PROPOSED PLAN
CHEROKEE COUNTY SITE
OPERABLE UNIT 08 -
RAILROADS
CHEROKEE COUNTY, KANSAS
U. S. Environmental Protection Agency
Region 7
11201 Renner Blvd
Lenexa, Kansas 66219
Prepared by:
August 2016
-------
Table of Contents
I. PURPOSE OF THE PROPOSED PLAN 1
II. SITE BACKGROUND 2
Site Location and Description.... 2
History of Contamination 2
Site Characteristics 3
Health Effects 3
EPA Response Actions 4
III. SCOPE AND ROLE OF THE PROPOSED RESPONSE ACTION 4
IV. SUMMARY OF SITE RISKS 4
Ecological Risk 4
Human Health Risk 6
V. REMEDIAL ACTION OBJECTIVES 6
Source Materials RAO.... 6
Soil RAO 6
VI. SUMMARY OF ALTERNATIVES 7
VII. EVALUATION OF ALTERNATIVES 9
Detailed Analysis of Proposed Remedial Alternative Compared to
Current Selected Remedy 10
Overall Protection of Human Health and the Environment 10
Compliance with ARARs 10
Long-term Effectiveness and Permanence 11
Reduction of Toxicity, Mobility or Volume of Contaminants through Treatment: 11
Short-term Effectiveness 12
Implementability 12
Cost 12
State/Support Agency Acceptance 13
Community Acceptance 13
VIII. PREFERRED ALTERNATIVE , 13
Statutory Determination 14
IX. COMMUNITY PARTICIPATION 14
Appendices
A. FIGURES
FIGURE 1 - SITE MAP
FIGURE 2 - CCR OU 08 MAP
B. TABLE 1 - COC CONCENTRATIONS EXPECTED TO PROVIDE ADEQUATE PROTECTION
OF ECOLOGICAL RECEPTORS
C. DETAILED COST ESTIMATE FOR ALTERNATIVE 3
iii
-------
I. PURPOSE OF THE PROPOSED PLAN
The U.S. Environmental Protection Agency is issuing this Proposed Remedial Action Plan (Proposed
Plan) to present the EPA's Preferred Alternative to address heavy metals contamination in inactive rail
lines as a remedy for the Cherokee County Railroads (CCR) operable unit (OU) 08 in the Cherokee
County Superfund site (Site).
The Site is located in Cherokee County, Kansas, the most southeastern county of the state of Kansas,
and represents the Kansas portion of the former Tri-State Mining District (TSMD). (Refer to Figure 1
for a map showing the location of the Site.) The National Superfund Database Identification Number for
the Site is KSD980741862.
The EPA is the lead agency for the Site, and the Kansas Department of Health and Environment
(KDHE) is the support agency. This Proposed Plan summarizes information from the Remedial
Investigation (RI), Feasibility Study (FS), human health risk assessment (HHRA), and ecological risk
assessment (ERA). The selected alternative is expected to meet applicable or relevant and appropriate
requirements (ARARs) and be protective of human and ecological receptors. All the documents the EPA
considered for this proposed remedy modification are contained in the Administrative Record (AR) for
the Site.
This Proposed Plan is being issued as part of the EPA's public participation requirements under Section
117 of the Comprehensive Environmental, Response, Compensation and Liability Act (CERCLA) of
1980, as amended, 42 U.S.C. § 9617, commonly known as Superfund, and Section 300.430(f)(ii) of the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR § 300.430(f)(ii).
After the close of the public comment period, the EPA will announce its selection of the remedy for the
CCR OU 08 in a Record of Decision (ROD). The public's comments will be considered and presented
with discussion in the Responsiveness Summary of the ROD. The EPA encourages the public to review
the documents that make up the Administrative Record to gain a more comprehensive understanding of
the Site and the Superfund activities that have been conducted.
The Administrative Record for the Site can be accessed at https://semspub.epa.gov/src/home/search.isf.
or at the following location:
U.S. Environmental Protection Agency
Program Representative
Region 7 Records Center
11201 Renner Blvd
Lenexa, Kansas 66219
Phone:(913) 551-7939
Hours: Monday - Friday, 8:00 am to 5:00 pm (by appointment only)
The Proposed Plan includes the following sections:
• Site Background
• Scope and Role of the Proposed Response Action
• Summary of Site Risks
• Remedial Action Objectives
• Summary of Alternatives
1
-------
• Evaluation of Alternatives
• EPA's Preferred Alternative
• Community Participation
II. SITE BACKGROUND
Site Location and Description
Cherokee County encompasses 591 square miles. The county is bordered by Crawford County on the
north, by Newton and Jasper Counties in Missouri on the east, by Labette County on the west and by
Ottawa and Craig Counties in Oklahoma on the south. The Site encompasses 115 square miles of
southeast Cherokee County. The communities of Baxter Springs, Columbus, Galena and Riverton are
located within the Site boundaries. Land use is predominantly agricultural interspersed with light
industrial and residential areas. The Site is arranged into nine OUs for administrative efficiency in
conducting environmental cleanups: OU 01, Galena Alternate Water Supply; OU 02, Spring River
Basin; OU 03, Baxter Springs subsite; OU 04, Treece subsite; OU 05, Galena Groundwater/Surface
Water; OU 06, Badger, Lawton, Waco, and Crestline subsites; OU 07, Galena Residential Soils; OU 08,
Railroads; and OU 09 Tar Creek Watershed.
This Proposed Plan is concerned solely with the CCR OU 08, consisting of the inactive rail lines within
the site boundaries and not previously addressed under other actions (Figure 2). The total length of the
rail lines in the CCR OU 08 is approximately 206,745 feet, or 39 miles.
Contaminated media at the OU 08 include mine waste (source material), soils, groundwater, sediments,
and surface water. The contaminants of concern (COCs) are lead and zinc. The contamination was
caused by lead and zinc ore mining and processing that began in Kansas in the 1870s and continued until
1970. The mining and processing generated chat piles and tailings that are the sources of the COCs.
History of Contamination
Lead and zinc mining began in the middle 1800s and continued for over a century in the TSMD; the
final mining activities ceased in 1970. Sphalerite (zinc sulfide) and galena (lead sulfide) were the
principle mined ores, and several other metal sulfides were found in association with the economic ores.
The mining activities changed the hydrology of the area by creating a labyrinth of underground voids
and many open conduits. These features facilitate surface subsidence and collapse as well as enhanced
flow of mineralized groundwater in the subsurface. Surficial mining wastes also leach metals into the
groundwater system and surface water bodies and sediments. The normal surface and subsurface flow
characteristics have been modified by past mining activities; and since much of the surface vegetation is
impacted or absent, there is increased infiltration of surface water into the shallow groundwater system
and erosion of mining wastes into surface water bodies. During the active mining years, water was
continually pumped out of the mines because the ore was predominantly located in the saturated zone of
the same bedrock formations that contain the area's shallow aquifer. When mining ceased, the mines
refilled with water as a result of natural groundwater recharge and surface water inflow through mine
shafts and subsidence areas. The upper aquifer is now contaminated with metals and is acidic in some
areas. Acid mine drainage is prevalent throughout many areas of the TSMD. Additionally, past practices
at the Site have resulted in mine waste being distributed to residential yards as fill or driveway material.
Lead and zinc are found in mining wastes and soils at maximum concentrations of several thousand
milligrams per kilogram (mg/kg).
9
-------
Site Characteristics
CCR OU 08 comprises the portions of the rail lines within the Cherokee County Site that were not
addressed under other OUs. During the years the mines operated, railroads were constructed in Cherokee
County to join conventional large-scale railroads to the individual mining operations. Figure 2 illustrates
the current and former rail line locations through the County. The ballast material used in the railroad
beds was composed of chat from surrounding mine waste piles. Traditionally, these historical railroads
were abandoned in place when mining operations ceased at that mine. Currently, the historical rail lines
that cross through private property vary in condition: some show little deterioration from their original
condition, while others have degraded to the point they are unidentifiable as former rail lines. Depending
on the current use of the area, some former rail lines exhibit extensive vegetative regrowth with a thick
organic layer, while others have been incorporated into the surrounding area. Some historical rail lines
have been investigated and remediated within other OUs. At some locations, some of the ballast may
have been completely removed in areas along the rail lines as a result of construction activities^ such as
highway cuts. A total of approximately 39 miles of inactive lines are within the Cherokee County site. A
range of average width for the inactive lines is 10.8 feet to 21.5 feet. Average thickness ranged from 1.6
feet to 3.5 feet.
Recently, many rail lines were abandoned by railroad companies and reverted back to the property
owner through the Surface Transportation Board. Regional plans exist to convert some historic rail beds
to the national Rails to Trails program. This conversion program has begun in the Missouri part of the
region with potential expansion into Kansas. This potential change in land use affects the exposure
scenarios evaluated in the HHRA and in the ERA.
Numerous remedial and removal actions have taken place throughout the Site as noted in RODs and
Five-Year Reviews for the various OUs. The RI/FS of CCR OU 08 is the first investigation of rail lines
that is not associated with investigations at areas identified as mining sites and characterized as part of
another OU.
The Site is underlain by two aquifers that are separated by a confining unit. The shallow aquifer is
comprised of Mississippian limestones which host the lead-zinc deposits that were mined at the subsites.
Water quality in the shallow aquifer is generally poor, with some water samples exceeding Maximum
Contaminant Levels (MCLs) for arsenic, cadmium, lead, mercury, and nickel. Groundwater from the
lower levels of the mine pools tends to be acidic. The shallow aquifer is not used at the subsite for
domestic or stock water supplies. The deep aquifer occurs in the Lower Ordovician Roubidoux
Formation and provides the principal source of water for public, industrial, domestic and stock supplies
at the subsites and surrounding areas.
The county is drained by the Neosho and Spring rivers and their tributaries. Lightning, Cherry, and Fly
creeks are the principal tributaries of the Neosho River in Cherokee County. Cow Creek, Shawnee
Creek, Shoal Creek, and Brush Creek are the principal tributaries of the Spring River.
Health Effects
In 1989, the Agency for Toxic Substances and Disease Registry (ATSDR) completed a Preliminary
Health Assessment (PHA) for the community of Galena. The study indicated that "lead and cadmium in
surface soil, surface water, and groundwater, are found at levels that are of public health concern."
Children were identified as the main sensitive subpopulation of concern because of their potential
exposure to contaminated soil and surface water. ATSDR concluded that the Site was a public health
3
-------
concern because of the risk to human health caused by the probable human exposure to hazardous
substances at concentrations that may result in adverse health effects.
EPA Response Actions
The EPA placed the Site on the National Priorities List (NPL), set forth at 40 C.F.R. Part 300, Appendix
B, by publication in the Federal Register'on September 8, 1983, 48 Fed. Reg. 40658. Subsequent to the
NPL listing, EPA identified and designated OU 08 in 2012. Investigation of OU 08 has consisted of the
RI/FS, Streamlined ERA, and the Baseline HHRA, as well as visits by the EPA and the KDHE to OU
08.
III. SCOPE AND ROLE OF THE PROPOSED RESPONSE ACTION
The cleanup of source materials and contaminated soils under this Proposed Plan is needed to mitigate
the principal threat of exposure from source materials to terrestrial ecosystems through soils. For the
remedy selection and status of other OUs at the Site, the EPA completed the Fifth Five-Year-Review
Report for the Site in September 2015, which can be found in the Administrative Record.
The Preferred Alternative will provide for cost effective and long-term protection of ecological health
from exposure to contaminated soil and source materials at the inactive rail lines in the Site. The main
component of the proposed remedy is excavation of source materials with disposal in select on-site
consolidation areas.
IV. SUMMARY OF SITE RISKS
A HHRA. and a streamlined ERA were prepared for OU 08 to determine whether contaminant exposure
posed unacceptable risks to residents and wildlife. No significant human health risks were identified in
the HHRA. The ERA results indicate that site-related contaminants in surface soil, surface water, and
sediment may pose a threat to ecological receptors such as fish, macro-invertebrates, birds, and other
terrestrial species. Ecological receptors are exposed to heavy metals primarily by ingestion of mine
waste, soils, sediments, surface water, vegetation, and prey as well as inhalation of toxic dusts.
However, sediment contamination does not appear to be attributable to the rail line. Based on the RI and
HHRA sampling, the average concentrations of lead and zinc in source materials and contaminated soils
are 761 parts per million (ppm) and 7,768 ppm, respectively. Additionally, the maximum values of lead
and zinc in source materials and contaminated soils are 16,533 ppm and 30,050 ppm.
It is the EPA's current judgment as the lead agency that the Preferred Alternative identified in this
Proposed Plan is necessary to protect the environment 'from actual or threatened releases of hazardous
substances into the environment. This view is also held by the support agency, KDHE.
Ecological Risk
The ERA for CCR OU8 was conducted in accordance with the EPA's Ecological Risk Assessment
Guidance for Superfund (EPA, 1992b), supplemented with more recent guidance and policy as
appropriate. Site characterization data collected during the RI was completed by Hydrogeologic, Inc.,
and samples collected from additional matrices by the EPA were used in the ERA to evaluate possible
health risks for wildlife within the study area.
4
-------
Metals present in the chat could potentially migrate into the underlying soil. Additional migration
pathways include soil to surface water/sediment, air to soil, and bioaccumulation. The potentially
exposed ecological populations include benthic organisms, fish, terrestrial plants, soil organisms, and
wildlife receptors (birds and mammals).
In terms of ecological receptors, the media of concern consist of potentially contaminated surface soil,'
surface water, and sediment. Exposure can occur through direct contact with these media. Sediment and
surface water are being addressed under a separate OU. For birds and mammals, exposure pathways also
include ingestion of surface water, incidental ingestion of soil and sediment, and consumption of food
(e.g., plants, invertebrates, fish, mammals) with contaminants accumulated in the tissue. Although
animals can inhale soil contaminants in dust, that inhalation pathway contributes negligibly as compared
to the ingestion exposure route and thus is not typically evaluated. Fur and feathers minimize the
potential for dermal absorption of contaminants.
A streamlined approach was used to characterize ecological risk in which ecological protective
concentrations were compared directly to previously established Cherokee County cleanup levels. These
cleanup levels for soil were established in the ROD for Cherokee County (OU 03 and OU 04). The
cleanup levels are meant to represent concentrations above which animals may exhibit impaired health
from exposure to metals. Compared to these cleanup levels, lead and zinc contamination was widespread
on the rail lines.
OU 08-specific clean-up levels for lead and zinc were then developed to account for the limited wildlife
exposure due to rail line contamination. Prior to adjusting clean-up levels for the rail lines, it was
determined that a simplified approach could be taken by focusing on zinc and lead. Although cadmium
concentrations were elevated at every rail line location, zinc appears to diminish the toxicity of
cadmium. Thus, high concentrations of zinc may interfere with the absorption of cadmium, and the high
zinc-to-cadmium ratio (approximately 150 to 1) along with the close correlation between these two
elements probably protects terrestrial food chains somewhat from cadmium toxicity. More importantly,
zinc toxicosis, (resulting in reduced survival) has.been documented in both birds and mammals in the
TSMD. Lead poisoning has also been documented in waterfowl, and elevated tissue concentrations of
lead have been confirmed in wild birds. These clean-up levels are based on the same terrestrial
assessment endpoint and corresponding exposure assumptions for vermivore receptors used to calculate
the Cherokee County ecological clean-up levels. However, the toxicity reference value (TRV) accounts
for a short-term (acute) exposure scenario. These rail line-specific clean-up levels are 1,770 mg/kg for
lead and 4,000 mg/kg for zinc.
Based on survival of vermivore receptors, the COCs and cleanup levels for source materials and
contaminated soils in the CCR OU 08 rail lines to protect the ecological receptors are:
Lead - 1,770 ppm
Zinc - 4,000 ppm
The EPA believes, based on the toxicity studies conducted for the CCR OU 08, that the cleanup levels
are protective of the terrestrial systems in the Site. (See Table 1.)
5
-------
Human Health Risk
An HHRA was conducted for the site consistent with current EPA guidelines for HHRA at
Superfund sites (USEPA 1989; 1991a; 1991b; 1992a; 2002a; 2002b; 2004; 2009). Site characterization
data collected during the RI was used in the HHRA to evaluate possible health risks for recreational
visitors and hypothetical future construction/excavation workers within the study area. Assumptions,
methods, and results are summarized below.
High- and low-frequency recreational visitors and hypothetical future workers were identified as
potentially exposed receptors for CCR OU 08. Recreational visitors (child, adolescent, and adult) are
those who may walk, hike, play, and/or trespass along the historic rail lines in the area and be exposed
via direct contact to surface soils along the rail beds. The hypothetical future worker represents
construction/excavation workers who may be exposed via direct contact to surface and subsurface soils
along the rail beds.
The exposure pathways identified and evaluated in the HHRA include incidental ingestion of surface
soil, dermal contact with surface soil, and inhalation of airborne soil particles. Based on the results of the
HHRA, human health risks for the recreational visitor (child, adolescent, and adult) and hypothetical
future worker were below non-cancer hazard indexes (His) of 1, and cancer risks were within the EPA's
target risk range of 1E-06 to 1E-04 for non-lead metals. For lead, using the Integrated Exposure Uptake
Biokinetic (IEUBK) model for children and the Adult Lead Methodology (ALM) for adults, the
probability that blood lead levels would exceed 10 micrograms per deciliter (|LLg/dL) were below the
EPA's health-based guideline (< 5 percent) for all receptors.
V. REMEDIAL ACTION OBJECTIVES
RAOs are quantitative, medium-specific goals for protecting 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. The RAOs specific to source materials and soils are presented
separately in this section.
Source Materials RAO
The source materials RAO is designed to address the potential risks associated with direct exposure to
COCs in the mining waste, chat, and tailings. The source material RAO is as follows:
• Prevent exposure of ecological receptors to COCs in source materials that would potentially
result in unacceptable ecological risks. Source materials containing less than 1,770 ppm lead and
less than 4,000 ppm zinc are deemed acceptable for these potential ecological risks.
Soil RAO
The soil RAO is designed to address the potential risks associated with direct exposure to COCs in the
contaminated soils. The soil RAO is as follows:
• Prevent exposure of ecological receptors to COCs in soils that would potentially result in
unacceptable ecological risks. Soils containing less than 1,770 ppm lead and less than 4,000 ppm
zinc are deemed acceptable for these potential ecological risks.
6
-------
VI. SUMMARY OF ALTERNATIVES
The EPA developed and evaluated four remedial action (RA) alternatives during the FS. The No Action
alternative was also evaluated; however, the EPA believes that the No Action Alternative is not
protective of ecological receptors and does not consider it a viable option. Additionally, each of the
alternatives would require, to varying degrees, institutional controls (ICs) to protect and augment the
remedy. The four action alternatives focus on mine waste and affected soils. During the upcoming
public comment period, the EPA welcomes and encourages public comment on the Preferred
Alternative, the other evaluated alternatives, or any other ideas or approaches.
After implementing the Preferred Alternative, a substantial amount of currently inaccessible land will
meet the objective of unlimited use and unrestricted exposure. Instances where unlimited use and
unrestricted exposure cannot be achieved will be addressed with ICs and under operation and
maintenance (O&M). Additionally, the Preferred Alternative will eliminate surface water and sediment
contamination from surficial runoff from mine waste.
Alternative 1 - No Action
Estimated Total Capital Cost: $0
Estimated Annual O&M Cost Range: $0
Estimated Present Worth Cost: $103,324
Estimated Construction Time Frame: None
Estimated Time to Achieve RAOs: RAOs unachievable
A "no action" alternative is required by the NCP, 40 CFR § 300.430(e)(6), to provide an environmental
baseline against which impacts of the various remedial alternatives can be compared. Under the no
action alternative, all current remedial activities would cease and no further action would be taken at the
site to remediate contaminated soils or address the associated risks to human health or the environment.
Five-Year Reviews would be performed as required by the NCP to evaluate whether adequate protection
of human health and the environment is provided.
Alternative 2 - Source Removal, On-Site Consolidation and Capping
Estimated Total Capital Cost: $14,250^426
Estimated Annual O&M Cost Range: $26,130 „
Estimated Present Worth Cost: $14,964,586
Estimated Construction Time Frame: 118 days
Estimated Time to Achieve RAOs: 232 days
Alternative 2 provides protection of ecological receptors through excavation and capping of
contaminated materials on site to limit exposure. Under this alternative, all ballast and contaminated soil
where concentrations of cadmium, lead, and/or zinc exceed the cleanup levels would be excavated and
then consolidated and capped in small containment areas on site. Assuming that some amounts of soil
below the footprint of the former rail bed would require removal, excavated areas would be backfilled
with clean fill. Vegetative cover would be established over the removal and capped areas to restore the
property and to provide vegetative root systems to hold the soil in place, preventing erosion and off-site
transport by surface runoff or wind.
7
-------
Source Removal
This alternative includes the removal of contaminated material above and below grade and backfilling
the excavation with clean soil. Railroad ballast material visually identified as chat would be removed
and then the underlying area would be scanned using an XRF to verify that metals concentrations in the
remaining soil are at or below cleanup levels. Excavation and removal of the underlying soil would
continue until these criteria are met. A hydraulic excavator would be used to excavate the material and
load dump trucks for transport and placement at on-site waste consolidation areas. The excavated areas
would be backfilled with clean fill and graded to provide positive drainage. Erosion and sediment
controls will be maintained for one year while the vegetative cover is being established on the backfilled
areas.
On-Site Waste Consolidation and Capping
The excavated materials would be placed in consolidation areas at each work site or within a cluster of
closely spaced small sites. A bulldozer or other grading equipment would be used to grade the mine
waste in the consolidation areas. The consolidation area would be capped with 12 inches of locally
available clayey soil and 6 inches of topsoil. This type of cap configuration has been successfully
implemented at similar OUs in Cherokee County. ICs will be required so that the consolidation areas are
not disturbed, thereby preventing exposure of the contaminated materials. O&M will be required to
maintain the integrity of the soil cover. For the purposes of this FS, this alternative assumes that
sufficient cover soil and topsoil are available within a 10-mile radius of each site and in the quantities,
and time frame required for establishing vegetative growth. It also assumes that the consolidation areas
will overlay a portion of the former rail beds (reducing the amount of material to be excavated) and that
approximately 58 small containment areas will be needed.
Alternative 3 - Source Removal with Consolidation and Capping at OU3/OU4 Consolidation
Areas
Estimated Total Capital Cost: $ 15,832,363
Estimated Annual O&M Cost Range: $7,454
Estimated Present Worth Cost: $16,028,070
Estimated Construction Time Frame: 144 days
Estimated Time to Achieve RAOs: 256 days
Alternative 3 provides protection of ecological receptors through excavation and removal, with disposal
at OU3/OU4 consolidation areas. This alternative is similar to Alternative 2, as all ballast material and
contaminated soil with metals concentrations exceeding the cleanup levels will be excavated and
removed. However, these wastes would be transported to existing consolidation areas for consolidation
and capping. ICs will be in place at the OU3/OU4 consolidation areas so that the consolidation areas are
not disturbed, thereby preventing exposure of the contaminated materials. O&M is also provided at the
OU3/OU4 consolidation areas. ICs at the OU 08 removal areas will be required to prevent residential
exposure.
Source Removal
This alternative includes the same approach to removal of mining wastes and the underlying
contaminated soil as described for Alternative 2.
Waste Consolidation and Capping
The excavated materials would be loaded into haul trucks and transported to a central consolidation area.
For the purpose of estimating costs and level of effort, it is assumed that one of the proposed waste
8
-------
consolidation areas to be. constructed as part of the OU3/OU4 Phase 2 and 3 RAs would have adequate
capacity to receive these materials, would be located within a 20-mile radius of each removal area, and
would actively be undergoing construction at the same time as the OU 08 removal activities will be
occurring.
Alternative 4 - On-Site Capping
Estimated Total Capital Cost: $9,071,027
Estimated Annual O&M Cost Range: $53,100
Estimated Present Worth Cost: $10,449,588
Estimated Construction Time Frame: 114 days
Estimated Time to Achieve RAOs: 226 days
This alternative involves capping the waste in place to prevent ecological contact. The cap would consist
of 12 inches of locally available clayey soil and 6 inches of topsoil. This type of cap configuration has
been successfully implemented at similar OUs addressed as part of the previous Baxter Springs, Treece,
Waco, and Lawton mine waste remedies. The alternative assumes that sufficient cover soil, topsoil, or
soil amendments are available within a 10-mile radius of each site and in the quantities and time frame
required for establishing vegetative growth. O&M will be required to maintain the integrity of the soil
cover, which is expected to extend for approximately 39 miles along the rail lines.
VII. EVALUATION OF ALTERNATIVES
Nine criteria, set forth in 40 CFR § 300.430(e)(9), are used to evaluate the different remediation
alternatives individually and against each other in order to select a remedy. This section of the Proposed
Plan profiles the relative performance of each alternative against the nine criteria, noting how it
compares to the other options under consideration. The nine criteria are discussed below.
9
-------
. , Evaluation Criteria for Superfund Remedial Alternatives
1. Overall Protection of Human Health and the Environment determines whether an alternative
eliminates, reduces, or controls threats to public health and the environment through institutional
controls, engineering controls, or treatment.
2. Compliance with ARARs evaluates whether the alternative meets Federal and State environmental
statutes, regulations, and other requirements that pertain to the site, or whether a waiver is justified.
3. Long-term Effectiveness and Permanence considers the ability of an alternative to maintain
protection of human health and the environment over time.
4. Reduction of Toxicity, Mobility, or Volume of Contaminants through Treatment evaluates an
alternative's use of treatment to reduce the harmful effects of principal contaminants, their ability to
move in the environment, and the amount of contamination present.
5. Short-term Effectiveness considers the length of time needed to implement an alternative and the
risks the alternative poses to workers, residents, and the environment during implementation.
6. Implementability considers the technical and administrative feasibility of implementing the
alternative, including factors such as the relative availability of goods and services.
7. Cost includes estimated capital and annual O&M costs, as well as present worth cost. Present worth
cost is the total of an alternative over time in today's dollar value. Cost estimates are expected to be
accurate within a range of +50 to -30 percent.
8. State/Support Agency Acceptance considers whether the State agrees with the EPA's analyses
and preferred alternative, as described in the RI/FS and Proposed Plan.
9. Community Acceptance considers whether the local community agrees with the EPA's analyses
and preferred alternative. Comments received on the Proposed Plan are an important indicator of
community acceptance.
10
-------
Detailed Analysis of Proposed Remedial Alternative Compared to Current Selected Remedy
Threshold Criteria
Overall Protection of Human Health and the Environment
Protection of human health and the environment is addressed to varying degrees .by the four evaluated
alternatives. The No Action Alternative would have no effect on contaminated soil. Therefore, it does
not address risks to human health.
Alternatives 2, 3, and 4 all provide protection by reducing exposure of ecological receptors to metals in
ballast and contaminated soils. Permanence is provided in Alternatives 2 and 3 through removal and
containment of contaminated materials with lead or zinc concentrations at or above their respective
cleanup levels. Permanence is provided in Alternative 4 by capping the contaminated materials in place.
Alternatives 2 and 4 leave contaminated materials on site, whereas Alternative 3 does not. Therefore,
Alternative 3 is the most protective of human health and the environment.
Compliance with ARARs
The No Action Alternative would not meet ARARs, whereas the remainder of the alternatives meet
federal and state ARARs. Chemical-, location-, and action-specific state and federal ARARs for the
remainder of the alternatives would be achieved by making sure all materials exceeding cleanup levels
are capped with a soil cover either on or off site. All alternatives except Alternative 1 would achieve
ambient air quality regulations by keeping the duration of excavation to a minimum and by employing
dust suppression measures while excavating and transporting contaminated soil. In addition, all
alternatives except Alternative 1 would remove or cover all contaminated materials with concentrations
greater than the cleanup levels and would achieve the goal of reducing the risk of exposure to ecological
receptors.
Primary Balancing Criteria
Long-term Effectiveness and Permanence
Alternative 1 would not provide long-term effectiveness for the protection of health and environment.
Under the remainder of the alternatives, the residual risks (the risk remaining after implementation)
would be significantly reduced. The removal or capping of contaminated soil ensures that future
potential for exposure would be significantly reduced. Alternative 3 would provide the most permanence
by removing all ballast and contaminated soils and disposing of them off site. Alternatives 2 and 4
would provide less permanence because contaminated materials would remain on site and could
potentially be exposed if cover material were to become disturbed.
Reduction of Toxicity. Mobility or Volume of Contaminants through Treatment
There would be no reduction in the toxicity, mobility, or volume of contamination under the No
Action Alternative (Alternative 1).
Alternatives 2, 3, and 4 would significantly reduce the mobility of the contaminants on site. Only
Alternative 3 reduces the volume of contaminants on site. None of the alternatives would reduce the
toxicity of the contaminants. Treatment methods identified in the FS that would be appropriate for heavy
metals contamination are pozzolanic stabilization, phosphate stabilization, and phytoextraction. The
limitations with in-place pozzolanic stabilization include increased material volume. The majority of the
former railbeds are in rural areas, and in many instances are in the middle of pastures or fields where
"paved" areas would not be desirable. Pilot scale studies performed at other sites have demonstrated that
i
11
-------
in the short-term, phosphate stabilization may reduce the bioavailability of lead by 30 to 50 percent in
residential soils; however, it is only effective on lead concentrations less than 1,200 mg/kg (Mosby, et
al., 2006). Its effectiveness on chat is unknown because chat is not a fine grained material like
residential soils. In addition, the use of phosphoric acid, which is the most effective for long term
stabilization of lead, may cause increased short term leaching of zinc (Mosby, et al., 2006). The data for
this site shows that zinc contamination above the cleanup levels is more widespread than lead
contamination. Plants used for phytoextraction may accumulate high concentrations of metals which
may necessitate the disposal of plant matter as special waste. In addition, getting plants to grow in the
chat may be problematic. Based on these reasons, these technologies will not be carried forward for
consideration in developing remedial alternatives to address the site risks.
No other treatment technologies were identified to adequately remediate the volume and type of waste at
the CCR OU 08. If such technology is identified at a later date, pilot studies and related analysis may
support a remedy decision change.
The residual waste found in the CCR OU 08 rail lines is considered a low-level threat waste, which is
defined as source materials containing COCs that generally are relatively immobile in air or
groundwater in the specific environmental setting (OSWER, Publication 9380.3-06FS, 1991). However,
the residual waste in the CCR OU 08 rail lines has the potential to be a principal threat waste when it is
mobilized by mechanical means, making remediation necessary to mitigate the potential risk. If the
residual waste in the CCR OU 08 rail lines becomes a principle threat waste, a treatment alternative will
be assessed in a remedy change decision document such as an Explanation of Significant Differences or
ROD Amendment. Overall, containment will be employed due to the effectiveness of nontreatment
technologies (excavation, consolidation, capping, revegetating) for source materials and contaminated
soils. •
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 would remain.
Alternatives 2 and 3 would have increased short-term risks for the public, environment, and construction
workers during excavation, backfilling, and transportation efforts. Disturbed contaminated soil could
enter the ambient air during excavation and transportation. However, dust suppression measures would
be implemented for the protection of community and workers during the RA. The alternatives would be
lengthy to implement, requiring years to complete. Alternative 3 has a higher airborne dust risk than
Alternative 2 because of the increased haul distance, and thus an extended duration to complete
implementation of the remedial alternative. Alternative 4 would have fewer short-term risks than
Alternatives 2 or 3 because contaminated materials would not be excavated, but would be capped in
place.
Implementability
Alternative 1 is highly implementable, requiring only Five-Year Reviews. The technologies involved in
the remaining alternatives are readily implementable and are technically feasible from an engineering
perspective. Earthwork is a typical construction operation. The experience from previous work
conducted for the other Cherokee County OUs by the EPA has shown that all four of these alternatives
would be readily implementable.
Cost
The total present value of the alternatives are estimated to be:
-------
• Alternative 1 - $103,324 with O&M costs of $0
• Alternative 2 - $14,964,586 with O&M costs of $627,533
• Alternative 3 - $16,028,070 with O&M costs of $179,010
• Alternative 4 - $ 10,449,588 with O&M costs of $ 1,275,238
No capital or O&M costs would be associated with Alternative 1 because no RAs would be conducted.
However, it is assumed that Five-Year Review costs would be associated with Alternative 1 (periodic
costs). Alternatives 2, 3, and 4 incur capital, O&M, and periodic costs.
I
Capital costs include the RA work and implementation of ICs. O&M costs include inspections and
maintenance of the consolidation areas to maintain the integrity of the caps. Periodic costs include Five-
Year Reviews. Alternative 3 would have the lowest O&M costs as O&M and ICs would be required
only for the off-site consolidation areas that would be maintained as part of the OU 04 Phase 3
Baxter/Treece RAs.
Modifying Criteria
State/Support Agency Acceptance
State acceptance of the alternatives will be fully determined after the public comment period closes for
the Proposed Plan. Any comments received from the State will be. reviewed and addressed in the
Responsiveness Summary.
Community Acceptance
Community acceptance of the Preferred Alternative will be evaluated after the public comment period
ends. The EPA will be addressing questions and comments in the Responsiveness Summary of the
ROD.
VIII. PREFERRED ALTERNATIVE
This section presents the detailed description of the EPA's Preferred Alternative, which is Alternative 3
in the FS. Alternative 3 is a remedial alternative based on excavating and disposing of source materials
and contaminated soils in on-site consolidation areas in the OU 03 and OU 04 subsites for addressing
the principal threats. This alternative relies on excavation and on-site disposal, containment, and capping
of source materials to attain the RAOs. Detailed costs associated with the implementation of Alternative
3 are presented in Appendix B. The total cost estimated for this alternative is $16,028,070 for capital
costs, with an estimated O&M cost of $ 179,010.
The Preferred Alternative consists of the following:
This alternative includes the removal of contaminated material above and below grade and backfilling
the excavation with clean soil. Railroad ballast material visually identified as chat would be removed
and then the underlying area would be scanned using x-ray fluorescence (XRF) to verify that metals
concentrations in the remaining soil are at or below cleanup levels. Excavation and removal of the
underlying soil would continue until these criteria are met. A hydraulic excavator would be used to
excavate the material and load dump trucks for transport and placement at on-site waste consolidation
areas. The excavated areas would be backfilled with clean fill and graded to provide positive drainage.
Erosion and sediment controls will be maintained for one year while the vegetative cover is being
established on the backfilled areas.
13
-------
The excavated materials would be loaded into haul trucks and transported to a central consolidation area.
For the purpose of estimating costs and level of effort, it is assumed that one of the proposed waste
consolidation areas to be constructed as part of the OU 04 Phase 2/3 Baxter/Treece RAs would have
adequate capacity to receive these materials, would be located within a 20-mile radius of each removal
area, and would actively be undergoing construction at the same time as the CCR OU 08 removal
activities will be occurring. The consolidation would not significantly enlarge the OU 03/04
consolidations areas, and the removal of materials from the OU 08 areas will increase other areas in the
county suitable for agricultural or other non-residential use.
Based on survival of vermivore receptors, the cleanup levels for source materials and contaminated soils
in the CCR OU 08 rail lines to protect the ecological receptors are:
Lead - 1,770 ppm
• Zinc - 4,000 ppm
The EPA is prepared to begin design of the Preferred Alternative within 12 months of issuance of the
ROD.
Statutory Determination
Based on the information currently available, the EPA believes the Preferred Alternative meets the
threshold criteria and provides the best balance of tradeoffs among the other alternatives with respect to
the balancing and modifying criteria. The EPA expects the Preferred Alternative to satisfy the following
statutory requirements of CERCLA § 121(b): (1) be protective of human health and the environment; (2)
comply with ARARs; (3) be cost-effective; (4) utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent practicable; and (5) satisfy the
preference for treatment as a principal element, or explain why the preference for treatment will not be
met.
IX. COMMUNITY PARTICIPATION
The EPA relies on public input to ensure that the remedy selected for each Superfund site meets the
concerns of the local community. The public is encouraged to participate in the Proposed Plan and ROD
process at OU 08. This Proposed Plan highlights key information from the RI and FS Reports, HHRA,
ERA, Five-Year Review Reports, and AR. Additionally, the public historically has been made aware of
the environmental issues in the county through the many public meetings, public availability sessions,
newspaper articles, television coverage, radio broadcasts, and press releases that have occurred at the
Site for the many environmental cleanups conducted to date. .
Public Comment Period - To allow for community involvement, a public comment period will be open
from August 13, 2016, through September 13, 2016. During this time the public is encouraged to submit
to the EPA any comments on the Proposed Plan.
Public Meeting - A public meeting will be held to discuss the Proposed Plan on August 15, 2016, from
6:30 p.m. to 8:30 p.m. The public meeting will be held at the Baxter Springs Community Center at 1101
East Avenue, Baxter Springs, Kansas.
Detailed information on the material discussed herein may be found in the AR for the Site, which
includes the CCR OU 08 RI, FS, HHRA, ERA, and other information used by the EPA in the decision-
14
-------
making process. The AR also includes relevant information related to the CCR OU 08. The EPA
encourages the public to review the AR in order to gain a more comprehensive understanding of the
subsite and the Superfund activities that have taken place there. Copies of the AR are available for
review at https://semspub.epa.gov/src/home/search.isf. or at the following location:
U.S. Environmental Protection Agency
Region 7 Records Center
11201 Renner Blvd
Lenexa, Kansas 66219
Hours: Monday through Friday, 8:00 am to 5:00 pm; by appointment with representatives below.
The deadline to submit comments is September 13, 2016. Written comments, questions about the
Proposed Plan or public meeting, and requests for information can be sent to either representative below:
Elizabeth Hagenmaier Brendan Corazzin
Remedial Project Manager Community Engagement Specialist
U.S. Environmental Protection Agency U.S. Environmental Protection Agency
Region 7 - SUPR/SPEB Region 7 - RGAD/ECO
11201 Renner Boulevard 11201 Renner Boulevard
Lenexa, Kansas 66219 Lenexa, Kansas 66219
(913) 551-7939 (913) 551-7429
Hagenmaier.Elizabeth@epa.gov Corazzin.Brendan@epa.gov
Following the conclusion of the public comment period on this Proposed Plan, the EPA will prepare a
Responsiveness Summary. The Responsiveness Summary will summarize and respond to comments on
EPA's Preferred Alternative for the CCR OU 08. The EPA will also prepare a formal decision
document, the ROD, which summarizes the decision and the remedy for the CCR OU 08. The ROD will
include the Responsiveness Summary. Copies of the ROD will be available for public review in the
designated repositories, described above.
15
-------
Figures
-------
HGL—Feasibility Study for Cherokee County Site OU8 Railroads, Cherokee County, Kansas
(>st-srv-QI HGL( US Cherokee County MSIW FS
(2-01 )Sile Vic inity mxJ
5 122016 JG
Source HGL ESRI Online USA TopoMaps
~ HGL
Legend
c::j Site Boundary
Figure 1 Site
Location
General
KANSAS
Cherokee County
-------
K
? Wm
WG£ /• east bihf\ Study for C 'herokee ('ounn Site Ql/fi
Railroads, Cherokee County. Kansas
/ Of]/
/ rul~Jr
r
7
Figure 2
Former Rail Line Classifications and
Sample Locations
/ [13TI
/ Cfvsdie r
. 1 4f»
fraction
Legend
1101 Sample Location
/.—, [g] Anq
•/ _ i^ii^'nfririi B J 311
Site Boundary
Rail Classification
/ [24j lM] y 1 JVIII]
/ / 1 |28] ®
/ fj
/ / 1 1221
"•¦m.
Former Line
No Longer Present or Remediated
/ 1c
Addressed Under Other OU
^ Rail Line Designation for Estimation of
Volume of Material Requiring Remediation
/ Hh# ^Vl
/ \ y
S ^k g C»ic»4^
f* \ B
V 1 J33I
|3] \ rr^ »fc US
\ 1^1321^
1 \M*| K
mi .. ton*
|13-Bi=^tJ
Hj
[ [3]
Ml^CD
LSrJ^
X, 1 ~,'"'°\2Ql
1 IT fill
®>. °J*H ~ r
(2-QJjRR ( 7o.it Xmtple Lots wtxti
OKI AHOMA ~7l0l
>t .A
•t" Pids«
*
5
1
&[
« «S0 l»J00 21 m
"2V2t>Ifi XI
So*ret lira
AniifS Onto* f S< Tap-Stop
v HGt
t«
•r
dm y
F«H
-------
Tables
-------
Table 1
COC Concentrations Expected to Provide Adequate Protection of Ecological Receptors
Habitat
Type/Name
Exposure
Medium
COC
Protective
Level
Units
Basis1
Assessment
Endpoint
Terrestrial
Soil
Lead
1,770
mg/kg
TRV
Terrestrial
receptors
(shrew, the
American
woodcock)
Zinc
4,000
mg/kg
TRV
Notes
1 Provide Basis of Selection: Toxicity reference value (TRV) for lead is based on a study by
Pankakoski et a!. (1994) for mammals. TRV for zinc is based on a study by Kalin et al. (1993)
for avians. TRVs were applied to specific receptors with assumed exposure scenarios of
incidental ingestion.
-------
Detailed Cost Estimate for Alternative 3
-------
Site: Cherokee County Superfund Site OU6
Location: Cherokee County, Kansas
Phase: Feasibility Study
Base Year: 2016
Date: 5/6/2016
Description: Capital Costs for Alternative 3
Unit costs are based on the most recent costing efforts for RA at Cherokee County OUs 3 and 4 unless noted below.
Item
Description
Estimated
Quantity
Unit of
Measure
Unit
Cost
Project
Cost
Notes '
01 - Initial Activities
• -•
•• •
$205,855
• ••• . •y-.'.-;.
01
Prepare Work Plans & Permits/Mobilization
1
$40,000.00
$40,000
02
Temporary Fencinq
2,000
LF
$4.07
$8,140
Resued as needed for hiqher traffic areas.
03
Temporary Access/Haul Road Improvements
64
LS
$1,500
$96,000
04
XRF Grid Survey
12,343
EA
$5.00
$61,715
Covers technician and XRF rental; assume 20 shots/hour. To determine lateral extent.
02 - Site Preparation
$203,445
05
Construction Survey and Stakinq
2
DY
$1,104
$2,207
Temporary Erosion and Sediment Control - Pre-Construction
06
Stabilized Construction Entrance
2
EA
$1,500
$3,000
07
Silt Fence
10,000
LF
$1.42
$14,200
06
Straw Bales
5,800
EA
$5.00
$29,000
Assume 100 bales/mile to address minor drainaqes and road ditches
09
Clearinq and Grubbinq
180.0
AC
$835.01
$150,302
Assumed 25' work area alonq line would need clearinq and qmbbinq
Demolition
10
Barbed VNfire Fence Demolition
. 3,200
LF
$1.48
$4,736
Assumed at least two per access area 25' width, no fences runninq alonq former rail bed
04 - Earthwork
$4,274,496
Mine Waste and Contaminated Soil
11
Excavation. Haulinq. and Placement - On Site Consolidation
BCY
$7.39
$0
12
Excavation. Haulinq, and Placement - Consolidation Area <10 miles
113,500
BCY
$8.41
$954,535
Assumed 35% of total volume and dozer work at consolidation area. R.S. Mean - 2 CY Excavotor. 18 CY
Haul Truck, D10 Bulldozer.
13
Excavation. Haulinq, and Placement -Consolidation Area 10 to 30 miles
'210,700
BCY
$15.23
$3,208,961
Assumed 65% of total volume and dozer work at consolidation area. R.S. Mean - 2 CY Excavotor. 18 CY
Haul Truck, D10 Bulldozer.
14
XRF Confirmation Samplinq
18,500
EA
$6.00
$111,000
Assume on a 50' spacing along centerlineand on each side of rail bed
05 • Restoration r
$5,334,440
Import and Place Soil from Off-Site Borrow Sources
General Restoration
15
Select Fill
117,676
ECY
$21.65
$2,547,688
Estimated volume needed to bring the excavations back flush with the ground surface.
16
Top Soil
68.042
ECY
$30.28
$2,060,307
Mine Waste Consolidation Area
17
Select Fill
ECY
$20.30
$0
Assume the OU3 or OU4 consolidation areas can receive the OU8 material at no cost to the OU8 project.
18
Top Soil
ECY
$29.75
$0
19
Finish Gradinq
142
AC
$1,123
$159,872
20
Mine Waste Consolidation Area Boundary Monuments
EA
$158.89
$0
Seed/Fertilizer/Mulch
21
Seed - Pasture
142
AC
$2,233
$317,975
22
Seed - Native -
AC
$2,814
$0
23
Seed - Wetland
AC
$2,987
$0
Drainaqe Improvements
24
Drainaqe Swale/Replace Roadway Ditch
4,135
LF
$17.36
$71,782
Assume 2% of protect length requires ditch repairs or new drainaqe
25
Replace/Repair Access Gate
16
EA
$607.45
$9,719
Assume one quarter of the temporary access points require qate replacement
26
Replace/Repair Barbed Wre Fence
3,840
LF
$4.07
$15,629
Demo lenqth plus 20%
27
Remove/Repair Temporary Access/Haul Road
13
LS
$1,500
$19,200
Assume 20% of the access points require removal or repair
Temporary Erosion and Sediment Control - Post-Construction
28
Silt Fence
10.000
LF
$1.42
$14,200
29
Straw Bales
5,800
LF
$13.46
$78,068
30
Straw Wattles
LF
$1.71
$0
31
Inspection and Maintenance
1
LS
$40,000.00
$40,000
Walking inspection of all disturbed areas plus miscellaneous topsoil repair and seedinq.
' SubTotal:
$10,018,236
32
Bid and Scope Contingency
35%
percent
$3,506,382.44
Scope contingency of 25% and Bid contingency of 10%
33
Project Management
5%
percent
$676,230.90
Based on EPA quidance.
34
Remedial Design
6%
percent
$811,477.08
Based on EPA quidance.
35
Construction Management
6%
percent
$811,477.08
Based on EPA quidance.
\ . v ^ •" .Estimated Construction Total:
. $15,823,803
AC: Acre; BCV: Bank Cubic Yard; DY Day: EA: Each; ECY: Embankment Cubic Yard; LF: Linear Feet: LS: Lump Sum; SY: Square Yard
E-10
-------
Site; Cherokee County Superfund Site OU8
Location: Cherokee County, Kansas
Phase: Feasibility Study
Base Year: 2016
Date: 5/6/2016
Description: Annual O&M for Alternative 3
Unit costs are based on the most recent costing efforts for RA at Cherokee County OUs 3 and 4 unless
noted below.
Item
Description
Estimated
Quantity
Unit of
Measure
Unit cost
Project Cost
Notes
Covei-'Maintenance • ~ ^ '
01
Repair Eroded Areas
02
Excavation, Haulinq, and Placement
140
ECY
$20.30
$2,842.00
03
Reveqetate Cover
1
acre
$2,233.18
$2,233.18
04
Staff Engineer - annual inspection of LuCs
8
per hour
$109.48
$875,84
RACER 33220106
'.-Subtotal:
!:;A.$5;951;Q2>H
•:?. * V 'V' - V).':' ^ . i*-'- ' -V ~ . ;Ai?<
05
Bid and Scope contingency
20%
percent
$1,190.20
Bid and Scope continqencv of 10% each.
06
Project Manaqement
5%
percent
$142.10
Based on EPA Guidance.
07
Technical Support
6%
percent
$170.52
Based on EPA Guidance.
' ^ Total O&M Cost
!i©is
E-11
-------
Site: Cherokee County Superfund Site OU8
Location: Cherokee County, Kansas
Phase: Feasibility Study
Base Year: 2016
Date: 5/6/2016
Description: Periodic Costs for Alternative 3
Item
Description
Estimated
Quantity
Unit of
Measure
Unit cost
Project Cost
Notes
5 Year Review, Re
portingv,p. .;¦¦¦!r~V. ¦¦¦-
; :: ^ \ S: :¦' ''
01
Staff Enqineer
12
per hour
$109.48
$1,313.77
RACER 33220106
02
Project Engineer
4
per hour
$139.21
$556.85
RACER 33220105
03
Draftsman/CADD
6
per hour
$87.39
$524.36
RACER 33220115
04
Project Manager
2
per hour
$169.75
$339.50
RACER 33220102
:.'k:/ '¦
.-J'.'!/"'1- -i'-V-1;.''
'ViTxP.
-HSubtStal:
• S2.734.48:'
V;. " 'Z7-.' . 'L ,V'¦
05
Bid and Scope contingency
20%
percent
$546.90
Bid and Scope contingency of 10% each.
06
Project Management
5%
percent
$136.72
Based on EPA Guidance.
07
Technical Support
6%
percent
$164.07
Based on EPA Guidance.
« Total Periodic Costs
$3,582.17
(
E-12
-------
Site: Cherokee County Superfund Site OU8
Location: Cherokee County, Kansas
Phase: Feasibility Study
Bass Year: 2016
Date: 5/6/2016
Description: LUCs for Alternative 3
Item
Description
Estimated
Quantity
Unit of
Measure
Unit cost
Project Cost
Notes
Implementation of LUCs - i f,,- 1 '.v.-;-'i; :-;'= ¦•'ai^
01
3-man survey crew
2
per hour
$208.38
$448.73
02
Staff Engineer
24
per hour
$115.99
$2,719.73
RACER 33220106
03
Project Engineer
8
per hour
$147.49
$1,152.78
RACER 33220105
04
Draftsman/CADD
13
per hour
$92.59
$1,175.99
RACER 33220115
OS
Project Manager
4.8
per hour
$179.84
$843.38
RACER 33220102
a«$«34o:60S!K
08 |Contingency | 35% ] percent |
$2,219.21
Scope Contingency of 25%. Bid Contingency of 10%
E-13
------- |