA. IN ADDITION,
THE LARGE NUMBER OF TREES BETWEEN THE SITE AND THE HOUSING AREA WOULD ACT AS A SCREEN TO LIMIT
DUST EXPOSURE.
8) COMMENT/QUESTION: ONE COMMENTOR ASKED IF CONTAMINATED SOIL FROM THE SITE AREA WAS USED AS
FILL ON SOME OF THE HOUSING DEVELOPMENTS.
RESPONSE: IN RESPONSE TO THIS CONCERN, THE INDIAN HEALTH SERVICE CONDUCTED SOIL INVESTIGATIONS
IN APRIL 1984 AT HUD HOUSING DEVELOPMENTS, BOTH ON THE RESERVATION AND IN THE HOOPA VALLEY. NO
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CONTAMINATED SOILS WERE DISCOVERED.
9) COMMENT/QUESTION: ONE COMMENTOR ASKED WHO IS RESPONSIBLE IF PEOPLE BECOME ILL FROM
EXPOSURE TO CONTAMINATION.
RESPONSE: UNDER THE SUPERFUND LEGISLATION, THE FEDERAL GOVERNMENT IS NOT LIABLE FOR HEALTH
IMPACTS CAUSED BY EXPOSURE TO HAZARDOUS WASTES AT A SUPERFUND SITE. IT IS ALSO VERY DIFFICULT
TO DETERMINE IF HEALTH PROBLEMS RESULT FROM EXPOSURE TO HAZARDOUS MATERIALS AT A SITE, OR FROM
OTHER CAUSES OR EXPOSURES. THE PURPOSE OF THE SUPERFUND PROGRAM IS TO RESPOND TO POTENTIALLY
HAZARDOUS SITUATIONS THAT HAVE BEEN DISCOVERED AND TO PREVENT ANY FURTHER POSSIBLE EXPOSURE TO
HAZARDOUS LEVELS. THIS IS BEING ACHIEVED AT THE CELTOR SITE BY THE IRM AND THE PERMANENT
CLEANUP ACTION.
EPA HAS IDENTIFIED A POTENTIALLY RESPONSIBLE PARTY AT THE CELTOR SITE AND IS CONDUCTING
NEGOTIATIONS TO DETERMINE THE FULL EXTENT OF THIS PARTY'S LIABILITY. ONCE THE NEGOTIATIONS ARE
CONCLUDED, THE RESPONSIBLE PARTY WOULD APPEAR TO BE THE ONLY SOURCE OF ECONOMIC REDRESS FOR
ILLNESS CAUSED BY EXPOSURE TO SITE CONTAMINATION.
10) COMMENT/QUESTION: ONE COMMENTOR ASKED ABOUT POSSIBLE HEALTH EFFECTS TO HER AND HER
CHILDREN FROM PICKING BERRIES IN CONTAMINATED AREAS OVER THE PERIOD OF TWO SUMMERS.
RESPONSE: IT IS UNLIKELY THAT THIS AMOUNT OF EXPOSURE, EITHER FROM EATING BERRIES OR FROM
CONTACT WITH DUST, WOULD RESULT IN ANY LONG-TERM HEALTH IMPACTS. ANY EXPOSURE TO ACID RUNOFF
THAT MAY HAVE OCCURRED WOULD HAVE BEEN APPARENT AT THE TIME BECAUSE IT WOULD HAVE BURNED THE
SKIN UPON CONTACT OR SOON AFTER CONTACT.
11) COMMENT/QUESTION: ONE COMMENTOR ASKED IF THE ROAD AND THE DRAINAGE AREAS LEAVING THE SITE
SHOULD BE POSTED TO PREVENT PEOPLE FROM USING THESE AREAS.
RESPONSE: THE ONLY AREA THAT CONTINUES TO PRESENT A POTENTIAL HEALTH HAZARD IS THE MAIN PLANT
SITE, WHICH HAS BEEN FENCED AND POSTED. DUST EMISSIONS FROM THE ROAD HAVE BEEN REDUCED BY THE
GRAVEL LAID DOWN DURING THE IRM. THE PASTURE AREA HAS BEEN COVERED WITH APPROXIMATELY 1-1/2
FEET OF CLEAN SOIL. CONTAMINATED SOIL IN THE GULLY IS PRACTICALLY INACCESSIBLE BECAUSE OF THE
VEGETATION.
THE WATER LEAVING THE SITE IN THE DITCHES BY THE PASTURE AND IN THE GULLY DOES CONTAIN
CONTAMINATION LEVELS ABOVE EPA PRIMARY AND SECONDARY DRINKING WATER REGULATIONS. HOWEVER, THIS
WOULD BE A HEALTH THREAT ONLY IF PEOPLE WERE TO DRINK LARGE QUANTITIES OF WATER (2 LITERS PER
DAY) OVER A LONG PERIOD OF TIME. BECAUSE THIS IS VERY UNLIKELY, EPA DOES NOT CONSIDER IT
NECESSARY TO POST THESE AREAS.
12) COMMENT/QUESTION: ONE COMMENTOR ASKED IF CATTLE BECOME CONTAMINATED FROM GRAZING OR
DRINKING IN THE FIELD; DOES THIS AFFECT THEIR MEAT AND PRESENT A HUMAN HEALTH THREAT?
RESPONSE: BEFORE THE IRM, CATTLE MAY HAVE BEEN EATING CONTAMINATED GRASS IN THE FIELD OR
DRINKING CONTAMINATED WATER. EPA ASKED THE PROPERTY OWNER IF THEY COULD EXAMINE THE LIVER OF
ANY CATTLE THAT DIED, SINCE THE LIVER WOULD SHOW THE HIGHEST CONCENTRATIONS OF CONTAMINANTS.
THE ONLY SPECIMEN THEY RECEIVED WAS A STILLBORN CALF, WHOSE LIVER SHOWED NO CONTAMINATION. IT
IS NOT POSSIBLE TO TELL IF ANY CATTLE WERE AFFECTED IN THE PAST.
SINCE THE FIELD WAS EXCAVATED DURING THE IRM AND NEW SOIL WAS DEPOSITED, NO GRASS HAS BEEN
GROWING; THEREFORE, CATTLE ARE NO LONGER GRAZING IN CONTAMINATED AREAS OF THE PASTURE.
OTHER COMMENTS
13) COMMENT/QUESTION: ONE COMMENTOR ASKED IF EPA WILL ATTEMPT TO RECOVER FUNDING FOR THE
CLEANUP ACTION FROM THE RESPONSIBLE PARTY.
RESPONSE: EPA HAS IDENTIFIED A POTENTIALLY RESPONSIBLE PARTY AT THE CELTOR SITE AND IS
CONDUCTING NEGOTIATIONS TO DETERMINE THE FINANCIAL OBLIGATIONS OF THIS PARTY.
14) COMMENT/QUESTION: ONE COMMENTOR FELT THAT PEOPLE HAD NOT BEEN SUFFICIENTLY INFORMED ABOUT
HAZARDOUS CONDITIONS AT THE SITE AND THEIR POSSIBLE EXPOSURE TO CONTAMINATION.
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RESPONSE: EPA HAS ATTEMPTED TO INFORM ALL INTERESTED PARTIES OF ITS ACTIVITIES AT THE SITE.
THIS HAS BEEN DONE THROUGH PUBLIC MEETINGS, NEWSPAPER ADS, FACT SHEETS, INFORMATION
REPOSITORIES, AND CONTACT WITH REPRESENTATIVES FROM THE HOOPA VALLEY BUSINESS COUNCIL. EPA
REGRETS ANY LACK OF COMMUNICATION THAT MAY HAVE OCCURRED, AND ENCOURAGES PEOPLE TO CONTACT
EITHER THE HOOPA VALLEY BUSINESS COUNCIL REPRESENTATIVE OR EPA IF THEY HAVE ANY QUESTIONS ABOUT
THE SITE OR WISH TO BE ADDED TO THE MAILING LIST TO RECEIVE FUTURE INFORMATION.
15) COMMENT/QUESTION: THE HOOPA VALLEY BUSINESS COUNCIL COMMENTED THAT THE TRIBAL EMPLOYMENT
RIGHTS ORDINANCE (T.E.R.O.) REQUIRES UTILIZATION OF THE LOCAL NATIVE AMERICAN LABOR FORCE WITHIN
THE HOOPA SQUARE TO THE MAXIMUM EXTENT POSSIBLE. THE T.E.R.O. OFFICER SHOULD BE CONTACTED
BEFORE FINALIZATION OF ANY SUBCONTRACT PROVISIONS.
RESPONSE: SEE RESPONSE NO. 8 UNDER CONCERNS RAISED PRIOR TO THE FEASIBILITY STUDY COMMENT
PERIOD.
THE T.E.R.O. OFFICER WILL BE CONTACTED TO DISCUSS SUBCONTRACTING PROVISIONS.
REMAINING CONCERNS
TWO CONCERNS REMAIN THAT WILL REQUIRE EPA ATTENTION DURING IMPLEMENTATION OF THE REMEDIAL
ACTION:
IDENTIFICATION AND CONTROL OF THE WHITE PRECIPITATE THAT HAS FORMED IN SOME SITE
AREAS IF IT IS DETERMINED TO BE HAZARDOUS (SEE RESPONSE NO. 5 UNDER CONCERNS RAISED
DURING THE FEASIBILITY STUDY COMMENT PERIOD)
HIRING OF LOCAL NATIVE AMERICAN LABOR FORCE WHERE POSSIBLE (SEE RESPONSE NO. 8 UNDER
CONCERNS RAISED PRIOR TO THE FEASIBILITY STUDY COMMENT PERIOD).
LIST OF COMMENTORS
COMMENTED AT PUBLIC MEETING JULY 11, 1985
DALE LEMIEUX, TRIBAL ENVIRONMENTAL DEPARTMENT
GEORGE KALISIK, TRIBAL ENVIRONMENTAL DEPARTMENT
DALE RIESLING, COMMUNITY MEMBER
ARDEN MCCOVEY, COMMUNITY MEMBER
DESERRIE MCCOVEY, COMMUNITY MEMBER
DAN JORDAN, COMMUNITY MEMBER
DEL ROBINSON, BUREAU OF INDIAN AFFAIRS, HOOPA
SUBMITTED WRITTEN COMMENTS
BUREAU OF INDIAN AFFAIRS, SACRAMENTO OFFICE
HOOPA VALLEY BUSINESS COUNCIL.
HOOPA VALLEY BUSINESS COUNCIL
P.O BOX 1348 HOOPA, CALIFORNIA 95546 (916)625-4211
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JULY 18, 1985
NICK MORGAN
TOXICS AND WASTE MANAGEMENT DIVISION
U.S. EPA (T-4-3)
215 FREMONT STREET
SAN FRANCISCO, CA 94105
DEAR MR. MORGAN:
THIS LETTER IS BEING SENT IN RESPONSE TO THE JUNE 28, 1985 FEASIBILITY STUDY REPORT FOR THE
CELTOR CHEMICAL WORKS "SUPERFUND" SITE. THE COMMENTS PRESENTED BELOW ARE CONCERNED PRIMARILY
WITH ALTERNATIVE ACTIONS AND CLEANUP OBJECTIVES.
ALTERNATIVES
AS INDICATED IN OUR JULY 10, 1985 LETTER, WE AGREE WITH THE EPA'S DECISION NOT TO SUPPORT THE
ENCAPSULATION ALTERNATIVE. HYDROLOGIC AND GEOLOGIC CONDITIONS, RESTRICTIONS ON FUTURE LAND USE,
MONITORING AND MAINTENANCE REQUIREMENTS, AND THE FINITE, UNPROVEN LIFE OF THE LINING MATERIAL
MAKE THIS ALTERNATIVE UNACCEPTABLE.
AS YOU STATED AT THE RECENT COMMUNITY MEETING IN HOOPA, OF THE THREE FINAL ALTERNATIVES
(ENCAPSULATION, REMOVAL, AND TREATMENT) YOUR AGENCY HAS CHOSEN TREATMENT AS THE PREFERRED
ACTION. WHILE THE TREATMENT ALTERNATIVE WILL REDUCE THE THREAT TO HUMAN HEALTH AND THE
ENVIRONMENT AND REDUCE THE VOLUME OF MATERIAL SENT TO A CLASS I LANDFILL THE EXPERIMENTAL NATURE
OF THE PROCESS AND THE PRESENCE OF RESIDUAL CONTAMINANTS IN TREATED SOIL MAKE THE ALTERNATIVE
LESS DESIRABLE THAN REMOVAL. THIS PROCESS HAS BEEN UTILIZED AT ONLY TWO OTHER SITES AND CELTOR
IS NOT CONSIDERED AN APPROPRIATE LOCATION FOR FURTHER DEVELOPMENT OF THE METHOD. IN ADDITION,
AS WITH ANY SUCH PROCESS, SOME CONTAMINANTS AND EXTRACTION MATERIAL RESIDUES WILL REMAIN IN THE
TREATED SOIL THAT WOULD BE RETURNED TO THE SITE.
THE REMOVAL ALTERNATIVE WILL INVOLVE REPLACEMENT OF CONTAMINATED MATERIAL WITH CLEAN SOIL
CONTAINING ONLY BACKGROUND LEVELS OF HEAVY METALS AND NO BY-PRODUCTS OF THE TREATMENT PROCESS.
THERE ARE NO UNCERTAINTIES INVOLVED WITH THE REMOVAL ALTERNATIVE SUCH AS UNFORESEEN PROBLEMS
WHICH COULD OCCUR WITH THE STILL EXPERIMENTAL TREATMENT METHOD. COMPARED TO TREATMENT, REMOVAL
WOULD MINIMIZE THE THREAT TO HUMAN HEALTH AND THE ENVIRONMENT, TAKE LESS TIME TO IMPLEMENT AND
BE LESS COSTLY. OUR PREFERRED ALTERNATIVE IS, THEREFORE, REMOVAL AND REPLACEMENT.
ALTHOUGH NOT CONSIDERED IN THE FEASIBILITY REPORT, AN ALTERNATIVE THAT REMOVES THE CONTAMINATED
SOIL AND REPLACES IT WITH CLEAN FILL COULD BE COMBINED WITH LIMITED TREATMENT. ONCE REMOVED
FROM THE CELTOR AREA, CONTAMINATED SOILS COULD BE SUBJECTED TO A LIMITED TREATMENT TO BRING
HEAVY METAL CONCENTRATIONS BELOW HAZARDOUS LEVELS. ALL TREATED SOILS COULD THEN BE HAULED TO A
CLASS II LANDFILL WITH HAZARDOUS WASTE OR SLUDGE REMOVED TO A CLASS I SITE AS IN THE TREATMENT
ALTERNATIVE. THIS APPROACH WOULD ADDRESS CONCERNS REGARDING THE EXPERIMENTAL NATURE OF THE
PROCESS AND RESIDUAL SOIL CONTAMINANTS AS WELL AS REDUCE THE VOLUME OF MATERIAL TO BE SENT TO A
CLASS I LANDFILL.
CLEANUP CRITERIA
PAGE SEVEN OF THE FEASIBILITY STUDY REPORT INDICATES THAT ADEQUATE PROTECTION OF THE ENVIRONMENT
WILL BE ACHIEVED IN PART BY INSURING THAT SURFACE WATER DISCHARGES DO NOT EXCEED THE FEDERAL
DRINKING WATER STANDARDS. THE DRAINAGE LEAVING THE PLANT AREA MAY SUPPORT AMPHIBIANS AND OTHER
FRESHWATER LIFE IF RESTORED TO ITS ORIGINAL CONDITION. WATER QUALITY CRITERIA FOR AQUATIC LIFE
SHOULD THEREFORE BE USED AS A STANDARD WHEN STRICTER THAN THE DRINKING WATER STANDARD.
THE CLEANUP CRITERIA ESTABLISHED FOR CADMIUM AND ARSENIC SOIL CONCENTRATIONS ARE BASED ON
INFORMATION FROM THE CENTERS FOR DISEASE CONTROL AND OTHER SUPERFUND SITES. THE EFFECTS OF
LONGTERM, LOW-LEVEL EXPOSURE ON HUMANS OF SUCH CARCINOGENS HAS NOT BEEN SUFFICIENTLY DETERMINED.
TO INSURE ADEQUATE PROTECTION, CLEANUP LEVELS FOR THESE SUBSTANCES SHOULD BE SET AT BACKGROUND
LEVELS.
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PAGE TWO
NICK MORGAN
JULY 18, 1985
OTHER CONCERNS
SINCE NEITHER THE CONCRETE PADS NOR THE SOILS BENEATH THE CONCRETE HAVE BEEN TESTED,
CONCENTRATION OF CONTAMINANTS SHOULD BE DETERMINED FOR EACH PRIOR TO FINAL ACTION IN THESE
AREAS. MATERIAL NOT MEETING THE CRITERIA IDENTIFIED ABOVE SHOULD BE REMOVED WITH OTHER
HAZARDOUS SOILS.
FINALLY, THE TRIBAL EMPLOYMENT RIGHTS ORDINANCE (T.E.R.O.) REQUIRES UTILIZATION OF THE LOCAL
NATIVE AMERICAN LABOR FORCE WITHIN THE HOOPA SQUARE TO THE MAXIMUM EXTENT POSSIBLE. JAMES
COLEGROVE, T.E.R.O OFFICER, SHOULD BE CONTACTED AT 916-625-4211 PRIOR TO FINALIZATION OF ANY
SUBCONTRACT PROVISIONS.
I HOPE THESE COMMENTS WILL BE USEFUL. THANK YOU ONCE AGAIN FOR YOUR CONTINUED COOPERATION.
SINCERELY,
WILFRED K. COLEGROVE, CHAIRMAN
HOOPA VALLEY BUSINESS COUNCIL
CC: DEL ROBINSON, BIA
NOEL PALMER, IHS
BILL STRICKLAND, HUMBOLDT COUNTY PUBLIC HEALTH
DON KNAPP, BIA.
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LAND OPERATIONS
UNITED STATES
DEPARTMENT OF THE INTERIOR
BUREAU OF INDIAN AFFAIRS
SACRAMENTO AREA OFFICE
2800 COTTAGE WAY
SACRAMENTO, CALIFORNIA 95825
MR. NICHOLAS MORGAN
TOXICS AND WASTE MANAGEMENT DIVISION
ENVIRONMENTAL PROTECTION AGENCY
215 FREMONT STREET, T-4-3
SAN FRANCISCO, CALIFORNIA 94105
DEAR MR. MORGAN:
WE HAVE REVIEWED THE EXECUTIVE SUMMARY FOR THE DRAFT FEASIBILITY STUDY OF JUNE 28, 1985 FOR THE
CELTOR CHEMICAL WORKS. WE SUPPORT THE ALTERNATIVE NO. 3B - REMOVAL AT AN ESTIMATED COST OF $3.1
MILLION. PLEASE SEND A COPY OF THE DRAFT FEASIBILITY STUDY.
SINCERELY,
AREA DIRECTOR.
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TABLE 1
SITE-SPECIFIC ACTION IiEVELS FOR THE CELTOR CHEMICAL WORKS SITE
METAL
SOILS
SURFACE
&
GROUND
WATER (1)
TRINITY
RIVER (2)
ARSENIC
CADMIUM
COPPER
LEAD
ZINC
100 MG/KG
25
2,500
500
5, 000
50 UG/L
10
1, 000
50
5, 000
50 UG/L
2.8
2.6
50
47
(1) SITE-SPECIFIC ACTION LEVELS FOR ON-SITE SURFACE WATER AND LOCAL GROUND WATER ARE MCLS OR
DWRS, AS PROMULGATED UNDER THE SDWA
(2) SITE-SPECIFIC ACTION LEVELS FOR THE TRINITY RIVER AT THE GULLY DISCHARGE POINT ARE THE
WQCAL, AS PROMULGATED UNDER THE CWA AND AS BASED ON A HARDNESS OF 75 MG/L AS CAC03,
EXCEPT FOR ARSENIC AND LEAD, WHERE THE MORE STRINGENT MCL WAS USED.
TABIiE 2
TECHNOLOGIES REMAINING AFTER SCREENING
RESPONSE ACTION TECHNOLOGIES
CONTAINMENT CAPPING OF HAZARDOUS SOILS AND NONHAZARDOUS
CONCRETE STRUCTURES
NATIVE SOIL (SILT)
IMPORTED CLAY
MULTILAYER SYSTEMS
SYNTHETIC COVER AND SOIL
LOAM OVER SYNTHETIC COVER OVER CLAY
NATIVE SOIL OVER IMPORTED CLAY
DRAINAGE SYSTEMS (THESE TECHNOLOGIES APPLY
TO ALL RESPONSE ACTIONS EXCEPT NO-ACTION)
INTERCEPTOR TRENCHES
PERMEABLE GEOTEXTILE FABRIC
DRAINAGE PIPES
GRAVEL LAYERS
ONSITE DISPOSAL SOIL EXCAVATION
ONSITE ENCAPSULATION OF HAZARDOUS SOIL
CLAY, NATIVE SOIL, AND SYNTHETIC LINER
COMBINATION
DRAINAGE SYSTEMS (SEE ABOVE LIST)
ONSITE BURIAL OF NONHAZARDOUS MATERIALS
(E.G., CONCRETE)
STRUCTURE DEMOLITION
BURIAL WITH NATIVE SOIL
OFFSITE DISPOSAL REMOVAL OF HAZARDOUS SOIL
SOIL EXCAVATION
TRUCKING TO CLASS 1 RCRA-APPROVED LANDFILL
DISPOSAL AT CLASS 1 RCRA-APPROVED LANDFILL
REMOVAL OF NONHAZARDOUS SOIL AND CONCRETE
SOIL EXCAVATION
STRUCTURE DEMOLITION
TRUCKING TO CLASS II OR CLASS III LANDFILL
TREATMENT
ONSITE TREATMENT
CHEMICAL.
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