Revised Final
Feasibility Study
Former United Zinc Site
Iola, Kansas
Prepared for:
U.S. Environmental Protection Agency Region 7
11201 Rentier Boulevard
Lenexa, Kansas 66219
Prepared by:
HydroGeoLogic, Inc
6340 Glenwood, Suite 200
Building #7
Overland Park, KS 66202
July 2016
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Av///.sy/.v < //>' ' >j)cr<11loi is
Exceeding Expectations
July 27, 2016
Ms. Debra Dorsey
EPA Task Order Project Officer
U.S. Environmental Protection Agency, Region 7
11201 Renner Boulevard
Lenexa, KS 66219
RE: Revised Final Feasibility Study Report
Former United Zinc Site
Iola, Kansas
U.S. EPA Region 7 AES Contract No. EP-S7-05-05; Task Order No. 0056
EPA Task Order Project Officer: Don Bahnke
Dear Ms. Dorsey:
HydroGeoLogic, Inc. (HGL) is pleased to submit one hard copy and two electronic copies of
the Revised Final Feasibility Study Report. The report summarizes remedial actions
objectives; identifies general response actions, remedial technologies, and process options; and
develops remedial alternatives to address surface soil contamination at residential and
residential-like properties.
Should you have any questions or comments, please contact the HGL Task Order Manager.
Sincerely,
Jeff Hodge, PMP
Enclosures
6340 Glenwood, Suite 200, Building #7, Overland Park, KS 66202
1 Phone:(913)317-8860 Fax:(913)317-8868 '
www.hgl.com
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TABLE OF CONTENTS
Section Page
EXECUTIVE SUMMARY ES-1
1.0 INTRODUCTION AND PURPOSE 1-1
2.0 SITE BACKGROUND 2-1
2.1 SITE LOCATION AND DESCRIPTION 2-1
2.2 PHYSICAL CHARACTERISTICS OF THE SITE 2-1
2.2.1 Surface Features 2-1
2.2.2 Geology 2-2
2.2.3 Hydrology 2-2
2.3 NATURE AND EXTENT OF CONTAMINATION 2-2
2.3.1 Chemicals of Potential Concern 2-2
2.3.2 Summary of Surface Soil Data 2-4
2.3.2.1 Source Area Surface Soil Results for Site-Related Metals .... 2-4
2.3.2.2 Source Area Surface Soil Results for Other Metals 2-5
2.4 FATE AND TRANSPORT 2-5
2.5 OVERVIEW OF HUMAN HEALTH RISK THROUGH SOIL EXPOSURE .. 2-6
2.5.1 Exposure Assessment 2-7
2.5.2 Summary of Human Health Risk Assessment Results 2-7
2.5.2.1 Lead Exposures 2-7
2.5.2.2 Non-lead Metals COPCs 2-8
2.5.3 Conclusions 2-8
2.6 EPA TIME CRITICAL REMOVAL ACTIONS 2-9
2.7 REMAINING PROPERTIES FOR REMEDIATION 2-9
3.0 REMEDIAL ACTION OBJECTIVES 3-1
3.1 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS ..3-1
3.1.1 Definition of ARARs 3-1
3.1.2 Identification of ARARs 3-3
3.2 DEVELOPMENT OF REMEDIAL ACTION OBJECTIVES 3-3
3.3 PRELIMINARY REMEDIATION GOALS 3-4
4.0 IDENTIFICATION AND SCREENING OF GENERAL RESPONSE ACTIONS,
REMEDIAL TECHNOLOGIES, AND PROCESS OPTIONS 4-1
4.1 OVERVIEW 4-1
4.2 GENERAL RESPONSE ACTIONS 4-1
4.2.1 No Action 4-2
4.2.2 . Institutional Controls 4-2
4.2.2.1 Proprietary Controls 4-2
4.2.2.2 Government Controls 4-2
4.2.2.3 Enforcement and Permit Tools with IC Components 4-3
4.2.2.4 Informational Devices 4-3
4.2.2.5 Access and Legal Restrictions 4-3
4.2.3 Public Health Education 4-3
4.2.4 Excavation 4-4
4.2.4.1 Partial Removal 4-4
4.2.4.2 Complete Removal 4-4
U.S. EPA Region 7
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TABLE OF CONTENTS (continued)
Section Page
4.2.5 Disposal 4-4
4.2.5.1 New Repository 4-5
4.2.5.2 Sanitary Landfill 4-5
4.2.5.3 Commercial Backfill 4-5
4.2.6 Capping Technologies 4-5
4.2.6.1 Soil Capping 4-6
4.2.6.2 Geosynthetic Materials 4-6
4.2.6.3 Vegetation 4-6
4.2.7 Stablization 4-6
4.2.7.1 Pozzolanic Stablization 4-7
4.2.7.2 Phosphate Stabilization 4-7
4.3 SCREENING OF REMEDIAL TECHNOLOGIES AND PROCESS
OPTIONS 4-7
4.3.1 No-Action 4-8
4.3.2 Institutional Controls 4-8
4.3.3 Public Health Education 4-9
4.3.4 Excavation 4-9
4.3.5 Disposal 4-9
4.3.6 Capping Technologies 4-9
4.3.7 Stabilization 4-10
4.4 RETAINED GRAS, REMEDIAL TECHNOLOGIES, AND PROCESS
OPTIONS 4-10
5.0 DEVELOPMENT AND SCREENING OF REMEDIAL ALTERNATIVES 5-1
5.1 OVERVIEW 5-1
5.2 ASSUMPTIONS AFFECTING DEVELOPMENT OF REMEDIAL
ALTERNATIVES 5-1
5.3 DESCRIPTION OF REMEDIAL ALTERNATIVES 5-2
5.3.1 Alternative 1: No Action 5-2
5.3.2 Alternative 2: Excavation of Soils with XRF Confirmation to Depth,
Disposal, Backfill with Clean Fill and Topsoil, Vegetative Cover,
Institutional Controls, and Public Health Education 5-2
5.3.3 Alternative 3: In Situ Phosphate Stabilization; Excavation of Soils,
Disposal, Backfill with Clean Fill and Topsoil, Vegetative Cover,
Institutional Controls, and Public Health Education 5-4
5.4 SCREENING EVALUATION OF ALTERNATIVES 5-6
5.5 SUMMARY OF ALTERNATIVES SCREENING 5-8
5.6 ALTERNATIVES RETAINED FOR DETAILED ANALYSIS 5-9
6.0 DEFINITION OF CRITERIA USED IN THE DETAILED ANALYSIS OF RETAINED
ALTERNATIVES 6-1
6.1 OVERALL PROTECTION OF HUMAN HEALTH AND THE
ENVIRONMENT 6-1
6.2 COMPLIANCE WITH ARARS 6-1
6.3 LONG-TERM EFFECTIVENESS AND PERMANENCE 6-1
6.4 REDUCTION OF TOXICITY, MOBILITY, OR VOLUME THROUGH
TREATMENT 6-2
U.S. EPA Region 7
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TABLE OF CONTENTS (continued)
Section Page
6.5 SHORT-TERM EFFECTIVENESS 6-3
6.6 IMPLEMENTABILITY 6-3
6.7 COST 6-4
6.8 STATE ACCEPTANCE 6-5
6.9 COMMUNITY ACCEPTANCE 6-5
6.10 CRITERIA PRIORITIES 6-5
7.0 DETAILED ANALYSIS OF RETAINED ALTERNATIVES 7-1
7.1 OVERVIEW 7-1
7.2 SECONDARY ASSUMPTIONS AFFECTING DETAILED ANALYSIS OF
REMEDIAL ALTERNATIVES 7-1
7.3 ALTERNATIVES FOR CONTAMINATED SOIL 7-2
7.3.1 Alternative 1: No Action 7-2
7.3.1.1 Remedial Alternative Description 7-2
7.3.1.2 Overall Protection of Human Health and the Environment ...7-2
7.3.1.3 Compliance with ARARs 7-2
7.3.1.4 Long-Term Effectiveness and Permanence 7-2
7.3.1.5 Reduction of Toxicity, Mobility, or Volume through
Treatment 7-2
7.3.1.6 Short-Term Effectiveness 7-2
7.3.1.7 Implementability 7-2
7.3.1.8 Cost 7-3
7.3.2 Alternative 2: Excavation of Soils with XRF Confirmation to Depth,
Disposal, Backfill with Clean Fill and Topsoil, Vegetative Cover,
Institutional Controls, and Public Health Education 7-3
7.3.2.1 Summary of Remedial Alternative 7-3
7.3.2.2 Overall Protection of Human Health and the Environment ...7-3
7.3.2.3 Compliance with ARARs 7-3
7.3.2.4 Long-Term Effectiveness and Permanence 7-4
7.3.2.5 Reduction of Toxicity, Mobility, or Volume thr ough
Treatment 7-4
7.3.2.6 Short-Term Effectiveness 7-4
7.3.2.7 Implementability 7-5
7.3.2.8 Cost 7-5
7.3.3 Alternative 3: In Situ Phosphate Stabilization; Excavation of Soils,
Disposal, Backfill with Clean Fill and Topsoil, Vegetative Cover,
Institutional Controls, and Public Health Education 7-5
7.3.3.1 Summary of Remedial Alternative 7-5
7.3.3.2 Overall Protection of Human Health and the Environment ...7-6
7.3.3.3 Compliance with ARARs 7-6
7.3.3.4 Long-Term Effectiveness and Permanence 7-7
7.3.3.5 Reduction of Toxicity, Mobility, or Volume through
Treatment 7-7
7.3.3.6 Short-Term Effectiveness 7-8
7.3.3.7 Implementability 7-8
7.3.3.8 Cost 7-9
U.S. EPA Region 7
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TABLE OF CONTENTS (continued)
Section Page
7.4 COMPARATIVE ANALYSIS OF ALTERNATIVES 7-9
7.4.1 Protection of Human Health and the Environment 7-9
7.4.2 Compliance with ARARs 7-10
7.4.3 Long-Term Effectiveness and Permanence 7-10
7.4.4 Reduction of Toxicity, Mobility or Volume 7-10
7.4.5 Short-Term Effectiveness 7-10
7.4.6 Implementability 7-11
7.4.7 Cost 7-11
7.4.8 State Acceptance 7-12
7.4.9 Community Acceptance 7-12
7.4.10 Detailed Analysis Summary 7-12
8.0 REFERENCES 8-1
U.S. EPA Region 7
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LIST OF TABLES
Table ES.l
PRCs for COPCs
Table ES.2
Summary of Comparative Analysis of Alternatives for the Former United Zinc Site
Table 2.1
Metal Evaluated as Contaminants of Potential Concern
Table 4.1
Retained Remedial Technologies and Process Options
Table 5.1
Assumptions Affecting Development of Remedial Alternatives
Table 5.2
Effectiveness Criteria
Table 5.3
Effectiveness Qualitative Ratings System
Table 5.4
Implementability Criteria
Table 5.5
Implementability Qualitative Ratings System
Table 5.6
Cost Qualitative Ratings System
Table 5.7
Summary of Alternatives Screening
Table 5.8
Summary of Potential Remedial Alternatives
Table 6.1
ARAR Waivers
Table 6.2
Implementability Factors to be Considered During Alternative Evaluation
Table 6.3
Criteria Priorities
Table 6.4
Ratings System for Evaluation of Alternatives
Table 7.1
Secondary Assumptions Affecting Refinement and Detailed Analysis of Remedial
Alternatives
Table 7.2
Summary of Comparative Analysis of Alternatives for the Former United Zinc
LIST OF FIGURES
Figure 1.1 Site Location
Figure 2,1 Former Smelter Locations
Figure 2.2 Contaminated Parcels - Estimated and Calculated Soil Volumes
Figure 2.3 Conceptual Site Model
U.S. EPA Region 7
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Appendix A
Appendix B
Appendix C
Appendix D
LIST OF APPENDICES
Summary of Federal and State Applicable or Relevant and Appropriate
Requirements
Determination of Remaining Properties for Remediation
Development of Preliminary Remediation Goals for Lead and Arsenic
Detailed Alternative Analysis Cost Information
U.S. EPA Region 7
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LIST OF ACRONYMS AND ABBREVIATIONS
AES Architect and Engineering Services
amsl above mean sea level
ARAR Applicable or Relevant and Appropriate Requirement
BLL blood lead level
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
CME central median exposure
COPC chemical of potential concern
CSM conceptual site model
CTE central tendency exposure
EBL elevated blood lead
EPA U.S. Environmental Protection Agency
EPC exposure point concentration
FRTR Federal Remediation Technologies Roundtable
FS Feasibility Study
GRA general response action
HGL HydroGeoLogic, Inc.
HHRA Human Health Risk Assessment
HI hazard index
HQ hazard quotient
IC institutional control
ICP Inductively Coupled Plasma
IEUBK Integrated Exposure Uptake Biokinetic
KC1 potassium chloride
KDHE Kansas Department of Health and Environment
//g/dL micrograms per deciliter
mg/kg milligrams per kilogram
NCP National Contingency Plan
O&M operation and maintenance
OMB Office of Management and Budget
ppm parts per million
PRG Preliminary Remediation Goal
RA remedial action
U.S. EPA Region 7
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LIST OF ACRONYMS AND ABBREVIATIONS (continued)
RAO remedial action objective
RI Remedial Investigation
RME reasonable maximum exposure
ROD Record of Decision
ROW right-of -way
RSL regional screening level
Site Former United Zinc Site
SRC Syracuse Research Corporation
TAL target analyte list
TCLP toxicity characteristic leaching procedure
TCRA Time Critical Removal Action
TWA time-weighted-average
UCL upper confidence limit
U.S.C. United States Code
XRF x-ray fluorescence
U.S. EPA Region 7
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EXECUTIVE SUMMARY
HvdmGeoLogic, Inc. (HGL) is conducting a Remedial Investigation (RI)/Feasibility Study (FS) at
the Former United Zinc Site (Site) located in lola, Allen County, Kansas. These activities are being
conducted by HGL under Region 7, U.S. Environmental Protection Agency (EPA) Architect and
Engineering Services (AES) contract EP-S7-05-05, Task Order 0056.
The cost estimates for each alternative were developed in accordance with the EPA guidance
document A Guide to Developing and Documenting Cost Estimates during the Feasibility Study
(2000). This FS report addresses contaminated soils at residential properties and residential-type
properties inside of the city limits that have contaminated soil from smelting operations. This FS
contains the detailed evaluation of remedial alternatives addressing human health risks at Former
United Zinc Site. Although EPA also prepared an ecological risk assessment for the Site, EPA
directed HGL to only address only human health risks, receptors, and exposure scenarios for
surface soil in this FS. Therefore, the FS evaluates remedial alternatives only for remediation of
surface soil at residential and publicly owned properties within the study area. The presumptive
remedy for this site is excavation and disposal. A presumptive remedy is a technology that EPA
believes, based upon its past experience, generally will be the most appropriate remedy for a
specified type of site. The FS was developed to assist the EPA, in consultation with the Kansas
Department of Health and Environment (KDHE), to propose and take public comment on a
preferred remedy that addresses contaminated soil at Former United Zinc.
Site Location, History, and Contamination
The city of lola was an international center for zinc and lead smelting until the end of World War I,
with multiple smelters operating in lola and the adjacent towns of Gas and La Harpe. The
development of shallow natural gas fields in the vicinity of lola at the end of the 19lh century, along
with existing rail access helped transition the smelting industry from primarily coal-fired works in
the Pittsburg, Kansas, area to areas where natural gas was abundant. Most of the smelters in this
area provided zinc for galvanizing; mined zinc was sent to the steel mills of Ohio, Pennsylvania,
and New Jersey for further processing. Though lead was often not the primary metal being smelted,
it was present as waste in the slag material.
There were three smelting facilities shown on Figure 2.1, each owned by different companies
during different times. The three facilities are referred to in this report as former United Zinc, East
lola, and IMP Boats, Each of the three smelter sites in or near lola are considered potential source
areas. A source area is defined as a smelter site where waste was released as part of the
manufacturing process. A description of each source area and the waste disposal area are provided
in the RI Report.
The RI Report summarizes the nature and extent of target analyte list metals contamination at
source areas, disposal areas, and residential properties in the vicinity of the Site found during
previous investigations and during the RI. The primary source of contamination at the Site is from
three smelter facility source areas identified in the RI as former United Zinc, East lola, and IMP
Boats. Additionally, it is suspected that smelter waste from the former United Zinc smelter facility
was disposed of on the nearby Coberly property, and a smelter may have been present on portions
U.S. EPA Region 7
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HCL—Feasibility Study. Former United Zinc-tola. KS
of the former railroad right-of-way (ROW). Metals-contaminated soil at nearby residential sites is
from atmospheric deposition from smoke stacks, dust dispersion, and water runoff from waste
piles, the use of smelter waste as road base, and the use of smelter wastes as a base for railroads.
Residents have also noted that smelter wastes were used as fill around houses, sidewalks,
and driveways.
Quantitative risk and hazard estimates were developed for residents based on screening against
risk-based screening values, primarily the EPA regional screening levels fRSLs) (hazard quotient
[HQ] = 0.1 and cancer risk = 1E-06). The primary risk-based chemicals of potential concern
(COPCs) for the site are lead and arsenic, which are associated with smelting activities in the Site
area. Some other metals that also have formerly been associated with smelting-related activities
near the Site were detected, but were not identified as COPCs based on Human Health Risk
Assessment (HHRA) analysis.
Previous investigations identified properties that warranted a time critical removal action (TCRA).
Properties that qualified for TCRAs were completed at properties that had a child with an elevated
blood lead (EBL) and lead result at or above 400 ppm (parts per million), schools with a lead result
at or greater than 400 ppm, and properties with a lead result at or greater than 800 ppm. TCRAs
were completed at properties between August 15 and November 13, 2006, and from March 13 to
June 21, 2007. An additional 403 properties qualified for Non-TCRA removals and are currently
awaiting remedial efforts. HGL's analysis, determined that of the approximately 2,684 properties
sampled, approximately 1,242 of the properties would require remediation. Out of these properties,
approximately 479 have been or will be remediated as part of a TCRA removal. This brings the
total number of properties requiring remediation to 763.
Additionally, it is estimated that 300 residential properties remain to be sampled. Given that 1,242
of 2,684 properties sampled exceeded screening criteria, the same exceedance ratio (46.3 percent)
was assumed for the remaining properties. Thus, for the FS 139 of the remaining properties to be
sampled were assumed to require remediation. It is important to note that this estimate of future
properties that will exceed screening criteria was only used for costing purposes and is not an
actual representation of projected human health risks for unsampled properties.
Therefore, approximately 902 properties remain to be remediated based on the analysis presented
in Appendix B, the number of TCRAs completed to date, and the expected results of residential
properties remaining to be sampled.
Remedial Action Objectives
Based on the HHRA, arsenic and lead are the COPCs for soil at the site. The ingestion of lead in
soil was identified as the primary contributor to human health risks at the site. To address these
risks, the following remedial action objectives (RAOs) have been developed for residential soils:
• Reduce the risk of exposure of young children to lead such that an individual child, or
group of similarly exposed children, have no greater than a five percent chance of having
a blood-lead level exceeding 10 micrograms per deciliter («g/dL).
• Reduce the risk of exposure to soils containing arsenic such that levels do not exceed the
target carcinogenic risk of I x 10"4 and a noncancer hazard index of 1.
U.S. EPA Region 7
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HGL—Feasibility Slmly, Former United Zinc—tola. KS
Preliminary Remediation Goals
Preliminary Remediation Goals (PRGs) are used to establish an acceptable contaminant level or
range oflevels for each complete exposure route. For the FS, EPA has adopted the EPA May 2016
non-carcinogenic regional screening levels (RSLs) as the PRGs for lead and arsenic. The PRGs
are summarized in Table ES.l below.
Table ES.l PRGs for COPCs
Contaminants of Concern
PRGs
ppm
Arsenic
35
Lead
400
ppm = parts per million
Remedial Alternatives
Combining individual process options and technologies develops possible remedial alternatives
for addressing soil contamination with lead and arsenic concentrations that exceed their respective
PRGs. Although lead is the most prevalent soil contaminant at residential properties, a small
fraction of these lead-contaminated properties are also contaminated with arsenic above the PRG
at the same locations. Therefore, alternatives addressing lead concentrations in soil that exceed the
cleanup level of 400 ppm would also address the soil contaminated with arsenic. Reducing lead
concentrations in soil to below the cleanup level of 400 ppm is protective of human health.
Additionally, a very small fraction of properties contains a cell or cells with arsenic concentrations
that exceed the PRG with the lead result not exceeding the PRG. These cells will be remediated
solely based on the arsenic result. The goal in developing the preliminary remedial alternatives is
to provide both a range of cleanup options to address soil COPCs (lead and arsenic) and sufficient
detail to adequately compare the alternatives.
The three remedial alternatives evaluated in this FS are:
Alternative 1: No Action
Alternative 2: Excavation of Soils with XRF Confirmation to Depth, Disposal, Backfill with
Clean Fill and Topsoil, Vegetative Cover, Institutional Controls, and Public
Health Education
Alternative 3: In Situ Phosphate Stabilization; Excavation of Soils, Disposal, Backfill with
Clean Fill and Topsoil, Vegetative Cover, Institutional Controls, and Public
Health Education
Approximately 2,684 properties were evaluated as part of the RI. Of these properties,
approximately 1,242 properties have lead concentrations in soils greater than the cleanup level of
400 ppm and/or arsenic concentrations greater than the cleanup level of 35 ppm. Accounting for
TCRA removals and results of remaining sampling as described above, approximately 902
properties remain to be remediated. The remaining properties requiring remediation would be
addressed under Alternative 2 or Alternative 3. Properties where no soil sample concentrations
exceeded the cleanup level for lead would not be addressed under either alternative.
U.S. EPA Region 7
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HGL—Feasibility Study, Farmer United Zinc-Ma, KS
Alternative 1 - No Action
Alternative 1 is required by the National Contingency Plan (NCP) to provide an environmental
baseline against which impacts of the various remedial alternatives can be compared. The only
actions that would be implemented for Alternative 1 are completion of Five-Year Reviews as
required by the NCP. There would be no change in the soil contaminant concentrations because
no treatment, containment, or removal of contaminated soil is included in this alternative.
Therefore, potential health risks due to exposure to contaminated soil would remain.
Alternative 2 - Excavation of Soils with XRF Confirmation to Depth, Disposal, Backfill with
Clean Fill and Topsoil, Vegetative Cover, Institutional Controls, and Public Health Education
Alternative 2 provides protection of human health through remedial action to limit exposure to and
transport of contaminants, and institutional controls such as Information Devices and Public Health
Education. Residential properties that have or are expected to have soil lead concentrations above
the cleanup level would be excavated. When the highest soil lead concentration in any non-drip
zone sample collected on the property exceeds the cleanup level for lead, removal/excavation of
soil up would be triggered. Excavation would occur until the soils at the extent of the excavation
exhibit lead levels below the cleanup level of 400 ppm (as determined using XRF). The excavated
area would then be backfilled with clean fill and topsoil, returning the property to its original
elevation and grade. Sod or Hydro-seeding would be applied to establish a vegetative cover to
restore the disturbed area, preventing erosion and off-site transport by surface runoff or wind.
Based on the average areas of exceedance as measured by HGL, and assuming an average 12-inch
depth of excavation (average of 124 cubic yards per property), HGL has calculated that a total of
112,000 cubic yards of soil would require excavation, off-site disposal, and replacement under
Alternative 2. Clean fill and topsoil (same approximate quantity removed) would be imported from
an approved borrow source to replace soil removed during excavation, returning the property to
its original elevation and grade.
Excavated soil would be disposed of at the nearby landfill in Eureka, Kansas. Soils that do not
meet the toxicity characteristic leaching procedure (TCLP) threshold limit of 5 milligrams per liter
for non-hazardous waste disposal for lead would be treated on site with a stabilization agent, and
would then be resampled and analyzed for lead using TCLP analysis. This procedure would be
repeated until the soils pass the lead TCLP threshold limit to allow soil to be disposed of as
non-hazardous material at the landfill. Although landfill disposal was used for costing purposes,
EPA will also evaluate other disposal and repository options during the remedial design phase.
An Information Registry containing lead hazard information on properties at the Site will be
maintained by the City of Iola and would include information concerning the lead hazards at
properties. Information maintained in the registry may include, but not be limited to, whether lead
concentrations in the soil at a property exceed the established cleanup levels, and if so, whether
the soil has been remediated, if necessary; and any certifications that are made in accordance with
the local proposed ordinances.
A public information center would be established in loin in cooperation with KDHE. The
information center would have an ongoing lead hazard educational program that would continue
U.S. EPA Region 7
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HGL—Feasibility Study. Former United Zinc—loin. A'5
through the completion of the remedial action. The public information center would distribute
written information on controlling lead hazards and respond to questions from the public
concerning EPA response activities. Public health education activities providing community
education through distribution of fact sheets containing information on controlling lead exposure
would be conducted. The EPA would provide continuing lead hazard information to the public
through public media (television, radio, newspapers, internet).
Alternative 3- In Situ Phosphate Stabilization; Excavation of Soils, Disposal, Backfill with Clean
Fill and Topsoil, Vegetative Cover, Informational Devices, and Public Health Education
Alternative 3 provides protection of human health through remedial action to limit exposure to and
transport of contaminants, and institutional controls such as Information Devices and Public Health
Education. Alternative 3 has the same remedy components as Alternative 2, except that the
properties with lead concentrations above 400 ppm, but below 572 ppm, will be stabilized in situ
with a phosphate amendment. Affected soils would be treated with a phosphate amendment to
reduce the bioavailability of metals in the soil, thereby controlling the health risk to children.
An estimated 1,242 properties have lead concentrations greater than 400 ppm and/or arsenic
concentrations above 35 ppm. Accounting for TCRA removals, approximately 763 properties
remain to be remediated, and a projected 139 additional properties will require remediation
following future sampling (902 total). Because the previous pilot studies at other sites estimated
that the bioavailability of lead can be reduced by 30 to 50 percent, it is conservatively assumed
that a phosphate amendment could only be effective at reducing risks associated with lead
concentrations in the soils by 30 percent. Consequently, phosphate stabilization would only be
conducted on soils with lead concentrations above 400 ppm but less than 572 ppm. The total
number of residential properties with lead concentrations above 400 ppm and below the effective
stabilization level of 572 ppm is estimated to be approximately 382 properties. Given that 382 of
763 properties sampled fall into the lead concentration range of 400 to 572 ppm, the same range
ratio (50 percent) was assumed for the remaining properties. Thus, of 139 additional properties
expected to exceed screening criteria, 70 are estimated to be in the phosphate stabilization range.
Therefore, a total of 452 properties would be remediated in situ with phosphate amendment.
Residential properties with lead concentrations above 572 ppm or arsenic above 35 ppm (the
remaining 450) lead would be excavated as described in Alternative 2.
Excluding properties remediated by phosphate stabilization (50 percent), and based on HGL's
measured average areas of exceedance, and assuming an average 12-inch depth of excavation
(average of 124 cubic yards per property), a total of 55,800 cubic yards would require excavation,
disposal, and replacement under Alternative 3. Clean fill and topsoil (same approximate quantity
removed) would be used to replace soil removed during excavation, returning the property to its
original elevation and grade.
Excavated soil would be disposed of at the nearby landfill in Eureka, Kansas. Soils that do not
meet the TCLP threshold limit for non-hazardous waste disposal for lead would be treated on site
with a stabilization agent, and would then be resampled and analyzed for lead using TCLP analysis.
This procedure would be repeated until the soils pass the lead TCLP threshold limit so that the soil
could be disposed of as non-hazardous material at the landfill.
U.S. EPA Region 7
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HCL—Feasibility Simly. Former United Zinc—loin. KS
An Information Registry would be established and public health education would be conducted as
described under Alternative 2.
Analysis of Remedial Alternatives
A detailed evaluation of the remedial alternatives was performed using seven of the nine EPA
evaluation criteria and is summarized in Table ES.2.
Protection of Human Health and the Environment
• Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
• Long-Term Effectiveness and Performance
• Reduction of Toxicity, Mobility, or Volume
• Short-Term Effectiveness
• Implementability
• Cost
State and community acceptance criteria cannot be adequately addressed until after the FS Report
is released for regulatory and public review. These criteria will be assessed in the Record of
Decision responsiveness summary.
U.S. EPA Region 7
ES-6
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HCL—Feasibility Study, Former United Zinc—tola, KS
Table ES.2
Summary of Comparative Analysis of Alternatives for the
Former United Zinc Site
Remedial
Alternative
Description
Threshold Criteria
Balancing Criteria
Overall
Protection of
Human
Health and
the
Environment
Compliance
with
ARARs
Long-Term
Effectiveness
and
Permanence
Reduction of
Toxicity,
Mobility, or
Volume
through
Treatment
Short-Term
Effectiveness
Lmplementabilitv
Present
Value Cost
(Dollars)
1
No Action
—
—
O
O
O
©
$27,820
2
Excavation of Soils with XRF
Confirmation to Depth, Disposal,
Backfill with Clean Fill and
Topsoil, Vegetative Cover,
Institutional Controls, and Public
Health Education
+
+
O
©
©
o
519,771,534
3
In Situ Phosphate Stabilization;
Excavation of Soils, Disposal,
Backfill with Clean Fill and
Topsoil, Vegetative Cover,
Institutional Controls, and Public
Health Education
+
+
©
©
©
©
$36,021,121
Notes:
1. The numerical designations for the qualitative ratings system used in this table are not used to quantitatively assess remedial alternatives (for instance, individual rankings for an alternative are not
additive).
2. Detailed cost spreadsheets (cost summaries, present value analyses, and cost worksheets') for each alternative are presented in Appendix D of the FS Report.
Legend for Qualitative Ratings Svsteni:
Threshold Criteria
— Unacceptable
"I" Acceptable
o
o
©
Balancing Criteria
(Excluding Cost)
None
Low
Low to Moderate
6
O
0
Moderate
Moderate to Hi«li
High
U.S. EPA Region 7
ES-7
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HGL—Feasibility Sntdv. Former United Zinc—Iota, KS
I .... I Remedial J I - . . i AU .. j Detailed i j „ ., .
, . • Site j i ... i Technology Alternative j c ! j Detailed
>nU°t % ~*l Background j-j o&e'tfces H S"Cening H SCreeni"8 H « H Ana'VSiS
1.0 INTRODUCTION AND PURPOSE
This Feasibility Study (FS) Report was prepared to support the Remedial Investigation (RI)/FS
activities at the Former United Zinc Site (Site) located in lola, Allen County, Kansas (Figure 1.1).
These activities are being conducted by HydroGeoLogic, Inc. (HGL) under Region 7,
U.S. Environmental Protection Agency (EPA) Architect and Engineering Services (AES) contract
EP-S7-05-05, Task Order 0056. "
The FS was developed to be consistent with EPA guidance for conducting an FS under the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
(EPA, 1988). The cost estimates for each alternative were developed in accordance with A Guide to
Developing and Documenting Cost Estimates during the Feasibility Study (EPA, 2000). This FS
report addresses contaminated soils at residential properties and residential-type properties inside
of the city limits that have contaminated soil from smelting operations. This FS contains the
detailed evaluation of remedial alternatives addressing human health risks at Former United Zinc
Site. Although EPA also prepared an ecological risk assessment for the Site, EPA directed HGL
to only address human health risks, receptors, and exposure scenarios for surface soil in this FS.
Therefore, the FS evaluates remedial alternatives only for remediation of surface soil at residential
and publically owned properties within the study area. The presumptive remedy for this site is
excavation and disposal. A presumptive remedy is a technology that EPA believes, based upon its
past experience, generally will be the most appropriate remedy for a specified type of site. The FS
was developed to assist the EPA, in consultation with the Kansas Department of Health and
Environment (KDHE), to propose and take public comment on a preferred remedy that addresses
contaminated soil at Former United Zinc. This report is organized as follows:
Section 1 discusses the purpose of the FS Report, and the report organization.
Section 2 describes the characteristics of the Former United Zinc, site features and physical
characteristics, a summary of the nature and extent of contamination, and a summary of the
implementation of past and current property remediation efforts.
Section 3 describes the process for identifying remedial action objectives (RAOs) by
establishing Preliminary Remediation Goals (PRGs) based on exposure pathways, and
identifying potential Applicable or Relevant and Appropriate Requirements (ARARs) for the
Site.
Section 4 describes the options for General Response Actions (GRAs) and the screening and
evaluation of applicable remedial technologies and process options.
Section 5 describes the remedial alternatives and the screening process followed to reduce the
remedial alternatives to those considered to be most suitable for possible implementation.
U.S. EPA Region 7
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HGL—Feasibility Siiitly. Former United Zinc—tola, KS
Section 6 describes the criteria used to evaluate the alternatives retained during the screening
process completed in Section 5.0.
Section 7 presents a detailed analysis of the remedial alternatives and summarizes the
comparative analysis conducted to compare and contrast the remedial alternatives.
Section 8 lists the references and documents referred to in this FS Report.
Appendix A provides a summary of Federal and State ARARs,
Appendix B documents the methodology and calculation of the number of likely properties
remaining to be remediated (on CD).
Appendix C provides the memorandum for development of PRGs for lead and arsenic.
Appendix D provides the detailed alternative analysis cost information. Detailed analysis cost
estimates have an expected accuracy range between +50 percent and -30 percent of the
actual costs.
U.S. EPA Region 7
1-2
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1IGL—Feasibility Slutly. Former United Zinc—loin. KS
, , H I ' Site U R!Tdia' i Technology | : Alternative I cDe,3iled
Introduction p, Backgroun(j p Screenin8 j- Screening ^
Detailed
Analysis
2.0 SITE BACKGROUND
2.1 SITE LOCATION AND DESCRIPTION
The city of Iola was an international center for zinc and lead smelting until the end of World War I,
with multiple smelters operating in Iola and the adjacent towns of Gas and La Harpe. The
development of shallow natural gas fields in the vicinity of Iola at the end of the 191'1 century, along
with existing rail access helped transition the smelting industry from primarily coal-fired works in
the Pittsburg, Kansas, area to areas where natural gas was abundant. Most of the smelters in this
area provided zinc for galvanizing; mined zinc was sent to the steel mills of Ohio, Pennsylvania,
and New Jersey for further processing. Though lead was often not the primary metal being smelted,
it was present as waste in the slag material.
The Site consists of two types of contaminated properties: properties with contamination associated
directly with smelting operations, and properties affected by waste and pollution that was removed
from contaminant source areas and transported to other locations by unidentified soil transporters.
There were three smelting facilities each owned by different companies at different times. The
three facilities are referred to in this report as former United Zinc, East Iola, and IMP Boats
(Figure 2.1). Each of the three smelter sites in or near Iola are considered source areas. A source
area is defined as a smelter site where waste was released as part of the manufacturing process. A
description of each source area and the waste disposal area are provided in the RI Report
(HGL, 2016).
In addition to the source areas, there are contaminated parcels within the city. The majority of the
contaminated parcels that will likely require remediation at the site are bound by State Street to
the west, Kentucky Street to the east, Buchanan Street to the north, and Irwin Street to the south
(Figure 2.2). An additional impacted area includes an abandoned rail line in the southeastern
portion of Iola that includes heavily contaminated parcels that extend along the rail line.
Heavy metals contamination was deposited across the town via atmospheric deposition from
smoke stacks, deposition through atmospheric and water run from waste piles, the use of smelter
wastes as road base, and the use of smelter waste in railroad ballasts. Residents have also stated
that smelter wastes were used as fill around houses, sidewalks, and driveways.
2.2 PHYSICAL CHARACTERISTICS OF THE SITE
2.2.1 Surface Features
Topography varies minimally throughout Allen County. The land is predominantly level with few
outstanding differences in the relief. The site area is generally flat land and slopes slightly to the
South toward Rock Creek, Elm Creek, and the Neosho River. The elevation of the ground surface
across the site ranges from 980 feet above mean sea level (amsl) to 1,040 feet amsl. The higher
elevations are in the northeast corner of town, and the lower elevations are along the creeks and rivers.
U.S. EPA Region 7
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HGL—Feasibility Sillily. Former United Zinc—lohi. KS
2.2.2 Geology
The site and its surroundings lie at the edge of a late-Paleozoic structure called the Cherokee Basin,
which is present in the southern part of Allen County. The basin is an area with a thicker sequence
of sedimentary deposits, with respect to the arches in the area. The Bourbon Arch extends into the
north portion of the county. These structural features are responsible for the natural gas deposits mined
below the site region. In general, the geology of the site area consists of late Paleozoic-aged bedrock.
The most prevalent bedrock formations beneath tola are the Bonner Springs and Lane shales and
the lola Limestone of the Kansas City Group. These two undifferentiated shales have an average
thickness of approximately 60 feet. Most exposures of lola Limestone lie in drainageways where
erosion has cut through the overlying Bonner Springs and Lane shales.
2.2.3 Hydrology
The regional topography of the area is flatlands with small bluffs on the cut banks of the Neosho
River. The elevation of the site ranges from approximately 950 to 1,000 feet amsl. Several surface
water features are located near the site. Rock Creek flows from northeast to southwest into Elm
Creek and is located approximately 2,200 feet south of the eastern former smelter properties and
the Coberly suspected waste disposal area. Elm Creek, a major tributary to the Neosho River, flows
to the west and is located approximately 4,200 feet southwest of the eastern former smelter properties.
No surface water bodies are located on any of the source area properties. Surface flow runoff from
the properties flow overland from drainage ditches that discharge into creeks that eventually
discharge into the Neosho River.
2.3 NATURE AND EXTENT OF CONTAMINATION
Based on the results of the RI and previous investigations, metals contamination associated with
former smelting operations are present at levels above Residential Soil RSLs in surface soil
samples collected across the city of lola. The primary COPCs in soil are lead and arsenic. The RI
Report summarizes the nature and extent of target analyte list (TAL) metals contamination at
source areas, disposal areas, and residential properties in the vicinity of the Site found during
previous investigations and during the RI. The primary source of contamination at the Site is from
three smelter facility source areas identified in the RI as former United Zinc, East lola, and IMP
Boats. Additionally, it is suspected that smelter waste from the former United Zinc smelter facility
was disposed of on the nearby Coberly property, and a smelter may have been present on portions
of the former railroad right-of-way (ROW). Metals-contaminated soil at nearby residential sites is
from atmospheric deposition from smoke stacks, dust dispersion, and water runoff from waste
piles, the use of smelter waste as road base, and the use of smelter wastes as a base for railroad
ballasts (HGL, 2016).
2.3.1 Chemicals of Potential Concern
Soil data were compared to the risk-based Residential Soil Regional Screening Levels (RSLs), as
defined in the EPA RSL Summary Table (EPA, 2016). Eighteen metals were detected above their
respective RSL values and were defined as chemicals of potential concern (COPCs) in the RI
U.S. EPA Region 7
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HGL—Feasibility Study, Former United Zinc—loin. KS
Report (HGL, 2016). The primary COPCs for the site are lead and arsenic, which are associated
with smelting activities in the Site area. Some additional metals that were evaluated as COPCs
also have formerly been associated with smelting-related activities near the Site. Based on the
findings noted in the Human Health Risk Assessment (HHRA), PRGs were developed only for
COPCs: arsenic and lead. Further details regarding the process to select metals for PRG
development is provided in Section 4 (Evaluating Exposure and Risk from Non-Lead COPCs) of
the HHRA. The HHRA was prepared by EPA contractor Syracuse Research Corporation (SRC),
but was incorporated into discussions in the R1 Report and included in its entirety as Appendix B
(HGL, 2016). Contamination related to smelting operations includes smelter wastes at the ground
surface, dust deposition from smelter smoke stacks, smelter waste improperly reused as
construction base and fill, and contaminated soil transported and placed in uncontaminated areas.
These contaminants may then contaminate soil in yards, create contaminated leachate that reaches
drinking water wells, and create contaminant-laden dust in homes. The COPCs for the Site and the
matrices in which the metal was detected are listed in Table 2.1.
Table 2.1 Metals Evaluated as Chemicals of Potential Concern
COPC
Matrix
Surface
Soil
Subsurface
Soil
Ground-
water
Sediment
Surface
Water
Sensitive
Habitat
Soil
Fish
Tissue
Source
Area
Surface
Soil
Aluminum
X
X
X
X
X
X
Antimony
X
X
X
X
Arsenic*
X
X
X
X
X
X
X
Bariu m*
X
Cadmium*
X
X
X
X
X
Chromium
X
X
X
X
X
X
X
X
Cobalt
X
X
X
X
X
X
X
Copper
X
X
X
Iron
X
X
X
X
X
X
Lead*
X
X
X
X
X
X
Manganese
X
X
X
X
X
X
X
Mercury
na
na
na
na
na
n a
X
na
Nickel
X
Selenium
X
Silver
X
X
X
Thallium
X
X
X
Vanadium
X
X
X
X
X
X
Zinc*
X
X
X
X
X
Notes:
*metal associated with the site mining/smelling activities,
na = noi analyzed;
X = melal detected above its respective RSL
U.S. EPA Region 7
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HGL- Feasibility Study. Former United Tinc—lolu. KS
All of the metals evaluated as potential COPCs are elements that are present in the earth's crust
and, therefore, are naturally present in air, soil, and groundwater. Discussion of metals
concentrations relative to typical background concentrations, screening values, and the physical
and chemical characteristics of these metals, along with typical industrial uses and general
pathways into the environment, are presented in detail in the RI Report. These metals were
evaluated in the revised final HHRA prepared by EPA and incorporated into the RI Report (HGL,
2016). Of these IS COPCs, only arsenic and lead pose unacceptable risk to current and future
receptors. These two metals are identified as the site COPCs in soil and require remedial action
based on human health risk. Further discussion of the HHRA evaluation is provided in Section 2.5.
2.3.2 Summary of Surface Soil Data
The RI Report provides a complete summary of the data compiled (as of April 2016) during
previous environmental investigations and assessments performed under the direction of K.DHE
and EPA (HGL, 2016). For sampling at each residential property, the property was divided into
sampling cells depending on property size and a drip zone. A drip zone is defined as that portion
of the property that is located within 30 inches of an exterior building wall. The remaining cells
were the areas within the property boundary that are located outside the drip zone. Additional
samples were collected from play areas, gardens, landscaping, gravel areas, and unpaved
driveways, if present.
Surface soil data discussed in the following subsections refers specifically to the 21 surface soil
samples collected from the source areas and the Coberly suspected waste disposal area as they are
expected to represent the highest concentrations of metals contamination at the site. However, only
residential and residential-type properties will be remediated under this FS. Source area and waste
disposal area contamination will be addressed in a separate remedial action.
2.3.2.1 Source Area Surface Soil Results for Site-Related Metals
Site-related metals that have historically been associated with smelting activities at the Site
include: arsenic, barium, cadmium, lead, and zinc. Surface soil results for these metals are
discussed in the below.
Arsenic - Arsenic was detected in all 21 samples collected at source areas and the Coberly Waste
Disposal Area at concentrations ranging from 5.3 milligrams per kilogram (mg/kg) to 291 mg/kg.
All arsenic detections exceeded the RSL of 0.67 mg/kg and the average arsenic background
concentration of 5.0 mg/kg. As with lead, the highest detection was observed in sample
IMP-Boats-5 collected adjacent to the large tailings pile on the south side of the IMP Boats source
area. The next highest arsenic concentration also correlated with the second highest lead
concentration, and was detected at 221 mg/kg along the former railroad ROW south of the Former
United Zinc and East lola Source Areas.
Barium - Barium was detected in all 21 samples at concentrations ranging from 106 mg/kg to
454 mg/kg. None of the detected barium concentrations exceeded its RSL of 1,500 mg/kg.
Cadmium - Cadmium was detected at concentrations ranging from 0.68 mg/kg to 111 mg/kg, with
14 of the 21 samples exceeding the RSL of 7 mg/kg and 15 exceeding the average cadmium
U.S. EPA Region 7
2-4
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HGL—Feasibility Study, Former United Zinc—loin. KS
' background concentration of 4.9 mg/kg. As with lead and arsenic, the highest cadmium
concentration was observed in the sample IMP Boats-5. Sample Former United Zinc-5 and the
former railroad ROW had the next highest cadmium concentrations, at 89.5 mg/kg and 88.9 mg/kg,
respectively. In general, the highest cadmium concentrations were observed at the former United
Zinc and IMP Boats source area properties.
Lead - Lead concentrations ranged from 53 mg/kg to 20,700 mg/kg. The highest detection was
observed in sample lMP-Boats-5 collected adjacent to the large tailings pile on the south side of
the IMP Boats source area property. The lead detections all exceeded the average background lead
level of 52.4 mg/kg. At the former United Zinc source area property, four of five samples had lead
concentrations above both background and the RSL of 400 mg/kg, as did two of five samples
collected at the Coberly Waste Disposal Area. One of the two samples collected from the street
ROW abutting the north side o f the East Iola source area property also contained a lead level above
background and the RSL.
The former railroad ROW south of the Former United Zinc and East Iola Source Areas is not a
separate designated source area. However, a sample collected from the railroad ballast had a lead
concentration of 14,500 mg/kg; the second highest lead concentration observed in comparison to
the source area samples. This contamination is likely the result of ore being transported via rail to
the source areas for processing or mine waste used to construct the rail ballast.
Zinc - Zinc was detected at concentrations ranging from 76 mg/kg to 55,300 mg/kg, with 9 of the
21 samples exceeding the RSL of 2,300 mg/kg, and 14 exceeding the average zinc background
| concentration of 68S mg/kg. The two highest concentrations were observed in the former railroad
ROW sample and sample IMP Boats-5, at concentrations of 55,300 mg/kg and 26,100 mg/kg,
respectively. In general, the highest zinc concentrations were observed at the former United Zinc
and IMP Boat source areas, including seven of the nine exceedances of the zinc RSL.
2.3.2.2 Source Area Surface Soil Results for Other Metals
Other metals detected at the site of note are those metals that have not historically been associated
with mining or smelting activities near the Site. They consist of aluminum, chromium, cobalt, iron,
manganese, and vanadium. These metals were determined not to be COPCs in the RI either based
on lack of detections exceeding the RSL, or because the site analytical results were comparable to
concentrations in background samples.
2.4 FATE AND TRANSPORT
Metals contamination associated with former smelting and processing activities may be
transported by the following processes:
• Dust generation during the ore transporting and smelting activities;
Atmospheric deposition from smoke stacks;
Disposal of ores or residual smelting wastes directly onto the ground surface; and
Transport and placement of contaminated soil to previously non-contaminated areas.
Many physical processes affect the transport of smelter wastes. The ore refinement process
activities create fine particulate material and volatile compounds that are released into the air and
)
U.S. EPA Region 7
2-5
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HGL—Feasibility Study, Former United Zinc—loin, KS
carried downwind, or released into waterways via liquid waste streams. The creation of smelter
waste piles leaves materials exposed to wind and precipitation, allowing transport of contaminants
in dust particles, in suspension into groundwater and streams, and through leaching into
groundwater and streams.
Figure 2.3 presents the conceptual site model (CSM) developed for the Site, and includes a visual
depiction of the pathway for smelter-related wastes to enter the environment.
The CSM developed for the site depicts smelter operations wastes impacting surface soil and
surface water. The main mechanism that these waste were released to the environment was by
physical placement of smelter wastes on the ground and aerial deposition through stack emissions.
A portion of the contaminants are still exposed at the ground surface in the form of spent ore and
mine tailings piles. Although most metals are expected to be chemically or physically bound to
soil particles, contaminants migrate through erosion, leaching, and air transport mechanisms.
Precipitation falling on exposed wastes has the potential to continue to transport metals into surface
water through erosion and runoff, and leach metals to groundwater, and contaminants can be
transported through wind erosion.
Metals may become part of a soil or sediment mass through precipitation (formation of oxides,
hydroxides, carbonates, salts, and other forms) or through absorption (binding to fine-grained soil
particles or organic matter). Soils and sediments can become sinks for heavy metals. Metals
generally have low water solubility, resulting in limited ability to dissolve in surface water or
groundwater under ambient conditions. They also tend to partition out of the aqueous phase onto
organic matter or fine-grained soil particles. These metals properties, combined with their natural
corrosion resistance, results in them being immobile and persistent in the environment. Soiption
to soil particles and organic matter, and precipitation as metal oxides are the primary means of
entrainment of metals contamination in the environment.
2.5 OVERVIEW OF HUMAN HEALTH RISK THROUGH SOIL EXPOSURE
The goal of the RI/FS was to gather information sufficient to support an informed risk management
decision regarding which remedy appears to be most appropriate for the Site. Cleanup of properties
with soil lead contamination at 400 mg/kg or greater is anticipated to bring the yard-wide average
below 400 mg/kg. The cleanup of surface soils at or above 400 mg/kg is anticipated to reduce child
blood lead levels (BLLs) to meet the RAOs and provide a protective remedy for the community.
The risk assessment discussion presented in this section is taken from the results of the HHRA
prepared by EPA contractor SRC. The complete HHRA is provided in Appendix B of the R1
Report. Although EPA also prepared an ecological risk assessment for the Site, EPA directed HGL
to address only human health risks, receptors, and exposure scenarios relative to surface soil in
developing this FS. Therefore, the FS evaluates remedial alternatives only for remediation of
surface soil at residential and publicly owned properties within the study area. The properties and
portions of properties requiring remediation were determined for the FS by comparing site-derived
concentrations to the PRGs for lead and arsenic in surface soil developed by EPA contractor SRC.
The PRG memo is provided as Appendix C.
U.S. EPA Region 7
2-6
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HGL—Feasibility Study. Former United Zinc—loin. KS
The HHRA conducted for the site was based on standard EPA guidance (EPA, 1989),
supplemented with more recent guidance and policy as appropriate. Site characterization data
collected for soil during the RI (including the arsenic reanalysis study) and previous field
investigations was used in the HHRA to evaluate possible health risks for identified receptors
within the study area. Assumptions, methods, and results are summarized below.
2.5.1 Exposure Assessment
The exposure assessment identifies the human population (receptors) that may be exposed to
chemicals at a site. It also identifies the particular exposure pathways for these receptors to come
into contact with the Site COPCs. For the former United Zinc Site, the HHRA identified the
resident, recreational user, and trespasser as applicable receptors and the exposure scenarios were
identified as direct contact with mine-related contaminants in surface soil, inhalation of indoor and
ambient dust, and ingestion through dietary consumption.
2.5.2 Summary of Human Health Risk Assessment Results
Quantitative risk and hazard estimates were developed for residents at the Site. COPCs were
identified based on screening against risk-based screening values, primarily the EPA RSLs (hazard
quotient [HQ] = 0.1 and cancer risk = 1E-06). A summary of the human health risks by property
is presented in the Final HHRA provided as Appendix B of the RI Report (HGL, 2016).
2.5.2.1 Lead Exposures
Lead contamination at the site poses actionable risk and thus lead is the contaminant of primary
human health concern. Lead exposure is not assessed using standard risk assessment methods.
Instead, exposures in residential settings are typically evaluated using EPA's Integrated Exposure
Uptake Biokinetic (IEUBK) model for lead in children. Young children (less than 7 years old) are
more susceptible to the toxic effects of lead, and generally receive the highest exposures to lead in
soil and dust. Because protection of young children will also protect adult residents in the same
environment, residential exposures were evaluated in the HHRA based solely through lead
exposure for young children.
Results of the 2006/2007 and 2013 dataset IEUBK modeling within the Site indicate that
approximately 40 percent of the properties (1,082 out of 2,691 properties) have a probability
greater than 5 percent that children living at these properties might have BLLs exceeding
10 micrograms per deciliter ((.ig/d L), which is EPA's health protection goal. The probability of the
BLL exceeding 10 (ig/dL is referred to as the P10 value. Of these 1,082 properties, 320 are
predicted to have P10 values of 5 to 10 percent, 334 properties would be expected to have
P10 values between 10 to 20 percent, and 428 properties are expected to have P10 values greater
than 20 percent.
Estimated P10 values were below EPA's health-based guideline (5 percent) for the adolescent
trespasser, adult trespasser, and adult recreational visitor at residential properties. No risk is
indicated for these receptors exposed to lead in sediment. The P10 value for the child recreational
visitor was estimated to be 6.2 percent, which exceeds the EPA health-based guideline.
U.S. EPA Region 7
2-7
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IICL— Feasibility Slinly. Former Uniletl Zinc—loin, A'.S
Data used to support the HHRA are not representative of all residential areas within the site.
Extrapolation of the results of the HHRA to properties that have not been previously sampled is
not possible. It cannot be assumed that predicted BLLs in exposed populations in uncharacterized
areas will be similar to BLLs estimated in this assessment. However, available data characterize
almost 2,700 residential properties, and the basic finding that approximately 40 percent of all
residences at the site have elevated soil lead levels can be accepted with confidence.
2.5.2.2 Non-lead Metals COPCs
Non-lead cancer and non-cancer risks were calculated for the resident receptor on a site-wide basis
and a property-specific basis. Site-wide risk calculations were performed using the 95 percent
upper confidence limit (UCL) as the exposure point concentration (EPC). Property-specific risk
calculations were performed using the maximum detection as the EPC. Site-wide residential
non-cancer hazard indexes (His) for the child and adult central tendency exposure (CTE) resident
receptors were within EPA guidelines. Cancer risks for the reasonable maximum exposure (RME)
time-weighted-average (TWA) adult resident, the central median exposure (CME) TWA child
resident, and the CME TWA adult resident were within EPA guidelines (1E-06 to 1E-04).
All non-cancer and cancer risks quantified for the RME and CTE trespasser receptor (adolescent
and adult) were within EPA target levels. No risk is identified for this receptor.
2.5.3 Conclusions
The HHRA identified the following human health risks hazards associated with exposure to mine-
related contaminated surface soil in residential yards and publically owned properties in Iola.
Based on the results of the IEUBK model, 40 percent of child residents had risks associated
with lead exposure greater EPA's target criterion of no more than a 5 percent probability of
exceeding a BLL of 10 (ig/dL.
• Under the RME risk scenario, the following receptors were identified with risk exceeding
target levels. For each receptor, primary risk drivers are also listed,
o RME Child Resident (Site-Wide) - thallium in soil
o RME TWA Resident (Site-Wide) - chromium in soil
o RME Child Resident (Property-Specific) - arsenic, copper, iron, thallium, and zinc
in soil
o RME Adult Resident (Property-Specific) - arsenic, copper, iron, thallium, and zinc
in soil
o RME TWA Resident (Property-Specific) - chromium in soil
PRGs were developed only for the COPCs arsenic and lead because of limited detections of other
metals and other uncertainties, such as laboratory analysis was for the total metal and not speciated
for the risk driving form of the metal, and unknown bioavailability. Further details regarding the
process to select metals for PRG development is provided in Section 4 (Evaluating Exposure and
Risk from Non-Lead COPCs) of the HHRA, which is included as Appendix B of the Final Remedial
Investigation Report.
U.S. EPA Region 7
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I
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HGL—Feasibility Study, Former United Zinc—loin, k"S
2.6 EPA TIME CRITICAL REMOVAL ACTIONS
Previous investigations identified properties that warranted a time critical removal action (TCRA).
TCRAs were completed at the properties meeting the TCRA removal criteria between August 15
and November 13, 2006, and from March 13 to June 21, 2007. Contaminated soils were excavated
at 129 total properties. The remaining 11 properties that met the TCRA criteria but were not
remediated included 8 properties where the owners denied access for soil removal efforts and
3 commercial properties (EPA, 2008). An additional 403 properties qualified for Non-TCRA
removals. TCRA removals are currently ongoing with an identified 350 additional properties for
removal. TCRA and Non-TCRA criteria are described below:
. TCRA
o Residential properties with soil lead levels greater than 800 mg/kg.
o Commercial properties with soil lead levels greater than 1,000 mg/kg.
o Schools, daycare facilities, or churches with soil lead levels greater than 400 mg/kg.
o Elevated blood lead (EBL) residences, defined as properties where children with EBL
levels reside and soil lead levels are greater than 400 mg/kg.
. Non-TCRA
o Residential properties with lead levels greater than 400 mg/kg but less than 800 mg/kg.
No waste removal efforts are known to have occurred at either of the three former smelter
properties or the Coberly Waste Disposal Area. Previous investigation reports for the former
United Zinc, Coberly, and East tola properties describe large piles of smelter process wastes that
no longer appear at the properties. It is possible the wastes were buried on site, buried nearby,
transported off site, or capped with concrete or asphalt. A large amount of smelter waste still exists
at the IMP Boats property. The waste at the IMP Boats property has been graded and leveled. The
volume of the waste is unknown due to a lack of depth information. The waste is estimated to
cover approximately 10 acres.
2.7 REMAINING PROPERTIES FOR REMEDIATION
The number of properties remaining to be remediated was determined from existing sample results.
All properties that exceed the PRGs for arsenic and/or lead will be remediated to below the PRG.
Development of screening criteria is discussed in Section 3.3. The methodology and calculations
for the determination of the remaining properties for remediation is detailed in Appendix B,
The analysis in Appendix B determined that approximately 2,684 properties have been sampled.
Of those, approximately 1,242 properties would require remediation as they are above the lead
PRG. Of these 1,242 properties, TCRA removals were performed on 129 properties in 2006/2007
and 350 additional TCRA removals will be performed through 2017. This brings the total number
of residential properties requiring remediation to 763.
Additionally, it is estimated that 300 residential properties remain to be sampled. Given that 1,242
of 2,684 properties sampled exceeded PRGs, the same exceedance ratio (46.3 percent) was
assumed for the remaining properties. Thus, for the FS 139 of the remaining properties to be
sampled were assumed to require remediation. It is important to note that this estimate of future
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properties that will exceed screening criteria was only used for costing purposes and is not an
actual representation of projected human health risks for unsampled properties.
Therefore, approximately 902 properties require remediation (763 that have been sampled plus
139 assumed from properties remaining to be sampled).
The volume of material to be excavated from properties investigated by HGL was based on
excavating to the extent of the sample cell dimensions to the required depth within properties that
exceeded PRGs (Section 3.3).
For properties investigated by Tetra Tech, Inc., the areas of the properties were not consistently
defined; therefore, to estimate a removal volume for this FS, HGL calculated an average
exceedance area based on per-property removals from properties investigated by HGL.
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Introduction
~ D fc a '—*• Action
| , Background ; | objcctives j
Remedial
Action
Technology !
Screening t"
Alternative
Screening
Detailed
Screening
Criteria
Detailed
Analysis
3.0 REMEDIAL ACTION OBJECTIVES
According to the National Contingency Plan (NCP) [40 Code of Federal Regulations [CFR]
300.430(a)(l)(i)], the goal of the remedy selection process is "'to select remedies that are protective
of human health and the environment, maintain protection over time, and minimize untreated
waste." To that end, RAOs are media-specific and source-specific general statements of cleanup
goals to achieve completion of a remedial action (RA) that is protective of human health and the
environment. These objectives are typically expressed in terms of the contaminant, the
concentration of the contaminant, and the exposure route and receptor.
RAOs are typically developed from three components of information: exposure pathways, COPC
concentrations that are protective of human health (PRGs), and tentatively identified ARARs.
A summary of exposure pathways is provided in the HHRA, details of the development of PRG
concentrations is provided in the memo in Appendix C, and the evaluation of ARARs is provided
in Section 3.1. These inputs provide the basis for determining whether protection of human health
is achieved for a remedial alternative.
The following sections present the ARARs, PRGs, and the subsequent RAOs that have been
identified for the site.
3.1 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
EPA and KDHE have tentatively identified regulations that may be applicable or relevant and
appropriate to the Site. Appendix A provides the initial identification and detailed description of
ARARs for the implementation of an RA at the Site as provided by EPA and KDHE. Final ARARs
will be set forth in the Record of Decision (ROD) as performance standards for development of
the remedial design and subsequent RA implementation.
Implementation of on-site remedial actions for the site would not require federal, state, or local
permits in accordance with Section 121(e) of CERCLA. Necessary on-site RAs could include not
only the contaminated area within the site boundary but also all areas in very close proximity to
the contamination found at the site. The response must comply with all substantive requirements
that are '"applicable" or "relevant and appropriate." Off-site actions such as hauling, disposal, and
borrow source development would not only require compliance with applicable requirements, but
compliance with both substantive and administrative components of the applicable regulations as
well. Appendix A contains a summary of the scope and intent of ARARs with regard to on-site
and off-site actions.
3.1.1 Definition of ARARs
Section 121(d) of CERCLA, 42 United States Code (U.S.C.) § 9621(d), the NCP, 40 CFR Part
300 (1990), and guidance and policy issued by EPA require that RAs under CERCLA comply with
substantive provisions of ARARs from state and federal environmental laws, and state facility
siting laws during and at the completion of the RA. ARARs are designated as either "applicable"
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or ''relevant and appropriate." according to EPA guidance. If a state or federal environmental law-
is determined to be either applicable or relevant and appropriate, compliance with the substantive
requirements of that ARAR are mandatory under CERCLA and the NCP. Compliance with
ARARs is threshold criteria that any selected remedy must meet unless a legal waiver as provided
by CERCLA Section 121(d) (4) is invoked.
Applicable Requirements
Applicable requirements specifically refer to cleanup standards, standards of control, and other
substantive requirements, criteria, or limitations promulgated under federal environmental laws or
state environmental and facility siting laws. These requirements address a hazardous substance,
pollutant, contaminant, remedial action, location, or other circumstance found at a CERCLA site.
Relevant and Appropriate Requirements
Relevant and appropriate requirements specifically refer to cleanup standards, standards of control,
and other substantive requirements, criteria, or limitations promulgated under federal
environmental laws or state environmental or facility siting laws. These requirements are not
directly applicable to hazardous substances, pollutants, contaminants, RAs, locations, or other
circumstances at a CERCLA site, but address problems or situations sufficiently similar (relevant)
to those encountered at the CERCLA site such that their use is well suited to the particular site.
The determination that a requirement is relevant and appropriate is a two-step process that consists
of: (1) the determination if a requirement is relevant; and, (2) the determination if a requirement is
appropriate. In general, this involves a comparison of a number of site-specific factors, including
an examination of the purpose of the requirement and the purpose of the proposed CERCLA action,
the medium and substances regulated by the requirement and the proposed RA, the actions or
activities regulated by the requirement and the RA, and the potential use of resources addressed in
the requirement and the RA. When the analysis results in a determination that a requirement is
both relevant and appropriate, such a requirement must be complied with to the same degree as if
it were applicable (EPA, 1988).
Other Requirements to be Considered
Many state requirements listed as ARARs are promulgated with identical or nearly identical
requirements to federal law pursuant to delegated environmental programs administered by EPA
and the state. The preamble to the NCP provides that such a situation results in citation to the state
provision and treatment of the provision as a federal requirement.
Also contained in this list are policies, guidance, or other sources of information which are "To Be
Considered" in the selection of the remedy and implementation of the ROD. Although not
enforceable requirements, these documents are important sources of information that EPA and the
state may consider during selection of the remedy, especially in regard to the evaluation of public
health and environmental risks, or which will be referred to, as appropriate, in selecting and
developing cleanup actions [40 CFR § 300.400(g)(3), 40 CFR § 300.415(i)].
Waivers of Specific ARARs
CERCLA Section 121(d)(4) authorizes that any ARAR may be waived under one of the following
six conditions if the protection of human health and the environment is assured:
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1) It is part of a total remedial action that will attain such level or standard of control when
completed (i.e. interim action waiver).
2) Compliance with the ARAR at a given site will result in greater risk to human health and
the environment than alternative options that do not comply with the ARAR.
3) Compliance with such a requirement is technically impracticable from an engineering
perspective.
4) The remedial action will attain a standard or performance equivalent to that required by the
ARARs through use of another method or approach.
5) The ARAR in question is a state standard and the state has not consistently applied (or
demonstrated the intention to consistently apply) the ARAR in similar circumstances at
other sites.
6) In meeting the ARAR, the selected RA will not provide a balance between the need for
protection of public health and welfare and the environment at the site and the availability
of Superfund monies to respond to other facilities.
3.1.2 Identification of ARARs
ARARs are defined as chemical-, location-, or action-specific. An ARAR can be one or a
combination of all three types of ARARs.
Chemical-specific requirements address chemical or physical characteristics of compounds or
substances on sites. These values establish acceptable amounts or concentrations of chemicals that
may be found in or discharged to the ambient environment.
' Location-specific requirements are restrictions placed upon the concentrations of hazardous
substances or the conduct of cleanup activities because they are in specific locations.
Location-specific ARARs relate to the geographical or physical positions of sites, rather than to
the nature of contaminants at sites.
Action-specific requirements are usually technology-based or activity-based requirements or
limitations on actions taken with respect to hazardous substances, pollutants, or contaminants. A
given cleanup activity will trigger an action-specific requirement. Such requirements do not
themselves determine the cleanup alternative but define how chosen cleanup methods should
be performed.
3.2 DEVELOPMENT OF REMEDIAL ACTION OBJECTIVES
According to the NCP [40 CFR 300.430(a)(l )(i)], the goal of the remedy selection process is "to
select remedies that are protective of human health and the environment, maintain protection over
time, and minimize untreated waste." RAOs are medium-specific and source-specific goals to be
achieved through completion of a RA that are protective of human health and the environment.
These objectives typically are expressed in terms of the contaminant, the concentration of the
contaminant, and the exposure route and receptor. They provide the basis for determining whether
protection of human health and the environment is achieved for a remedial alternative.
RAOs are typically developed by evaluating several sources of information, including results of
the HHRA, PRG determinations, and preliminarily identified ARARs. During development of the
I
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RAOs, other remedial goals and interests may be considered that have been expressed by various
Site stakeholders. Although these goals are not considered requirements pursuant to the NCP
(40 CFR 300), they may serve to guide the remedial development process. The RAOs provide the
foundation for the numerical cleanup levels (PRGs), and remediation alternatives, which will be
established by EPA in the ROD for the Site.
The preliminary RAOs identified for protection of human health at the Site are:
• Reduce the risk of exposure of young children to lead such that an individual child, or
group of similarly exposed children, have no greater than a 5 percent chance of having a
blood-lead level exceeding 10//g/dL.
• Reduce the risk of exposure to soils containing arsenic such that levels do not exceed the
carcinogenic risk of lxl 0"4 and a non-cancer total HI of 1.
3.3 PRELIMINARY REMEDIATION GOALS
PRGs are used to establish an acceptable contaminant level or range of levels for each exposure
route. PRGs are developed on the basis of chemical-specific ARARs, when available, or calculated
from site-specific risk factors. PRGs should result in residual risks consistent with NCP
requirements for protection of human health and the environment. A PRG may undergo refinement
during the RL/FS process, taking a number of other considerations into account, ultimately
resulting in a final remediation goal. These PRGs are the presumptive cleanup levels for the
purpose of the report. Though, final cleanup levels are determined when the remedy is selected in
the ROD.
EPA's risk assessment contractor SRC prepared a memorandum (dated May 18, 2016) that
developed PRGs for protection of residents from lead and arsenic in surface soils at the Site. This
Memorandum is presented in Appendix C of this FS report and is summarized below. The PRGs
were calculated for lead using the IEUBK model and for arsenic using EPA guidance.
The standard model developed by EPA to assess the risks of lead exposure in residential children
is the IEUBK model (EPA, 1994). This model requires input data on the levels of lead in various
environmental media at a specific location, and on the amount of these media contacted by a child
living at that location. These input data were the same parameters used in the HHRA in the RI.
The model then calculates the expected distribution of BLLs, and estimates the probability that
any random child might have a BLL over 10 |.ig/dL. The probability of having a BLL above 10
ug/dL is referred to as P10. The PRG for lead was calculated with the IEUBK model by finding
the concentration of lead in soil that yields a P10 value equal to EPA's health-based goal of P10 <
5 percent. The calculated PRG for lead in residential soil using inductively couple plasma (ICP)
was 423 ppm. This corresponds to a PRG of 366 ppm in the bulk soil analyzed using x-ray
fluorescence (XRF).
The PRG for arsenic was calculated in accordance with EPA guidance (EPA, 1991). The same
equations used in the HHRA (HGL, 2016) to calculate non-cancer hazard and cancer risk
attributable to a specified EPC of a chemical were re-arranged to solve for the concentration of
arsenic that corresponds to a specified target level. For arsenic, PRG values were calculated for
both non-cancer effects and cancer effects. Since the calculated non-cancer PRG is the most
conservative value compared to the cancer PRG based on a target risk of 1E-04, the non-cancer
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PRG was selected. The calculated PRG for arsenic in soil measured using ICP is 35 mg/kg. This
corresponds to a PRG of 32 mg/kg in soil analyzed using XRF.
EPA has chosen to adopt the EPA May 2016 non-carcinogenic RSLs as the PRGs for lead
(400 ppm) and arsenic (35 ppm). Remediation of properties with soil lead contamination at
400 ppm or greater and soil arsenic contamination at 35 ppm or greater is anticipated to bring the
yard-wide average below the PRGs. The remediation of surface soils at or above PRGs is
anticipated to reduce child BLLs to meet the RAOs and provide a protective remedy for the
community.
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Introduction
Site i
Background j *;
Remedial
Action
Objectives
Technology j J Alternative
Screening i Screening
Detailed
Screening
Criteria
Detailed
Analysis
4.0 IDENTIFICATION AND SCREENING OF GENERAL RESPONSE
ACTIONS, REMEDIAL TECHNOLOGIES, AND PROCESS
OPTIONS
4.1 OVERVIEW
This section identifies GRAs, remedial technologies, and process options that are potentially useful
to address the preliminary RAOs identified in Section 3.0 for contaminated surface soil. Screening
of the GRAs, remedial technologies, and process options is then performed in accordance with the
NCP to retain representative technologies and process options that can be assembled into remedial
alternatives as discussed in Section 5.
The identification and screening process consists of the following general steps:
• Develop GRAs for the contaminated media that will satisfy the RAOs identified in
Section 3.2.
• Compile remedial technologies and process options for each GRA that are potentially
viable for remediation of the contaminated media.
• Screen the remedial technologies and process options with respect to technical
implementability for the contaminated media at the site. Technologies and process options
that are not technically implementable relative to the contaminated media are eliminated
from further consideration in this FS.
• Evaluate and screen the retained remedial technologies and process options with respect to
effectiveness, ease of implementability, and relative cost. Technologies and process
options that have low effectiveness, low implementability, or high cost relative to the
contaminated media are eliminated from further consideration in this FS.
• Combine and assemble the retained technologies and process options for the contaminated
media into sitewide remedial alternatives as presented in Section 5.0.
This section categorizes the contaminated media and evaluates GRAs, technologies, and process
options that are potentially viable for addressing the RAOs and ARARs discussed in Section 3.0.
4.2 GENERAL RESPONSE ACTIONS
GRAs are initial broad response actions considered to address the preliminary RAOs for the
contaminated media identified as a concern at Former United Zinc. GRAs include several remedial
categories, such as containment, removal, disposal, and treatment of contamination within the
media. Site-specific GRAs are first developed to satisfy the preliminary RAOs for the
contaminated media and then are evaluated as part of the identification and screening of remedial
technologies and process options for the contaminated media.
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The GRAs considered for remediation of the contaminant media (soil) are:
No Action
• Institutional Controls
• Public Health Education
• Excavation
• Disposal
• Capping Technologies
• Stabilization
4.2.1 No Action
No action leaves contaminant media in their existing condition with no control or cleanup planned.
In accordance with the NCP, this GRA must be considered to provide a baseline against which
other options can be compared.
4.2.2 Institutional Controls
Institutional controls (TC) are non-engineered instruments, such as administrative and/or legal
controls, that help to minimize the potential for human exposure to contamination and/or protect
the integrity of a remedy. ICs work by limiting land or resource use and by providing information
that helps modify or guide human behavior at a site. ICs are developed to reduce or prevent
exposure to contamination in soil and dust and to protect the remedy where wastes are left in place.
Therefore, ICs are included in this section along with engineered technologies. The following
categories of IC mechanisms are discussed in this Final FS: Proprietary Controls, Government
Controls, Enforcement and Permit Tools with IC Component, Informational Devices, and Access
and Legal Restrictions.
4.2.2.1 Proprietary Controls
Proprietary controls are based on State law and use a variety of tools to prohibit activities that may
compromise the effectiveness of the remedy or restrict activities or future uses of resources that
may result in unacceptable risk to human health or the environment. They may also be used to
provide site access for operation and maintenance activities. The most common examples of
proprietary controls are easements and restrictive covenants that control certain uses of the
property. This type of IC "runs with the land" and is binding on subsequent purchasers of the
property. This type of IC is not presently being used to control activities at the Site.
4.2.2.2 Government Controls
Government controls impose land or resource restrictions using the authority of an existing unit of
government. Typical examples of government controls include zoning, building codes, and other
ordinances. Zoning is an exercise of police power, which is defined as the authority of the
government to exercise controls to protect the public's health, safety and welfare. Zoning
ordinances typically consist of a map indicating the various land use zones in the community and
set forth the regulations for the development of land. Zoning can serve as an effective IC when a
large number of properties are affected by the remedy. Local governments may also adopt building
codes or other ordinances to protect the public. They may require property owners seeking a
building permit for construction activities in a particular area to be notified of contamination and
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informed of any relevant management requirements for the contamination. Such measures could
be used to prohibit certain types of construction (such as excavation) that would result in
unacceptable exposures. Other types of local ordinances could address requirements for property
owners that rent properties to ensure that their properties do not pose an unacceptable health risk
to their tenants. Local ordinances could also require lead hazards at properties to be mitigated
or abated.
4.2.2.3 Enforcement and Permit Tools with IC Components
Enforcement and permit tools with IC components include orders, permits, and consent decrees.
These instruments may be issued unilaterally or negotiated to compel a party to limit certain site
activities as well as ensure the performance of affirmative obligations. Enforcement orders could
potentially be used to enable EPA to obtain access to properties to sample the soil.
4.2.2.4 Informational Devices
Informational devices provide information or notification about whether a remedy is operating as
designed or that residual or contained contamination may remain on site. Typical information
devices include state and local registries, deed notices, and advisories. Deed notices are filed in
the local land records but, unlike proprietary controls, are not intended to convey an interest in real
property. Consequently, such notices do not serve as enforceable restrictions on the future use of
the property. However, a deed notice does provide notice to anyone reviewing the chain of title
that the property either is, or was, contaminated and whether there may be other restrictions on the
property. The state or local governments could establish and maintain a registry that contains
' information concerning the properties at the site such as the status of soil sampling or soil
remediation indicating that the property does not present a hazard.
4.2.2.5 Access and Legal Restrictions
Physical restrictions, such as fencing, do not have applicability to existing residential homes.
Physical restrictions that limit access of young children to contaminated soil in residential
properties are not practical. Likewise, legal restrictions are not easily implemented and sometimes
are not permanent or enforceable for residential properties.
4.2.3 Public Health Education
Public health education involves distribution of information about contaminant exposure to people
in areas affected by metals in soils. Education can alert residents to the issues of exposure routes,
sources of contaminants, people at risk, and preventative measures. Educating citizens living in
residences with metals in soils can be used as a supplemental action to reduce exposure and
decrease risk. Specific education activities that may prove effective at reducing exposures include:
Providing community education through meetings and literature.
• Distributing fact sheets containing information on controlling lead exposure.
Establishing public information centers that may distribute written information on
controlling lead hazards or respond to questions from the public concerning lead hazards.
• Providing lead hazard information to the public through public media (television, radio,
newspapers, internet).
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Education, especially if it is the primary means of reaching remediation goals, must be an ongoing
process. A limitation to public education is that educational programs require not only the
cooperation of public health institutions, but public cooperation as well, to be successful. In
addition, public concern and awareness may wane with time unless a continual mechanism of
public education is in place. Additionally, education activities conducted over a long period of
time can become expensive. Typically, the EPA prefers that health education is not a stand-alone
remedy, but is used only as a supplemental activity in conjunction with an engineered action.
Health education activities are useful to help address initial site risks as the remedy is implemented,
and then could be phased out as cleanup of the contamination is completed.
4.2.4 Excavation
Excavation prevents human contact with soils through physical removal of contaminated soils,
which will be disposed of. Residential soils can be either partially or totally removed. Soil
excavation may be difficult and costly, particularly if properties are confined, inaccessible, steeply
sloped, or contain trees, shrubs, walkways, and driveways.
4-2.4.1 Partial Removal
Partial removal of soils refers to excavation of portions of properties containing concentrations of
lead above the action level and leaving behind soils with concentrations of lead below the action
level. Portions of a property, but not the entire property, may contain soil with lead above the PRG.
Partial removal of soils may be appropriate for these properties. The limitation of partial
excavation is the need for extensive testing to carefully delineate the soils to be removed. However,
the cost for testing may be offset by the lower removal, transportation, and disposal costs for
smaller quantities of soil. All excavated soils require appropriate disposal.
4.2.4.2 Complete Removal
Complete removal is the excavation of soil to a predetermined depth for entire properties.
Complete excavation may not be appropriate because soils containing low concentrations of lead
with little associated risk are removed, along with soils containing higher lead concentrations. In
addition, complete removal may result in more unavoidable disturbance/disruption to property
such as destruction of flower beds, gardens, and other sensitive areas that could be avoided if soil
testing indicates some areas of the property contain lead concentrations that are below PRGs.
Complete soil removal may be most appropriate where the majority of the properties contain soil
contamination above the PRG, and the extensive sampling associated with partial removal may be
eliminated. EPA has data indicating that many of the properties with soil concentrations above the
PRGs also have areas of their properties below the PRG, and a complete removal of soils from
properties may not be necessary.
4.2.5 Disposal
Disposal options must be considered with either partial or total excavation. The metals-
contaminated soils removed from residential areas will require disposal in a secure facility. Several
options exist for disposal of lead-contaminated soil from the site and are discussed in the following
paragraphs.
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4.2.5.1 New Repository
A soil repository could be constructed on an existing area within or near the Superfund site. The
repository, which would be covered and/or revegetated, would allow for disposal of soils in a
controlled environment, minimizing transport of lead. The primary limitations for this technology
is land availability and long term maintenance. Additionally, if the EPA constructed a discrete
on-site repository for lead- contaminated soil disposal, the facility may require long-term operation
and maintenance (O&M) by the State of Kansas or through a permanent and enforceable agreement
with the property owner.
4.2.5.2 Sanitary Landfill
Soils could also be disposed in off-site sanitary landfills for use as daily cover or as a special waste.
The advantage of using existing landfills is the elimination of design and construction of a soil
repository and long term O&M. The limitations of using an off-site disposal facility are possible
regulatory constraints and cost. Costs for off-site disposal could be greater than on-site disposal
due to the additional transportation expense and tipping fees at the landfill. Use as daily cover
could reduce cost by lowering or eliminating tipping fees and reducing the tax burden. Another
disadvantage to disposal in a sanitary landfill may be a limitation in the capacity of the landfill
used for the soil disposal. Additionally, the soils require testing prior to disposal using the toxicity
characteristic leaching procedure (TCLF). If soils fail the TCLP test for lead, pretreatment would
be required before landfdl disposal. Because of the potentially large quantities of soil to be
generated from excavation activities, pretreatment of soil before disposal may be difficult to
implement, as well as cost prohibitive.
4.2.5.3 Commercial Backfill
The soil excavated from the residential properties in Iola potentially could be used as beneficial
fill in a commercial land use project, if it can be demonstrated that there would be no unacceptable
risk to human health or the environment. While the lead-contaminated soil presents a hazard to
humans, especially children in residential settings, no significant risks would be created in a
commercial or industrial setting if the soil is properly placed and appropriate ICs are placed on the
disposal property.
4.2.6 Capping Technologies
Capping prevents direct human contact with waste. The technologies used for capping include:
. Soil
• Geosynthetic materials
• Vegetation
Capping technologies could be used separately or in combination, at individual properties, in a
central soil repository, or in other land use projects, to prevent human contact with metals in soil.
Each of the capping technologies is described in the following subsections.
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4.2.6.1 Soil Capping
Soil caps are constructed using either simple topsoil covers or low permeability clay layers to
prevent human contact and transport of soils off site. Simple topsoil caps could be used at
individual properties to cover contaminated soil with a protective layer, preventing human contact
with the covered contaminated soil. The advantage of topsoil capping is that contaminated soils
remain in place, eliminating excavation, transport, and disposal costs. However, in-place capping
would raise the property level 6 to 12 inches, which creates problems in correct contouring to
existing driveways, walkways, and below grade window openings of homes. At large properties,
capping could be used effectively in combination with excavation to achieve proper final grading
of the property around existing structures.
Low permeability clay caps, although not applicable for residential properties, may be used as final
cover for soil disposal areas. These types of soil covers are typically used for preventing infiltration
of water into a contaminated soil disposal pile and to control future contaminant migration from
the soil disposal area.
4.2.6.2 Geosvnthetic Materials
Geosynthetic materials can consist of geotextile fabrics and geomembrane barriers. Geotextile
fabrics are woven from synthetic material and made to withstand both chemical degradation and
biodegradation. The fabric is laid over untreated or undisturbed soils, effectively separating them
from clean fill material. In residential soils, geotextile materials can be used as either a physical or
visual barrier to separate the clean soil cover from underlying contaminated soil. The advantage
of these barriers is that a resident digging in a remediated property with contamination at depth
would become aware of the contamination by the presence of the barrier.
Geomembrane barriers also have applicability as cover material over a soil disposal area to prevent
surface water infiltration and control surface migration of contaminants. These types of covers,
however, are significantly costlier than soil covers.
4.2.6.3 Vegetation
Vegetative covers, such as sod, can prevent human contact with soils by creating a physical banner.
Roots from cover plants hold the soil in place, preventing erosion and off-site transport by surface
runoff or wind. Vegetative covers may be appropriate alone for soils with low concentrations of
metals. Vegetative covers may also be used in conjunction with clay caps, clean fill (dust control),
or geotextile fabrics. The advantage of a vegetative cover is that grass grows well in the Iola area
and, with proper maintenance, can be an effective barrier. The limitation of a vegetative cover is
that routine maintenance (i.e., mowing, watering, and fertilizing) is necessary to maintain the
cover. An additional disadvantage of a grass-only cover is that the protective layer is very thin,
and without proper maintenance, the grass can die and contaminated soil can be readily re-exposed.
4.2.7 Stablization
Stabilization refers to treatment of soils with chemical agents to either fix metals in place or form
complexes that make metals less toxic. Two methods of stabilization appropriate for lead
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HGL—Feasibility Study, Former United Zinc—Iota, KS
contamination are pozzolanic stabilization and phosphate addition. These technologies are both
routinely used as treatment technologies in certain applications. Each stabilization method is
described in the following subsections.
4.2.7.1 Pozzolanic Stablizntion
Pozzolanic stabilization of residential soils is the addition of a solidifying agent, such as Portland
cement or fly ash, with soils to form a monolith, similar to concrete. The pozzolan is added in
place by introduction of a slurry mixture into the soil with auger mixing. The monolith created
would reduce teachability and mobility of metals in soils by reducing soil particle surface area and
inhibiting human contact by encapsulating contaminants in soil. The advantage of pozzolanic
stabilization is that treatment materials are inexpensive and readily available. The limitations with
in-place pozzolanic stabilization include increased material volume, which would change the
elevation of properties. Since paving properties is not generally acceptable to residents, this
technology will not be further evaluated for application in residential properties.
4.2.7.2 Phosphate Stabilization
Phosphate stabilization is a chemical stabilization procedure in which phosphate salts are added to
soils in either solid or liquid form and mixed with the soil. Phosphate ions combine with lead to
form the less soluble lead phosphate complexes. Although the metals are not removed from the
property, they become less bioavailable to humans since the lead that occurs in the soil as
lead-phosphate is less likely to be absorbed by the body when ingested.
Phosphate can be added to the soil in the form of a phosphoric acid gel, triple-super phosphate, or
phosphate rock. For purposes of developing an alternative for this Final FS, phosphate stabilization
would consist of adding phosphorus in the form of phosphoric acid gel along with potassium
chloride (KC1) to the residential soils. This combination is intended to react with lead in the soil
to form the extremely insoluble chloropyromorphite, thus rendering the lead unavailable for
leaching and less bioavailable to humans. Following application of the phosphoric acid, lime
would be added to raise the soil pH to acceptable levels and the property would be sodded. An
advantage of phosphate stabilization is that a limited amount of soil would have to be removed.
Limitations of phosphate stabilization include: (1) pilot scale studies performed at other sites have
demonstrated that in the short-term, phosphate stabilization may reduce the bioavailability of lead
by 30 to 50 percent (Mosby, et al., 2006), thus limiting its applicability to properties with high lead
concentrations; (2) its long-term effectiveness is inconclusive; (3) the application of phosphoric
acid to residential soils to reduce the bioavailability of lead has not been implemented on a large
scale at residential properties which could raise public concerns; and (4) a large amount of
phosphoric acid would be transported and used in residential areas, which could result in increased
short-term risks during implementation.
4.3 SCREENING OF REMEDIAL TECHNOLOGIES AND PROCESS OPTIONS
Feasible remedial technologies and associated process options for the contaminated media were
primarily identified using the Federal Remediation Technologies Roundtable (FRTR)
Remediation Technologies Screening Matrix and Reference Guide, Version 4.0 (FRTR, 2002).
U.S. EPA Region 7
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HGL—Feasibility Study. Former United Zinc—Iota. KS
GRAs have been identified to satisfy the RAOs established for the site. The GRAs include no-
action, ICs, public health education, excavation, disposal, capping, and stabilization. Specific
process options under these GRAs have also been identified and preliminarily screened. Remedial
technologies include excavation and removal, stabilization and capping. Process options for
excavation and removal involve partial excavation of a property. Capping involves placing a
protective barrier over the contaminated soil using soil, geosynthetics, or vegetation. Stabilization
involves mixing of contaminated soil with amendments to make heavy metals less bioavailable
and less leaehable. The screening evaluation was based on technical and administrative
implementability, effectiveness, and relative cost. The screening process of the remedial
technologies and process options is discussed in this section.
The remedial technologies in this section have been screened and identified for further
consideration in developing remedial alternatives to satisfy the RAOs.
4.3.1 No-Action
The "no-action" GRA is required as a baseline alternative against which the effectiveness of the
other alternatives can be compared. Under this alternative, no remedial actions are taken at the site.
Current risks posed from contaminants at the site remain unmitigated, uncontrolled, and
umnanaged. Actions taken to reduce the potential for exposure (for example, site fencing, public
education, etc.) are not included as a component of the no-action alternative.
4.3.2 Institutional Controls
• Proprietary controls are difficult to implement because it is necessary for the restrictions to
extend beyond the period of the RA and the EPA does not have a property interest at the
site. This type of 1C is not presently being used to control activities at the Former United
Zinc Site but may become useful in the future and will be carried forward for possible
incorporation into a remedial alternative.
• Government Controls - Government controls that impose land restrictions using the
authority of an existing unit of government are applicable to the Former United Zinc.
Typical examples of government controls include zoning, building codes, and other
ordinances. Although zoning can serve as an effective IC when a large number of properties
are affected by the remedy, a zoning ordinance that would restrict use of existing residential
properties at the Site may not be readily implementable and will not be earned forward for
incorporation into a remedial alternative.
• Enforcement and permit tools - Enforcement and permit tools with IC components include
orders, permits, and consent decrees. Enforcement orders could potentially be used to
enable EPA to obtain access to properties to sample or remediate the soil. Although EPA
may eventually use enforcement orders to obtain access to sample properties, enforcement
orders will not be carried forward for incorporation into a remedial alternative
• Informational Devices - Informational devices provide information about the Site to
property owners. Informational devices will be carried toward for incorporation into the
remedial alternatives. An information device that will be carried through for incorporation
into the alternatives is establishment of a local registry that contains information
concerning soil sampling and soil remediation indicating that the property does not present
a hazard.
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HGL—Feasibility Stmly, Former United Zinc—Ma, KS
4.3.3 Public Health Education
Public health education includes providing community education through meetings and
literature, distributing fact sheets containing information on controlling lead exposure;
establishing public information centers that may distribute written information on controlling
lead hazards or respond to questions from the public concerning lead hazards; and providing
lead hazard information to the public through public media (television, radio, newspapers,
internet). Public health education is an effective means of controlling exposure to lead and will
be carried forward for incorporation into the remedial alternatives,
4.3.4 Excavation
Excavation of contaminated soil from residential properties is an accepted and highly utilized
technology for addressing site risks. Excavation is easily implementable with readily available
equipment. For puiposes of this report the excavation process option includes backfilling
excavated properties with clean soil. This technology will be carried forward for consideration in
developing remedial alternatives to address Site risks.
4.3.5 Disposal
Disposal of contaminated soil excavated from residential properties is an accepted and highly
utilized technology for addressing site risks. Disposal is easily implementable with readily
available equipment. Several options have been identified for disposal of the excavated
contaminated soil. For purposes of this FS, the excavation process option includes transportation
' of the excavated soil to a sanitary landfill for use as landfill cover. The nearby sanitary landfills
where the excavated soil could be used for daily cover include the Coffey County Landfill located
in Burlington or the Greenwood County Landfill located in Eureka. This technology will be carried
forward for consideration in developing remedial alternatives to address Site risks.
4.3.6 Capping Technologies
Capping of large residential properties with clean topsoil to reduce exposures to contamination is
less costly than excavation and disposal, yet still may be as protective in preventing exposure.
Other types of capping, such as paving, are not practical for residential property soil contamination.
Capping with topsoil will be retained for consideration in developing remedial alternatives to
address Site risks.
Geomembrane barriers and low permeable clay caps have applicability for cover material over the
soil disposal area to prevent surface water infiltration and control surface migration of
contaminants. Geotextile fabrics can also be used as a physical barrier in residential properties to
separate clean fill from contaminated soil at the bottom of excavations. These types of technologies
will be retained for consideration during remedial alternative development, to address the soil
disposal areas, and in some instances, in residential properties.
Vegetative covers are not considered protective when used alone in residential properties and will
not be retained for consideration in developing remedial alternatives for residential properties.
f
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HCL—Feasibility Study. Former United Ztite—Ioht, KS
Vegetative covers are applicable for use in capping excavated soil at disposal areas and are retained
for further consideration in those applications.
4.3.7 Stabilization
Pozzolonic stabilization is not an appropriate technology for residential soil in that it essentially
turns the soil into a concrete slab. This technology will not be considered further.
Previous pilot scale studies have demonstrated that phosphate stabilization may reduce the
bioavailability of lead by 30 to 50 percent in some soils. However, the long-term effectiveness of
phosphate stabilization to reduce the bioavailability of lead in soils has not been demonstrated.
While not fully proven as effective, this technology will be retained for further consideration in a
remedial alternative.
4.4 RETAINED GRAs, REMEDIAL TECHNOLOGIES, AND PROCESS OPTIONS
Based on the results of the initial screening process described in Section 4.3, a reduced number of
remedial technologies and process options for the contaminated media were retained for further
evaluation and the development of RA alternatives. Other technologies were eliminated as either
not technically practical or not cost effective for the Site. These retained remedial technologies
and process options are presented in Table 4,1.
The retained remedial technologies and process options are assembled into remedial alternatives
in Section 5.0.
Table 4.1
Retained Remedial Technologies and Process Options
General Rc$ponse~Actioii j
¦M-' : "¥
< - ^ - -
- '-i*£ ¦ ' . ' - ¦¦*?
=: Remedial Technology#
"-!HSPr .
Process Option .
-iF JF -.a
No Action
None
No action
Institutional Controls
Informational Devices
Soil Sampling and Remediation Registry
Proprietary Controls
Easements, Environmental Covenants,
Deed Notices
Public Health Education
Community Education
Fact Sheets, Public Information Centers,
Media Outreach
Excavation
Excavation
Partial excavation of soil that exceed PRGs
Disposal
Disposal
Disposal of impacted soil at a sanitary
landfill for use as soil cover
Capping Teclinologies
Soil Capping
Using soil cover to cap contaminated areas
Geosythetic Materials
Using low permeability clay and/or
geomembranes
Stabilization
Phosphate Stabilization
Reducing Bioavailabilty of Lead with
amendments
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HGL— Feasibility Study, Former United Zim -Ioiu. KS
Introduction
Site
Background
Remedial
Action
Objectives
Technology i
Screening ~
Alternative
Screening
Detailed
Screening
Criteria
Detailed
Analysis
5.0 DEVELOPMENT AND SCREENING OF REMEDIAL
ALTERNATIVES
5.1 OVERVIEW
In this section, RA alternatives (herein referred to as remedial alternatives) are assembled by
combining the retained remedial technologies and process options presented in Section 4.0 for the
contaminated medium. Remedial alternatives are developed from either stand-alone process
options or combinations of the retained process options. The process options would be
implemented in combinations for the contaminated medium of concern that would:
• Achieve threshold evaluation criteria (protection of human health and the environment and
compliance with ARARs).
Achieve preliminary RAOs to the extent possible (Section 3.2).
• Achieve COPC concentration levels below PRGs to the extent possible (Section 3.3).
Alternatives must represent the full range of possible remedies from No Action to treatment and/or
removal. To avoid considering all possible combinations of technologies, criteria are applied to
limit the number of alternatives to only the most effective and implementable. These remedial
alternatives are then screened using a qualitative process with standard evaluation to determine
overall effectiveness, implementability, and cost. The purpose of alternative screening is to reduce
the number of remedial alternatives retained for detailed analysis in the FS. Alternatives will be a
combination of those technologies and process options listed in Table 4.1.
5.2 ASSUMPTIONS AFFECTING DEVELOPMENT OF REMEDIAL
ALTERNATIVES
Fundamental assumptions affect the development of remedial alternatives evaluated (other than
the No Action alternative). These assumptions are driven by requirements of the RAOs identified
in Section 3.2 and site limitations and constraints that cannot be overcome by using one or more
remedial technology/process options as described in Section 4. These fundamental assumptions
were taken into consideration during development of remedial alternatives and include the items
listed in Table 5.1.
Table 5.1
Assumptions Affecting Development of Remedial Alternatives
Fundamental Assumption
a Rationale *
Partial Excavation and disposal volumes
will be dynamic, based on XRF screening
results.
Once identified, cells that exceed PRGs are partially excavated, the
excavation extents will be screened with XRF to ensure the extent
is below the PRCs of arsenic and lead.
Removal actions addressing arsenic and
lead-contaminated soil would also address
soil contaminated with other metals.
Based on analytical data, a fraction of the properties that have
arsenic or lead-contaminated soil also have other metals
concentrations requiring remediation.
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5.3 DESCRIPTION OF REMEDIAL ALTERNATIVES
The following alternatives are based on the applicable technologies identified in Section 4 and
were developed to most efficiently meet the RAOs and satisfy the ARARs. Also included for
comparison is the No Action alternative. Additionally, the alternatives were developed to
specifically address contamination resulting from smelter operations.
5.3.1 Alternative 1: No Action
The EPA is required by the NCP, 40 C.F.R. § 300.430(e)(6) to evaluate the No Action alternative.
The No Action alternative may be appropriate at some sites where an RA has already occurred that
has reduced risks to human health. Although an RA is occurring at the Site, residual risks to human
health remain as documented in the HHRA. Under the No Action alternative, the existing RA
would cease. The concentrations of lead in surface soils would remain at levels above the PRG of
400 ppm that present a risk to human health, particularly for young children residing at the Site.
The No Action alternative is therefore not protective of human health.
5.3.2 Alternative 2: Excavation of Soils with XRF Confirmation to Depth, Disposal,
Backfill with Clean Fill and Topsoil, Vegetative Cover, Institutional Controls, and
Public Health Education
Under this alternative, residential property soils with at least one non-drip zone sample greater
than the 400 ppm lead PRG and 35 ppm arsenic PRG would be excavated and disposed of off Site.
The existing soil sampling program would be continued to identify residential properties that
require excavation. Properties where only the drip zone soil exceeds 400 ppm lead would not be
addressed under this action, as it is likely that contamination is from lead-based paint from the
property building and not from smelter activities. Excavated soil would be disposed at the existing
sanitary landfill in Eureka, Kansas or at a new repository. A local lead hazard registry would be
established and operated to further control residual risks associated with soil contamination below
PRGs and other non-soil sources of lead.
HGL estimates that 902 properties contain soils with lead and/or arsenic concentrations that exceed
the respective PRGs of 400 and 35 ppm and have not been remediated. The projected remediation
pace is approximately 425 properties per year. If the soil remediation continues at this pace, the
RA would be completed in approximately 3 years. The time to implement this alternative could be
shortened or lengthened by reducing or increasing the pace of soil remediation.
Excavation
This alternative includes the excavation and removal of soil, and backfilling the excavation with
clean soil imported from an approved borrow source. Excavation of a property would be triggered
when the result for a soil sample for the property contains greater than 400 ppm lead and/or 35 ppm
arsenic. Properties with at least one cell sample testing greater than the PRGs would have all cells
exceeding criteria and possibly the drip zones remediated. The drip zones would be remediated if
the lead concentration is greater than 400 ppm or the arsenic concentration is above 35 ppm.
Soil would be excavated using lightweight excavation equipment and hand tools in the portions of
the property where the surface soil exceeds PRGs. Excavation depth would be dynamic based on
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HCL—Feasibility Sriuly, Fanner United Zinc—lola, KS
XRF screening and would continue until reaching residual lead/arsenic concentrations of less than
400/35 ppm in the excavation. Excavation depth at properties could vary from 2 inches to
24 inches. An average depth of 12 inches was used for volume estimation and costing purposes
for this FS. Fugitive dust would be controlled and monitored during soil excavation using dust
suppression techniques. Following excavation, clean fill and topsoil would be used to replace the
soil removed, returning the property to its original elevation and grade.
Vegetation Cover
After the topsoil layer has been emplaced, the excavated area would be sodded to restore the lawn.
However, hydro-seeding or conventional seeding may be used in areas of properties with special
considerations at the property owner's request.
Disposal
Three options are available to accommodate disposal of the excavated soils. The first option would
be to haul the contaminated soil to an off-site sanitary landfill for use as daily cover and/or for
disposal. Before the soil is hauled to the landfill, it is placed in a staging area and TCLP tests are
conducted to ensure the soil is non-hazardous. To date, no soil samples from any staging area at
the Site have failed TCLP. If the soil does fail TCLP for lead, it would be treated on site with a
stabilization agent, and would then be resampled and analyzed for lead using TCLP analysis. This
procedure would be repeated until the soils pass the lead TCLP threshold limit to allow soil to be
disposed of as non-hazardous material at the landfill.
The second option would be to use the soil excavated from the residential properties as beneficial
fill in the construction of a commercial or industrial facility. Lead-contaminated soils at the site
are considered a risk to human health only in residential settings. Removed soils could be safely
used in a commercial/industrial setting without creating a risk to human health. Constructed
engineering features may also be necessary to protect the fill area. Long-term maintenance of any
constructed engineering features would also be necessary.
Option three would consist of constructing a new repository on public or privately owned land.
Public land would offer the advantage of control over future use of the property. Significant design
and site preparation may be required for construction of the facility. This option is limited by the
availability of land and willingness of landowners to maintain such a facility.
Institutional Controls
Informational Devices
Information devices that will be implemented at the Site include operation of a local registry
containing lead hazard information on properties at the Site. The registry would be operated by the
City of lola and would include information concerning the lead hazards at properties. Information
maintained in the registry may include, but not be limited to, whether lead concentrations in the
soil at a property exceeded PRGs, and if so, whether the soil has been remediated; and any other
pertinent information.
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IIGL—Feasibility Study, Former United Zinc—lola, KS
Proprietary Conlro/s
There may be a need for proprietary controls such as deed notices, easements, or environmental
covenants. These controls would be used only if necessary to provide protection for a specific
property.
Public Henlth Education
A public information center would be established in lola in cooperation with the KDHE. The
information center would have an ongoing lead hazard education program that would continue
through the completion of the remedial action. The public information centers would distribute
written information on controlling lead hazards and respond to questions from the public
concerning EPA response activities. Public health education activities providing community
education through distribution of fact sheets containing information on controlling lead exposure
would be conducted. EPA would provide continuing lead hazard information to the public through
public media (television, radio, newspapers, internet).
5.3.3 Alternative 3: In Situ Phosphate Stabilization; Excavation of Soils, Disposal, Backfill
with Clean Fill and Topsoil, Vegetative Cover, Institutional Controls, and Public
Health Education
This alternative involves a combination of excavation and in situ phosphate stabilization of soils
and high child impact areas found to contain lead concentrations above 400 ppm. An estimated
902 properties remain to be remediated that have lead concentrations greater than 400 ppm and/or
arsenic concentrations above 35 ppm. Because pilot studies at other sites estimated that the
bioavailability of lead can be reduced by 30 to 50 percent using phosphate amendments, it is
conservatively assumed that a phosphate amendment could only be effective at reducing risks
associated with lead concentrations in the soils by 30 percent. Consequently, phosphate
stabilization would be conducted only on soils with lead concentrations above 400 ppm but less
than 572 ppm. Properties with lead concentrations above 572 ppm lead or above 35 ppm for arsenic
would be excavated as described in Alternative 2.
The total number of residential properties with lead concentrations above 400 ppm and below the
effective stabilization level of 572 ppm is estimated to be approximately 452 properties. The
remaining 450 properties would be remediated as described in Alternative 2.
In addition, this alternative includes all other activities described in Alternative 2, including public
information and public health education.
Phosphate Stabilization
Under this alternative, all residential properties and residential-type properties (i.e., child care
facilities, parks, and playgrounds) with lead concentrations exceeding 400 ppm, but less than
572 ppm (the assumed concentration for costing purposes), would be treated with a phosphate
amendment to reduce the bioavailability of metals in the soil, thereby controlling the health risk to
children. Pilot studies scale studies performed at other sites soils indicated that 1.5 phosphoric acid
(weight, % phosphorus) would be the most effective amendment for reducing the bioavailability
of lead in soils. Consequently, this alternative will assume the phosphate amendment that is used
will be 1.5 phosphoric acid. This alternative would involve stabilizing metals in the soil by adding
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HGL—Feasibility Slucly, Former Untied Zinc—lola, KS
phosphate into the soil to a depth of 6 to 10 inches. It is anticipated that the phosphate, in the form
of phosphoric acid, would be roto-tilled into the soil, and allowed to stabilize for a few days. Then
lime would be added to the soil to raise the pH, and the lawn would be re-established. Fencing
would be installed and remain in place from the time of phosphoric acid application until the pH
of the soil returns to a neutral pH. Stabilization of a property would be performed on properties
when the highest measured non-drip zone sample for the property is greater than 400 ppm lead,
but less than the effective stabilization level (assumed to be 572 ppm for cost purposes.) A
long-term monitoring program would be instituted to assess the effectiveness of phosphate
stabilization. The program would include soil chemistry monitoring to assess the effects of natural
weathering and the long-term stability of the lead-phosphate minerals formed during phosphate
treatment. For costing purposes, 10 percent of the properties remediated using phosphate
stabilization will be tested at 6 months. 2 years, and 5 years.
Excavation
As with Alternative 2, this alternative includes the excavation and removal of soil, and backfilling
the excavation with clean soil. Excavation of a property would be triggered when the soil sample
result for the property contains greater than 572 ppm lead. Residential properties with at least one
cell sample testing greater than 572 ppm would have all cells exceeding criteria and possibly the
drip zones remediated. The drip zones would be remediated if the lead concentration is greater
than 400 ppm or the arsenic concentration is above 35 ppm, as phosphate mixing may not be
practical in these areas.
Soil would be excavated using lightweight excavation equipment and hand tools in the portions of
the property where the surface soil exceeds PRGs. Excavation depth would be dynamic based on
XRF screening and would continue until reaching residual lead/arsenic concentrations of less than
572/35 ppm in the excavation. Excavation depth at properties could vary from 2 inches to 24
inches. An average depth of 12 inches will be used for volume estimation purposes. Fugitive dust
would be controlled and monitored during soil excavation using dust suppression techniques.
Following excavation, clean Fill and topsoil would be used to replace the soil removed, returning
the property to its original elevation and grade.
Vegetative Cover
Vegetative cover would be implemented as described under Alternative 2.
Disposal
Disposal would be implemented as described under Alternative 2.
Institutional Controls
Institutional Controls would be implemented as described under Alternative 2.
Public Health Education
A public information center would be established and operated as described under Alternative 2.
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HGL—Feasibility Study. Former United Zinc—lehi. k'S
5.4 SCREENING EVALUATION OF ALTERNATIVES
The purpose of the screening evaluation is to reduce the number of proposed remedial alternatives
that undergo a more thorough and extensive analysis. Therefore, screened alternatives are
qualitatively evaluated using a smaller set of screening evaluation criteria than criteria used to
complete the detailed evaluation of retained alternatives after screening. Per the NCP guidance,
each of these proposed alternatives is screened using the short- and long-term aspects (where
applicable) of three broad criteria: effectiveness, implementability, and cost as described below.
Effectiveness
Effectiveness relates to the ability of the remedial alternative to satisfy screening evaluation criteria
detailed in Table 5.2.
Table 5.2
Effectiveness Criteria
Effectiveness Criteria
Overall protection of human health and the environment1
Compliance with ARARs1
Short-term effectiveness (during the remedial construction and implementation period)
Long-term effectiveness and permanence (following remedial construction)
Reduction of toxicity, mobility, or volume through treatment
These criteria are referred 10 as "threslmkl criteria" thai an alternative must meet to be viable (except the "no action"
alternative).
Effectiveness of each of the proposed alternatives is judged against the five effectiveness screening
criteria using the qualitative ratings system presented in Table 5.3.
Table 5.3
Effectiveness Qualitative Ratings System
Effectiveness Ratings Categories
©
None
O
Low
©
Low to moderate
©
Moderate
0
Moderate to high
©
High
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HGL—Feasibility Study, Former United Zinc—loin, KS
Implementability
Implementability relates to the ability of the remedial alternative to satisfy screening evaluation
criteria detailed in Table 5.4.
Tabic 5.4
Iniplementnbility Criteria
Criteria
Description
Technical feasibility
Ability to construct, reliably operate, and meet technology-specific
regulations for process options until a remedial action is complete
Ability to operate, maintain, replace, and monitor technical components
after the remedial action is complete
Administrative
feasibility
Ability to obtain approvals from other agencies
Availability and capacity of treatment, storage, and disposal services
Availability of property, specific materials and equipment, and technical
specialists required for a remedial action
Implementability of each of the proposed alternatives is judged against the screening criteria using
the qualitative ratings system presented in Table 5.5.
Table 5.5
Implementability Qualitative Ratings System
I
linplementability Ratings Categories
©
None
0
Low
©
Low to moderate
©
Moderate
o
Moderate to high
0
High
Determination that an alternative is not technically feasible would usually preclude it from further
consideration. Negative factors affecting administrative feasibility would normally involve
coordination steps to lessen the negative aspects of the alternative but would not necessarily
eliminate an alternative from consideration.
Cost
For the preliminary screening of alternatives, the relative cost of each alternative was used to rate
the alternatives. The cost ratings are as presented in Table 5.6 below.
)
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HCL—Feasibility Study, Former United Zinc-late. KS
Table 5.6 Cost Qualitative Ratings System
Cost Ratings Categories
$
Low
$$
Low to moderate
$$$
Moderate
$$$$
Moderate to high
High
Cost estimates were prepared to screen alternatives based on cost. Cost estimates have an expected
accuracy range between +50 percent and -30 percent of the actual costs and are presented in
Appendix D,
5.5 SUMMARY OF ALTERNATIVES SCREENING
Each alternative developed and described in Section 5.3 was evaluated to determine its overall
effectiveness, implementability, and cost using the qualitative ratings system discussed in
Section 5.4. Details on the alternative screening are presented in Section 7.0. This evaluation and
screening process is inherently qualitative in nature. The evaluation criteria described in
Section 5.4 are specified by EPA guidance (EPA, 1988); however, the degree to which the criteria
are weighted against each other are not specified. Determination of how the individual evaluation
criteria influence the overall rankings requires engineering judgment.
Generally, alternatives with similar scope and essential components would have overall rankings
that are similar, unless other considerations such as large differences in waste volumes or differing
construction durations exist between them. Factors that affect the tlireshold criteria (overall
protection of human health and the environment and compliance with ARARs) are given
considerable weight in the overall ranking for effectiveness since alternatives must fully meet these
criteria to be viable as a selected remedy.
Table 5.7 summarizes the results for the screening of alternatives for the site. The alternatives
screening process involves a qualitative assessment of the degree to which remedial alternatives
address evaluation criteria presented in Section 3.0. The numerical designations for the qualitative
ratings system used in this table are not used to quantitatively assess remedial alternatives (for
instance, rankings for an alternative are not additive). Generally, alternatives that have a low rating
for effectiveness and/or implementability coupled with a high cost would be eliminated from
further consideration. No remedial alternatives have been eliminated from further consideration
during this screening process.
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MCL—Feasibility Study. Former United Zinc—lota. KS
Table 5.7
Summary of Alternatives Screening
Alternative
Description
Effectiveness
Implementability
Approx. Cost
(Present Value
Dollars)
1
No Action
©
©
$
i
Excavation and Disposal with
Institutional Controls and Public
Health Education
0
0
$$$$
3
In Situ Phosphate Stabilization;
Excavation and Disposal with
Institutional Controls and Public
Health Education
©
©
$$$$$
Legend for Qualitative Ratings System:
Effectiveness and Implementahility Cost (Present Value Dollars)
©
None
©
None
o
Low
S
Low
0
Low to Moderate
$$
Low to Moderate
©
Moderate
$$$
Moderate
o
Moderate to High
$$$$
Moderate to High
0
High
$ss$s
High
5.6 ALTERNATIVES RETAINED FOR DETAILED ANALYSIS
Table 5.8 summarizes the remedial alternatives retained for detailed analysis in Section 7.0 of
this FS.
Table 5.8
Summary of Potential Remedial Alternatives
Alternative
Designation
Remedial Alternative Title
1
No Action
2
Excavation and Disposal with Institutional Controls and Public Health Education
3
In Situ Phosphate Stabilization; Excavation and Disposal with Institutional Controls and Public
Health Education
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HGL—Foisihiliiy Stiidw Former United Zinc— I old, KS
Introduction
i Site i !
p*: Background j"~*|
Remedial
Action
Objectives
Technology j Alternative
Screening i Screening
Detailed
Screening
Criteria
Detailed
Analysis
6.0 DEFINITION OF CRITERIA USED IN THE DETAILED ANALYSIS
OF RETAINED ALTERNATIVES
The remedial alternatives retained after completion of the preliminary alternative screening step
of the FS process (summarized in Section 5.0) are evaluated using nine evaluation criteria. These
criteria were developed to address statutory requirements and considerations for RAs in
accordance with the NCP and additional technical and policy considerations that have proven to
be important for selecting among remedial alternatives (EPA, 1988). Alternatives are further
developed and evaluated in Section 7.0. The following subsections describe the nine evaluation
criteria used in the detailed analysis of remedial alternatives and the priority in which the criteria
are considered.
6.1 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
Each alternative is assessed to determine whether it can provide adequate protection of human
health and the environment (short- and long-term) from unacceptable risks posed by hazardous
substances, pollutants, or contaminants present at the site. Evaluation of this criterion focuses on
how site risks are eliminated, reduced, or controlled through treatment, engineered controls, or
institutional controls and whether an alternative poses any unacceptable cross-media impacts.
6.2 COMPLIANCE WITH ARARS
For this criterion, each alternative is evaluated to determine j Criteria Used to
compliance with chemical-, location-, and action-specific Evaluate Remedial
ARARs. If the assessment indicates an ARAR will not be met, Alternatives Address i
then the basis for justifying one of the six ARAR waivers allowed Multiple Areas
under CERCLA (Table 6.1) is discussed. i
r.
6.3 LONG-TERM EFFECTIVENESS AND
PERMANENCE
• Protection of Human
Health and Environment
Long-term effectiveness evaluates the likelihood that the remedy
will be successful and the permanence that it affords. Factors to
be considered, as appropriate, include the following:
• Compliance with ARARs
• Long-Term Effectiveness
and Permanence
• Magnitude of residual risk remaining from untreated
waste or treatment residuals remaining at the conclusion
of the remedial activities. The characteristics of the
residuals are considered to the degree that they remain
hazardous, taking into account their toxicity, mobility, or
volume and propensity to bioaccumulate.
• Reduction of Toxicity,
Mobility, or Volume
through Treatment
• Short-Term Effectiveness
• Implementability
• Cost
• State Acceptance
• Community Acceptance
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• Adequacy and reliability of controls thai are used to manage treatment residuals and
untreated waste remaining at the Site. This factor includes an assessment of containment
systems and institutional controls to determine if they are sufficient to ensure that any
exposure to humans is within protective levels. This factor also addresses the long-term
reliability of management controls for providing continued protection from residuals, the
assessment of the potential need to replace technical components of the alternative, and the
potential exposure pathways and risks posed should the RA need replacement.
Table 6.1
ARAR Waivers
Waiver
Description
Interim Measures
The RA selected is only part of a total RA that will attain such level or
standard of control when completed. (CERCLA §121(d)(4)(A).)
Greater Risk to Health and
the Environment
Compliance with such requirement at the facility will result in greater risk
to human health and the environment than alternative options. (CERCLA
jj 121(d)(4)(B).)
Technical Impracticability
Compliance with such requirement is technically impracticable from an
engineering perspective. (CERCLA §121(d)(4)(C).)
Equivalent Standard of
Performance
The RA selected will attain a standard of performance that is equivalent to
that required under the otherwise applicable standard, requirement,
criteria, or limitation through use of another method or approach.
(CERCLA § 121(d)(4)(D).)
Inconsistent Application of
State Requirements
With respect to a state standard, requirement, criteria, or limitation, the
state has not consistently applied (or demonstrated the intention to
consistently apply) the standard, requirement, criteria, or limitation in
similar circumstances at other RAs. (CERCLA § 121 (d)(4)(E).)
Fund Balancing
In the case of a RA to be undertaken solely under Section 104 using the
fund, selection of a RA that attains such level or standard of control will
not provide a balance between the need for protection of public health and
welfare and the environment at the facility under consideration and the
availability of amounts from the fund to respond to other sites which
present or may present a threat to public health or welfare or the
environment, taking into consideration the relative immediacy of such
threats. (CERCLA §121(d)(4)(F).)
6.4 REDUCTION OF TOXICITY, MOBILITY, OR VOLUME THROUGH
TREATMENT
Each alternative is assessed for the degree to which it employs technology to permanently and
significantly reduce toxicity, mobility, or volume, including how treatment is used to address the
principal threats posed by the site. Factors to be considered, as appropriate, include the following:
• The treatment processes used and materials they will treat
• The amount of hazardous substances, pollutants, or contaminants that will be destroyed or
treated, including how the principal threat(s) will be addressed
• The degree of expected reduction in toxicity, mobility, or volume of the waste due to
treatment
• The degree to which the treatment is irreversible
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The type and quantity of residuals that will remain following treatment, considering the
persistence, toxicity, mobility, and propensity to bioaccumulate such hazardous substances
and their constituents
• Whether the alternative would satisfy the statutory preference for treatment as a principal
element of the RA
6.5 SHORT-TERM EFFECTIVENESS
This criterion reviews the effects of each alternative during the construction and implementation
phase of the RA until remedial response objectives are met. The short-term impacts of each
alternative are assessed, considering the following factors, as appropriate:
• Short-term risks that might be posed to the community during implementation of an
alternative
• Potential impacts on workers during RA and the effectiveness and reliability of protective
measures
• Potential adverse environmental impacts resulting from construction and implementation
of an alternative and the reliability of the available mitigation measures during
implementation in preventing or reducing the potential impacts
• Time until protection is achieved
6.6 IMPLEMENTABILITY
The technical and administrative feasibility of implementing an alternative and the availability
of various services and materials required during its implementation are evaluated under this
criterion. The ease or difficulty of implementing each alternative will be assessed by considering
the factors detailed in Table 6.2.
Table 6.2
Iniplenientability Factors to be Considered During Alternative Evaluation
. Criteria
C ii Factors to be-Considcred
S.fK ¦ ¦ Mif. ¦
Technical Feasibility
• Technical difficulties and unknowns associated with the construction and operation
of a technology.
• Reliability of the technology, focusing on technical problems that will lead to
schedule delays.
• Ease of undertaking additional RAs, including what, if any, future RAs would be
needed and the difficulty to implement additional RAs.
• Ability to monitor the effectiveness of the remedy, including an evaluation of risks
of exposure should monitoring be insufficient to detect a system failure.
Administrative Feasibility
• Activities needed to coordinate with other offices and agencies and the ability and
time required to obtain any necessary approvals and permits from other agencies
(for offsite actions).
Availability of Services
and Materials
• Availability of adequate off-site treatment, storage capacity, and disposal capacity
and services.
• Availability of necessary equipment and specialists and provisions to ensure any
necessary additional resources.
• Availability of services and materials plus the potential for obtaining competitive
bids, which is particularly important for innovative technologies.
• Availability of prospective technologies.
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6.7 COST
Types of costs that are assessed for each alternative include the following:
Capital costs
Annual O&M costs
• Periodic costs
• Present value of capital and annual O&M costs
Cost estimates are developed according to A Guide to Developing and Documenting Cost
Estimates during the Feasibility Study (EPA, 2000). Cost unit rates for excavation and disposal of
soil were based on the per property rate from the Omaha Lead FS conducted for EPA in 2009,
adjusted for inflation (Black and Veatcli, 2009). Flexibility is incorporated into each alternative
for the location of remedial facilities, the selection of cleanup levels, and the period in which RA
will be completed. Assumptions of the project scope and duration are defined for each alternative
to provide cost estimates for the various remedial alternatives. Important assumptions specific to
each alternative are summarized in the description of the alternative. Additional assumptions are
included in the detailed cost estimates in Appendix D.
The levels of detail employed in making these estimates are conceptual but are considered
appropriate for making choices between alternatives. The information provided in the cost estimate
is based on the best available information regarding the anticipated scope of the remedial
alternatives.
The costs are evaluated with respect to the following categories:
• Capital costs are those expenditures that are required to construct an RA. They are
exclusive of costs required to operate or maintain the action throughout its lifetime. Capital
costs consist primarily of expenditures initially incurred to build or install the RA
(e.g., excavation and backfilling of contaminated soil areas). Capital costs include all labor,
equipment, and material costs (including contractor markups, such as overhead and profit)
associated with activities, such as mobilization/demobilization; monitoring site work; and
disposal. Capital costs also include expenditures for professional/technical services that are
necessary to support construction of the RA.
• Annual O&M costs are those post-construction costs necessary to ensure or verify the
continued effectiveness of an RA. These costs are estimated mostly on an annual basis.
Annual O&M costs include all labor, equipment, and material costs (including contractor
markups, such as overhead and profit) associated with activities, such as monitoring and
maintenance. Annual O&M costs also include expenditures for professional/technical
services necessary to support O&M activities.
• Periodic costs are those costs that occur only once every few years (such as Five-Year
Reviews, and capital costs) or expenditures that occur only once during the entire O&M
period or remedial time frame (such as site closeout, remedy failure/replacement). These
costs may be either capital or O&M costs but, because of their periodic nature, it is more
practical to consider them separately from other capital or O&M costs in the estimating
process.
• The present value of each alternative provides the basis for the cost comparison. The
present value cost represents the amount of money that, if invested in the initial year of the
RA at a given rate, would provide the funds required to make future payments to cover all
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costs associated with the RA over its planned life. Future O&M and periodic costs are
included and reduced by a present value discount rate. The use of discount rales for present
value cost analyses is stated in the preamble to the NCP (55 FR 8722) and in OSWER
Directive 9355.3-20, Revisions to Office of Management and Budget (OMB) Circular
A-94 on Guidelines and Discount Rates for Benefit-Cost Analysis, (EPA, 1993). As
outlined in A Guide to Developing and Documenting Cost Estimates dining the Feasibility
Study (EPA, 2000), a 7 percent real discount rate should be applied over the period of
evaluation for each alternative. The real discount rate is defined as:
Real discount rate = [(1+nominal discount rate)/( 1 +inflation rate)] - I
The nominal discount rate is typically called the nominal interest rate (e.g., on bonds).
A 7 percent real discount rate not considering inflation would yield a nominal discount rate of
7 percent. In addition, a 7 percent real discount rate considering inflation would result in a nominal
discount rate greater than 7 percent.
The 20-year nominal treasury interest rates (OMB, 2015) for the last 12 years (no data is available
prior to 2004 for the 20-year interest rate) have been less than 6 percent, and inflation over the
same period has averaged around 3 percent per year. Thus, the 7 percent real discount rate is not
appropriate to use for alternative evaluation cost estimating within this FS at this time for the
reasons cited. An inflation rate of 2.24 percent (average of 20 years of Engineering News Record
Construction Cost Indices rounded to nearest hundredth of a percent) and a nominal discount
(interest) rate of 5 percent (average of the available data for nominal 30-year treasury interest rates
rounded to the nearest quarter of a percent) will be applied separately in the determination of net
present value.
6.8 STATE ACCEPTANCE
This criterion evaluates the technical and administrative issues and concerns the state may have
regarding each of the alternatives. Assessment of state concerns will be completed after comments
on the FS and proposed plan have been received by EPA and are addressed in the ROD. Thus,
state acceptance is not considered in the detailed evaluation of alternatives presented in this FS.
6.9 COMMUNITY ACCEPTANCE
Assessment of concerns from the public will be completed after comments on the FS and proposed
plan have been received by EPA and are addressed in the ROD responsiveness summary. Thus,
community acceptance is not considered in the detailed evaluation of alternatives presented in
this FS.
6.10 CRITERIA PRIORITIES
The nine evaluation criteria are separated into three groups to establish priority among these
criteria during detailed evaluation of the remedial alternatives as detailed in Table 6.3.
For this FS, threshold criteria are evaluated for each alternative using an acceptable or
unacceptable pass/fail rating system, and balancing criteria are evaluated for each alternative using
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a qualitative rating system. The ratings system defines the ability of the alternative to satisfy each
of the threshold and balancing criteria, with exception to cost. Cost is rated based on the actual
cost provided in the cost estimate for each alternative. The qualitative ratings system definitions
for the threshold and balancing criteria are provided in Table 6.4.
Table 6.3
Criteria Priorities
Group
Criteria
Definition
Threshold Criteria
• Overall Protection of Human Health and the
Environment
• Compliance with ARARs
Must be satisfied by the remedial
alternative being considered as the
preferred remedy.
Balancing Criteria
• Long-Term Effectiveness and Permanence
• Reduction of Toxicity, Mobility, or Volume
through Treatment
• Short-Term Effectiveness
• Implementability
• Cost
Technical criteria evaluated among
those alternatives satisfying the
threshold criteria.
Modifying Criteria
* State Acceptance
• Community Acceptance
Not evaluated in this FS; will be
evaluated after comments are received
on the FS and proposed plan.
Table 6.4
Ratings System for Evaluation of Alternatives
Ratings Categories
for Threshold
Criteria
Ratings Categories for
Balancing Criteria
— Unacceptable
© None
"4" Acceptable
© Low
© Low to moderate
© Moderate
O Moderate to high
© High
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I ' Site 1_J ^ion3' Technology j__ Alternative |_J |_J Detailed
Objectives
..... juc i i . .. i tfLiiiKjiuKY ; Miiermjuve i • ,
n ro uc ,on p*j Background p| objCrtivcs Screening r* Screening ^*\ H Analysis
7.0 DETAILED ANALYSIS OF RETAINED ALTERNATIVES
7.1 OVERVIEW
In this section, remedial alternatives retained in Section 5 undergo detailed analysis. During
detailed analysis, each alternative is assessed using the two threshold criteria and five balancing
criteria presented in Section 6. The results of the detailed analysis for each remedial alternative are
then arrayed to perform a comparative analysis of the alternatives and identify the key tradeoffs
between them. The following alternatives were retained for detailed analysis:
Alternative 1: No Action
Alternative 2: Excavation of Soils with XRF Confirmation to Depth, Disposal, Backfill with
Clean Fill and Topsoil, Vegetative Cover, Institutional Controls, and Public
Health Education
Alternative 3: In Situ Phosphate Stabilization; Excavation of Soils, Disposal, Backfill with
Clean Fill and Topsoil, Vegetative Cover, Institutional Controls, and Public
Health Education
7.2 SECONDARY ASSUMPTIONS AFFECTING DETAILED ANALYSIS OF
REMEDIAL ALTERNATIVES
Fundamental assumptions for all remedial alternatives used during alternative development and
screening were presented in Section 5. However, there are numerous secondary assumptions that
affect the detailed analysis of alternatives but are not fundamental controlling considerations.
These assumptions are driven mainly by site limitations and constraints that cannot be overcome
by using one or more retained remedial technology/process options as described in Section 4. Some
of these secondary assumptions are grouped into distinct categories and include the items listed in
Table 7.1.
Table 7.1
Secondary Assumptions Affecting Refinement and
Detailed Analysis of Remedial Alternatives
Secondary
Assumption
Category
Secondary Assumption
Description
Rationale
Number of Properties
Requiring Sampling
and Remediation
The number of properties
requiring sampling and
remediation is based on available
information.
Analysis of the existing sample results through
2016 and 2010 census data provides a reasonable
approach for determining the number of properties
remaining to be sampled and remediated.
Volume Remediated at
each Property
Volume at each property to be
remediated is based on sample
cell dimensions measured by
HGL to an average depth of 12
inches.
Remediation volume is based on average
exceedance areas of properties investigated by
HGL. The average exceedance area was applied to
properties investigated by Tetra Tech, Inc. as the
sample cell areas were not consistently defined.
Average depth is assumed to be 12 inches, but may
vary as much as 2 to 24 inches.
\
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7.3 ALTERNATIVES FOR CONTAMINATED SOIL i
7,3.1 Alternative 1: No Action
7.3.1.1 Remedial Alternative Description
Alternative 1 is required by the NCP to provide an environmental baseline against which impacts
of the various remedial alternatives can be compared. The only actions that would be implemented
for Alternative 1 are completion of Five-Year Reviews as required by the NCP. There would be
no change in the soil contaminant concentrations because no treatment, containment, or removal
of contaminated soil is included in this alternative.
7.3.1.2 Overall Protection of Human Health and the Environment
This alternative does not provide protection for the environment or residents in Iola because no
actions are taken to mitigate the exposure to lead-contaminated soil. The overall rating on this
criterion for Alternative 1 is unacceptable.
7.3.1.3 Compliance with ARARs
The location-specific and action-specific ARARs are not applicable to this alternative. This
alternative would not meet federal '"To Be Considered" criteria. EPA (40 CFR Part 745) and HUD
(24 CFR Part 35) regulations. ARARs evaluated for this alternative are included in Appendix A.
The overall rating on this criterion for Alternative 1 is unacceptable.
7.3.1.4 Long-Term Effectiveness and Permanence '
This alternative provides no effectiveness for the protection of health and environment over the
long term. The public is still exposed to elevated levels of lead. The overall rating on this criterion
for Alternative 1 is none.
7.3.1.5 Reduction of Toxicity. Mobility, or Volume through Treatment
There is no reduction in the toxicity, mobility, or volume of contamination under the No Action
alternative. The overall rating on this criterion for Alternative 1 is none.
7.3.1.6 Short-Term Effectiveness
No risk is imposed on the remedial action workers during the short term. The public and
environment are still exposed to the same levels of lead. The overall rating on this criterion for
Alternative 1 is none.
7.3.1.7 Implenientability
This alternative does not require implementation. The overall rating on this criterion for
Alternative 1 is high.
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7.3.1.8 Cost
The costs associated with the No Action alternative would be for the Five-Year Review. Detailed
cost estimates for this alternative are included in Appendix D. The present value cost for
Alternative 1 is $27,820.
7.3.2 Alternative 2: Excavation of Soils with XRF Confirmation to Depth, Disposal,
Backfill with Clean Fill and Topsoil, Vegetative Cover, Institutional Controls, and
Public Health Education
7.3.2.1 Summary of Remedial Alternative
Alternative 2 provides protection of human health through RA to limit exposure, limit transport of
contaminants, and institutional controls. Residential properties that have or are expected to have
soil lead concentrations above the cleanup level of 400 ppm for lead and 35 ppm for arsenic would
be excavated to dynamic depths based on XRF screening results. Once excavation extents are
confirmed to be below PRGs, the excavation area will be backfilled and restored. Excavated soil
will be stabilized (if needed to meet TCLP requirements) before off-site disposal at a landfill or
contaminated soil repository. Public education would be conducted. The components of
Alternative 2 are described in detail in Section 5.3.2. Assuming 902 properties remain to be
remediated and average areas of exceedance, and an average 12-inch depth of excavation and
average of 124.35 cubic yards per property requires remediation. Thus, a total of 112,000 cubic
yards would require excavation, disposal, and replacement. Clean fill and topsoil would be used
to replace soil removed after excavation, returning the property to its original elevation and grade.
7.3.2.2 Overall Protection of Human Health and the Environment
Excavation of soils at properties with soil-lead concentrations greater than 400 ppm would
permanently remove contaminated soil, thereby mitigating the exposure pathway between
lead- contaminated soils and children. Under Alternative 2, excavation would remove the potential
for exposure to all contaminated soils. Sanitary landfill, controlled fill areas, and soil repositories
can be designed and engineered to protect human health and the environment, including
controlling migration of contaminants into groundwater and surface water. With appropriate
precautions taken during staging and hauling of the soil, there will be no unacceptable impact
associated with implementation of the excavation and soil replacement elements of this alternative.
This alternative would control the significant exposure pathways associated with contaminated
residential soils. Once residential soils excavation, soil replacement, and revegetation is complete,
the soils are properly disposed, the information registry is implemented, and the ongoing education
program is continued, risks associated with lead- contaminated residential soils will be controlled.
The overall rating on this criterion for Alternative 2 is acceptable.
7.3.2.3 Compliance with ARARs
As discussed previously, there are no promulgated laws or standards for lead- contaminated soil.
Site-specific action levels (PRGs) of 400 ppm and 35 ppm, respectively, for lead and arsenic in
soils is being advanced in this Final FS to provide for the protection of human health at this Site
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based on information from the HHRA and the Development of PRGs memo included in
Appendix C.
Alternative 2 would comply with the chemical- and location-specific ARARs and To Be
Considered criteria identified in Section 3.1. Because there would not be any structures constructed
in waterways or in areas of critical habitat to threatened or endangered species, Alternative 2 would
comply with the Endangered Species Act and the Rivers and Harbors Act. Excavation of properties
would be performed in a manner to minimize the effect on historical landmarks at the Site and
would comply with the National Historic Preservation Act.
The RA would comply with requirements of the Clean Water Act. Storm water discharge permits
requirements are not applicable to excavation of residential properties since excavation of
residential properties would not disturb more than one acre. However, there may be larger areas
such as parks and churches that require stormwater permits as the properties exceed one acre.
Landfills, controlled fills, or repositories where the excavated soil is disposed of would comply
with the discharge permit regulations in 40 CFR Part 122.
ARARs evaluated for this alternative are included in Appendix A. The overall rating on this
criterion for Alternative 2 is acceptable.
7.3.2.4 Long-Term Effectiveness and Permanence
The residual risks (the risk remaining after implementation) would be significantly reduced under
this alternative. Properties with lead and arsenic concentrations greater than 400 and 35 ppm,
respectively, would have the soil removed to reach a residual concentration of less than the PRG.
The removal of contaminated soil, replacement with clean backfill, and revegetation ensures that
future potential for exposure will be significantly reduced. The overall rating on this criterion for
Alternative 2 is moderate to high.
7.3.2.5 Reduction of Toxicity. Mobility, or Volume through Treatment
This alternative would significantly reduce the mobility of the COPCs by consolidation and
containment of the contaminated soils in a landfill or other disposal area. Although the exposure
pathway would be eliminated or minimized, the toxicity and volume of the material would not be
reduced. Proper maintenance at the existing sanitary landfill or construction and long term
maintenance of a controlled fill area or soil repository are important components of this alternative
that ensure a significant reduction of mobility. The overall rating on this criterion for Alternative 2
is low to moderate.
7.3.2.6 Short-Term Effectiveness
This alternative is protective in the short term. Although lead-laden dust could be generated during
excavation, dust suppression would be implemented for the protection of community and workers
during the remedial action. The alternative would be lengthy to implement for all affected
residences, requiring several years to complete. The average length of time to complete all
elements of soil replacement and restoration at any one residence could be several weeks; however
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residential exposure to dust would be minimal since dust suppression would be implemented when
disturbance of contaminated soil is occurring.
Contaminated soils could be used as daily cover in a sanitary landfill, used as beneficial fill, or
placed in a permanent repository. Disposal of the soil in a landfill or repository would have no
negative environmental impacts provided storm water controls and other design and engineering
controls are achieved and maintained. The overall rating on this criterion for Alternative 2
is moderate.
7.3.2.7 Implementabilitv
This alternative is readily implementable. Excavation methods, backfilling, and revegetation are
typical engineering activities. Experience gained during previous EPA RAs has shown that this
action is readily implementable. The information and education components of this alternative are
implementable, but require cooperation and action by the local government entities. The overall
rating on this criterion for Alternative 2 is moderate to high.
7.3.2.8 Cost
This alternative is expected to have approximate capital costs of $18.9 million, as shown in
Appendix D, based on the estimate of $15,181 per property for excavation, transport, backfill, dust
suppression, and restoration.
Annual costs for Alternative 2 are shown in Appendix D. The annual costs during years one
through 10 are estimated to be approximately $1 10,935 per year and are associated with
maintaining the information registry and ongoing public health education. The present worth value
of Alternative 2 over a 10-year period is estimated to be $19.8 million. The cost estimate is within
an accuracy range of +50 percent to -30 percent.
7.3.3 Alternative 3: In Situ Phosphate Stabilization; Excavation of Soils, Disposal, Backfill
with Clean Fill and Topsoil, Vegetative Cover, Institutional Controls, and Public
Health Education
In situ treatment is generally done by mixing the amendment with the soil with a rototiller or
excavator bucket. In situ treatment would not require disposal; rather, the treated soil would be left
in place. Treatment should reduce the risk of exposure to contaminated soils because the COPCs
in soils would be converted to relatively insoluble minerals, resulting in reduced bioavailability.
7.3.3.1 Summary of Remedial Alternative
Alternative 3 provides protection of human health through remedial action to limit exposure, limit
transport of contaminants, and institutional controls. Alternative 3 has the same remedy
components as Alternative 2, except that the properties with lead concentrations above 400 ppm,
but below 572 ppm, will be stabilized in situ using phosphate amendment.
As described in Alternative 2, an estimated 902 properties remain to be remediated that have lead
concentrations greater than 400 ppm and/or arsenic concentrations above 35 ppm. The total
number of residential properties with lead concentrations above 400 ppm and below the effective
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stabilization level of 572 ppm is estimated to be approximately 4^2 properties. The remaining
450 properties would be excavated as described in Alternative 2.
A study conducted in 2007 by Black & Veatcli (under contract to EPA) regarding the use of this
technology at the Omaha Lead Site indicates concern about implementability, cost effectiveness,
and community acceptance in a residential setting, as well as the long-term presence of lead in the
soil even if its bioavailability has been reduced, and the need for continued monitoring (Black &
Veatch, 2007).
7.3.3.2 Overall Protection of Human Health and the Environment
Treatment of soils with lead concentrations between 400 ppm and 572 ppm would control the
primary threat to human health. Excavation of soils at properties with soil-lead concentrations
greater than 572 ppm would permanently remove contaminated soil, thereby breaking the exposure
pathway between lead- contaminated soils and children. Under Alternative 3, excavation would
remove the potential for exposure to the most highly contaminated soils, and phosphate treatment
of moderately contaminated soils will convert the lead into a form that would be less bioavailable,
reducing risk to humans.
Phosphate stabilization has not been used on a full-scale basis to remediate lead-contaminated soils
in a residential setting. The long-term effectiveness of phosphate treatment has not been
demonstrated, and future soil chemistry testing of treated soils would be required to assure
continued protectiveness of this process.
Sanitary landfill, controlled fill areas, and soil repositories can be designed and engineered to
protect human health and the environment, including controlling migration of contaminants into
groundwater and surface water. With appropriate precautions taken during staging and hauling of
the soil, there will be no unacceptable impact associated with implementation of the excavation
and soil replacement elements of this alternative.
This alternative would eliminate the significant exposure pathways associated with contaminated
residential soils. Once residential soils are treated with the phosphate amendment; or removed
through excavation and properly disposed of, risks associated with lead-contaminated residential
soils will be controlled. The phosphate stabilization and excavation and disposal alternative is
protective of human health and the environment if the phosphate treatment significantly reduces
the bioavailability of lead on a long term basis. The overall rating on this criterion for Alternative 3
is acceptable.
7.3.3.3 Compliance with ARARs
As discussed previously, there are no promulgated laws or standards for lead-contaminated soil.
Site-specific action levels (PRGs) of 400 ppm and 35 ppm, respectively, for lead and arsenic in
soils is being advanced in this Final FS to provide for the protection of human health at this site
based on information from the HHRA and the Development of PRGs memo included in
Appendix C.
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Alternative 3 would not comply with the To Be Considered criteria if the in situ phosphate
treatment was not effective in reducing the bioavailability of lead over a long period of time. Under
these circumstances, some residential properties would continue to have P10 values that would not
meet the EPA health-based goal of 5 percent. Because there would not be any structures
constructed in waterways or in areas of critical habitat to threatened or endangered species,
Alternative 2 would comply with the Endangered Species Act and the Rivers and Harbors Act.
Excavation of residential properties would be performed in a manner to minimize the effect on
historic landmarks at the Site and would comply with the National Historic Preservation Act.
The RA would comply with requirements of the Clean Water Act. Storm water discharge permits
requirements are not applicable to excavation of residential properties since excavation of
residential properties would not disturb more than one acre. Landfills, controlled fills, or
repositories where the excavated soil is disposed would comply with the discharge permit
regulations in 40 CFR Part 122.
ARARs evaluated for this alternative are included in Appendix A. The overall rating on this
criterion for Alternative 2 is acceptable.
7.3.3.4 Long-Term Effectiveness and Permanence
The residual risks (the risk remaining after implementation) would be significantly reduced under
the excavation portion of this alternative because soils exceeding 572 ppm for lead or 35 ppm for
arsenic would be excavated and removed. Effective treatment of soils from 400 to 572 ppm and
I permanent removal of excavated soils ensure that potential for future exposure will be significantly
reduced.
In situ phosphate stabilization of soils with soil lead levels between 400 and 572 ppm has not been
implemented at a residential site and the long-term effectiveness of phosphate stabilization has not
been completely demonstrated. Long-term monitoring would be required to demonstrate the
long-term effectiveness of this alternative. The overall rating on this criterion for Alternative 3
is moderate.
7.3.3.5 Reduction of Toxicity, Mobility, or Volume through Treatment
The treatment portion of this alternative would reduce the toxicity and mobility of the
contamination for those properties with lead contamination between 400 and 572 ppm. The volume
of the contaminated soils would not be reduced. However, the amount of soil requiring excavation
and disposal would be approximately 50 percent less than Alternative 2.
The excavation portion of this alternative would significantly reduce the mobility of the
contaminants of concern by consolidation of the contaminated soils in the landfill or other disposal
area. Although the exposure pathway would be eliminated or minimized, the toxicity and volume
of the material would not be reduced. Proper maintenance at the existing sanitary landfill or
construction and long-term maintenance of a controlled fill or soil repository are important
components of this alternative that ensure a significant reduction of mobility. The overall rating
on this criterion for Alternative 3 is moderate.
)
U.S. EPA Region 7
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HGL—Feasibility Slittly. Former United Zinc—loin, KS
7.3.3.6 Short-Term Effectiveness
The phosphate stabilization alternative may present significant risks to residents, workers, and the
community in the short term. Depending on the application method, there would he a risk to
workers from aerosol spray during application of the phosphoric acid. Workers would be required
to wear protective clothing, including respiratory protection, during the application of the
phosphoric acid. Workers may be exposed to phosphoric acid during transfer of acid from the
storage tanks to the transport trucks. There would be short-term risk to the public from transporting
large volumes of phosphoric acid through residential neighborhoods.
During the first 7 to 10 days after the addition of the phosphoric acid, the soil would have a low
pH near the surface which could cause skin irritation or burns and pose a hazard to human health.
Application of the phosphoric acid could also damage the exterior of the house, shrubs, or personal
property if the acid were not carefully applied to control aerosol dispersion. The property would
have to be fenced prior to the application of the phosphoric acid to keep people and pets off of the
property during treatment of the property. The fence would have to remain in place until the lime
is applied to raise the pH of the soil. Small animals and birds would still have access to the property
and contact with the soil prior to the application of the lime could pose a risk to them.
The excavation and disposal portion of this alternative is protective in the short term. Although
lead-laden dust could be generated during the excavation, dust suppression would be implemented
for protection of community and workers during remedial action. The alternative would be lengthy
to implement for all affected residences, requiring several years to complete. The length of time to
complete all elements of soil replacement and restoration could be several weeks; however
residential exposure to dust would be minimal since dust suppression would be implemented
during disturbance of contaminated soils.
The contaminated soils would continue to be used as a cover in a sanitary landfill or placed in a
controlled fill or permanent repository. Disposal of the soil in a landfill, controlled fill, or
repository would have no negative environmental impacts provided storm water controls and other
appropriate design and engineering controls are achieved and maintained. The overall rating on
this criterion for Alternative 3 is low to moderate.
7.3.3.7 Iniplementability
The iniplementability of the in situ phosphate treatment technology, which can achieve moderate
reduction, has not been tested at a residential property by EPA. This alternative would be
implementable, although the phosphate treatment portion of the alternative would require careful
planning. Phosphate application methods include the use of typical lawn or garden maintenance
equipment. The application of the phosphoric acid treatment on residential properties has not been
attempted on a large scale. This treatment alternative can cause skin irritation as well as damage
to the respiratory system of workers if not handled properly. Phosphoric acid is viscous, making
application difficult and it may crystallize in winter. Bulk storage facilities would be required and
the phosphoric acid would have to be transported to the properties in vehicles. Additional risks to
the public would include accidents involving the transport vehicles and chemical spills. If there is
excess phosphoric acid, disposal of the excess acid will require the selection of a treatment and
disposal facility or an agreement with the vendor to return the excess acid.
U.S. EPA Region 7
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NGL—Feasibility Study, Former United Zinc—Joltt. KS
Excavation methods, backfilling, and revegetation are typical engineering activities. Phosphate
treatment of residential soils has not been accomplished on a large scale in a residential area and
may not be easily implemented. The information and education component of this alternative is
implementable, but requires cooperation and action by local government entities. The overall
rating on this criterion for Alternative 3 is low to moderate.
7.3.3.8 Cost
Costs for Alternative 3 are presented in Appendix D. The excavation portion of this alternative is
expected to have capital costs of $6.8 million, based on the estimate of $15,181 per property for
excavation, transport, dust suppression, backfill, and restoration. The capital costs of in situ
phosphoric acid treatment and restoration is $18.8 million based on the estimate of $41,567 per
property for phosphoric acid treatment and site restoration. The total capital cost for this
alternative, including phosphate treatment and excavation, is estimated to be $36 million.
Annual costs for Alternative 3 are shown in Appendix D. The annual costs for years one through
10 are estimated to be approximately $110,935 and are associated with maintaining the
information registry and ongoing public health education. Annual costs for the long term
monitoring program for the properties treated with the phosphate amendment are an additional
$18,157 in years 2, 5, 10, 15, and 20. The present worth value of Alternative 3 is estimated to be
$36 million. The cost estimate is within an accuracy range of+50 percent to -30 percent. Detailed
cost estimates for this alternative are included in Appendix D.
7.4 COMPARATIVE ANALYSIS OF ALTERNATIVES
A comparative analysis of alternatives using each of the nine evaluation criteria, as required by
federal regulation, is presented in this section. The purpose of this analysis is to identify the
advantages and disadvantages of each alternative relative to the other alternatives. A separate
comparison of the alternatives is presented under the heading of each criterion.
7.4.1 Protection of Human Health and the Environment
Protection of human health and the environment is addressed to varying degrees by the three
evaluated alternatives. The No Action alternative would have no effect on contaminated soil.
Therefore, it does not address risks to human health.
As part of Alternatives 2 and 3, excavation provides protection of human health by reducing
exposure to metals in contaminated soils. Protection is provided by removing or covering the
contaminated soil from the exposure pathway and placement of clean soil. For both alternatives,
health education programs provide ongoing risk reduction.
Alternative 2 provides permanence through complete removal and containment of contaminated
soils at or above 400 ppm lead concentrations. Alternative 3 provides permanence through a
combination of excavation and soil replacement and immobilization of lead in phosphate-treated
contaminated soils. Permanence would be provided only if the phosphate stabilization remains
effective long-term.
U.S. EPA Region 7
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HGL—Feasibility Study, Former United Zinc—lata. KS
7.4.2 Compliance with ARARs
The No Action alternative would not meet ARARs. Alternative 2 complies with identified federal
and state ARARs and To Be Considered Criteria. Alternative 3 would comply with the To Be
Considered criteria if the phosphate treatment were effective in reducing the bioavailability of
lead, and would likely comply with identified federal and state ARARs.
Water quality criteria for Alternatives 2 and 3 would be met during excavation by using Best
Management Practices to minimize storm run-off and then seeding the property when the excavation
area is backfilled with clean soil. Excavated soils failing the TCLP limit would be treated with a lead
stabilization agent before final placement in the landfill. Best Management Practices would be
implemented to prevent storm runoff (benns, silt-fences, etc.) during implementation of the RA.
7.4.3 Long-Term Effectiveness and Permanence
Alternative 1 would not provide long-term effectiveness for the protection of health and
environment. Alternative 3 reduces risks through a combination of in situ treatment and excavation,
while Alternative 2 achieves risk reduction through excavation only. Both Alternatives 2 and 3
reduce risks for properties with soil lead and arsenic levels at or above 400 ppm and 35 ppm,
respectively, by using effective engineering controls. Previous studies are inconclusive as to
whether phosphate treatment results in long-term reduction in the bioavailability of lead in soils.
Treatment of residential soils using a phosphate amendment has not been implemented during a
full scale remediation project. Alternatives 2 and 3 also utilize an information registry and public
education to further control residual risks by raising the awareness of property owners of the hazards
present at the site.
7.4.4 Reduction of Toxicity, Mobility or Volume
There would be no reduction in the toxicity, mobility, or volume of contamination under the No
Action Alternative (Alternative 1). Alternative 2 would significantly reduce contaminant mobility
for residences with soils having lead and/or arsenic concentrations greater than 400 ppm and 35
ppm, respectively, through soil excavation and replacement. Alternative 3 would reduce toxicity
and mobility of contaminants through phosphate treatment of soils with lead concentrations
between 400 ppm and 572 ppm lead, and through the removal and replacement of excavated soils.
The volume of contaminants would not be reduced. Mobility of excavated materials placed in a
soil repository or landfill is greatly reduced due to the engineering features designed to contain the
contaminated soils. Under Alternatives 2 and 3, the excavated areas would be backfilled with
clean soil.
7.4.5 Short-Term Effectiveness
There would be no short-term risk to workers for Alternative 1 because no remediation efforts would
be performed. However, exposure pathways for the public and environment would remain.
Alternative 2 has short-term risks for the public, environment, and construction workers from
excavation and transportation efforts. Disturbed contaminated soil could enter the ambient air
during excavation and transportation. However, dust suppression would be implemented for the
U.S. EPA Region 7
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HCL—Feasibility Study, Former United Zinc—loin. KS
protection of the community and workers during the remedial action. The alternative would be
lengthy to implement for all affected residences, requiring several years to complete. However,
the length of time at any one residence during excavation would be minimal.
Alternative 3 has the same risks as Alternative 2 in addition to exposing workers, residents, and
animals to phosphoric acid and lime. Depending on the method of applying the phosphoric acid,
there would be a risk to workers and property from aerosol spray. Workers would be required to
wear protective clothing, including respiratory protection, during the application of the phosphoric
acid. Workers would also be exposed to phosphoric acid during transfer of phosphoric acid from
bulk storage facilities to the transport trucks. In addition, there would be increased risks to residents
from transporting bulk phosphoric acid through residential neighborhoods.
7.4.6 Implementability
Alternative 1 is highly implementable, requiring only Five-Year Reviews. Alternative 2 and the soil
excavation and disposal portion of Alternative 3 are readily implementable from an engineering
perspective. Excavation methods, backfilling, and revegetation are typical engineering controls.
The experience of previous and ongoing actions taken at the Site by the EPA has shown that this
alternative is readily implementable.
The phosphate treatment portion of Alternative 3 would be more difficult to implement. The
application of the phosphoric acid treatment on residential properties has not been attempted on a
large scale. This treatment alternative can cause skin irritation as well as damage to the respiratory
system of workers if not handled properly. Phosphoric acid is viscous, making application difficult
and it may crystallize in winter.
The phosphoric acid could damage the exterior of a home or personal property around the home if
the acid is not carefully applied. The property would have to be fenced prior to the application of
the phosphoric acid to restrict access to treated areas during treatment of the property. The fence
would have to remain in place until the lime was applied. Small animals and birds would still have
access to the property and contact with the soil prior to the application of the lime could pose a
risk to them.
7.4.7 Cost
The total present value of Alternative 1 is estimated to be $27,820. The total present value of
Alternative 2 is estimated to be $19,771,534. The total present value of Alternative 3 is estimated to
be $36,021,121. Detailed costs are presented in Appendix D.
No capital or O&M costs would be associated with Alternative 1 because no remedial actions would
be conducted. However, it is assumed that Five-Year Review costs would be associated with
Alternative 1. Alternatives 2 and 3 incur O&M costs for the informational bulletins provided to
residents, and the Five Year Review costs. Alternative 3 had additional reoccurring costs for the
long-term monitoring of the phosphate treatment.
\
U.S. EPA Region 7
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HGL—Feasibility Study. Former United Zinc—tola. KS
7.4.8 State Acceptance
State acceptance of the alternatives will be flilly determined after the public comment period closes
for the Proposed Plan and this FS.
7.4.9 Community Acceptance
Community acceptance of the alternatives will be fully determined after the public comment period
closes for this FS and for the Proposed Plan,
7.4.10 Detailed Analysis Summary
A summary of the detailed analysts of alternatives described above is presented in Table 7.2.
U.S. EPA Region 7
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HGL— Feasibility Study, Former United Zinc—Iota, KS
Table 7.2
Summary of Comparative Analysis of Alternatives for the
Former United Zinc Site
Threshold Criteria
Balancing Criteria
Remedial
Alternative
Description
Overall
Protection of
Human
Health and
the
Environment
Compliance
with
ARARs
Long-Term
Effectiveness
and
Permanence
Reduction of
Toxicity,
Mobility, or
Volume
through
Treatment
Short-Term
Effectiveness
lmplementability
Present
Value Cost
(Dollars)
1
No Action
—
—
O
O
O
0
$27,820
9
Excavation of Soils with XRF
Confirmation to Depth, Disposal,
Backfill with Clean Fill and
Topsoil, Vegetative Cover,
Institutional Controls, and Public
Health Education
+
+
O
0
©
O
$19,771,534
3
In situ phosphate Stabilization;
Excavation of Soils, Disposal,
Backfill with Clean Fill and
Topsoil, Vegetative Cover,
Institutional Controls, and Public
Health Education
+
+
©
©
©
©
$36,021,121
Notes:
1. The numerical designations for the qualitative ratings system used in this table are not used to quantitatively assess remedial alternatives (for instance, individual rankings for an alternative are not
additive).
2. Detailed cost spreadsheets (cost summaries, present value analyses, and cost worksheets) for each alternative are presented in Appendix D,
Legend for Qualitative Ratings Svstem:
Threshold Criteria
— Unacceptable
4" Acceptable
U.S. EPA Region 7
7-13
Balancing Criteria
(Excluding Cost)
© None
O Low
© Low to Moderate
©
Q
0
Moderate
Moderate to High
High
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HGL—Feasibility Study. Former Uuiieil Zitic—tola. KS
8.0 REFERENCES
Black & Veatch Special Projects Corporation ( Black & Veatch), 2007. Evaluation of Phosphate
Treatment of Residential Properties: Omaha Lead Site, Omaha, Nebraska. April 25.
Black & Veatch, 2009. Final Feasibility Study, Omaha Lead Site, Omaha, Nebraska. April.
Federal Remediation Technologies Roundtable (FRTR), 2002. Remediation Technologies
Screening Matrix and Reference Guide, Version 4.0.
(http://www.frtr.gov/matrix2/top_page.htnil).
HydroGeoLogic, Inc. (HGL), 2016. Revised Final Remedial Investigation Report, Former United
Zinc Site, lola, Kansas. May.
Mosby, Casteel, Yang, Gantzer (Mosby), 2006. Final Report Lead Bioavailability Study
Phosphate Treatment of Lead-Contaminated Soils, Joplin, Missouri, Jasper County
Superfund Site. Prepared for Missouri Department of natural Resources Hazardous Waste
Program, Jefferson City, MO and U.S. Environmental Protection Agency Region VI1,
Kansas City, KS, December.
Office of Management and Budget (OMB), 2015. Table of Past Years Discount Rates from
Appendix C of OMB Circular No. A-94. (https://www.whitehouse.gov/sites/
default/files/omb/assets/a94/dischist-2016.pdf). November.
U.S. Environmental Protection Agency (EPA), 1988. Guidance for Conducting Remedial
Investigations and Feasibility Studies Under CERCLA. Interim Final. EPA/540/G-89/004.
OSWER Directive 9355.3-01. October.
EPA. 1989. Risk Assessment Guidance for Superfund. Volume I. Human Health Evaluation
Manual (Part A). EPA/540/1-89/002.
EPA. 1991. Risk Assessment Guidance for Superfund: Volume 1 - Human Health Evaluation
Manual (Part B, Development of Risk-based Preliminary Remediation Goals). Interim.
U.S. Environmental Protection Agency, Office of Emergency and Remedial Response.
Publication Number 9285.7-01 B. EPA/540/R-92/003.
EPA, 1993. Revisions to OMB Circular A-94 on Guidelines and Discount Rates for Benefit-Cost
Analysis, OSWER 9355.3-20, June.
EPA. 1994. Guidance Manual for the Integrated Exposure Uptake Biokinetic Model for Lead in
Children. U.S. Environmental Protection Agency, Office of Emergency and Remedial
Response. Publication Number 9285.7-15-1. EPA/540/R-93/081.
EPA, 2000. A Guide to Developing and Documenting Cost Estimates during the Feasibility Study,
OSWER 9355.0-75, July.
U.S. EPA Region 7
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HGL—Feasibility¦ Suttly. Former United Sue— Ma, KS
EPA, 2008, Removal Action Summary Report; United Zinc #/ Site, lokt, Kansas. Superfund
Division, May.
EPA, 2016. Regional Screening Level (RSL) Summary Table May 2016 al:
http://w\vw. eua.gov/region9/superliind/pra/.
U.S. EPA Region 7
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I
Figure(s)
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Miles
Garnett
>l2ttiiRoad
Burlington
Humboldt
Chanute
— _
Statewide Location
KANSAS
HGL—Feasibility Study Report, Former United Zinc Site tola. KS
(i.st-sn -OI hfzlgis llnifed Zinc MSIW
2015 RI Report
(I-01 )Sife_ Luc. rnxci
6 29 2015 JCj
Sourc e HGL. ArcGIS Online Imagery
v HGL
Legend
• Town
Interstate
Highway
Iola City Limits
Figure 1.1
Site Location
-------
HGL Feasibility Study Report, Former United Zinc Site lola. KS
NebraskaTRoad
,/ ako
Bassola
Miles
^Oregon,Road.
Dakota Road
Former United Zinc
Cv
ygrr h**
|
3j
East lola]
1 v *mvi nSnNr*
Facility
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2015 RI Report
(I-02)lola_f.oc.mxd
5 5 2016 JG
Sourc e: HGL, ESRl.
A rciilS Online Imagery
v HGL
Legend
Surface Water Course
* Former Smelter
I i
lola City Limits
Figure 2.1
Former Smelter
Locations
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-------
HGL—Feasibility Study Report, Former United Zinc Site—tola, KS
Stack
Buno.ff
Sediment
Tailings/Processed
Ore Pile
Limestone Bedrock
Figure Not to Scale
Fill for Leveling |
'I Loess/Alluvium]
Runoff-
Rail Bed
Ballast
Residential
Properties
City Park'
Blowing"
' Dust;;
; ; ; ;
Street • sidewalk
Base ' ' Base
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Appendix A
Summary of Federal and State Applicable or Relevant and
Appropriate Requirements
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Appendix A
Federal Action-Specific ARARs
Former United Zinc Site
Iola, Kansas
Citation
Description
A. Applicable or Relevant and Appropriate Requirements (ARARs)
1. Clean Water Act
National Pollutant Discharge Elimination System
(NPDES) 40 CFR Parts 122-^125.
Requires permits for the discharge of pollutants from any point
source into the waters of the United States.
2. Clean Water Act
Water Quality Criteria, 40 CFR Part 131, Water
Quality Standards.
Establishes non-enforceable standards to protect aquatic life.
3. Noise Control Act of 1972
42 USC Section 4901 et seq.
Federal activities must not result in noise that will jeopardize the
health or welfare of the public.
4. NPDES Storm Water
Discharge for Permanent
Repository
40 CFR, Part 122, 122.25.
Establishes permitting process and discharge regulations for
stormwater. Requires management of repository where waste
materials come into contact with storm water. Also required during
construction of the repository.
5. RCRA
Subtitle D, 42 U.S.C §6941 et seq.
Establishes disposal processes.
6. RCRA
Subtitle C, 42 U.S.C §6921 et seq.
Establishes procedures for the handling of hazardous waste if
material fails TCLP analysis
7. DOT Hazardous Material
Transportation
49 CFR Parts 107, 171-177
Establishes procedures for transportation of hazardous waste.
B. To Be Considered
1. Safe Drinking Water Act
Standards for Owners and Operators of Public Water
Supply Systems.
Provides treatment (water quality) requirements for public water
supply.
2. Safe Drinking Water Act
Underground Injection Control (UIC) Regulations.
40 CFR, Parts 144-147.
Provides for protection of underground sources of drinking water.
3. Clean Water Act
Toxic Pollutant Effluent Standards 40 CFR, Part
129.
Establishes effluent standards or prohibitions for certain toxic
pollutants.
4. Clean Water Act
National Pretreatment Standards 40 CFR, Part 403.
Sets standards to control pollutants that pass through or interfere
with treatment processes in POTWs or that may contaminate sewage
sludge.
5. EPA Guidance on Remedial
Actions for Contaminated
Ground Water at Superfund
Sites
Summary of Key Existing EPA CERCLA Policies
for Groundwater Restoration, OSWER Directive
9283 (EPA/540/G-S8/003).
Guidance focuses on the development, evaluation, and selection of
groundwater remedial actions at Superfund sites. This guidance
discusses ARARs and should be considered for alternatives that
involve groundwater remedial actions.
Page 1 of 1
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Appendix A
Federal Chemical-Specific ARARs
Former United Zinc Site
Iola, Kansas
k ¦ ¦ ; Citations
Description
A. ARARs
1. Safe Drinking Water Act
National Primary Drinking Water Standards
40 Code of Federal Regulations (CFR) Part 141
Subpart B and G.
Establishes maximum contaminant levels (MCLs), which are health
based standards for public water systems.
B, To Be Considered
1. Safe Drinking Water Act
National Secondary Drinking Water Standards,
40 CFR Part 143.
Establishes secondary maximum contaminant levels (SMCLs) which
are non-enforceable guidelines for public water systems to protect the
aesthetic quality of the water. SMCLs may be relevant and appropriate
if groundwater is used as a source of drinking water.
2. Safe Drinking Water Act
Maximum Contaminant Level Goals (MCLGs),
40 CFR Part 141, Subpart F.
Establishes noil-enforceable drinking water quality goals. The goals are
set to levels that produce no known anticipated adverse health effects.
The MCLGs include an adequate margin of safety.
3. Clean Water Act
Water Quality Criteria,
40 CFR Part 131 Water Quality Standards.
Establishes non-enforceable standards to protect aquatic life. May be
relevant and appropriate to surface water discharges, or may be a TBC.
4, Clean Water Act
Toxic Pollutant Effluent Standards,
40 CFR Part 129.
Establishes effluent standards or prohibitions for certain toxic
pollutants.
5. Clean Water Act
National Pollutant Discharge Elimination System
(NPDES), 40 CFR Parts 122, 125.
Determines maximum concentrations of the discharge of pollutants
from any point source into water of the United States.
6, Clean Water Act
National Pretreatment Standards,
40 CFR Part 403.
Sets standards to control pollutants that pass through or interfere with
treatment processes in publicly owned treatment works (POTWs) or
that may contain sewage sludge.
7. Clean Air Act
National Primary and Secondary Ambient Air
Quality Standards 40 CFR Part 50
Establishes Standards for ambient air quality to protect public health
and welfare Establishes Standards for ambient air quality to protect
public health and welfare.
Page 1 of 2
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Appendix A
Federal Chemical-Specific ARARs (continued)
Former United Zinc Site
Tola, Kansas
Citations
Description
B. To Be Considered (Continued)
8. Baseline Human Health Risk
Assessment (HHRA)
Draft Remedial Investigation Report, Former
United Zinc, Iola, Kansas; Appendix B (Draft
Human Health Risk Assessment), May 2015,
This document evaluated the baseline health risk from current site
exposures and established contaminant levels in environmental media
at the site for the protection of public health.
9, Superfund Lead-
Contaminated Residential
Sites Handbook
Environmental Protection Agency (EPA) Office
of Solid Waste and Emergency Response
(OSWER) 9285.7-50, August 2003.
Handbook developed by EPA to promote a nationally consistent
decision making process for assessing and managing risks associated
with lead-contaminated residential sites across the country.
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Appendix A
Federal Location-Specific ARARs
Former United Zinc Site
Iola, Kansas
Citation
Description
A. ARARs
1. Historic project owned or
controlled by a federal
agency
National Historic Preservation Act: 16 United
States Code (USC) 470, et seq.; 40 CFR § 6.301;
36 CFR Part I.
Property within areas of the site is included in or eligible for the
National Register of Historic Places. The remedial alternatives will be
designed to minimize the effect on historic landmarks.
2. Site within an area where
action may cause irreparable
harm, loss, or destruction of
artifacts
Archeological and Historic Preservation Act; 16
USC 469, 40 CFR 6.301,
Property within areas of the site contains historical and archeological
features. The remedial alternative will be designed to minimize the
effect on historical and archeological features.
3. Site located in area of critical
habitat upon which
endangered or threatened
species depend
Endangered Species Act of 1973, 16 USC 1531-
1543; 50 CFR Parts 17; 40 CFR 6.302. Federal
Migratory Bird Act; 16 USC 703-712.
Determination of the presence of endangered or threatened species.
The remedial alternatives will be designed to conserve endangered or
threatened species and their habitat, including consultation with the
Department of Interior if such areas are affected.
4. Site located within a
floodplain
Protection of Floodplains, Executive Order
11988; 40 CFR Part 6.302, Appendix A.
Remedial action will take place within a 100-year floodplain. The
remedial action will be designed to avoid adversely impacting the
floodplain. Planning and budget considerations will account for
potential flood hazards and floodplain management.
5, Site located within wetlands
Protection of Wetlands; Executive Order 11990,
40 CFR Part 6, Appendix A.
Remedial actions may affect wetlands. The remedial action will be
designed to avoid adversely impacting wetlands wherever possible
including minimizing wetlands destruction and preserving wetland
value.
6. Structures in waterways
Rivers & Harbors Act, 33 CFR Parts 320-330.
Placement of structures in waterways is restricted to pre-approval by
the U.S. Army Corps of Engineers.
7. Area containing fish and
wildlife habitat
Fish and Wildlife Conservation Act of 19S0, 16
USC Part 2901 et seq.; 50 CFR Part 83 and 16
USC Part 661, et seq. Federal Migratory Bird
Act, 16 USC Part 703.
Regulates activity affecting wildlife and non-game fish. Remedial
action will conserve and promote conservation of non-game fish and
wildlife and their habitats.
Page 1 of 2
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Appendix A
Federal Location-Specific ARARs (continued)
Former United Zinc Site
Iola, Kansas
Citation
Description
A. ARARs (continued)
8. Wild and Scenic River Act
16 USC 1271 et seq.; Section 7,40 CFR 6.302(e).
Prohibits adverse effects on any of the scenic rivers listed in 16 USC
1276(a).
9. Fish and Wildlife
Coordination Act
16 USC Section 661 et seq.; 33 CFR Parts 320-
330 40 C.F. R. 6.302.
Requires consultation when a federal department or agency proposes
or authorizes any modification of any stream or other water body, and
adequate provision for protection of fish and wildlife resources.
10. 100-year Floodplain
Location Standard for Hazardous Waste
Facilities - Resource Conservation and Recovery
Act (RCRA); 42 USC 6901; 40 CFR 264.18(b).
RCRA hazardous waste treatment and disposal. Facility located in a
100-year floodplain must be designed, constructed, operated, and
maintained to prevent washout during any 100-year/24 hour flood.
11. Historic Site, Buildings, and
Antiquities Act
16 USC Section 461 et seq. 40 CFR Section
6.301(a).
Requires Federal agencies to consider the existence and location of
landmarks on the National Registry of Natural Landmarks and to avoid
undesirable impacts on such landmarks.
12. Salt Dome Formations, Salt
Bed Formations,
Underground Mines and
Caves
40 CFR 264.18.
Placement of non-containerized or bulk liquid RCRA hazardous waste
is prohibited within salt dome formations, underground mines, or
caves.
B. To Be Considered
1. Clean Water Act
Dredge or Fill Requirements (Section 404), 40
CFR Parts 230 and 231.
Requires permits for discharge of dredged or fill material into
navigable waters.
2. Wilderness Act
16 USC 1311 et seq.; 50 CFR 35.1 et seq.
Requires that federally owned wilderness areas are managed to insure
they are not impacted.
3. EPA Regulations on Sole-
Source Aquifers
40 CFR 149.
No activities, including drilling, in an area designated a sole-source
aquifer may take place without permission of the EPA.
Page 2 of 2
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Appendix A
State Action-Specific ARARs
Former United Zinc Site
Iola, Kansas
• : T.
Citation
Description
A. ARARs
1. Kansas Board of Technical
Professions
Kansas Department of Health and Environment,
K.A.R. 66-6 through 66-14
Establishes the requirements for licensing of engineers, site
surveyors, geologist and architects.
2. Ambient Air Quality
Standards and Air Pollution
Control
Kansas Department of Health and Environment,
K.A.R, 28-19
Regulates air emissions from processing operations, indirect heating
equipment, and incinerators. Establishes requirements for Attainment
and Non-Attainment Areas. Establishes requirement for Stack
Heights. Restricts open burning.
3, Spill Reporting
Kansas Department of Health and Environment,
K.A.R. 28-48
Requires reporting of unpermitted discharges or accidental spills.
Requires that containment and immediate environmental response
measures are implemented.
B, To Be Considered - None
Page 1 of 1
-------
Appendix A
State Chemical-Specific ARARs
Former United Zinc Site
Iola, Kansas
¦if-
Citation *
Description
A. ARARs
1. Kansas Water Appropriations Act
Kansas Department of Health and
Environment,
K.A.R. 5-1 through 5-10 and 5-50
Establishes the requirements for obtaining and maintaining and
transferring water appropriations.
2. Hazardous Waste Management
Standards and Regulations
Kansas Department of Health and
Environment, Bureau of Waste
Management,
K.A.R. 28-31
Identifies the characteristics and listing of hazardous waste.
Prohibits underground burial of hazardous waste except as granted
by EPA or Kansas Department of Health and Environment
(KDHE). Establishes restrictions on land disposal. Establishes
standards for generators or transporters of hazardous waste.
Establishes standards for hazardous waste storage, treatment and
disposal facilities.
3. Water Pollution Control
Kansas Department of Health and
Environment,
K.A.R. 28-16
Provides regulation of sewage discharge. Establishes pre-treatment
standards for industry. Designates uses of rivers and streams.
Establishes River Basin Quality Criteria. Provides for
establishment of Critical Water Quality Management Areas.
B. To Be Considered
1. Voluntary Cleanup and Property
Redevelopment Program
Kansas Department of Health and
Environment,
K.A.R. 28-71
Provides a mechanism for property owners. Facility operators,
prospective purchasers, and local governments to voluntarily
address contaminated properties with technical and regulatory
guidance from KDHE.
Page 1 of 1
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Appendix A
State Location-Specific ARARs
Former United Zinc Site
Iola, Kansas
Citation
Description
A. ARARs
1. Kansas Historic Preservation
Act
Kansas Department of Health and Environment,
K.A.R. 118-3
Provides for the protection and preservation of sites and buildings
listed on state or federal historic registries.
2. Non-Game, Threatened or
Endangered Species
Kansas Department of Health and Environment,
K.A.R. 115-5
Identifies Threatened and Endangered Species.
B. To Be Considered - None
Page 1 of 1
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Appendix B
Determination of Remaining Properties for Remediation
(Backup Calculations Provided on CD)
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Appendix B
Determination of Remaining Properties for Remediation
Former United Zinc Site
lola, KS
HGL Area of Properties with an Exeeedanee
Area of Exeeedanee within
ESTIMATED TOTAL VOLUME TO
Zone
HGL Properties Exceeded
(Acres)
Properties (Total Acres)
Estimated Area of Exeeedanee Soil (sqft)
EXCAVATE in CV (assume 12 inch depth)
Zone 1
20
31.787
2.114
92068.341
3409.939
Zone 2
33S
89.213
30.050
1308982.253
48480.824
Zone 3
292
161.88S
31.848
1387284.950
51380.924
Other
0
0.000
0.000
0.000
0.000
Total
650
282.888
64.011
2788335.544
103271.687
Tetratech Area of Properties with an
Estimated Percentage Exeeedanee
ESTIMATED TOTAL VOLUME TO
Zone
Tetratech Exceeding
Properties
Exeeedanee (Acres)
by Zone
Estimated Area of Exeeedanee Soil (sqft)
EXCAVATE in CV (assume 12 inch depth)
Zone 1
0
0.000
6.65%
0.000
0.000
Zone 2
299
56.323
33.68%
826393.874
30607.181
Zone 3
293
64.794
19.67%
555246.421
20564.682
Other
0
0.000
0.00%
0.000
0.000
Total
592
121.117
1381640.295
51171.863
Total Estimated Removal Volume before
TCRA removals (CV)
154443.55
Average Cubic Yards per Property
124.35
Total Sampled Properties 26S4
Total Properties that Exceeded
1242
Planned or completed TCRA removals
479
Remaining Properties to be sampled
300
Estimated Exeeedanee Rate of Remaining
Properties (1,242/2,684)
0.463
Estimated Additional Remaining Properties
that Require Removal
139
Total Estimated Properties for Removal
902
Total Estimated Removal Volume (CY)
112152
Notes:
CV - cuhie vards
TCRA ¦ lime critical removal action
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Appendix C
Development of Preliminary Remediation Goals
for Lead and Arsenic
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Memorandum
Via e-mail
DATE: May IS. 2016
TO: 1 odd Phillips and Don Bahnke (EPA)
FROM: Amber Bacom and Mark Follansbee (SRC)
Subject: Preliminary Remediation Goals for Lead and Arsenic in Residential Soils at the Former United
Zinc (FUZ) Site
1.0 INTRODUCTION
This memorandum presents preliminary remediation goals (PRCs) for lead and arsenic in surface soil at
the Former United Zinc (FUZ) site. The FUZ human health risk assessment (HHRA) identified lead and
arsenic as the principal chemicals of concern (COCs) in surface soil of residential yards (USEPA 2015).
Thus, this memorandum is focused on deriving PRG values for these two COCs.
2.0 PRELIMINARY REMEDIATION GOALS (PRCs)
A PRG is the average concentration of a contaminant in a medium that is considered protective of human
health for a specified land use. A PRG is used by risk managers mainly to help in a preliminary
evaluation of the feasibility of various remedial alternatives. A PRG may undergo refinement during the
Remedial Investigation and the Feasibility Study, taking a number of other considerations into account,
ultimately resulting in a final remediation goal (RG) (USEPA 1991).
PRGs are calculated by taking the forward-going risk equation and solving the equation for the
concentration that yields a specified target risk level. The PRG value for lead in residential soil
represents the average concentration of lead in a residential yard that is associated with no more than a
5% chance that a child (age 0-84 months of age) living at the property will have a blood lead level that
exceeds 10 ^ig/dL (USEPA 1998). The PRG value for arsenic in residential soil represents the average
concentration of arsenic in a residential yard that is associated with a target hazard quotient (THQ) of I or
a target cancer risk (TR) ranging between IE-06 and 1E-04 (whichever produces the lower soil
concentration).
3.0 METHOD FOR CALCULATING THE PRG FOR LEAD
Mathematical Model
The standard model developed by the USEPA to assess the risks of lead exposure in residential children is
referred to as the Integrated Exposure Uptake Biokinetic (1EUBK) model (USEPA 1994). This model
requires input data on the levels of lead in various environmental media at a specific location, and on the
amount of these media contacted by a child living at that location. All of these inputs to the IEUBK
1
-------
J*.
model are central tendency point estimates (i.e.. arithmetic means or medians). These point estimates are
used to calculate an estimate of the central tendency (the geometric mean. GM) of the distribution of
blood lead values that might occur in a population of children exposed to lead under the specified
conditions. Assuming the distribution is lognormal. and given (as input) an estimate of the variability
between different children (this is specified by the geometric standard deviation or GSD), the model
calculates the expected distribution of blood lead values, and estimates the probability that any random
child might have a blood lead value over 10 |.ig/dL. For convenience, the probability of having a blood
lead level above 10 ng/dL is referred to as PIO.
The PRG is computed by finding the concentration of lead in soil that yields a P10 value equal to EPA's
health-based goal (PIO < 5%). This is done within the IEUBK model (Integrated Exposure Uptake
Biokinetic Model for Lead in Children; Version 1.1 Build 11).
Input Parameters
The IEUBK model input parameters used in the PRG model runs are the same values used in the baseline
human health risk assessment (USEPA 2015). These values are presented in Table 1. Most of the values
are the national defaults recommended for use by USEPA (USEPA 1994). Some of the values (i.e., the
relative bioavailability of lead and the concentration of lead in water) are based on site-specific data, as
described in the HHRA (USEPA 2015).
4.0 METHOD FOR CALCULATING THE PRG FOR ARSENIC
The PRG for arsenic is computed in accordance with USEPA guidance (USEPA 1991). The same
equations used in the HHRA (USEPA 2015) to calculate non-cancer hazard and cancer risk attributable to
a specified exposure point concentration of a chemical were re-arranged to solve for the concentration of
arsenic that corresponds to a specified target level. For arsenic, PRG values are calculated for both non-
cancer effects and cancer effects. A non-cancer based PRG is based on exposure to a reasonably
maximally exposed (RME) residential child (age 0-6 years). A cancer based PRG is based on exposure to
a time-weighted average (TWA) resident.
For ingestion exposure to residential soil, the PRG equations are:
PRG(non-cancer) = (Target HQ ¦ AT • BW) / (EF ¦ ED ¦ (RBA/RfD) ¦ IR • CF)
PRG(cancer) = (Target Risk ¦ AT) / (SF • RBA • IFS ¦ CF)
Where:
IR
Intake rate of soil (mg/day).
BW
Body weight of the exposed person (kg).
EF
Exposure frequency (days/year).
-------
ED = Exposure duration (years),
AT = Averaging time (days). For a chemical which causes non-cancer effects, the
averaging time is equal to the exposure duration. For a chemical that causes
cancer effects, the averaging time is 70 years.
RBA = Relative bioavailability (unitless).
CF = Conversion factor (kg/mg).
IFS = Soil intake factor (mg/kg). IFS = EFc • EDc ¦ !Rc / BWc + EFa ¦ EDa • IRa /
BWa where the "c" and "a" represent child and adult, respectively.
RID = Oral reference dose (mg/kg-day)
SF = Cancer slope factor (mg/kg-day)"1
For dermal exposure to residential soil, the PRG equations are:
PRG(non-cancer) = (Target HQ • AT • BW) / (EF • ED • (1/RfD • GIABS) • SA • AF -ABSd ¦ CF)
PRG(cancer) = Target Risk / (ABSj ¦ DFS • SF)
where:
GIABS = Gastrointestinal absorption (unitless).
SA = Exposed skin surface area (cm2).
AF = Dermal adherence factor (nig/cnr).
ABSd = Dermal absorption fraction (unitless).
DFS = Soil dermal factor (mg/kg).
DFS = EFc • EDc • SAc • AFc / BWc + EFa ¦ EDa • SAa ¦ A Fa / BWa where the
"c" and "a" represent child and adult, respectively.
The total PRGs are computed as I / (I / PRG(ingestion) + 1 / PRG(dermal)), This is done using the EPA
Regional Screening Level (RSL) online calculator1 and the site-specific input parameters described
below.
-------
Parameter Vakies
Exposure parameters and toxicity factors (RfD and SF) used to caIciilate the arsenic PRG are the same as
were used in the HHRA to calculate non-cancer hazards to RME child resident and cancer risks to the
TWA resident, as described in USEPA (2015). These vakies are summarized in Table 2.
For non-cancer, the target hazard quotient (HQ) was set to I, while tor cancer the target risk was set to
1E-04. I E-05 or I E-06.
5.0 RESULTS
5.1 Lead
Based on the approaches and inputs specified above and in Table I, the PRG for lead in residential soil at
the FUZ site is 423 mg/kg.
This PRG value for lead is somewhat uncertain, due to uncertainty in the true values of the input
parameters used in the 1EUBK model calculation. This uncertainty includes all of the inputs listed in
Table 1. Of these parameters, the uncertainty in the soil and dust ingestion rates and in the true geometric
standard deviation (GSD) are usually the most important. In addition to these user-adjustable parameters,
there are also a large number of other pharmacokinetic variables that are used in the model but are not
subject to revision by the model user.
For the purposes of this evaluation, a series of alternative PRG calculations were performed to evaluate
the uncertainty in the PRG that arises from the site-specific relative bioavailability (RBA) term. Tliree
alternative RBA values were evaluated. These values included the IEUBK model default RBA for lead
(0.6), as well as a low estimate (0.49) and high estimate (0.79) based on site-specific data. All other input
values were maintained at the values shown in Table 1. The alternative PRG estimates based on the
different RBA values are:
Site-specific RBA (62%) = 423 mg/kg
Default RBA (60%) = 437 mg/kg
Low RBA (49%) = 548 mg/kg
High RBA (79%) = 326 mg/kg
Given the range of PRG estimates, the site-specific RBA of 423 mg/kg is considered the best estimate.
However, most data on the concentration of lead in residential yards at the FUZ site are based on
measurement of lead in soil using X-ray fluorescence (XRF). This complicates the use of the PRG of 423
mg/kg in that measurements of lead in soil using XRF are subject to a wide variety of interferences (e.g.,
water content, particle size, presence of other metals, etc.). Thus, to the extent that XRF yields a biased
estimate of the true concentration, use of XRF data for comparison to the PRG might cause an error in
either direction.
4
-------
£SliP£I
Because of the observable differences in lead concentrations associated wilh the potential for differences
between XRF and ICR analytical techniques utilized at this site, the risk-based PRG of 423 mg/kg was
converted to an 1CP equivalent concentration.
In order to derive a site-specific XRF to ICP relationship, USEPA Region 7 collected paired
measurements of the concentration of lead in bulk residential soil samples analyzed using ICP and XRF.
Two individual sampling events were conducted in which 324 paired samples were collected from
properties in 2006/2007 and 714 paired samples were collected from additional properties in 2013
(USEPA 2015). The data are shown in Figures 1 and 2. As shown, the XRF concentrations were better
correlated with the ICP concentrations for the 2013 dataset (R2 = 0.9) than the 2006/2007 dataset (R2 =
0.6). As such, the relationship between the ICP and XRF measurements were modeled using the lineai-
equation derived for the 2013 dataset:
ICP-equivalent - 1.1021 ¦ XRF + 19.872
The XRF PRG is computed by solving for the value that corresponds to an ICP value of 423 mg/kg:
XRF PRG = (423 - 19.872) / 1.1021 = 366 mg/kg
Summary of Lead PRG
The risk-based PRG for lead in residential soil using ICP is 423 mg/kg. This corresponds to a PRG of
366 mg/kg in the bulk soil analyzed using XRF.
5.2 Arsenic
Based on the approaches and inputs specified above and in Table 2, the non-cancer and cancer-based
PRGs for arsenic in residential soil at the FUZ site are:
Non-cancer PRG = 34.5 mg/kg
Cancer PRGs:
Target risk 1 F.-06 - 0.67 mg/kg
Target risk 1E-05 = 6.7 mg/kg
Target risk 1E-04 = 67 mg/kg
As described in the HHRA, limited data (n = 5 samples) on arsenic concentrations in background soil
samples collected 1.25 miles north of the FUZ site ranged from noil-detect at a reporting limit around 4
mg/kg to 7.2 mg/kg (USEPA 2015). Arsenic concentrations reported by the U.S. Geological Survey
(USGS) in background soils in counties near the FUZ site are around 8 to 12 mg/kg (USGS Pluto
Database2). On this basis, the cancer PRGs based on target risks of 1E-06 and I E-05 are likely below or
2 USGS Pluto Database available online at: http://mrdata.usas.gov/pluto/soil/. No data are available for Allen
County. Data pulled from Shaekletie H T for nearby Cherokee and Montgomery counties indicate arsenic
concentrations measuring 8.3 and 12 mg/kg. respectively.
5
-------
at background arsenic concentrations. Since the non-cancer PRG is the most conservative value compared
to the cancer PRG based on a target risk of 1E-04, the PRG for arsenic in residential soil at the FUZ site is
35 mg/kg.
This PRG is appropriate for comparison to arsenic analyzed by an accurate laboratory method such as ICP
spectrometry. Similar to lead, most data on the concentration of arsenic in residential yards at the FUZ
site are based on XRF measurements. Because of the observable differences in arsenic concentrations
associated with the potential for differences between XRF and ICP analytical techniques utilized at this
site, the risk-based PRG of 35 mg/kg was converted to an ICP equivalent concentration.
In order to derive a site-specific XRF to ICP relationship, USEPA Region 7 re-analyzed archived
residential soil samples collected in 2013 to generate paired measurements of the concentration of arsenic
analyzed by ICP and XRF using 120 source seconds. Factors that contribute to the low correlation
observed in the HHRA between arsenic ICP and arsenic XRF data include limited numbers of samples
with detectable arsenic and potential interference from high lead concentrations. Focusing on soil
samples with low lead concentrations (<400 mg/kg), ICP/XRF correlations were determined based only
on those samples evaluated in the HHRA with a high arsenic concentration (>35 mg/kg) (referred to as
"dataset I") and based on re-analysis of all the samples collected in 2013 (referred to as "dataset 2"). The
data are shown in Figures 3 and 4. As shown, the XRF concentrations were better correlated with the ICP
concentrations for the dataset I (R: = 0.9) than for dataset 2 (R2 = 0.75). As such, the relationship
between the ICP and XRF measurements were modeled using the linear equation derived for dataset I:
ICP-equivalent(dataset 1) = 1.1054 • XRF -0.0742
The XRF PRG is computed by solving for the value that corresponds to an ICP value of 35 mg/kg:
XRF PRG(dataset 1) = (35 + 0.0742) / 1.1054 = 32 mg/kg
Summary of Arsenic PRG
The risk-based PRG for arsenic in soil measured using ICP is 35 mg/kg. This corresponds to a PRG of 32
mg/kg in soil analyzed using XRT.
6
-------
6.0 REFERENCES
USEPA. 1991. Risk Assessment Guidance for Stiperfund: Volume I - Human Health Evaluation Manual
(Part B, Development of Risk-based Preliminary Remediation Goals). Interim. U.S. Environmental
Protection Agency. Office of Emergency and Remedial Response. Publication Number 9285.7-01B.
EPA/540/R-92/003.
USEPA. 1994. Guidance Manual for the Integrated Exposure Uptake Biokinetie Model for Lead in
Children. U.S. Environmental Protection Agency, Office of Emergency and Remedial Response.
Publication Number 9285.7-15-1. EPA/540/R-93/081.
USEPA. 1998. Clarification to the 1994 Revised Interim Soil Lead Guidance for CERCLA Sites and
RCRA Corrective Action Facilities. OSWER Directive 9200.4-27. EPA/540-F98/030. August.
USEPA. 2015. Baseline Human Health Risk Assessment for the Former United Zinc Site, lola, Kansas.
7
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T-"- ;ss>»
Table 1. IEUBK Model Inputs
CONSTANT MODEL INPUTS
PARAMETER
VALUE
BASIS
Soil concentration (nig/kg)
Decision Unit-
specific weighted
soil concentration
Time weighted soil lead concentration for
each DU
Dust concentration (mg/kg)*
C,i„s, 0.7 • Csoii
Derived from residential soil lead
concentration IEUBK Default (EPA
1994)
Air concentration (|_ig/iirv)
0.10
IEUBK Default (EPA 1994)
Indoor air concentration ((.ig/ni3)
30% of outdoors
IEUBK Default (EPA 1994)
Drinking water concentration (pg/L)
1.7
Site-specific value (90"' percentile for
City of lola drinking water measured
2011-2013)
Absorption Fractions:
Ait-
Diet
Water
Soil/Dust (residential soil)
32%
50%
50%
31%
IEUBK Default (EPA 1994)
IEUBK Default (EPA 1994)
IEUBK Default (EPA 1994)
Site-specific based on arithmetic mean
RBA
RBA: Residential soil
Sediment
62%
60%
Site-specific arithmetic mean: See Table
5-2.
IEUBK Default (EPA 1994)
Fraction soil
45%
IEUBK Default (EPA 1994)
GSD
1.6
IEUBK Default (EPA 1994)
^Assuming that site soil will be trackedbnck to the residence by recreational visitors, this value is based on Cdusi=0.7-Csoii(wcistnej).
AGE DEPENDENT MODEL INPUTS*
AIR
DIET
WATER
SOIL
Time
Ventilation
Dietary
Outdoors
Rate
Intake [1|
Intake
Intake
Age
(hrs)
(m3/day)
(Mg/day)
(L/day)
(mg/day)
0-1
1.0
2.0
2.26
0.20
85
1-2
2.0
3.0
1.96
0.50
135
2-3
3.0
5.0
2.13
0.52
135
3-4
4.0
5.0
2.04
0.53
135
4-5
4.0
5.0
1.95
0.55
100
5-6
4.0
7.0
2.05
0.58
90
6-7
4.0
7.0
2.22
0.59
85
[I] Revised USEPA (2009) recommended dietary intake parameters, based on updated dietary lead intake
estimates from the Food and Drug Administration Total Diet Study (FDA 2006) and food consumption data
from NI-IANES III (CDC 1997).
8
-------
Table 2. Arsenic Exposure Parameters and Toxicity Factors
Exposure
Exposure Input Parameter
Units
RME
Pathway
Adult
Child
Body Weight (BW)
kg
80
15
Exposure frequency (EF)
davs/yr
350
350
Exposure duration (ED)
yr
20
6
General
Averaging Time. Cancer (AT)
days
25.550
25.550
Averaging Time. Noncancer (AT)
days
7.300
2.190
Relative Bioavailability (RBA)
days
0.6
0.6
Reference Dose (RtD)
mg/kg-day
3.00E-04
3.00E-04
Slope Factor (SF)
(mg/kg-day V
1.50E+00
1.50E+00
Ingestion of Soil
Ingestion rate (IR)
mg/day
100
200
Conversion factor (CF)
kg/mg
IE-06
1E-06
Exposed Surface Area (SA)
enr/event
6,032
2.690
Dermal Exposure
to Soil
Adherence Factor (A F)
mg/cm2
0.07
0.2
Dermal Absorption Fraction (ABSd)
unitless
0.03
0.03
Conversion factor (CF)
kg/mg
1.00E-06
1.00 E-06
Gastrointestinal absorption (GiABS)
unitless
1
I
9
-------
Figure 1. ICP/XRF Correlation Based on 2006/2007 Lead Data
Panel A: Linear
6000 !
XRF (mg/kg)
Panel B: Log-Transformed
XRF (mg/kg)
10
-------
Figure 2. ICP/XRF Correlation Based on 2013 Lead Data
Panel A: Linear
XRF (mg/kg)
I
Panel B: Log-Transformed
XRF (mg/kg)
-------
Figure 3. ICP/XRF Arsenic Correlation Based on Dataset 1
20 40 60 80 100 120 140
Arsenic XRF (ppm)
Figure 4. ICP/XRF Arsenic Correlation Based on Dataset 2
140
120 -
100
Q.
U
•| 60
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Appendix D
Detailed Alternative Analysis Cost Information
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Appendix D
Alternative 1 Cost Estimate - No Action
Former United Zinc Feasibility Study
tola, KS
Description
Quantity
Unit
Unit Cost
Estimated Total
Capital Costs
1 TOTAL CAPITAL COSTS
SO
Description
Year
Frequency
Total Cost
per Event
Tola! Cost
Present Value
Present Value Analysis
2 Total Capital Cost
0
5, 10, 15, 20,
25 and 30
once
$0
SO
SO
3 Five Year Reviews
varies
$10,000
$60,000
S27.820
18 TOTAL PRESENT VALUE OF ALTERNATIVE
S27.X20
Notes:
I, All cost estimates are based on current understanding of (he si ic us described in the FS and should be considered preliminary. Cost estimates are conceptual in nature and subject to
revision.
2 All costs are rounded where appropriate.
3 All cost estimates include, material ntitl labor, unless otherwise noted.
•1 Present value calculations were perfunned using a discount rale of 5%
Page 1 of 1
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Appendix D
Alternative 2 Cost Estimate - Excavation and Disposal
Former United Zinc Feasibility Study
Iola, KS
Description
Quantity
Unit
Unit Cost
Estimated Total'
Capital C'osls
1 Mobilization
1
LS
558.387
S58.387
Material Excavation, Transport. Disposal, Backfill, Dust Suppression, anil Site
Restoration
902
Per Properly
SI 5,181
$13,692,911
3 Post Cleanup Reports
902
Per Properly
SI 17
S 105.330
4 Plan Preparation, (Sampling Plan, H&S, QAPP>
300
Hours
SI 17
$35,032
5 CAPITAL COSTS SUBTOTAL
$13,891,660
6 Bid and Scope Contingency (20%)
$2,778,332
7 TOTAL DIRECT CAPITAL COSTS
$16,669,992
8 Construction Services (10%)
$1,666,999
9 CONSTRUCTION COSTS TOTAL
$18,336,991
10 Remedial Engineering Design (3%)
$550.110
1 1 TOTAL CAPITAL COSTS
$ 18,887, HI 1
Description
Year
Frequency
Total Cost
uer Event2
Total Cost
Present Value3
Present Value Analysts
12 Total Capital Cost
0
once
$18,887,101
$18,887,101
$18,887,101
13 Information Dissemination via Mass Media, Including
1 - 10
annually
$11.677
SI 16,774
$90,170
14 Establish Information Registry
1 - 10
annually
$29,193
$291,935
5225,424
15 Public Health Education
1 - 10
annually
$58,387
$5X3,870
S450.849
16 Maintain Public Information Center
1 - 10
annually
$11,677
$116,774
$90,170
17 Total Annual Costs (Excluding Year 0)
1 - 10
annually
$1 10.935
$1,109,352
$856,612
18 Five Year Reviews
5. 10, 15.20,
25 and 30
varies
$10,000
$60,000
$27,820
19 TOTAL PRESENT VALUE OF ALTERNATIVE
$19,771,534
Notes:
]. AH cos! estimates are bused on current understanding of the site as described in the FS and should be considered preliminary. Cost estimates are concepivi.il in nature and subject to
revision.
2. Per EPA direction, unit cost estimates are based on residential soil remediation projects of similar type, adjusted tor scale as necessary, escalated for inflation ,i! a rase of 2.2-1%
3. Present value calculations were performed using a discount rate of 5%
All costs are rounded where appropriate.
All cost estimates include material and labor, unless otherwise noted,
FS - Feasibility Study LS - lump sum
1 LtS - Health & Safety QAPP - Quality Assurance Project Plan
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Appendix D
Alternative 3 Cost Estimate - Phosphate Stabilization, Excavation and Disposal
Former United Zinc Feasibility Study
Iola, KS
Description
Quantity
Unit
Unit Cost
Estimated lotal
Capital Costs
1 Mobilization
1
LS
$58.3X7
$58,387
Material Excavation, Transport, Disposal. Backfill, Dust Suppression, and Site
Restoration
450
Per Property
515,181
$6,831,275
3 Post Cleanup Reports
450
Per Property
$117
$52,548
4 Phosphoric Acid Treatment and Site Restoration
452
Per Property
S41,567
$18,788,215
Long-Term Monitoring Program tor Phosphate Treated
5 Properties (10% of total properties at 6 months after
45
Per Property
S402
$18,157
remediation, year 0)
. Long-Term Monitoring Reports for Phosphate Treated
6 ,
Properties
45
I lours
$1 17
$5,278
7 Plan Preparation. (Sampling Plan. H&S, QAPP)
300
Hours
$117
$35,032
8 CAPITAL COSTS SUBTOTAL
$25,788,892
9 Bid and Scope Contingency (20%)
$5,157,778
10 TOTAL DIRECT CAPITAL COSTS
$30,946,671
11 Construction Services {10%)
$3,094,667
12 CONSTRUCTION COSTS TOTAL
$34.04 l,33S
13 Remedial Engineering Design (3%)
SI.021,240
14 TOTAL CAPITAL COS TS
$35,062,578
Description
Year
lrc(|ticiicy
"I'otal Cost per
Event"
Total Cost
Present Value3
Present Value Analysis
15 Total Capital Cost
0
once
$35,062,578
$35,062,578
$35,062,578
16 Information Dissemination via Mass Media, Including
1 - 10
annually
SI 1,677
$116,774
$90,170
17 Establish Information Registry
I - 10
annually
$29,193
$291,935
$225,424
IS Public Health Education
I - 10
annually
$58,387
$583,870
$450,849
19 Maintain Public Information Center
1 - 10
annually
$11,677
$116,774
$90,170
20 TOTAL ANNUAL COSTS (Excluding Year 0)
I - 10
annuallv
$110,935
$1,109,352
$856,612
Long-Term Monitoring Program for Phosphate Treated
Properties (10% of total properties)
2,5, 10, 15,
and 20
varies
SIS,157
$90,785
$57,419
^ Long-Term Monitoring Reports for Phosphate Treated
Properties
2, 5. 10, 15,
and 20
varies
$5,278
$26,391
$16,692
23 TOTAL PHOSPHATE TREATMENT RECURRING COSTS
2, 5, 10, 15,
and 20
varies
$23,435
$117,176
$74,111
24 Five Year Reviews
5, 10, 15, 20,
25 and 30
varies
$10,000
$60,000
$27,820
25 TOTAL PRESENT VALUE OF ALTERNATIVE
$36,021,121
Nolcs:
1. All cosl estimates are based on current uiukrstnmling of the site as described in the FS and should he considered preliminary. Cost estimates are conceptual in nature and subject to revision.
2. Per EPA direction, umf cost estimates arc hosed on residential soil remediation projects of similar type, adjusted for scale as necessary, escalated for inflation at a rate of 2.24%
3. Present value calculations were performed using a discount rate of 5%
All costs are rounded where appropriate.
All cost estimates include material and labor, unless otherwise noicd.
FS - Feasibility Study L$ - lump sum
H&S - Health & Safety QAPP - Quality Assurance Project Plan
Page 1 of I
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