FINAL
FEASIBILITY STUDY
CHEROKEE COUNTY OPERABLE UNIT 8 RAILROADS SITE
CHEROKEE COUNTY, KANSAS
Prepared for:
U.S. Environmental Protection Agency Region 7
11201 Renner Boulevard
Lenexa, KS 66219
Architect and Engineering Services Contract EP-S7-05-05
Task Order: 0061
July 2016
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FINAL
FEASIBILITY STUDY
CHEROKEE COUNTY OPERABLE UNIT 8 RAILROADS SITE
CHEROKEE COUNTY, KANSAS
Prepared for:
U.S. Environmental Protection Agency Region 7
901 North 5th Street
Kansas City, KS 66101
Prepared by:
HydroGeoLogic, Inc.
6340 Glenwood, Suite 200
Building #7
Overland Park, KS 66202
July 2016
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Section
TABLE OF CONTENTS
Page
EXECUTIVE SUMMARY 1
1.0 INTRODUCTION AM) PURPOSE 1-1
2.0 SITE BACKGROUND 2-1
2.1 SITE LOCATION AND DESCRIPTION 2-1
2.2 REGIONAL TOPOGRAPHY AND SURFACE DRAINAGE 2-2
2.3 NATURE AND EXTENT OF CONTAMINATION 2-3
2.3.1 Chemicals of Potential Concern 2-3
2.3.2 Summary of Soil Data 2-4
2.4 FATE AND TRANSPORT 2-5
2.5 RISK ASSESSMENT OVERVIEW 2-6
2.5.1 Human Health Risk Assessment Summary 2-6
2.5.2 Ecological Risk Assessment Summary 2-7
2.5.3 Conclusions 2-8
3.0 REMEDIAL ACTION OBJECTIVES 3-1
3.1 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS ... 3-1
3.1.1 Definition of ARARs 3-2
3.1.2 Identification of ARARs 3-3
3.2 PRELIMINARY REMEDIAL ACTION OBJECTIVES 3-4
3.3 PRELIMINARY CLEANUP LEVELS 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
4.3 IDENTIFICATION AND SCREENING OF REMEDIAL TECHNOLOGIES
AM) PROCESS OPTIONS 4-2
4.3.1 Identification of Potentially Applicable Technologies and Process
Options 4-2
4.3.2 Screening of Potentially Applicable Technologies and Process Options 4-3
4.4 RETAINED GRAS, REMEDIAL TECHNOLOGIES, AND PROCESS
OPTIONS 4-4
5.0 DEVELOPMENT AND SCREENING OF 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 Acti on 5-2
5.3.2 Alternative 2: Source Removal, On-Site Waste Consolidation and
Capping 5-2
5.3.3 Alternative 3: Source Removal, Waste Consolidation and Capping at
OU3/OU4 Consolidation Areas 5-3
5.3.4 Alternative 4: On-Site Capping 5-4
5.4 SCREENING EVALUATION OF ALTERNATIVES 5-4
5.5 SUMMARY OF ALTERNATIVES SCREENING 5-6
5.6 ALTERNATIVES RETAINED FOR DETAILED ANALYSIS 5-7
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Section
TABLE OF CONTENTS (continued)
Page
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
6.5 SHORT-TERM EFFECTIVENESS 6-2
6.6 IV1PI.I:V1I:M ABILITY 6-3
6.7 COST 6-3
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 Acti on 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 7-3
7.3.1.5 Reduction of Toxicity, Mobility, or Volume through
Treatment 7-3
7.3.1.6 Short-Term Effectiveness 7-3
7.3.1.7 Implementability 7-3
7.3.1.8 Cost 7-3
7.3.2 Alternative 2: Source Removal, On-Site Waste Consolidation and
Capping 7-3
7.3.2.1 Summary of Remedial Alternative 7-3
7.3.2.2 Overall Protection of Human Health and the Environment.... 7-4
7.3.2.3 Compliance with ARARs 7-4
7.3.2.4 Long-Term Effectiveness and Permanence 7-4
7.3.2.5 Reduction of Toxicity, Mobility, or Volume through
Treatment 7-4
7.3.2.6 Short-Term Effectiveness 7-5
7.3.2.7 Implementability 7-5
7.3.2.8 Cost 7-5
7.3.3 Alternative 3: Source Removal, Waste Consolidation and Capping at
OU3/OU4 Consolidation Areas 7-5
7.3.3.1 Summary of Remedial Alternative 7-5
7.3.3.2 Overall Protection of Human Health and the Environment.... 7-5
7.3.3.3 Compliance with ARARs 7-5
7.3.3.4 Long-Term Effectiveness and Permanence 7-6
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TABLE OF CONTENTS (continued)
Section Page
7.3.3.5 Reduction of Toxicity, Mobility, or Volume through
Treatment 7-6
7.3.3.6 Short-Term Effectiveness 7-6
7.3.3.7 Implementability 7-6
7.3.3.8 Cost 7-6
7.3.1 Alternative 4: On-Site Capping 7-6
7.3.1.1 Summary of Remedial Alternative 7-6
7.3.1.2 Overall Protection of Human Health and the Environment.... 7-6
7.3.1.3 Compliance with ARARs 7-7
7.3.1.4 Long-Term Effectiveness and Permanence 7-7
7.3.1.5 Reduction of Toxicity, Mobility, or Volume through
Treatment 7-7
7.3.1.6 Short-Term Effectiveness 7-7
7.3.1.7 Implementability 7-7
7.3.1.8 Cost 7-7
7.4 COMPARATIVE ANALYSIS OF ALTERNATIVES 7-7
7.4.1 Protection of Human Health and the Environment 7-8
7.4.2 Compliance with ARARs 7-8
7.4.3 Long-Term Effectiveness and Permanence 7-8
7.4.4 Reduction of Toxicity, Mobility or Volume 7-8
7.4.5 Short-Term Effectiveness 7-9
7.4.6 Implementability 7-9
7.4.7 Cost 7-9
7.4.8 State Acceptance 7-10
7.4.9 Community Acceptance 7-10
7.4.10 Detailed Analysis Summary 7-10
8.0 REFERENCES 8-1
U.S. EPA Region 7
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LIST OF TABLES
Table ES. 1 Preliminary Cleanup Levels for COCs
Table ES.2 Summary of Comparative Analysis of Alternatives for the Cherokee County
Operable Unit 8 Railroads Mining Site
Table 2.1 Preliminary Chemicals of Potential Concern
Table 2.2 XRF Screening Data from RI
Table 3.1 Scope and Extent of ARARs
Table 3.2 Preliminary Cleanup Levels for COCs
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 Rating 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 Cherokee County OU8
Railroads Site
LIST OF FIGURES
Figure 2.1 Site Location
Figure 2.2 Former Rail Line Classifications and Sample Locations
Figure 2.3 Conceptual Site Model
U.S. EPA Region 7
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LIST OF APPENDICES
Appendix A Summary of Federal and State Applicable or Relevant and Appropriate
Requirements
Appendix B Preliminary Screening of Remedial Alternatives
Appendix C Detailed Analysis of Remedial Alternatives
Appendix D Volume Estimations
Appendix E Detailed Alternative Analysis Cost Information
U.S. EPA Region 7
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LIST OF ACRONYMS AND ABBREVIATIONS
AES
Architect and Engineering Services
ALM
adult lead methodology
ARAR
Applicable or Relevant and Appropriate Requirement
bgs
below ground surface
CCR
Cherokee County Site-Operable Unit 8 Railroads
CERCLA
Comprehensive Environmental Response, Compensation, and Liability Act
CFR
Code of Federal Regulations
COC
contaminant of concern
COPC
contaminant of potential concern
CSM
conceptual site model
CY
cubic yards
EPA
U.S. Environmental Protection Agency
ERA
ecological risk assessment
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 controls
IEUBK
Integrated Exposure Uptake Biokinetic
jug/dL
micrograms per deciliter
mg/kg
milligrams per kilogram
NCP
National Contingency Plan
O&M
operation and maintenance
OMB
Office of Management and Budget
OU
operable unit
PRG
preliminary remediation goal
RA
remedial action
RAO
remedial action objective
RI
Remedial Investigation
ROD
Record of Decision
RSL
regional screening level
U.S. EPA Region 7
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LIST OF ACRONYMS AND ABBREVIATIONS (continued)
TAL
target analyte list
TRV
toxicity reference value
U.S.C.
United States Code
XRF
x-ray fluorescence
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EXECUTIVE SUMMARY
HydroGeoLogic, Inc. (HGL) is conducting a Remedial Investigation (RI)/Feasibility Study (FS) at
the Cherokee County Site - Operable Unit (OU)8 Railroads (CCR) site in Cherokee County, Kansas.
This work is being completed under the Region 7 U.S. Environmental Protection Agency (EPA)
Architect and Engineering Services (AES) contract EP-S7-05-05, Task Order 0061.
This FS was developed to be consistent with EPA guidance for conducting an FS under the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). 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 (EPA, 2000).
This FS contains the detailed evaluation of remedial alternatives addressing the human health and
environmental risks and concerns at OU8 and was developed to assist the EPA to propose and take
public comment on a preferred remedy that addresses contaminated soil at OU8.
Site Location, History, and Contamination
The Cherokee County Superfund Site spans 115 square miles and represents the Kansas portion
of the Tri-State mining district. The Tri-State Mining District covers approximately 2,500 square
miles in northeast Oklahoma, southwest Missouri and southeast Kansas and was one of the
foremost lead-zinc mining areas of the world. The district provided nearly continuous production
from about 1850 until 1970, during which it produced an estimated 500 million tons of ore, with
about 115 million tons produced from the Kansas portion of the district.
The Cherokee County Superfund Site consists of mine tailings, soil, sediment, surface water, and
groundwater contaminated with heavy metals (principally lead, zinc, and cadmium). The primary
sources of contamination are the residual metals in the abandoned mine workings, chat piles, and
tailings impoundments in addition to historical impacts from smelting operations. The Site was
placed on the National Priorities List in 1983. As listed, the Cherokee County Superfund Site
encompasses 115 square miles including the following seven subsites: Galena, Baxter Springs,
Treece, Badger, Lawton, Waco, and Crestline. These seven subsites encompass most of the area
where mining occurred within the Site and where physical surface disturbances were evident.
These subsites have been divided or grouped into the following OUs:
• OU1 - Galena Alternate Water Supply;
• OU2 - Spring River Basin;
• OU3 - Baxter Springs subsite;
• OU4 - Treece subsite;
• OU5 - Galena Groundwater/Surface Water;
• OU6 - Badger, Lawton, Waco, and Crestline subsites; and
• OU7 - Galena Residential Soils;
• OU8 - Railroads; and
• OU9 - Tar Creek Watershed.
During the years the mines operated, railroads were constructed in Cherokee County to join
conventional large-scale railroads to the individual mining operations. The ballast material used in
the railroad beds was composed of chat from surrounding mine waste piles. Traditionally, these
U.S. EPA Region 7
ES-1
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HGL—Feasibility Study, Cherokee County 0U8 Railroads Site—Cherokee County, Kansas
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; 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.
OU8 comprises the portions of the rail lines within the Cherokee County Superfund Site that have
not been or will not be addressed in the remediation of other OUs and that have not been addressed
by other means.
During the RI phase of this project, a human health risk assessment (HHRA) and a streamlined
ecological risk assessment (ERA) was prepared for OU8 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. However, sediment
contamination does not appear to be attributable to the rail line. This FS addresses soil
contamination only.
Remedial Action Objectives
Based on the results of the risk assessments, lead and zinc were identified as contaminants of
concern (COCs) posing risk to ecological receptors. To address these risks, the remedial action
objectives (RAO)s identified for CCR OU8 for protection of ecological receptors are:
• Prevent exposure of ecological receptors to COCs in source materials that would
potentially result in unacceptable ecological risks.
• Prevent exposure of ecological receptors to COCs in soils that would potentially result in
unacceptable ecological risks.
Cleanup Levels
Ecological cleanup levels for soil were established as part of the ERA (EPA, 2015) and, at EPA's
directive, are being used in this FS to determine the volume of materials requiring remediation.
Preliminary cleanup levels for site COCs in soil are presented in Table ES.l.
Table ES.l
Preliminary Cleanup Levels for Soil COCs
COCs
( 'loiiiiiip Lex el
Soil (nig/kg)
Lead
1,770
Zinc
4,000
mg/kg = milligrams per kilogram
Remedial Alternatives
U.S. EPA Region 7
ES-2
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HGL—Feasibility Study, Cherokee County 0U8 Railroads Site—Cherokee County, Kansas
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 source materials or contaminated soil is included in this
alternative. Therefore, potential ecological risks due to exposure to contaminated materials would
remain.
Alternative 2 - Source Removal, On-Site Consolidation and Capping
Alternative 2 provides protection of ecological receptors through remedial action (RA) involving
excavation and removal to limit exposure to and mobility of contaminants. Under this alternative,
all ballast and contaminated soil with concentrations of lead and/or zinc that exceed the preliminary
cleanup levels would be excavated and then consolidated and capped in small containment areas
along the former rail beds. Excavated areas, assuming that some amount of soil below the footprint
of the former railroad spurs requires removal, would be backfilled with clean fill and topsoil and
the areas graded to provide positive drainage. Vegetative cover would be established over the
backfilled area 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. Erosion and sediment
controls will be maintained for 1 year while the vegetative cover is being established.
Excavated soil 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 mine waste consolidation areas would be covered with
a multi-layer cap to prevent future contact with and erosion of the mine waste. 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 consolidation areas would
be graded to provide positive drainage. Operation and maintenance (O&M) will be required to
retain the integrity of the cap.
Alternative 3 - Source Removal, Waste Consolidation and Capping at OU3/OU4
Consolidation Areas
Alternative 3 provides protection of ecological receptors through RA involving excavation and
removal to limit exposure to and mobility of contaminants. As in Alternative 2, all ballast and
contaminated soil with concentrations of lead and/or zinc that exceed the preliminary cleanup
levels would be excavated, the remediated areas backfilled with clean fill and topsoil, and graded
to provide positive drainage. Vegetative cover would be established over the backfilled area 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. Erosion and sediment controls will be
maintained for 1 year while the vegetative cover is being established.
U.S. EPA Region 7
ES-3
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HGL—Feasibility Study, Cherokee County 0U8 Railroads Site—Cherokee County, Kansas
Excavated soil would be loaded into haul trucks and transported to a central consolidation area,
dumped, graded, and capped as described above under Alternative 2. 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 OU4 Phase 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 OU8 removal activities.
Alternative 4 - On-Site Capping
Alternative 4 requires no excavation of materials but provides protection of ecological receptors
by capping the contaminated materials in place with 12 inches of locally available clayey soil and
6 inches of topsoil and establishing vegetation on the cap. O&M will be required to retain the
integrity of the cap.
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 are the final two EPA evaluation criteria and 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-4
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HGL—Feasibility Study, Cherokee County 0U8 Railroads Site—Cherokee County, Kansas
Table ES.2
Summary of Comparative Analysis of Alternatives for the
Cherokee County OU8 Railroads Site
Remedial
Alternative
Description
Threshold Criteria
Balancing Criteria
Overall
Protection of
Human
Health and
the
Environment
Compliance
with
AR\Rs
Long-Term
Effectiveness
and
Permanence
Reduction of
Toxicity,
Mobility, or
Volume
through
Treatment
Short-Term
Effectiveness
Implementability
Present Value
Cost (Dollars)
1
No Action
—
—
O
o
O
e
$103,000
2
Source Removal, On-Site
Waste Consolidation and
Capping
+
+
©
o
e
e
$14,965,000
3
Source Removal, Waste
Consolidation and Capping at
OU3/OU4 Consolidation
Areas
+
+
o
o
e
o
$16,028,000
4
On-Site Capping
+
+
©
o
e
e
$10,450,000
Notes:
1. Hie 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).
Legend for Qualitative Ratings System:
, ,, „ . Balancing Criteria
Threshold Criteria . .. ,, ^
(Excluding Cost)
Unacceptable © None ©
Acceptable © Low ©
© Low to Moderate ©
Moderate
Moderate to High
High
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HGL—Feasibility Study, Cherokee County 0U8 Railroads Site—Cherokee County, Kansas
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Introduction
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Site
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Remedial
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Technology
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Detailed
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Detailed
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1.0 INTRODUCTION AND PURPOSE
HydroGeoLogic, Inc. (HGL) is conducting a Remedial Investigation (RI)/Feasibility Study (FS) at
the Cherokee County Site - Operable Unit (OU)8 Railroads (CCR) site in Cherokee County, Kansas.
This work is being completed under the Region 7 U.S. Environmental Protection Agency (EPA)
Architect and Engineering Services (AES) contract EP-S7-05-05, Task Order 0061.
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). In addition, 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 chat (source material) in OU8, which was used as ballast material
for rail beds and underlying soil contaminated with heavy metals. This FS report contains a detailed
evaluation of remedial alternatives addressing the environmental risks and concerns at OU8. It was
developed to assist the EPA to propose and take public comment on a preferred remedy that
addresses the source material and contaminated soil at OU8. This report is organized as follows:
Section 1 discusses the purpose of the FS report, and the report organization.
Section 2 describes the background and characteristics of the site, including site features and
physical characteristics, a summary of the nature and extent of contamination, and a summary
of the risk assessment.
Section 3 describes the process for identifying preliminary remedial action (RA) objectives
(RAOs) and cleanup levels. This section also identifies 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.
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 retained 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.
Appendix A provides a summary of Federal and State ARARs.
Appendix B documents the preliminary screening of alternatives.
U.S. EPA Region 7
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HGL—Feasibility Study, Cherokee County 0U8 Railroads Site—Cherokee County, Kansas
Appendix C provides the detailed analysis of alternatives.
Appendix D provides the estimation of volumes of waste requiring remediation and backfill.
Appendix E 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
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HGL—Feasibility Study, Cherokee County 0U8 Railroads Site—Cherokee County, Kansas
Introduction
I
-
f N,
Site
Background
-
Remedial
Action
Objectives
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Technology
Screening
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-
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Alternative
Screening
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-
Detailed
Screening
Criteria
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Detailed
Analysis
2.0 SITE BACKGROUND
2.1 SITE LOCATION AND DESCRIPTION
The Cherokee County Superfund Site spans 115 square miles and represents the Kansas portion
of the Tri-State mining district (Figure 2.1). The Tri-State Mining District covers approximately
2,500 square miles in northeast Oklahoma, southwest Missouri and southeast Kansas and was one
of the foremost lead-zinc mining areas of the world. The district provided nearly continuous
production from about 1850 until 1970, during which it produced an estimated 500 million tons of
ore, with about 115 million tons produced from the Kansas portion of the district.
The Tri-State Mining District is characterized by a variety of mine waste features that exhibit
sparse to no vegetation. Local stream systems also contain mining wastes and mining-impacted
sediments and surface water. Residential areas are adjacent to mine waste accumulations in some
areas or have suffered historic impacts as a result of smelting. Lead and zinc are found in mining
wastes and soils at maximum concentrations of several thousand milligrams per kilogram (mg/kg),
while cadmium is typically found at levels less than 500 mg/kg.
EPA has listed four mining-related Superfund Sites in the Tri-State Mining District: the Tar Creek
Site in Oklahoma; the Jasper County and Newton County sites in Missouri; and the Cherokee
County Site in Kansas.
The Cherokee County Site consists of mine tailings, soil, sediment, surface water, and groundwater
contaminated with heavy metals (principally lead, zinc, and cadmium). The primary sources of
contamination are the residual metals in the abandoned mine workings, chat piles, and tailings
impoundments in addition to historical impacts from smelting operations. The Site was placed on
the National Priorities List in 1983. As listed, the Cherokee County Site encompasses 115 square
miles including the following seven subsites: Galena, Baxter Springs, Treece, Badger, Lawton,
Waco, and Crestline. These seven subsites encompass most of the area where mining occurred
within the Site and where physical surface disturbances were evident. These subsites have been
divided or grouped into the following OUs:
• OU1 - Galena Alternate Water Supply;
• OU2 - Spring River Basin;
• OU3 - Baxter Springs subsite;
• OU4 - Treece subsite;
• OU5 - Galena Groundwater/Surface Water;
• OU6 - Badger, Lawton, Waco, and Crestline subsites;
• OU7 - Galena Residential Soils;
• OU8 - Railroads; and
• OU9 - Tar Creek Watershed.
During the years the mines operated, railroads were constructed in Cherokee County to join
conventional large-scale railroads to the individual mining operations. Figure 2.2 illustrates the
U.S. EPA Region 7
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HGL—Feasibility Study, Cherokee County 0U8 Railroads Site—Cherokee County, Kansas
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; 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.
OU8 comprises the portions of the rail lines within the Cherokee County Superfund Site that have
not been or will not be addressed in the remediation of other OUs and that have not been addressed
by other means.
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 human health risk assessment (HHRA) and in the
ecological risk assessment (ERA).
Numerous remedial and removal actions have taken place throughout the Site as noted in RODs
and Five-Year Reviews for the various OUs. Only those segments of the rail beds that run through
other OUs or subsites at the Cherokee County Site have been investigated and remediated. The
RI/FS of OU8 is the first investigation of rail lines that are not associated with investigations at
areas identified as mining sites and characterized as part of another OU.
2.2 REGIONAL TOPOGRAPHY AND SURFACE DRAINAGE
The topography in southeast Kansas is generally gently sloping, except in the river valleys and
areas of waste stockpiles and collapsed mine areas (Figure 2.1). Topographic relief in the stockpile
areas within the Cherokee County Site approaches over 50 feet. Topographic relief associated with
existing mine shafts and collapse features is on the order of 50 to 100 feet. Side slopes along the
collapse features are generally very steep. The site topography along the rail road lines follows the
regional topography.
The area generally east of the Spring River is in the Springfield Plateau section of the Ozark
Plateaus province and is typical of the hilly timbered land in the Missouri Ozarks. Local relief
between hilltops and stream valleys is as much as 200 feet in this area.
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.
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HGL—Feasibility Study, Cherokee County 0U8 Railroads Site—Cherokee County, Kansas
2.3 NATURE AND EXTENT OF CONTAMINATION
The RI Report summarizes the nature and extent of target analyte list (TAL) metals contamination
in the rail beds in OU8 (HGL, 2016). The primary source of contamination for CCR OU8 is the
chat used to construct the rail bed ballasts. The chat originated from mining activities and ore
refinement processes that created chat, tailings, and other mine waste material that was transported
to CCR OU8.
As a part of the RI, 102 test pits were excavated with a backhoe across the rail ballasts at 34
locations selected to represent varying rail bed conditions, classification, and geographical
locations across CCR OU8. The locations are shown in Figure 2.2. At each test pit location, grab
samples were collected at 6-inch intervals from the surface to a depth of 4 feet (48 inches) below
ground surface (bgs) and screened with x-ray fluorescence (XRF). Depending on the location, one
to five test pits were excavated and sampled.
Analytical results and visual observations were used to determine if there was consistency in the
depth of the chat layer and if contamination had migrated into the native soil. Rail lines traversed
both rural and residential areas.
2.3.1 Chemicals of Potential Concern
All soils contain trace amounts of metals that are naturally occurring in the Earth's crust. The
chemicals of potential concern (COPC) metals for CCR OU8 and the matrices in which they occur
are listed in Table 2.1 below.
Table 2.1
Preliminary Chemicals of Potential Concern
Preliminary COPC
Matrix
Surface Soil
Subsurface
Soil
Cadmium
X
X
Lead
X
X
Zinc
X
X
The COPC metals listed above have been detected above the regional screening levels (RSLs) and
have formerly been associated with mining-related activities in Cherokee County. However, all of
the COPC metals 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 (HGL, 2016). These metals were evaluated in the final HHRA
and streamlined ERA performed by EPA and included in the RI Report (HGL, 2016). Results of
the final HHRA and ERA evaluations are summarized in Section 2.5.
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2.3.2 Summary of Soil Data
During the RI activities, soil samples were collected at 6-inch intervals from the ground surface to
48 inches bgs, yielding 101 surface soil samples (0 to 6 inches bgs) and 486 subsurface soil samples
(6 to 48 inches bgs). In all 101 surface soil samples the surficial materials consisted primarily of
weathered chat and not native soil. In the 486 subsurface soil samples, material consisted of
weathered chat to a depth of about 30 inches where the material generally transitioned to native
soil. Table 2.2 summarizes the RI data.
Table 2.2
XRF Screening Data
10 m RI
Depth
lnler\ 21I
(hgs)
kcsidenliiil
Soil RSI.
Detection K nil lie
Nil in her
of
Siimples
Nil in her
of
Detections
RSI.
Kxceediinces
Minimum
Miixiniiini
Ciuliiiiiiin
0-6 inches
14
66
101
67
67
6-12 inches
14
74
81
62
62
12-18 inches
14
72
71
54
54
18-24 inches
7.1
14
74
68
47
47
24-30 inches
14
79
68
28
28
30-36 inches
18
36
68
25
25
36-42 inches
15
49
65
12
12
42-48 inches
13
37
65
10
10
l.esul
0-6 inches
13
2,271
101
99
44
6-12 inches
14
2,255
81
80
43
12-18 inches
22
2,218
71
70
37
18-24 inches
400
17
3,490
68
65
32
24-30 inches
10
16,533
68
59
16
30-36 inches
11
7,739
68
55
15
36-42 inches
12
2,720
65
49
6
42-48 inches
7
2.01^
65
41
1
Zinc
0-6 inches
55
20,467
101
101
71
6-12 inches
71
23,967
81
81
62
12-18 inches
81
30,050
71
71
53
18-24 inches
2,300
29
19,433
68
68
45
24-30 inches
18
22,603
68
68
23
30-36 inches
27
19,100
68
68
20
36-42 inches
20
7,429
65
65
8
42-48 inches
18
7,720
65
61
5
RSL = regional screening level
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It should be noted that the cadmium detection limit for the XRF exceeded the Residential Soil RSL
(HQ = 0.1) in all soil samples reported as nondetect for the metal.
The highest XRF readings observed are as follows:
• Cadmium
o Surface soil - 66 at Location 5.
o Subsurface soil - 79 at Location 27 (24 to 30 inches bgs).
• Lead
o Surface soil - 2,271 at Location 9.
o Subsurface soil - 16,533 at Location 13 (24 to 30 inches bgs).
• Zinc
o Surface soil - 20,467 at Location 29.
o Subsurface soil - 30,050 at Location 17 (12 to 18 inches bgs).
As shown in the RI data, COPC contamination was found to be widespread in both the surface and
subsurface rail bed materials and no hotspots were indicated from the data. Metals concentrations
generally decreased in the samples of native soil collected beneath the chat if it was encountered
above the target depth of 48 inches. Ten samples collected from the deepest sample interval (42 to
48 inches) contained one or more of the three metals above their respective Residential Soil RSL.
Chat was found to extend to the target depth of 48 inches at 7 locations shown on Figure 2.2:
Locations 7, 8, 13, 21, 22, and 29.
2.4 FATE AND TRANSPORT
The Conceptual Site Model (CSM) is key to assessing the potential remedies that may be suitable
for a site contaminated with organic or inorganic (metals) compounds. Characterization of the
nature of the release and migration mechanisms, the extent of contamination, as well as an
exposure pathway analysis, are required to determine the level of risk posed by the contaminant
release and to select and to design an appropriate remedy. The physical and chemical
characteristics of the COPCs are also taken into account when developing the CSM.
Based on historical background information and analytical results from previous field efforts,
initial data considered in developing the CSM included:
• Chat from mining activities conducted in Cherokee County from 1850 to 1970 was used
as ballast on rail road beds in the county;
• Selected metals contamination was detected in the surface and subsurface soil fill material
(chat) used as ballast for the rail beds;
• Native soil also was contaminated with metals to a depth of 48 inches bgs, likely due to
leaching of metals from the overlying weathered chat ballast;
• Surface soils on and near the rail beds also may have been impacted by surface water runoff
and airborne dust from mine wastes lying adjacent to the abandoned rail lines in some areas,
or from the same migration mechanisms acting on the rail beds themselves; and
• The three COPCs (cadmium, lead, and zinc) were detected above their respective
Residential Soil RSLs.
Figure 2.3 presents the CSM developed for the site, and includes a visual depiction of the pathway
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for mining-related wastes to enter the environment. Section 2.5 discusses the conceptual exposure
models for human health and ecological risk developed to identify potentially exposed populations
by tracking contaminant movement in the environment from the source to receptor.
Analytical data from the RI and previous investigations indicate that COPC metals are present in
the chat supplied as rail road ballast, in the surface and subsurface soils of the rail beds that are
predominantly weathered chat, and also in the underlying native soils at concentrations that exceed
their Residential Soil RSLs. This is supported by analytical data indicating that elevated metals
concentrations generally decreased significantly in samples of native soils versus the overlying
weathered chat.
The near-surface soils present in Cherokee County include many silts and clays, which also
underlie the weathered chat. Organic materials in the silts and the fine-grained nature of the clays
make it likely that metals weathering and leaching from the chat would bind tightly to the soil
particles and become immobile in the environment. The COPC metals have a tendency to adsorb
to soils and their mobility is highly limited, especially in the case of fine-grained soils and/or soils
with high content of 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 properties combined with their natural
corrosion resistance lead to their being immobile and persistent in the environment. Sorption and
precipitation to soil particles, metal oxides, and organic matter are the primary means of
entrainment of metals contamination in the environment.
2.5 RISK ASSESSMENT OVERVIEW
The following risk assessment discussion is taken from the RI Report (HGL, 2016). The HHRA
and streamlined ERA were performed by EPA and are included in the RI Report as Appendices J
and K, respectively. The risk assessments were conducted using soil data from the RI and
additional data from surface water and sediment samples collected by EPA.
2.5.1 Human Health Risk Assessment Summary
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 (EPA, 2015a). 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 OU8. 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.
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HGL—Feasibility Study, Cherokee County 0U8 Railroads Site—Cherokee County, Kansas
The exposure pathways identified and evaluated in the HHRA include: incidental ingestion of
surface and subsurface soil, dermal contact with surface and subsurface 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 (|ig/dL) were below the EPA's health based guideline (< 5 percent) for
all receptors.
2.5.2 Ecological Risk Assessment Summary
The ERA for CCR OU8 was conducted in accordance with EPA's Ecological Risk Assessment
Guidance for Superfund (EPA, 1992b), supplemented with more recent guidance and policy as
appropriate (EPA, 2015b). Site characterization data collected during the RI completed by HGL,
and samples collected from additional matrices by EPA were used in the ERA to evaluate possible
health risks for wildlife within the study area. Assumptions, methods, and results are summarized
below.
During the years the mines operated, railroads were constructed in Cherokee County to join
conventional large-scale railroads to the individual mining operations. Historically, the ballast used
in the railroad beds was composed of chat from surrounding mine waste piles. 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. 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, the 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.
EPA determined that a simplified approach focusing on lead and zinc could be taken in the ERA
to develop cleanup levels for soils because of the limited wildlife exposure to rail line
contamination at OU8. Although cadmium concentrations were elevated at every rail line location,
the high concentrations of zinc appear to diminish the toxicity of cadmium by interfering with the
absorption of cadmium. This phenomenon has been noted by several researchers (Eisler, 1993;
Fox et al., 1983; Kowalczyk et al., 1984). The high zinc-to-cadmium ratio (approximately 150 to
1) and the close correlation between these two elements likely protects terrestrial food chains
somewhat from cadmium toxicity (Chaney et al., 2001).
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HGL—Feasibility Study, Cherokee County 0U8 Railroads Site—Cherokee County, Kansas
The cleanup levels developed for lead and zinc are based on the same terrestrial assessment
endpoint and corresponding exposure assumptions for vermivore receptors used to calculate the
Cherokee County ecological cleanup levels. However, the toxicity reference value (TRV) accounts
for a short-term (acute) exposure scenario. Although the TRV is based on acute effects, the limited
area represented by rail lines was assumed to result in exposures that are even shorter in duration
than the exposures used to estimate the acute TRVs. According to the ERA, this will be protective
of sensitive species foraging on the rail line for a short period of time and, for zinc in particular,
organisms should be able to recover from limited exposure to high zinc levels due to the
physiological ability to regulate zinc. Based on these assumptions, the cleanup levels established
in the ERA are 1,770 mg/kg for lead and 4,000 mg/kg for zinc. These clean-up levels would only
be applicable to rail lines that have not been disturbed by land owners and are not surrounded by
other mining related impacts. Only in these cases would the limited exposure assumptions apply.
The cleanup levels for sediment are based on the values established for the Tri-State Mining
District (MacDonald et al., 2010). Finally, surface water cleanup levels are based on chronic
National Ambient Water Quality Criteria, and are adjusted based on site-specific hardness. The
cleanup levels are meant to represent concentrations above which animals may exhibit impaired
health from exposure to metals.
Based on the assessment endpoints selected for the development of the Cherokee County cleanup
levels, each of the 34 test pit locations and nine stream locations were considered separate exposure
areas within the ERA.
The ERA results indicate that site-related contaminants in surface soil, surface water, and sediment
may pose a threat to ecological receptors:
• Surface soil concentrations exceeded the ERA-established cleanup values for zinc at 29
locations and lead at 11 locations.
• Surface water contamination was identified at three sample locations. Based on nearby soil
sample results, contamination at one of the locations appears to be attributable to the rail
line.
• Sediment concentrations of zinc exceed cleanup levels at one location; however, the
contamination does not appear to be attributable to the rail line.
Note that this FS covers surface soil contamination only. Surface water and sediment
contamination are to be addressed under separate OUs.
2.5.3 Conclusions
Based on the results of the HHRA, no significant human health risks are identified for either the
recreational visitor (child, adolescent, and adult) or hypothetical future worker, as all calculated
non-cancer His and cancer risks were below target levels. The ERA results indicate that site-related
contaminants in surface soil, surface water, and sediment may pose a threat to ecological receptors.
Based on these results, lead and zinc were retained as soil COCs and evaluated in this FS. The
cleanup levels established in the ERA are 1,770 mg/kg for lead and 4,000 mg/kg for zinc.
U.S. EPA Region 7
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HGL—Feasibility Study, Cherokee County 0U8 Railroads Site—Cherokee County, Kansas
Introduction
—~
Site
Background
-#•
Remedial
Action
Objectives
-
{ \
Technology
Screening
—~
f "\
Alternative
Screening
—~
Detailed
Screening
Criteria
—+¦
r \
Detailed
Analysis
v. v
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." Preliminary RAOs are media-specific and source-specific goals achieved through
completion of an 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.
Preliminary RAOs are typically developed by evaluating several sources of information, including
results of risk assessments and tentatively identified ARARs. These inputs provide the basis for
determination of whether protection of human health and the environment is achieved for a
remedial alternative.
The following sections present the ARARs, preliminary RAOs, and the cleanup levels that have
been identified for the site.
3.1 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
EPA and the Kansas Department of Health and the Environment (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 ROD as
performance standards for development of the remedial design and subsequent RA
implementation.
Implementation of on-site RAs 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. Table 3.1 contains a summary of the scope and intent of ARARs with regards to on-site and
off-site actions.
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HGL—Feasibility Study, Cherokee County 0U8 Railroads Site—Cherokee County, Kansas
Table 3.1
Scope and Extent of ARARs
Scope of Requirements
Extent to Which Other Laws Apply
On-site Compliance
Substantive
Applicable or Relevant and Appropriate
Off-site Compliance
Substantive and Administrative
Applicable Requirements
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"
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 a threshold criterion 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, RA, 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
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HGL—Feasibility Study, Cherokee County 0U8 Railroads Site—Cherokee County, Kansas
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:
1) It is part of a total RA 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 RA 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.
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HGL—Feasibility Study, Cherokee County 0U8 Railroads Site—Cherokee County, Kansas
3.2 PRELIMINARY 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 an 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.
Preliminary RAOs are typically developed by evaluating several sources of information, including
results of the HHRA and preliminarily identified ARARs. During development of the preliminary
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 preliminary RAOs
provide the foundation for the numerical cleanup levels, and remediation alternatives, which will
be established by EPA in the ROD for the Site.
The preliminary RAOs identified for protection of ecological receptors for CCR OU8 are:
• Prevent exposure of ecological receptors to COCs in source materials that would
potentially result in unacceptable ecological risks.
• Prevent exposure of ecological receptors to COCs in soils that would potentially result in
unacceptable ecological risks.
3.3 PRELIMINARY CLEANUP LEVELS
This FS is focused on cleanup of soils, and does not address sediment or surface water. The
ecological cleanup levels for soil were established in the ERA for OU8 (EPA, 2015). The cleanup
levels are meant to represent concentrations above which animals may exhibit impaired health
from exposure to metals. Preliminary cleanup levels for site COCs in soil are presented in Table
3.2.
Table 3.2
Preliminary Cleanup Levels for COCs
COCs
Cloiiiiiip Lcm'I for Soil (in«/k«)
Lead
1,770
Zinc
4,000
U.S. EPA Region 7
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HGL—Feasibility Study, Cherokee County 0U8 Railroads Site—Cherokee County, Kansas
f ^
Introduction
I J
-
/ s
Site
Background
^ J
-
Remedial
Action
Objectives
>
Technology
Screening
r \
Alternative
Screening
V J
-
Detailed
Screening
Criteria
V -/
-
C *\
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 the contaminated media. 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 5.0.
The identification and screening process consists of the following general steps:
• Develop GRAs for the contaminated media that will satisfy the preliminary 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 preliminary 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 CCR OU8. 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 source materials and contaminated soils are:
• No action • Source Removal
• Containment • Source Treatment
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.
Containment includes such actions as capping, covering, armoring, or habitat modification. These
actions are designed to reduce contaminant mobility, and biota exposure by physical separation.
Source Removal involves a complete or partial removal of contaminated media, followed by
transport, consolidation, and disposal at an on-site/off-site location. These actions are designed to
eliminate the exposure of biota to contaminants on site.
Source Treatment involves biological, chemical, thermal, and/or physical measures applied to
the contaminated media that reduce toxicity, mobility, and/or volume of the contaminants present.
4.3 IDENTIFICATION AND SCREENING OF REMEDIAL TECHNOLOGIES AND
PROCESS OPTIONS
During this general scoping phase, a wide range of potential remedial technologies and process
options were reviewed and the following determinations made:
• Remedial technologies/process options that should be eliminated and have no further
consideration because they are unable to remediate the contaminated media due to site
conditions or the lack of compatibility with the contaminated media.
• Remedial technologies/process options that are technically implementable but that should
be eliminated and have no further consideration based on low effectiveness, low
administrative implementability, and/or high cost for the contaminated media.
• Remedial technologies/process options that could provide remedial benefits in
combination with other remedial technologies but would only have cost-effective
application for specific site elements and particular conditions.
• Remedial technologies/process options that have substantial potential and applicability as
a stand-alone remedy are being retained for further consideration.
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).
4.3.1 Identification of Potentially Applicable Technologies and Process Options
The following remedial technologies were identified during the general scoping phase of the FS:
• No Action.
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• Containment - capping the contaminated media with a protective barrier using soil,
geosynthetics, or vegetation.
• Source Removal - excavation, transport, consolidation, and disposal. Process options for
source removal include partial excavation.
• Treatment - in situ or ex situ mixing of contaminated source materials and soil with
amendments to make heavy metals less bioavailable and less leachable.
4.3.2 Screening of Potentially Applicable Technologies and Process Options
The remedial technologies in this section have been screened and identified for further
consideration in developing remedial alternatives to satisfy the RAOs. Treatment of contaminated
soil to reduce bioavailability of metals has not been found to be a technically feasible, readily
implementable technology in past remedial efforts at the Cherokee County site. These types of
technologies will not be carried forward for consideration in developing remedial alternatives to
address site risks.
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 RAs are taken at the site. Current
risks posed from contaminants at the site remain unmitigated, uncontrolled, and unmanaged. In
accordance with the NCP, this GRA must be considered to provide a baseline against which other
options can be compared.
Containment
Soil/clay caps, with a topsoil layer and vegetative cover, have been used extensively to immobilize
contaminants and physically isolate biota from contaminated media. This technology is highly
applicable to the Cherokee County site and will be carried forward for consideration in developing
remedial alternatives to address the site risks.
Source Removal, Transport Consolidation, and Disposal
Excavation of contaminated ballast and soil is an accepted and highly utilized technology for
addressing risks at sites where mining waste is present. Excavation is easily implementable with
readily available equipment and labor. For purposes of this FS, the excavation process option
includes backfilling with clean soil, returning the property to its original elevation and grade, and
revegetating. This technology will be carried forward for consideration in developing remedial
alternatives to address site risks.
Consolidation and disposal of contaminated materials excavated is an accepted and highly utilized
technology for addressing site risks. Consolidation and disposal are easily implementable with
readily available equipment and labor. Consolidation and disposal would be either on-site or off-
site. Alternate disposal and repository options will only be evaluated if they result in a cost savings.
This technology will be carried forward for consideration in developing remedial alternatives to
address the site risks.
Treatment
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Treatment methods appropriate for heavy metals contamination are: pozzolanic stabilization,
phosphate stabilization, and phytoextraction.
Pozzolanic stabilization. This method addresses metals in soils by the addition of a solidifying
agent, such as Portland cement or fly ash, to form a monolith, similar to concrete. The pozzolan
agent is added in situ by introducing a slurry mixture into the soil, then mixing with an auger. The
monolith created would reduce leachability and mobility of metals in soils by reducing soil particle
surface area and inhibiting human contact by encapsulating soils. 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. The majority of the former
rail beds are in rural areas, and in many times are in the middle of pastures or fields where "paved"
areas would not be desirable. Therefore, this technology will not be carried forward for
consideration in developing remedial alternatives to address the site risks.
Phosphate stabilization. This method is a chemical stabilization procedure in which phosphate
salts are added to soils, sediments, and mine tailings in either solid or liquid form and mixed with
the soil. Phosphate ions combine with heavy metals to form less soluble phosphate complexes.
Although the metals are not removed, they become less bioavailable and are less likely to be
absorbed when ingested. Phosphate can be added to the soil in the form of phosphoric acid, triple-
super phosphate, or phosphate rock. Following application of the phosphoric acid, lime is added
to raise the pH to acceptable levels and the area revegetated. 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 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 the CCR site shows that zinc contamination
above the cleanup levels is more widespread than lead contamination. Based on these reasons, this
technology will not be carried forward for consideration in developing remedial alternatives to
address the site risks.
Phytoextraction. This treatment method uses specific plants and soil amendments to increase
uptake of heavy metals. Plants used for phytoextraction may accumulate concentrations of metals
high enough to necessitate the disposal of plant matter as special waste. In addition, chat has little
to no organic matter; therefore, it is likely to be problematic to establish vegetation in this medium.
This technology will not be carried forward for consideration in developing remedial alternatives
to address the site risks.
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. These retained remedial technologies and
process options are presented in Table 4.1.
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The retained remedial technologies and process options are assembled into remedial alternatives
in Section 5.0.
Table 4.1
Retained Remedial Technologies ant
Process Options
(idici'iil Response Action
kcmcdi;il Technology
Process Option
No Action
None
No action
Excavation
Excavate mining wastes and
contaminated soil
Removal, Transport, Consolidation,
and Disposal
Hauling
Highway and off-road trucks
Consolidation and Disposal
On- or off-site
Containment
Capping
Soil cap and vegetated soil cover
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Introduction
I
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C \
Site
Background
^ J
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Remedial
Action
Objectives
r \
Technology
Screening
^ J
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C "N
Alternative
Screening
^ y'
Detailed
Screening
Criteria
v y
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Detailed
Analysis
v y
5.0 DEVELOPMENT AND SCREENING OF 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 (identified in Section 3.2).
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.
The remedial alternatives for OU8 span a range of categories defined by the NCP as follows:
• No action alternative.
• Alternatives that address the principal threats but involve little or no treatment; protection
would be by prevention or control of exposure through actions such as containment and/or
engineered controls and institutional controls (ICs).
• Alternatives that, as their principal element, employ treatment that reduces the toxicity,
mobility, or volume of the contaminants.
• Alternatives that remove or destroy contaminants to the maximum extent, eliminating or
minimizing long-term management.
• Alternatives that include treatment technologies.
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 preliminary 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 4.0. These fundamental
assumptions were taken into consideration during development of remedial alternatives and
include the items listed in Table 5.1.
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Table 5.1
Assumptions Affecting Development of Remedial Alternatives
Fundamental Assumption
Rationale
Removal actions addressing zinc-
contaminated soil would also address lead-
contaminated soil.
Based on analytical data, all of the railway benn samples collected
during the remedial investigation phase that contained elevated
concentrations of zinc also had elevated concentrations of lead.
The soils underlying raised railway
ballasts constructed of chat or other
mining-related materials likely exceed the
preliminary cleanup levels.
Surface water and precipitation falling on the railway areas can
easily percolate down through the porous rail bed materials and
leach metals into the underlying fine-grained soils.
5.3 DESCRIPTION OF REMEDIAL ALTERNATIVES
Remedial alternatives were assembled by combining the retained remedial technologies and
process options. Table 4.1 provides a list of the retained remedial technologies/process options
that were used to develop each remedial alternative. The fundamental site assumptions and factors
described in Section 5.2 were also considered during development of the remedial alternatives.
The remedial alternatives evaluated were:
• Alternative 1: No Action
• Alternative 2: Source Removal, On-Site Waste Consolidation and Capping
• Alternative 3: Source Removal, Waste Consolidation and Capping at OU3/OU4
Consolidation Areas
• Alternative 4: Containment and Capping in Place
The following subsections provide generalized descriptions of the remedy components for
remedial alternatives to be evaluated during the screening process presented in this section.
5.3.1 Alternative 1: No Action
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.
5.3.2 Alternative 2: Source Removal, On-Site Waste Consolidation and Capping
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 whose concentrations of lead and/or zinc exceed the preliminary cleanup levels
would be excavated and then consolidated and capped in small containment areas on site.
Excavated areas, assuming that some amount of soil below the footprint of the former rail bed may
require removal, 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.
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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 preliminary 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 1 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 and contaminated materials becomes exposed. Operation and
maintenance (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.
5.3.3 Alternative 3: Source Removal, Waste Consolidation and Capping at OU3/OU4
Consolidation Areas
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 preliminary cleanup
levels will be excavated and removed; however, these wastes would be transported to existing
consolidation areas for consolidation and capping.
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 consolidation areas to be constructed as part of the OU4 Phase 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 OU8 removal
activities will be occurring.
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5.3.4 Alternative 4: On-Site Capping
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.
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
KITccli\ cncss ( riloriii
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
1 These criteria are referred to as "threshold criteria" that 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.
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Table 5.3.
Effectiveness Qualitative Ratings System
KITeclhcncss killings ( jiloyories
©
None
o
Low
©
Low to moderate
©
Moderate
o
Moderate to high
©
High
Implementabilitv
Implementability relates to the ability of the remedial alternative to satisfy screening evaluation
criteria detailed in Table 5.4.
Table 5.4 Implementability Criteria
C 'ritorisi
Description
Tcchnii'iil IV;isihili(\
\hility to construct, reliably operate, and meet technology-specific
regulations for process options until an RA is complete
\hi lity to operate, maintain, replace, and monitor technical components
al'lcr the RA is complete
\(lniinis(r;i(i\c
IViisihililv
\hi Lity to obtain approvals from other agencies
\\ ailability and capacity of treatment, storage, and disposal services
\\ ailability of property, specific materials and equipment, and technical
specialists required for an RA
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
IniplcnicnliihililY killings C :ilc«orios
©
None
o
Low
©
Low to moderate
©
Moderate
o
Moderate to high
©
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
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Cost estimates were not prepared for the screening evaluation. Instead, the relative cost of each
alternative was used to rate the alternatives. The cost rating categories are as presented in
Table 5.6.
Table 5.6
Cost Qualitative Ratings System
Cost Killings ( jiloyories
$
Low
$$
Low to moderate
$$$
Moderate
$$$$
Moderate to high
C'C' C'C'
4)4)4)4)4)
High
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 Appendix B. 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 threshold 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 Appendix B. 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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Table 5.7
Summary of A
ternatives Screening
Alternative
Description
Effectiveness
Implementability
Approx. Cost
(Present Value
Dollars)
1
No Action
Q
©
$
2
Source Removal, On-Site Waste
Consolidation and Capping
©
©
$$$$
3
Source Removal, Waste
Consolidation and Capping at
OU3/OU4 Consolidation Areas
o
9
$$$$
4
On-Site Capping
©
©
$$
Legend for Qualitative Ratings System:
Effectiveness and Implementability Cost (Present Value Dollars)
O
None
© None
o
Low
$ Low
0
Low to Moderate
$$ Low to Moderate
e
Moderate
$$$ Moderate
o
Moderate to High
$$$$ Moderate to High
e
High
$$$$$ 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
Source Removal, On-Site Waste Consolidation and Capping
3
Source Removal, Waste Consolidation and Capping at OU3/OU4 Consolidation Areas
4
On-Site Capping
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f ^
Introduction
I J
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Site
Background
^ J
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Remedial
Action
Objectives
r \
Technology
Screening
^ J
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Alternative
Screening
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Screening
Criteria
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Detailed
Analysis
v y
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 compliance with chemical-, location-,
and action-specific ARARs. If the assessment indicates an ARAR will not be met, then the basis
for justifying one of the six ARAR waivers allowed under CERCLA (Table 6.1) is discussed.
6.3 LONG-TERM EFFECTIVENESS AND PERMANENCE
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:
• 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.
• Adequacy and reliability of controls that 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
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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 enviromnent than alternative options. (CERCLA
§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 an RA to be undertaken solely under Section 104 using the fund,
selection of an 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
enviromnent 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 enviromnent, 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
• 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:
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• 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
Implementabi
ity Factors to be Considered During Alternative Evaluation
Crileriii
I'iiclors to he Considered
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.
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
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Cost estimates are developed according to A Guide to Developing and Documenting Cost
Estimates during the Feasibility Study (EPA, 2000). 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 E.
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 equipment replacement) 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
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 rates 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, 1993). As outlined in^4
Guide to Developing and Documenting Cost Estimates during the Feasibility Study (EPA,
2000), a 7 percent real discount rate should be applied over the period of evaluation for
each alternative.
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The 30-year nominal treasury interest rates (OMB, 2015) for the last 20 years (have generally 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 estimating cost for the alternative
evaluation in this FS at this time for the reasons cited. Based on the Table of Past Years Discount
Rates from Appendix C of OMB Circular No. A-94, a discount rate of 1.5 % was applied to the
cost calculations.
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: threshold criteria, balancing criteria,
and modifying criteria (Table 6.3). These criteria help prioritize among the factors that affect the
remedial alternatives evaluation during detailed evaluation.
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
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.
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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 and 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
+ Acceptable
O Low
© Low to moderate
© Moderate
© Moderate to high
© High
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Introduction
Site
Background
Remedial
Action
Objectives
Technology
Screening
Alternative
Screening
Detailed
Screening
Criteria
Detailed
Analysis
7.0 DETAILED ANALYSIS OF RETAINED ALTERNATIVES
7.1 OVERVIEW
In this section, remedial alternatives retained in Section 5.0 undergo detailed analysis. During
detailed analysis, each alternative is assessed using the two threshold criteria and five balancing
criteria presented in Section 6.0. 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
Alternative 2
Alternative 3
Alternative 4:
No Action
Source Removal, On-Site Waste Consolidation and Capping
Source Removal, Waste Consolidation and Capping at OU3/OU4
Consolidation Areas
On-Site Capping
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 5.0. 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 4.0.
Some of these secondary assumptions are grouped into distinct categories and include the items
listed in Table 7.1.
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Table 7.1
Secondary Assumptions Affecting Refinement and
Detailed Analysis of Remedial Alternatives
Secondary
Assumption
Category
Secondary Assumption
Description
Rationale
Waste Removal
All mining wastes visible at the
ground surface will be removed,
regardless of the concentrations
of COCs in the material.
This is consistent with the EPA's position on
waste removal on similar OUs in Cherokee
County.
Waste Containment
and Capping
The number of consolidation
areas should be limited, if
possible.
The KDHE's position during previous and
ongoing phases of similar work at other OUs in
Cherokee County lias been to limit the number of
waste consolidation areas. KDHE will be
responsible for long term operation and
maintenance of the consolidation areas; therefore,
they prefer to have fewer areas to manage.
Remedial Action
Scheduling
The construction activities can
be scheduled to coincide with
similar activities being
conducted on OUs 3 and 4 in
Baxter Springs and Treece,
Kansas, and that there is
sufficient space in the waste
consolidation areas to be
constructed in those OUs.
The OU8 construction activities are similar to
those conducted during previous and ongoing
phases of OUs 3 and 4. Scheduling the OU8 work
to coincide with future work at OUs 3 and 4 and
including it in the scope for OU4 will result in cost
savings associated with putting the project out to
bid and construction, as well as reducing the
number of waste consolidation areas in the area.
7.3 ALTERNATIVES FOR CONTAMINATED SOIL
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
Evaluation of overall protection of human health and the environment for Alternative 1 is provided
in Table C. 1A (Appendix C) using the evaluation criteria along with the qualitative rating for each
and the justification for the rating. The overall rating on this criterion for Alternative 1 is
unacceptable. —
7.3.1.3 Compliance with ARARs
Evaluation of compliance with ARARs for Alternative 1 is provided in Table C.1B (Appendix C)
using the evaluation criteria considerations along with the qualitative rating for each and the
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justification for the rating. 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
Evaluation of long-term effectiveness and permanence for Alternative 1 is provided in Table C.1C
(Appendix C) using the evaluation criteria considerations along with the qualitative rating for each
and the justification for the rating. The overall rating on this criterion for Alternative 1 is none. ©
7.3.1.5 Reduction of Toxicity, Mobility, or Volume through Treatment
Alternative 1 does not provide reduction of toxicity, mobility, or volume through treatment
because treatment is not an option under Alternative 1. See Table C. ID (Appendix C) for a detailed
evaluation of criteria considerations along with the qualitative rating for each and the justification
for the rating. The overall rating on this criterion for Alternative 1 is none. ©
7.3.1.6 Short-Term Effectiveness
Evaluation of short-term effectiveness for Alternative 1 is provided in Table C.1E (Appendix C)
using the evaluation criteria considerations along with the qualitative rating for each and the
justification for the rating. The overall rating on this criterion for Alternative 1 is none. ©
7.3.1.7 Implementabilitv
Evaluation of implementability for Alternative 1 is provided in Table C.1F (Appendix C) using
the evaluation criteria considerations along with the qualitative rating for each and the justification
for the rating. The overall rating on this criterion for Alternative 1 is high. ©
7.3.1.8 Cost
Evaluation of cost for Alternative 1 is provided in Table C.1G (Appendix C) using the evaluation
criteria considerations along with the cost rating for each and the justification for the rating.
Detailed cost estimates for this alternative are included in Appendix E. The present value cost for
Alternative 1 is $103,000.
7.3.2 Alternative 2: Source Removal, On-Site Waste Consolidation and Capping
7.3.2.1 Summary of Remedial Alternative
Alternative 2 provides protection of ecological receptors through excavation and capping of
contaminated materials to limit exposure and transport of contaminants. Under this alternative, all
ballast and contaminated soil whose concentrations of lead and/or zinc exceed the preliminary
cleanup levels would be excavated, consolidated, and capped in small on-site containment areas.
For the purposes of this FS, it was assumed that the on-site containment areas would overlay a
portion of the former rail bed and that some amount of soil below the footprint of the former rail
bed may require removal. The excavated areas would be backfilled with clean fill and graded to
provide positive drainage. Vegetative cover would be established over the backfilled area to restore
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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. On-site consolidation areas would be constructed
that overlay a portion of the former rail bed. The consolidation areas would be capped with 12
inches of clayey soil and 6 inches of topsoil. For the purposes of this FS, this alternative 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. The
components of Alternative 2 are described in detail in Section 5.3.2.
Based on the information provided in the RI, estimated volumes of materials that would need
remediation were calculated and the methodology, assumptions, and calculations are included as
Appendix D. Based on these calculations, approximately 266,000 cubic yards (CY) of material
would require excavation and consolidation. Assuming that the excavations will be backfilled to
provide positive drainage, the amount of backfill will be approximately 82,000 CY. An additional
176,000 CY of fill material will be required to construct the cover on the consolidation areas.
7.3.2.2 Overall Protection of Human Health and the Environment
Evaluation of overall protection of human health and the environment for Alternative 2 is provided
in Table C.2A (Appendix C) using the evaluation criteria along with the qualitative rating for each
and the justification for the rating. The overall rating on this criterion for Alternative 2 is
acceptable. +
7.3.2.3 Compliance with ARARs
Evaluation of compliance with ARARs for Alternative 2 is provided in Table C.2B (Appendix C)
using the evaluation criteria considerations along with the qualitative rating for each and the
justification for the rating. 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
Evaluation of long-term effectiveness and permanence for Alternative 2 is provided in Table C.2C
(Appendix C) using the evaluation criteria considerations along with the qualitative rating for each
and the justification for the rating. 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
No off-site transportation and disposal will be implemented in this alternative. No treatment of
soils will be conducted. See Table C.2D (Appendix C) for a detailed evaluation on this criterion
using the evaluation criteria considerations along with the qualitative rating for each and the
justification for the rating. The overall rating on this criterion for Alternative 2 is low. O
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7.3.2.6 Short-Term Effectiveness
Evaluation of short-term effectiveness for Alternative 2 is provided in Table C.2E (Appendix C)
using the evaluation criteria considerations along with the qualitative rating for each and the
justification for the rating. The overall rating on this criterion for Alternative 2 is moderate. ©
7.3.2.7 Implementabilitv
Evaluation of implementability for Alternative 2 is provided in Table C.2F (Appendix C) using
the evaluation criteria considerations along with the qualitative rating for each and the justification
for the rating. The overall rating on this criterion for Alternative 2 is moderate to high. ©
7.3.2.8 Cost
Evaluation of cost for Alternative 2 is provided in Table C.2G (Appendix C) using the evaluation
criteria considerations along with the cost rating for each and the justification for the rating.
Detailed cost estimates for this alternative are included in Appendix E. The present value cost for
Alternative 2 is $14,965,000.
7.3.3 Alternative 3: Source Removal, Waste Consolidation and Capping at OU3/OU4
Consolidation Areas
7.3.3.1 Summary of Remedial Alternative
Alternative 3 provides protection of ecological receptors through RA (excavation and removal,
vegetative cover) to limit exposure and transport of contaminants, as described above for
Alternative 2. It also includes removal of all ballast and contaminated soil whose metals
concentrations exceed the preliminary cleanup levels. These wastes would be transported to the
OU3/OU4 consolidation areas for consolidation and capping. The remedy components of
Alternative 3 are detailed in Section 5.3.3. Based on the methodology and assumptions presented
in Appendix D, approximately 324,000 CY would require excavation and disposal and
approximately 186,000 CY would be required for backfill to bring the excavation up to grade. It
is assumed that the increase in the amount of materials needed to cover the consolidation areas is
negligible for the purposes of this FS.
7.3.3.2 Overall Protection of Human Health and the Environment
Evaluation of overall protection of human health and the environment for Alternative 3 is provided
in Table C.3 A (Appendix C) using the evaluation criteria along with the qualitative rating for each
and the justification for the rating. The overall rating on this criterion for Alternative 3 is
acceptable. +
7.3.3.3 Compliance with ARARs
Evaluation of compliance with ARARs for Alternative 3 is provided in Table C.3B (Appendix C)
using the evaluation criteria considerations along with the qualitative rating for each and the
justification for the rating. ARARs evaluated for this alternative are included in Appendix A. The
overall rating on this criterion for Alternative 3 is acceptable. +
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7.3.3.4 Long-Term Effectiveness and Permanence
Evaluation of long-term effectiveness and permanence for Alternative 3 is provided in Table C.3C
(Appendix C) using the evaluation criteria considerations along with the qualitative rating for each
and the justification for the rating. The overall rating on this criterion for Alternative 3 is moderate
to high. O
7.3.3.5 Reduction of Toxicity, Mobility, or Volume through Treatment
Transportation and disposal will be implemented in this alternative; however, no treatment of soil
is involved. See Table C.3D (Appendix C) for a detailed evaluation on this criterion using the
evaluation criteria considerations along with the qualitative rating for each and the justification for
the rating. The overall rating on this criterion for Alternative 3 is low. O
7.3.3.6 Short-Term Effectiveness
Evaluation of short-term effectiveness for Alternative 3 is provided in Table C.3E (Appendix C)
using the evaluation criteria considerations along with the qualitative rating for each and the
justification for the rating. The overall rating on this criterion for Alternative 3 is moderate. ©
7.3.3.7 Implementability
Evaluation of implementability for Alternative 3 is provided in Table C.3F (Appendix C) using
the evaluation criteria considerations along with the qualitative rating for each and the justification
for the rating. The overall rating on this criterion for Alternative 3 is moderate to high. O
7.3.3.8 Cost
Evaluation of cost for Alternative 3 is provided in Table C.3G (Appendix C) using the evaluation
criteria considerations along with the cost rating for each and the justification for the rating.
Detailed cost estimates for this alternative are included in Appendix E. The present value cost for
Alternative 3 is $16,028,000.
7.3.1 Alternative 4: On-Site Capping
7.3.1.1 Summary of Remedial Alternative
Alternative 4 also provides protection by capping of contaminated soils in place to limit exposure
and transport of contaminants. The remedy components of Alternative 4 are detailed in
Section 5.3.6. Approximately 211,000 CY of material would be required to cap the former rail bed
in place, assuming an extent of 39 miles of rail lines in OU8.
7.3.1.2 Overall Protection of Human Health and the Environment
Evaluation of overall protection of human health and the environment for Alternative 4 is provided
in Table C.4A (Appendix C) using the evaluation criteria along with the qualitative rating for each
and the justification for the rating. The overall rating on this criterion for Alternative 4 is
acceptable. +
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7.3.1.3 Compliance with ARARs
Evaluation of compliance with ARARs for Alternative 4 is provided in Table C.4B (Appendix C)
using the evaluation criteria considerations along with the qualitative rating for each and the
justification for the rating. ARARs evaluated for this alternative are included in Appendix A. The
overall rating on this criterion for Alternative 4 is acceptable. +
7.3.1.4 Long-Term Effectiveness and Permanence
Evaluation of long-term effectiveness and permanence for Alternative 4 is provided in Table C.4C
(Appendix C) using the evaluation criteria considerations along with the qualitative rating for each
and the justification for the rating. The overall rating on this criterion for Alternative 4 is moderate
to high. ©
7.3.1.5 Reduction of Toxicity, Mobility, or Volume through Treatment
No treatment of soil is included in this alternative. See Table C.4D (Appendix C) for a detailed
evaluation on this criterion using the evaluation criteria considerations along with the qualitative
rating for each and the justification for the rating. The overall rating on this criterion for Alternative
4 is low. O
7.3.1.6 Short-Term Effectiveness
Evaluation of short-term effectiveness for Alternative 4 is provided in Table C.4E (Appendix C)
using the evaluation criteria considerations along with the qualitative rating for each and the
justification for the rating. The overall rating on this criterion for Alternative 4 is moderate. ©
7.3.1.7 Implementability
Evaluation of implementability for Alternative 4 is provided in Table C.4F (Appendix C) using
the evaluation criteria considerations along with the qualitative rating for each and the justification
for the rating. The overall rating on this criterion for Alternative 4 is moderate to high. ©
7.3.1.8 Cost
Evaluation of cost for Alternative 4 is provided in Table C.4G (Appendix C) using the evaluation
criteria considerations along with the cost rating for each and the justification for the rating.
Detailed cost estimates for this alternative are included in Appendix E. The present value cost for
Alternative 4 is $10,450,000.
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.
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7.4.1 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 preliminary 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.
7.4.2 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 is 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 preliminary cleanup levels and would achieve the goal of reducing
the risk of exposure to ecological receptors.
7.4.3 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.
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).
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.
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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 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 risks 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.
7.4.6 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 have shown that all four
of these alternatives would be readily implementable.
7.4.7 Cost
The total present value of the alternatives are estimated to be:
• Alternative 1 - $103,000
• Alternative 2 - $14,965,000
• Alternative 3 - $16,028,000
• Alternative 4 - $10,450,000
Detailed costs are presented in Appendix E.
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. 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 consolidation areas that would be maintained as part of the OU3 and OU4
RAs.
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7.4.8 State Acceptance
State acceptance of the alternatives will be fully 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 the Proposed Plan and this FS.
7.4.10 Detailed Analysis Summary
A summary of the detailed analysis of alternatives described above is presented in Table 7.2.
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Table 7.2
Summary of Comparative Analysis of Alternatives for the
Cherokee County OU8 Railroads 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
Implementability
Present Value
Cost (Dollars)
1
No Action
—
—
O
o
O
©
$103,000
2
Source Removal, On-Site
Waste Consolidation and
Capping
+
+
©
o
©
©
$14,965,000
3
Source Removal, Waste
Consolidation and
Capping at OU3/OU4
Consolidation Areas
+
+
o
o
©
o
$16,028,000
4
On-Site Capping
+
+
©
o
©
e
$10,450,000
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 E.
Legend for Qualitative Ratings System:
Threshold Criteria
Unacceptable
"I™ Acceptable
o
o
©
Balancing Criteria
(Excluding Cost)
None
Low
Low to Moderate
©
o
©
Moderate
Moderate to High
High
U.S. EPA Region 7
7-11
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HGL—Feasibility Study, Cherokee County 0U8 Railroads Site—Cherokee County, Kansas
8.0 REFERENCES
Chaney, R.L., J.A. Ryan, and P.G. Reeves. 2001. Strategies in soil protection - missions and
visions. Proc. Symposium on Soil Protection in the United States: Congress of the German
and Austrian Soil Science Societies (Sept. 5, 2001, Vienna Austria). Trans. Austrian Soil
Sci. Soc. 74:53-66.
Eisler, R. 2000. Handbook of Chemical Risk Assessment: Health Hazards to Humans, Plants, and
Animals. Volume 1: Metals.
Federal Remediation Technologies Roundtable (FRTR), 2002. Remediation Technologies
Screening Matrix and Reference Guide, Version 4.0.
(http://www.frtr.gov/matrix2/top_page.html).
Fox, M.R.S. 1988. Nutritional Factors that may Influence Bioavailability of Cadmium. J. Environ.
Qual. 17:175-180.
HydroGeoLogic, Inc. (HGL), 2016. Final Remedial Investigation Report, Cherokee County
Operable Unit 8 Railroads Site, Cherokee County, Kansas. March.
Kowalzcyk, D.F., D.E. Gunson, C.R. Shoop, and D.F. Ramberg. 1986. The Effects of Natural
Exposure to High Levels of Zinc and Cadmium in the Immature Pony as a Function of
Age. Environ. Res. 40:285-300.
MacDonald, D., D. Smorong, C. Ingersoll, J. Besser, W. Brumbaugh, N. Kemble, T. May, C. Ivey,
S. Irving, and M. O'Hare, 2010. Development and Evaluation of Sediment and Pore-Water
Toxicity Thresholds to Support Sediment Quality Assessments in the Tri-State Mining
District (TSMD), Missouri, Oklahoma, and Kansas. Draft Final Technical Report. Volume
I: Text.
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, and U.S. Environmental Protection Agency Region VII. December.
Office of Management and Budget (OMB), 1993. Revisions to Office of Management and Budget
[OMB] Circular A-94 on Guidelines and Discount Rates for Benefit-Cost Analysis.
OMB, 2015. Table of Past Years Discount Rates from Appendix C of OMB Circular No. A-94.
(http://www.whitehouse.gov/sites/
default/files/omb/assets/a94/dischist.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.
U.S. EPA Region 7
8-1
-------
HGL—Feasibility Study, Cherokee County 0U8 Railroads Site—Cherokee County, Kansas
EPA, 1989. Risk Assessment Guidance for Superfund, Volume I, Human Health Evaluation
Manual (Part A). EPA/540/1-89/002. December.
EPA, 1991a. Human Health Evaluation Manual, Supplemental Guidance: "Standard Default
Exposure Factors." Office of Solid Waste and Emergency Response (OSWER) Directive
9285.6-03.
EPA, 1991b. Role of the Baseline Risk Assessment in Superfund Remedy Selection Decisions.
OSWER Directive 9355.0-30.
EPA, 1992a. Supplemental Guidance to RAGS: Calculating the Concentration Term. Publication
9285.7-081.
EPA, 1992b. Framework for Ecological Risk Assessment. EPA/63-R-92/001.
EPA, 2000. A Guide to Developing and Documenting Cost Estimates during the Feasibility Study,
OSWER 9355.0-75, July.
EPA, 2002a. Calculating Upper Confidence Limits for Exposure Point Concentrations at
Hazardous Waste Sites. OSWER Directive 9285.6-10. December.
EPA, 2002b. Supplemental Guidance for Developing Soil Screening Levels for Superfund Sites.
OSWER 9355.4-24. December.
EPA, 2004. Risk Assessment Guidance for Superfund, Volume 1: Human Health Evaluation
Manual, Part E, Supplemental Guidance for Dermal Risk Assessment. EPA/540/R/99/005.
July.
EPA, 2006. EPA Superfund Record of Decision Amendment: Cherokee County Superfund Site,
Baxter Springs and Treece Subsites, Operable Units #03 and #04, Cherokee County,
Kansas. September.
EPA, 2009. Risk Assessment Guidance for Superfund, Volume I: Human Health Evaluation
Manual, Part F, Supplemental Guidance for Inhalation Risk Assessment.
EPA/540/R/070/002. January.
EPA, 2015a. Baseline Human Health Risk Assessment for the Cherokee County Railroads Site
Operable Unit 8—Located in Cherokee County, Kansas. May.
EPA, 2015b. Streamlined Ecological Risk Assessment, Cherokee County Railroads Site Operable
Unit Eight. June.
U.S. EPA Region 7
8-2
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Figures
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IK if.—Feasibility Study for Cherokee Comity Site 0V8 Railroads, Cherokee County, Kansas
-------
v,„HV H,
-166—
KANSAS
919 ft
Columbus
Waco
OKLAHOMA
999 .'f! Picher
C ardin
Carl
Junction
Nrw ton"
Eagte Creek
Goll C lub
if®. i 0,500
BriatbfO"
I Counir
Club
f 34,ft
Feet
IK if.—Feasibility Study for Cherokee County Site OU8
Railroads, Cherokee County, Kansas
Figure 2.2
Former Rail Line Classifications and
Sample Locations
Legend
Rol Sample Location
Site Boundary
Rail Classification
Active Line
Former Line
No Longer Present or Remediated
Addressed Under Other OU
Rail Line Designation for Estimation of
Volume of Material Requiring Remediation
\ \Gsi-sn>-&l WGiGlS\CherokeeJ2ounty\_MSIVi'W&
(2-02)RR_Class_Sample_Locs. mxd
7/29/2016 JG
Source: HGL,
ArcGIS Online USA TopoMap
y HGL
37 HydroGeoLogic, Inc
-------
HGL—Feasibility Study for Cherokee County Site 0U8 Railroads, Cherokee County, Kansas
Native Soil
Not to Scale
\ \ Gst-srv-01 \hglgis\Cherokee_County\_MSIW\FS\
(2-03)Site_Co nceptual_Model. cdr
5/3/2016 JG
Source: HGL
v HGL
Figure 2.3
Conceptual Site Model
-------
-------
Appendix A
Summary of Federal and State Applicable or Relevant and
Appropriate Requirements
-------
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-------
Table A.l
Federal Chemical-Specific ARARs
Cilsilions
Description
ARARS
1. Clean W ater Aci
Waier Quality Criteria 40 C.F.R. Pari 131
Water Quality Standards
Establishes non-enforceable standards lo protect aquatic life.
2. Clean Air Act
National Ambient Air Quality
Standards/NESHAPS
42 U.S.C. 74112; 40 C.F.R. 50.6 and
50.12
Emissions standards for particulate matter and lead.
3. Resource Conservation and
Recovery Act
42 U.S.C. Section 6901
40 C.F.R. 264 18(b)
Requires that any hazardous waste facility located within the
100-year floodplain be designed, constructed, operated,
and maintained to avoid washout.
To lie Considered
1. Draft Soil Screening
Guidance
OSWER Directive 9355.4-14FS,
December 1994. EPA/540/R-94/101 and
106
Describes the soil screening process and its application at
CERCLA sites.
2. Revised Interim Soil Lead
Guidance for CERCLA Sites
OSWER Directive No. 9355.4-12, August
1994
Guidance on site-specific preliminary Remediation Goals and
soil lead cleanup at CERCLA sites.
3. Risk Management Derived
Residential Yard Soils
Remedial Action Levels for
Lead and Cadmium
EPA Region 7 Record of Decision for the
Baxter Springs and Treece subsites (OU3
and OU4) of the Cherokee County
Superfund Site, 1997
Preliminary Remediation Goals for OU3 and OU4.
Page A-l
-------
Table A.2
State Chemical-Specific ARARs
Cilsilions
Description
ARARS
1. Kansas Clean W aler Aci
Water Qua lily Standards i W QS j KSA 65-
170, KAR 28-16-28
WQS specific lo stream classification.
2. Kansas Hazardous Waste
Management Act
KSA 65-3430, KAR 28-31-1 to 28-31
Regulations involving the systematic control of the collection,
storage, transportation, processing, treatment, recovery, and
disposal of hazardous waste
To lie Considered
1. Kansas Clean Water Law
Kansas Surface Water Quality Standards
Total Maximum Daily Load Regulations
Page A-2
-------
Table A.3
Federal Location-Specific ARARs
Citations
Description
ARARS
1. Historic project owned or
controlled by a federal
agency
National Historic Preservation Act: 16
U.S. Code (USC) 470, et.seq; 40 Code of
Federal Regulations (CFR) § 6.301; 36
CFR Part 1
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 6.30
Property within areas of the site may contain historical and
archaeological data. The remedial alternative will be designed
to minimize the effect on historical and archeological data.
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. Waters in and around the site
Clean Water Act, (Section 404 Permits)
Dredge or Fill Substantive Requirements,
33 USC Parts 1251-1376; 40 CFR Parts
230, 231
Capping, dike stabilization, construction of berms and levees,
and disposal of contaminated soil, waste material or dredged
material are examples of activities that may involve a
discharge of dredge or fill material. Five conditions must be
satisfied before dredge and fill is an allowable alternative:
1. There must not be a practical alternative.
2. Discharge of dredged or fill material must not cause a
violation of State water quality standards, violate
applicable toxic effluent standards, jeopardize threatened or
endangered species or injure a marine sanctuary.
3. No discharge shall be permitted that will cause or
contribute to significant degradation of the water.
4. Appropriate steps to minimize adverse effects must be
taken.
5. Determine long- and short-term effects on physical,
chemical, and biological components of the aquatic
ecosystem.
Page A-3
-------
Table A.3 (Continued)
Federal Location-Specific ARARs
Citsitions
Description
5. Areas containing fish and
wildlife habitat
Fish and Wildlife Conservation Act of
1980, 16 USC Part 2901 et seq.; 50 CFR
Part 83.9 and 16 U.S.C. 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.
6. Fish and Wildlife
Coordination Act
16 USC Section 661 et seq.; 33 CFR Parts
320-330; 40 CFR 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.
7. 100-year floodplain
Location Standard for Hazardous Waste
Facilities - 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.
8. Historic Site, Buildings, and
Antiquities Act
16 USC Section 470 et seq., 40 CFR
Section301(a), and 36 CFR Part 1
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.
To Ik1 Considered
1. Wetlands located in and
around the site
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 values.
2. Site located within a
floodplain
Protection of Floodplains, Executive Order
11988;40 CFR Part 6.302, Appendix A
Remedial action may take place within a 100-year floodplain.
The remedial action will be designed to avoid adversely
impacting the floodplain in and around a potential future soil
repository or residential actions to ensure that the action
planning and budget reflects consideration of the flood
hazards and floodplain management.
Page A-4
-------
Table A.4
State Location-Specific ARARs
Cilsilions
Description
ARARS
1. Kansas i\ oil-game and
Endangered
KSA 32-957 ilirougli 32-963, 32-1009
through 32-1012, and 32-1033; KAR 23-
17-2 and KAR 115-15-3
Requirement lor actions involving solid waste disposal areas
or other actions impacting state listed species. Prohibits
destruction, adverse modification of critical habitat, or taking
of endangered or threatened species.
To Ik1 Considered
None
Page A-5
-------
Table A.5
Federal Action-Specific ARARs
Citations
Description
ARARS
1. Disposal of Solid Waste in a
Landfill or a Potential Future
Soil Repository and Closure
of a Potential Future Soil
Repository.
Subtitle D of RCRA, 42 U.S.C. 6907 et
seq. and 6941, et seq.
Implements State or Regional Solid Waste Plans and
implements federal and state regulations to control disposal of
solid waste. The yard soils disposed in the landfill or potential
future repository may not exhibit the toxicity characteristic
and therefore, are not hazardous waste. However, these soils
may be solid waste. Contaminated residential soils will be
consolidated from yards throughout the site into a single
location. The disposal of this waste material should be in
accordance with regulated solid waste management practices.
2. Clean Water Act
Water Quality Criteria 40 C.F.R. Part 131
Water Quality Standards
Establishes non-enforceable standards to protect aquatic life.
3. Clean Air Act
National Ambient Air Quality Standards/
NESHAPS 42 U.S.C. 74112; 40 C.F.R.
50.6 and 50.12
Emissions standards for particulate matter and lead.
4. Transportation of excavated
soils.
Hazardous Materials Transportation
Regulations, 49 C.F.R. Parts 107, 171-177
Regulates transportation of hazardous materials.
5. NPDES Storm Water
Discharge
40 C.F.R. Part 122.26; 33 U.S.C 402 (p)
Establishes discharge regulations for storm water.
6. Solid Waste Disposal Act
Hazardous Waste Management Systems
General, 40 C.F.R. Part 260 to 268
Establishes procedures and definitions pertaining to solid and
hazardous waste.
7. Solid Waste Disposal Act
Identification and Listing of Hazardous
Waste, 40 C.F.R. Parts 261
Defines those solid wastes that are subject to regulations as
hazardous wastes under 40 C.F.R. Parts 262-265and Parts
124, 270, and 271.
8. Solid Waste Disposal Act
Standards Applicable to Generators of
Hazardous Waste, 40 C.F.R. Parts 262 to
262.11
Waste determination.
9. Solid Waste Disposal Act
Standards Applicable to Transporters of
Hazardous Wastes, 40 C.F.R. Parts 263
Establishes standards that apply to persons transporting
hazardous waste within the U.S. if the transportation requires
a manifest under 40 C.F.R. Parts 262.
Page A-6
-------
Table A.5 (Continued)
Federal Action-Specific ARARs
Citations
Description
10. Solid Waste Disposal Act
Standards for Owners and Operators of
Hazardous Waste Treatment, Storage and
Disposal Facilities, 40 C.F.R. Parts 264
and 265
Establishes minimum national standards which define the
acceptable management of hazardous waste for owners and
operators of facilities that treat, store, or dispose of hazardous
waste.
11. Solid Waste Disposal Act
Land Disposal, 40 C.F.R. Parts 268
Establishes a ban or restrictions on burial of wastes and other
hazardous materials.
12. Solid Waste Disposal Act
Hazardous Waste Permit Program, 40
C.F.R. Parts 270
Establishes provisions covering RCRA permitting
requirements.
13. Waters in and around the
site.
Clean Water Act, (Section 404 Permits)
Dredge or Fill Substantive Requirements,
33 U.S.C. Parts 1251-1376; 40 C.F.R.
Parts 230, 231.
Capping, dike stabilization, construction of berms and levees,
and disposal of contaminated soil, waste material or dredged
material are examples of activities that may involve a
discharge of dredge or fill material. Four conditions must be
satisfied before dredge and fill is an allowable alternative:
1. There must not be a practical alternative.
2. Discharge of dredged or fill material must not cause a
violation of State water quality standards, violate
applicable toxic effluent standards, jeopardize threatened or
endangered species or injure a marine sanctuary.
3. No discharge shall be permitted that will cause or
contribute to significant degradation of the water.
4. Appropriate steps to minimize adverse effects must be
taken.
5. Determine long- and short-term effects on physical,
chemical, and biological components of the aquatic
ecosystem.
To lie Considered
None
Page A-7
-------
Table A.6
State Action-Specific ARARs
Citations
Description
ARARS
1. Kansas Hazardous Waste
KSA 65-3430, KAR 28-31-1 lo 28-31
Regulations involving die systematic control ol the
Management Act
collection, storage, transportation, processing, treatment,
recovery, and disposal of hazardous waste.
To lie Considered
None
Page A-8
-------
Appendix B
Preliminary Screening of Remedial Alternatives
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-------
Ratings System for Evaluation of Alternatives
1
ITocliveiu'ss iiiul ImplciiK'nliihilih
Cosl (I'resenl Value Dollars)
O
None
o
None
o
Low
$
Low
©
Low to Moderate
$$
Low to Moderate
©
Moderate
$$$
Moderate
o
Moderate to High
$$$$
Moderate to High
©
High
c c c c c
$ $ $ $ $
High
B-l
-------
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-------
Alternative 1
No Action
-------
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-------
Table B.1A
Effectiveness Screening - Alternative 1
Effectiveness Criteria
Evaluation Summary
Overall protection of human health and
the environment
• All soil contamination is left unremediated.
• Unremediated soil contamination allows continued release and
migration of COCs.
• Exposure to metals-contaminated soils would be probable; thus, no
protection is provided to biota in this alternative.
Compliance with ARARs
• The preliminary remediation goals (PRGs) established in the ROD
for Cherokee County (OU3 and OU4) would not be met.
• Action-specific ARARs addressing proper disposal and
transportation of contaminated soils would not be met.
Short-term effectiveness (during the
remedial construction and
implementation period)
• No further remedial action (RA) would be undertaken to address
contamination sources; thus, none of these criteria are met.
Long-term effectiveness and permanence
(following remedial construction)
Reduction of toxicity, mobility, or
volume through treatment
Overall Rating
O
Table B.1B
Implementability Screening - Alternative 1
Implementability Criteria
Evaluation Summary
Ability to construct, reliably operate, and
meet technology-specific regulations for
process options until an RA is complete
• No further RA would be undertaken to address source materials
and contaminated soils; thus, ability to meet this criterion is high.
Ability to operate, maintain, replace, and
monitor technical components after the
RA is complete
Ability to obtain approvals from other
agencies
• Contamination would be left unremediated and no RA would be
undertaken; thus, there is no need to obtain approvals from other
regulatory agencies.
Availability and capacity of treatment,
storage, and disposal services
• No RA would be undertaken to address contaminated areas; thus,
this criterion is not applicable.
Availability of property, specific
materials and equipment, and technical
specialists required for an RA
• Technical equipment and specialists are available for monitoring;
thus, the ability to meet this criterion is high.
Overall Rating
6
Table B.1C
Cost Screening - Alternative 1
Evaluation Factors for Cost
Overall Rating
Present Value Cost
$
B-2
-------
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-------
Alternative 2
Source Removal, On-Site Waste Consolidation and Capping
-------
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-------
Table B.2A
Effectiveness Screening - Alternative 2
KITecliveiu'ss C'rilcri;i
Kviiliiiilion Suniniiirx
(hcrall piokviioii of human health and
ilic cn\ in hi mail
• All mining-related wastes with metals concentrations greater than
the PRGs will be addressed through excavation and on-site disposal
in capped containment areas. This will eliminate the exposure
pathway.
• Excavated contaminated materials will be replaced with clean fill
and topsoil, and a vegetative cover (seeding) will be maintained to
restore the property and prevent erosion.
• Operation and maintenance (O&M) activities will be required to
maintain the integrity of the cap so that it remains protective of
human health and the environment.
• Institutional controls (ICs) would be required to prohibit digging in
containment areas and exposing the contaminated soils.
• Monitoring in the form of Five-Year Reviews would be performed
to ensure the protectiveness of the remedy.
Compliance wiili ARARs
• Removal of mining wastes and contaminated materials and placing
them under a soil cover would physically address contaminant
sources, thus meeting chemical-specific ARARs.
• Location- and action-specific ARARs for the remedy would be
addressed during implementation.
Shon-kini i Jiirinu ilic
remedial ci>n^irncli(>n and iniplc-
niciiiaiioii period)
• Excavation and handling of mining wastes and contaminated soil
could pose short-term risks to workers.
• Safety measures such as use of personal protective equipment
(PPE), dust suppression, and establishment of work zones would
protect workers and the community during implementation.
l.iiii»-k'rm cffcciiwiicss and permanence
(following remedial coiiMi'uciioin
• Long-term effectiveness is not entirely ensured since contaminated
soil consolidated and capped on-site potentially poses a risk.
• Long-term effectiveness of ICs for consolidation areas is not
ensured, particularly on privately owned parcels.
• O&M activities will be required to maintain the integrity of the cap
so that it retains its long term effectiveness and permanence.
• Monitoring and periodic risk evaluation updates would be
performed through Five-Year Reviews to ensure the long-term
effectiveness and permanence of the remedy.
Rcduciion df u>\k'ii\. inobiliix. or
\ okiine ihi'iuiL'h ii'caiineiii
• This alternative does not treat mining wastes or metals-
contaminated soils.
Overall Rating
e
B-3
-------
Table B.2B
Implementability Screening - Alternative 2
Implementability Criteria
Evaluation Summary
Ability to construct, reliably operate, and
meet technology-specific regulations for
process options until an RA is complete
• Removal, consolidation, and capping has been successfully
implemented at mining sites in other OUs in Cherokee County and
is relatively straightforward.
• Excavating and backfilling around streams, drainage ways, and in
flood plains may be challenging at specific locations.
• Contaminated wastes can be transported using off-road trucks or
general highway haul trucks.
• ICs for the many small consolidation areas needed under this
alternative may be difficult to implement and reliably operate,
especially for privately owned parcels, due to types of ownership,
levels of occupancy, and land use
Ability to operate, maintain, replace, and
monitor technical components after the
RA is complete
• Periodic monitoring and risk evaluation updates across the site
would be a continuous process.
• O&M activities, including inspection, maintenance, and repair will
be required to maintain the integrity of the cap. These O&M
activities are usually easy to implement; however, the number of
small consolidation and capped areas may hinder the ease at which
these activities are implemented.
• Enforcement of ICs for the many on-site consolidation areas
required may be difficult, especially for privately owned land due
to types of ownership, levels of occupancy, and land use.
Ability to obtain approvals from other
agencies
• Regulatory approval needed for removals and to construct on-site
disposal facilities may be difficult to obtain given the number of
individual containment areas.
• Identification of off-site borrow sources for backfill and cover
materials would require coordination and approval from the
regulatory agencies.
• Regulatory approvals for monitoring and engineered controls
should be obtainable.
• Regulatory approvals for ICs for on-site consolidation areas may
be difficult to obtain given the large number of small containment
areas required under this alternative.
Availability and capacity of treatment,
storage, and disposal services
• The availability of sufficient area to accommodate an on-site
consolidation area at each removal area is unknown. Consolidating
wastes from several nearby or adjacent rail line removal areas
likely would be required.
Availability of property, specific
materials and equipment, and technical
specialists required for an RA
• Access to privately owned parcels for implementing the RA must
be obtained.
• Labor, equipment, and materials for excavation, backfill, and
cover construction are available.
• Contaminant-free backfill and topsoil materials would be required
from off-site sources. These materials would also need to be able
to support vegetative growth.
• Materials, equipment, and labor resources used for ICs and
monitoring are easily obtainable.
Overall Rating
©
B-4
-------
Table B.2C
Cost Screening - Alternative 2
Kvalualion I'aclors lor Cosl
Overall Rating
Present Value Cost
ssss
B-5
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-------
Alternative 3
Source Removal, Off-Site Waste Consolidation and Capping
-------
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-------
Table B.3A
Effectiveness Screening - Alternative 3
Effectiveness Criteria
Evaluation Summary
Overall protection of human health and
the environment
• All mining-related wastes with metals concentrations greater than
the PRGs will be addressed through excavation and off-site disposal
in capped containment areas. This will eliminate the exposure
pathway. No contaminated materials will remain at the location of
the former rail bed.
• Excavated contaminated materials will be replaced with clean fill
and topsoil, and a vegetative cover (seeding) will be maintained to
restore the property and prevent erosion.
• Operation and maintenance (O&M) activities will be required to
maintain the integrity of the cap so that it remains protective of
human health and the environment.
• ICs would be required to prohibit digging in containment areas and
exposing the contaminated soils.
• Monitoring in the form of Five-Year Reviews would be performed
to ensure the protectiveness of the remedy.
Compliance with ARARs
• Removal of mining wastes and contaminated materials would
physically address contaminant sources, thus meeting chemical-
specific ARARs.
• Location- and action-specific ARARs for the remedy would be
addressed during implementation.
Short-term effectiveness (during the
remedial construction and imple-
mentation period)
• Excavation and handling of mining wastes and contaminated soil
could pose short-term risks to workers.
• Safety measures such as use of personal protective equipment
(PPE), dust suppression, and establishment of work zones would
protect workers and the community during implementation.
Long-term effectiveness and permanence
(following remedial construction)
• Long-term effectiveness and permanence for parcels containing the
former rail beds is addressed through excavation and off-site
disposal, so that no contaminants remain at the former rail beds.
• Long-term effectiveness for off-site consolidation areas is not
entirely ensured since contaminated soil potentially poses a risk if
exposed.
• Long-term effectiveness of ICs for consolidation areas is not
ensured, particularly on privately owned parcels.
• O&M activities will be required to maintain the integrity of the cap
so that it retains its long term effectiveness and permanence.
• Monitoring and periodic risk evaluation updates would be
performed through Five-Year Reviews of the off-site consolidation
areas to ensure the long-term effectiveness and permanence of the
remedy.
Reduction of toxicity, mobility, or
volume through treatment
• This alternative does not treat mining wastes or metals-
contaminated soils.
Overall Rating
o
B-5
-------
Table B.3B
Implementability Screening - Alternative 3
Implementability Criteria
Evaluation Summary
Ability to construct, reliably operate,
and meet technology-specific regulations
for process options until an RA is
complete
• Removal and consolidation at an off-site containment area has been
successfully implemented at mining sites in other OUs in Cherokee
County and is relatively straightforward.
• Excavating and backfilling around streams, drainage ways, and in
flood plains may be challenging at specific locations.
• Contaminated soil can be transported using general highway haul
trucks.
Ability to operate, maintain, replace,
and monitor technical components after
the RA is complete
• Inspection, maintenance, and replacement of vegetative covers
during the first year are relatively easy to implement.
Ability to obtain approvals from other
agencies
• Regulatory approval needed for removals and disposal at off-site
consolidation areas already under construction during ongoing RA
at OUs 3 and 4 should be obtainable; Kansas Department of Health
and the Environment (KDHE) has historically been involved with
the design, construction, and O&M phases at similar mining sites in
nearby OUs in Cherokee County.
• Identification of off-site borrow sources for backfill would require
coordination and approval from the regulatory agencies.
• Regulatory approvals for ICs for off-site consolidation areas should
be obtainable.
Availability and capacity of treatment,
storage, and disposal services
• Sufficient area to accommodate off-site disposal in approved
consolidation areas concurrently under construction for OUs 3 and
4 should be readily available
Availability of property, specific
materials and equipment, and technical
specialists required for an RA
• Access to privately owned parcels for implementing the RA must be
obtained.
• Labor, equipment, and materials for excavation and backfill are
available.
• Contaminant-free backfill and topsoil materials would be required
from off-site sources. These materials would also need to be able
to support vegetative growth.
• Materials, equipment, and labor resources used for ICs and
monitoring are easily obtainable.
Overall Rating
@
Table B.3C
Cost Screening - Alternative 3
Evaluation Factors for Cost
Overall Rating
Present Value Cost
c c c c c
B-6
-------
Alternative 4
On-Site Capping
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Table B.4A
Effectiveness Screening - Alternative 4
KITccliveiu'ss Crileri;i
(hcrall pink-aimi ol hiimaii health and
the cn\ ii'oninciu
Kviilusilioii Suiiiin;ir\
• All mining-related wask-s wiili mcials coikviiiraiions givakT ilian
the PRGs would be capped with an 18-inch soil barrier consisting
of 12 inches of clayey soil topped by 6 inches of topsoil to
eliminate the exposure pathway.
• O&M activities will be required to maintain the integrity of the cap
so that it remains protective of human health and the environment.
• ICs would be required to prohibit disturbance of the containment
areas which would expose the contaminated soils.
• Monitoring in the form of O&M inspections and Five-Year
Reviews would be performed to ensure the protectiveness of the
remedy.
Compliance with ARARs
• Capping of mining wastes and contaminated materials would
physically address contaminant sources, thus meeting chemical-
specific ARARs.
• Location- and action-specific ARARs for the remedy would be
addressed during implementation.
Short-term clTccii\ciicss (during the
remedial construction and imple-
mentation period)
• Construction of the cap could pose short-term risks to workers.
• Safety measures such as use of personal protective equipment
(PPE), dust suppression, and establishment of work zones would
protect workers and the community during implementation.
Long-term cffccii\cncss and permanence
(following remedial construction)
• Long-term effectiveness is not entirely ensured since contaminated
materials capped on-site potentially poses a risk.
• Operation and maintenance (O&M) activities will be periodically
required to repair the cap and maintain its integrity.
• Long-term effectiveness of ICs for consolidation areas is not
ensured, particularly on privately owned parcels.
• Monitoring and periodic risk evaluation updates would be
performed through Five-Year Reviews to ensure the long-term
effectiveness and permanence of the remedy.
Reduction df t(i\icit\. iimhilii\. or
\ uliiinc ihrniiL'h treatment
• This alternative does not treat mining wastes or metals-
contaminated soils.
Overall Rating
€>
B-7
-------
Table B.4B
Implementability Screening - Alternative 4
Impk'iiK'iikibilih Crilerin
Ahilii\ in construct. reliable operate,
and meet technology-spccilie regulations
I'nr process options iimil an RA is
complete
Ahilii\ to operate. inainiain. replace,
and moniior technical components alter
ilk- RA is complete
Ahilii\ lo obtain appro\als from oilier
agencies
A\ailahiliix and capacity of treatment,
storage. and disposal sen ices
A\ailahilii\ of property. specific
maierials and equipment, and technical
specialists required for an RA
Kviilimlion Summ;ii\\
• Capping contaminated materials is relatively straightforward and
has been successfully implemented at mining sites in other OUs in
Cherokee County.
• Construction of the cap around streams, drainage ways, and in
I'loodplains may be challenging at specific locations.
• M aterials for the cap can be transported using off-road or general
highway haul trucks.
• ICs for the capped rail beds may be more difficult to implement and
reliably operate given the liner length of the rail bed, especially for
privately owned parcels, due to types of ownership, levels of
occupancy, and land use.
• Periodic monitoring and risk evaluation updates across the site
would be a continuous process.
• Inspection, maintenance, and replacement of cap material is
relatively easy to implement.
• Implementation of O&M monitoring is easily implemented.
• M aintenance of ICs may be difficult given the linear length of the
capped area, especially for privately owned parcels due to types of
ownership, levels of occupancy, and land use.
• Regulatory approval needed to construct a cap of this magnitude
may be difficult to obtain.
• Identification of off-site borrow sources for cover materials would
require coordination and approval from the regulatory agencies.
• Regulatory approvals for ICs for the capped areas may be difficult
to obtain given the extent of the capped areas and the fact that they
traverse multiple properties. Difficulties may be encountered with
regard to types of restrictions, especially on privately owned
parcels.
• Not applicable.
• Access to privately owned parcels for implementing the RA must be
obtained.
• 1 .abor, equipment, and materials for construction of the cap are
a\ailable.
• ('ontaminant-free backfill and topsoil materials would be required
from off-site sources. These materials would also need to be able
to support vegetative growth.
• Materials, equipment, and labor resources used for ICs and O&M
are readily obtainable.
Overall Rating
€>
Table B.4C
Cost Screening - Alternative 4
Kv.iliiiilion I'iiclors lor Cos!
Ovomll Killing
Present Value Cost
B-8
-------
Appendix C
Detailed Analysis of Remedial Alternatives
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Ratings System for Evaluation of Alternatives
killings Ciilcjiorics lor
Threshold Crilcriii
killings C'iilo^ories lor liiihincing
Criliriii
— Unacceptable
© None
+ Acceptable
O Low
© Low to moderate
© Moderate
© Moderate to high
© High
C-l
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Alternative 1
No Action
-------
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Table C.1A
Evaluation Summary for Overall Protection of Human Health and the Environment -
Alternative 1
Evaluation Factors for Overall Protection
of Human Health and the Environment
Evaluation Summary
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
• The no action alternative does not address
unacceptable risks posed by hazardous contaminants at
properties. Therefore, this criterion is not met.
Overall Protection of Human Health and the
Environment Rating:
—
Table C.1B
Evaluation Summary for Compliance with ARARs - Alternative 1
Evaluation Factors for Compliance with
ARARs
Evaluation Summary
Compliance with Chemical-Specific ARARs
• No action is taken to address soil contamination;
therefore, this criterion is not met.
Compliance with Location-Specific ARARs
• No remedial action (RA) would occur to address soil
contamination; therefore, location-specific ARARs
would not be triggered.
Compliance with Action-Specific ARARs
• No RA would occur to address soil contamination;
therefore, action-specific ARARs would not be
triggered.
Compliance with ARARs Rating:
—
T*
Evaluation Summary for Long-Term
ible C.1C
effectiveness and Permanence - Alternative 1
Evaluation Factors for Long-Term
Effectiveness and Permanence
Evaluation Summary
Magnitude of residual risk remaining from
untreated waste or treatment residuals remaining at
the conclusion of the remedial activities
• No further RA would be undertaken to address soil
contamination; therefore, this criterion is not met.
Adequacy and reliability of controls that are used
to manage treatment residuals and untreated waste
remaining at the site
• No controls are put in place under this alternative.
• Contaminated soil remains uncontained at the Site.
Long-Term Effectiveness and Permanence Rating:
o
C-3
-------
Table C.1D
Evaluation Summary for Reduction of Toxicity, Mobility, or Volume through Treatment-
Alternative 1
Evaluation Factors for Reduction of
Toxicity, Mobility, or Volume through
Treatment
Evaluation Summary
The treatment process, the alternative uses, and
materials they will treat
• The no action alternative does not address contaminated
soil; therefore, these criteria are not met.
The degree of expected reduction in toxicity,
mobility, or volume of contamination due to
treatment
The type and quantity of materials that will
remain following treatment
Whether the alternative would satisfy the
statutory preference for treatment as a principal
element of the RA.
Reduction of Toxicity, Mobility, or Volume
through Treatment:
o
Table C.1E
Short-Term Effectiveness Evaluation Summary - Alternative 1
Evaluation Factors for Short-Term
Effectiveness
Evaluation Summary
Short-term risks that might be posed to the
community during implementation of an
alternative
• The short-term risks to the ecological community are
unchanged by this alternative. No impacts to workers
during implementation would occur and no adverse
enviromnental impacts would occur during
implementation; however, since short term risks are not
addressed and the time frame is open ended, the
criterion is not met.
Potential impacts to workers during
implementation and the reliability of protective
measures taken to minimize these impacts
Potential adverse enviromnental impacts
resulting from implementation of an alternative
and the reliability of the available mitigation
measure during implementation
Short-Term Effectiveness Rating:
o
C-4
-------
Table C.1F
Implementability Evaluation Summary - Alternative 1
Evaluation Factors for Implementability
Evaluation Summary
Technical Feasibility
Technical difficulties and unknowns
associated with the construction and
operation of a technology
• The no action alternative has no
technical component and is therefore
highly implementable.
Reliability of the technology, focusing
on technical problems that will lead to
schedule delays
Administrative Feasibility
Coordination issues with other office
and agencies during construction or
operations of the remedy.
• The no action alternative has no
administrative component and is
therefore highly implementable.
The ability and time required to obtain
necessary approvals and permits from
other agencies for off-site actions or
discharge scenarios
Availability of Goods and
Services
Availability of adequate off-site
treatment, storage capacity, and
disposal capacity and services
• The no action alternative would
include limited periodic soil sampling
in support of Five-Year Reviews; soil
sampling is highly implementable.
Availability of necessary equipment
and specialists required to completed
construction of remedy components
Availability of services and materials
plus the potential for obtaining
competitive bids
Availability of prospective
technologies
Implementability Rating:
©
Table C.1G
Cost Evaluation Summary - Alternative 1
Evaluation Factors for Costs
Approximate Cost (Dollars)
Total Capital Costs
$0
Total Annual O&M Costs
$0
Total Periodic Cost
$133,000
Total Present Value Cost
$103,000
Note: Total costs are for the assumed period of evaluation (Years 1 through 30). Costs are rounded to the nearest $1,000.
C-5
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Alternative 2
Source Removal, On-Site Waste Consolidation, and Capping
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Table C.2A
Evaluation Summary for Overall Protection of Human Health and the Environment -
Alt
ernative 2
Evaluation Factors for Overall Protection
of Human Health and the Environment
Evaluation Summary
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
• All mining-related wastes with metals concentrations
greater than the preliminary cleanup goals will be
addressed through excavation and disposal of soils,
which will eliminate the exposure pathway for biota.
• Excavated contaminated materials will be replaced
with clean fill and topsoil, and a vegetative cover
(seeding) will be maintained to restore the property and
prevent erosion.
• Excavated materials will be placed in on-site
consolidation areas and capped with 12 inches of
clayey soil and 6 inches of topsoil to prevent future
exposures.
• Dust suppression would be practiced during excavation
and consolidation to mitigate soil recontamination and
off-site migration of lead contaminated dust.
• Operation and maintenance (O&M) activities will be
required to maintain the integrity of the cap so that it
remains protective of human health and the
enviromnent.
• Institutional controls (ICs) would be required to
prohibit digging in contaimnent areas and exposing the
contaminated soils.
Overall Protection of Human Health and the
Environment Rating:
+
Table C.2B
Evaluation Summary for Compliance with ARARs - Alternative 2
Evaluation Factors for Compliance with
ARARs
Evaluation Summary
Compliance with Chemical-Specific Applicable or
Relevant and Appropriate Requirement (ARARs)
• Removal of mining wastes and contaminated materials
and placing them under a soil cover would physically
address contaminant sources, thus meeting chemical-
specific ARARs.
• Chemical-specific ARARs for the remedy would be
addressed during implementation.
Compliance with Location-Specific ARARs
• Location-specific ARARs for the remedy would be
addressed during implementation.
Compliance with Action-Specific ARARs
• The majority of action-specific ARARs are
requirements for proper disposal of excavated soils,
which would be addressed during implementation.
Compliance with ARARs Rating:
+
C-7
-------
Table C.2C
Evaluation Summary for Long-Term Effectiveness and Permanence - Alternative 2
Evaluation Factors for Long-Term
Effectiveness and Permanence
Evaluation Summary
Magnitude of residual risk remaining from
untreated waste or treatment residuals
remaining at the conclusion of the remedial
activities
• Long-term effectiveness and permanence for parcels
containing mine waste and metals-contaminated soil is
addressed through excavation of soil, and backfilling of
excavated areas with clean soil.
• This alternative significantly reduces the risk of being
exposed to contaminated materials, but long-term
effectiveness is not entirely ensured because contaminated
waste in on-site consolidation areas potentially poses a
risk.
• O&M activities, including inspection, maintenance, and
repair will be required to maintain the integrity of the cap.
These O&M activities are usually easy to implement;
however, the number of small consolidation and capped
areas may hinder the ease at which these activities are
implemented.
• Long-term effectiveness of ICs for on-site consolidation
areas is not ensured, particularly on privately owned
parcels.
• Monitoring and periodic risk evaluation updates would be
performed to ensure the long-term effectiveness and
permanence of the remedy.
Adequacy and reliability of controls that are
used to manage treatment residuals and
untreated waste remaining at the site
Long-Term Effectiveness and Permanence
Rating:
©
Table C.2D
Evaluation Summary for Reduction of Toxicity, Mobility, or Volume through Treatment-
Alternative 2
Evaluation Factors for Reduction of
Toxicity, Mobility, or Volume through
Treatment
Evaluation Summary
The treatment process, the alternative uses, and
materials they will treat
• This alternative does not treat mining wastes or metals-
contaminated soils. However, the mine waste and metals-
contaminated soils would be placed in on-site
consolidation areas and capped, thereby significantly
reducing the mobility of the contamination. The toxicity
and volume of contamination would remain unchanged.
The degree of expected reduction in toxicity,
mobility, or volume of contamination due to
treatment
The type and quantity of materials that will
remain following treatment
Whether the alternative would satisfy the
statutory preference for treatment as a principal
element of the RA.
Reduction of Toxicity, Mobility, or Volume
through Treatment:
o
C-8
-------
Table C.2E
Short-Term Effectiveness Evaluation Summary - Alternative 2
Evaluation Factors for Short-Term
Effectiveness
Evaluation Summary
Short-term risks that might be posed to the
community during implementation of an
alternative
• This alternative would be performed by licensed
contractors who would collect and dispose of
contaminated materials in properly designed consolidation
areas.
• Contaminant exposure for construction workers during
excavation would be managed using standard health and
safety (H&S) procedures and protocols.
• Work zones to protect the community would be
implemented.
• Dust suppression would mitigate any lead-laden dust in
excavation areas.
Potential impacts to workers during
implementation and the reliability of protective
measures taken to minimize these impacts
• Workers would have Occupational Safety and Health
Administration Hazardous Waste Operations and
Emergency Response (OSHA HAZWOPER) training and
would be required to wear appropriate personal protective
equipment (PPE).
• Work zones to protect workers would be implemented.
Potential adverse enviromnental impacts
resulting from implementation of an alternative
and the reliability of the available mitigation
measure during implementation
• No adverse impacts to the enviromnent are expected from
excavation, transport, or disposal of contaminated soil.
• Proper procedures for handling, transporting, and
disposing of contaminated soil would prevent any release
to the enviromnent.
Short-Term Effectiveness Rating:
©
C-9
-------
Table C.2F
Implementability Evaluation Summary - Alternative 2
Evaluation Factors for Implementability
Evaluation Summary
Technical Feasibility
Technical difficulties and unknowns
associated with the construction and
operation of a technology
• Implementation of this alternative
would include standard excavation
equipment, depending on site
accessibility.
• Backfill, transport and disposal are
common, relatively straightforward,
and very implementable.
• Removal, consolidation, and capping
has been successfully implemented at
mining sites in other OUs in
Cherokee County and is relatively
straightforward.
Reliability of the technology, focusing
on technical problems that will lead to
schedule delays
• The proposed technologies are
reliable and have been readily
implemented at other OUs at the
Cherokee County Site.
Administrative Feasibility
Coordination issues with other office
and agencies during construction or
operations of the remedy.
• This alternative would require
coordination with residents and
property owners to proceed with the
RA.
The ability and time required to obtain
necessary approvals and permits from
other agencies for off-site actions or
discharge scenarios
• Regulatory approval needed for
removals and to construct on-site
waste consolidation areas may be
difficult to obtain given the number
of individual areas.
Availability of Goods and
Services
Availability of adequate off-site
treatment, storage capacity, and
disposal capacity and services
• Not applicable as mine wastes and
contaminated soils would be disposed
of on site.
Availability of necessary equipment
and specialists required to completed
construction of remedy components
• A licensed contractor would be
needed to perform soil excavation,
backfill, and restoration activities.
• Large quantities of clean fill would
be needed for both backfilling
excavations and for constructing the
cap on the consolidation areas. There
may be difficulty in obtaining an
adequate quantity of clean fill.
Availability of services and materials
plus the potential for obtaining
competitive bids
Availability of prospective
technologies
Implementability Rating:
©
Table C.2G
Cost Evaluation Summary - Alternative 2
Evaluation Factors for Costs
Approximate Cost (Dollars)
Total Capital Costs
$14,250,000
Total Annual O&M Costs
$784,000
Total Periodic Cost
$111,000
Total Present Value Cost
$14,965,000
Note: Total costs are for the assumed period of evaluation. Costs are rounded to the nearest $ 1,000.
C-10
-------
Alternative 3
Source Removal, Waste Consolidation, and Capping at OU3/OU4
Consolidation Areas
-------
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-------
Table C.3A
Evaluation Summary for Overall Protection of Human Health and the Environment -
Alt
ernative 3
Evaluation Factors for Overall Protection
of Human Health and the Environment
Evaluation Summary
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
• All mining-related wastes with metals concentrations
greater than the preliminary cleanup goals will be
addressed through excavation and disposal of soils,
which will eliminate the exposure pathway. No
contaminated materials will remain at the location of
the former rail bed.
• Excavated contaminated materials will be replaced
with clean fill and topsoil, and a vegetative cover
(seeding) will be maintained to restore the property and
prevent erosion.
• Dust suppression would be practiced during excavation
to mitigate soil recontamination and off-site migration
of lead-contaminated dust.
Overall Protection of Human Health and the
Environment Rating:
+
Table C.3B
Evaluation Summary for Compliance with ARARs - Alternative 3
Evaluation Factors for Compliance with
ARARs
Evaluation Summary
Compliance with Chemical-Specific ARARs
• Removal of mining wastes and contaminated materials
would physically address contaminant sources, thus
meeting chemical-specific ARARs.
• Chemical-specific ARARs for the remedy would be
addressed during implementation.
Compliance with Location-Specific ARARs
• Location-specific ARARs for the remedy would be
addressed during implementation.
Compliance with Action-Specific ARARs
• The majority of action-specific ARARs are
requirements for proper disposal of excavated soils,
which would be addressed during implementation.
Compliance with ARARs Rating:
+
C-ll
-------
Table C.3C
Evaluation Summary for Long-Term
effectiveness and Permanence - Alternative 3
Evaluation Factors for Long-Term
Effectiveness and Permanence
Evaluation Summary
Magnitude of residual risk remaining from
untreated waste or treatment residuals remaining at
the conclusion of the remedial activities
• Long-term effectiveness and permanence for parcels
containing mine waste and metals-contaminated soil is
addressed through excavation of soil, and backfilling
of excavated areas with clean soil.
• This alternative significantly reduces the risk of
exposure because contaminated waste is disposed of
in capped consolidation areas associated with OUs 3
and 4.
• O&M will be periodically required to inspect and
maintain the consolidation areas.
• Monitoring and periodic risk evaluation updates would
be performed to ensure the long-term effectiveness and
permanence of the remedy.
Adequacy and reliability of controls that are used
to manage treatment residuals and untreated waste
remaining at the site
Long-Term Effectiveness and Permanence Rating:
o
Tf
Evaluation Summary for Reduction of To
Alt
ible C.3D
xicity, Mobility, or Volume through Treatment -
ernative 3
Evaluation Factors for Reduction of
Toxicity, Mobility, or Volume through
Treatment
Evaluation Summary
The treatment process, the alternative uses, and
materials they will treat
• This alternative does not treat mining wastes or metals-
contaminated soils. However, the mine waste and
metals-contaminated soils would be placed in an OU3/
OU4 consolidation area and capped, thereby
significantly reducing the mobility of the
contamination, however, the toxicity of the
contamination would remain unchanged.
Contamination on site would be removed.
The degree of expected reduction in toxicity,
mobility, or volume of contamination due to
treatment
The type and quantity of materials that will remain
following treatment
Whether the alternative would satisfy the statutory
preference for treatment as a principal element of
the RA.
Reduction of Toxicity, Mobility, or Volume through
Treatment:
o
C-12
-------
Table C.3E
Short-Term Effectiveness Evaluation Summary - Alternative 3
Evaluation Factors for Short-Term
Effectiveness
Evaluation Summary
Short-term risks that might be posed to the
community during implementation of an
alternative
• This alternative would be performed by licensed
contractors who would excavate and dispose of
contaminated soils in proper disposal areas.
• Higher short-term risks are involved because of the high
traffic on public roads during transport of contaminated
materials to off-site consolidation areas.
• Work zones to protect the community would be
implemented.
• Dust suppression would mitigate any lead-laden dust in
excavation areas.
Potential impacts to workers during
implementation and the reliability of protective
measures taken to minimize these impacts
• Contaminant exposure for construction workers during
excavation would be managed using standard H&S
procedures and protocols.
• All workers would be OSHA trained and would be
required to wear appropriate PPE.
• Work zones to protect workers would be implemented.
Potential adverse enviromnental impacts
resulting from implementation of an alternative
and the reliability of the available mitigation
measure during implementation
• No adverse impacts to the enviromnent are expected from
excavation, transport, or disposal of contaminated soil.
• Proper procedures for handling, transporting, and
disposing of contaminated soil would prevent any release
to the enviromnent.
Short-Term Effectiveness Rating:
©
C-13
-------
Table C.3F
Implementability Evaluation Summary - Alternative 3
Evaluation Factors for Implementability
Evaluation Summary
Technical Feasibility
Technical difficulties and unknowns
associated with the construction and
operation of a technology
• Implementation of this alternative
would include standard excavation
equipment, depending on site
accessibility.
• Backfill, transport and disposal are
common, relatively straightforward
and very implementable.
Reliability of the technology, focusing
on technical problems that will lead to
schedule delays
• The proposed technologies are
reliable and have been readily
implemented at other OUs at the
Cherokee County Site.
Administrative Feasibility
Coordination issues with other office
and agencies during construction or
operations of the remedy.
• This alternative would require
coordination with residents and
property owners to proceed with the
RA.
• Coordination with RA activities at
OUs 3 and 4 will be required for
disposal at consolidation areas
concurrently under construction.
The ability and time required to obtain
necessary approvals and permits from
other agencies for off-site actions or
discharge scenarios
Availability of Goods and
Services
Availability of adequate off-site
treatment, storage capacity, and
disposal capacity and services
• Coordination with RA activities at
OUs 3 and 4 will be required for
disposal at consolidation areas
concurrently under construction.
Availability of necessary equipment
and specialists required to completed
construction of remedy components
• A licensed contractor would be
needed to perform soil excavation,
backfill, and restoration activities.
• Large quantities of clean fill would
be needed for backfilling
excavations. There may be difficulty
in obtaining adequate capacity of
clean fill.
Availability of services and materials
plus the potential for obtaining
competitive bids
Availability of prospective
technologies
Implementability Rating:
o
Table C.3G
Cost Evaluation Summary - Alternative 3
Evaluation Factors for Costs
Approximate Cost (Dollars)
Total Capital Costs
$15,832,000
Total Annual O&M Costs
$224,000
Total Periodic Cost
$21,000
Total Present Value Cost
$16,028,000
Note: Total costs are for the assumed period of evaluation. Costs are rounded to the nearest $ 1,000.
C-14
-------
Alternative 4
On-Site Capping
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Table C.4A
Evaluation Summary for Overall Protection of Human Health and the Environment -
Alt
ernative 4
Evaluation Factors for Overall Protection
of Human Health and the Environment
Evaluation Summary
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
• All mining-related wastes with metals concentrations
greater than the preliminary cleanup goals would be
capped with an 18-inch soil barrier consisting of 12
inches of clayey soil topped with 6 inches of topsoil to
eliminate the exposure pathway.
• O&M will be required to maintain the integrity of the
cap so that it remains protective of human health and
the enviromnent.
• Institutional controls (ICs) would be required to
prohibit disturbance of the contaimnent areas which
would expose the contaminated soils.
• Monitoring in the form of Five Year Reviews would be
performed to ensure the protectiveness of the remedy.
Overall Protection of Human Health and the
Environment Rating:
+
Table C.4B
Evaluation Summary for Compliance with ARARs - Alternative 4
Evaluation Factors for Compliance with
ARARs
Evaluation Summary
Compliance with Chemical-Specific ARARs
• Capping of mining wastes and contaminated materials
and placing them under a soil cover would physically
address contaminant sources, thus meeting chemical-
specific ARARs
• Chemical-specific ARARs for the remedy would be
addressed during implementation.
Compliance with Location-Specific ARARs
• Location-specific ARARs for the remedy would be
addressed during implementation.
Compliance with Action-Specific ARARs
• The majority of action-specific ARARs are
requirements for proper disposal of excavated soils,
which would be addressed during implementation.
Compliance with ARARs Rating:
+
C-15
-------
Table C.4C
Evaluation Summary for Long-Term
effectiveness and Permanence - Alternative 4
Evaluation Factors for Long-Term
Effectiveness and Permanence
Evaluation Summary
Magnitude of residual risk remaining from
untreated waste or treatment residuals remaining at
the conclusion of the remedial activities
• Long-term effectiveness and permanence for parcels
containing mine waste and metals-contaminated soil is
addressed through capping of the contaminated
materials in place.
• This alternative significantly reduces the risk of
exposure, but long-term effectiveness is not entirely
ensured because contaminated waste in on-site
consolidation areas potentially poses a risk.
• Operation and maintenance (O&M) activities will be
periodically required to repair the on-site consolidation
areas.
• Long-term effectiveness of ICs for on-site
consolidation areas is not ensured, particularly on
privately owned parcels.
• Monitoring and periodic risk evaluation updates would
be performed to ensure the long-term effectiveness and
permanence of the remedy.
Adequacy and reliability of controls that are used
to manage treatment residuals and untreated waste
remaining at the site
Long-Term Effectiveness and Permanence Rating:
©
Tf
Evaluation Summary for Reduction of To
Alt
ible C.4D
xicity, Mobility, or Volume through Treatment -
ernative 4
Evaluation Factors for Reduction of
Toxicity, Mobility, or Volume through
Treatment
Evaluation Summary
The treatment process, the alternative uses, and
materials they will treat
• This alternative does not treat mining wastes or metals-
contaminated soils. However, the mine waste and
metals-contaminated soils would be capped in place,
thereby significantly reducing the mobility of the
contamination. The toxicity and volume of
contamination would remain unchanged.
The degree of expected reduction in toxicity,
mobility, or volume of contamination due to
treatment
The type and quantity of materials that will remain
following treatment
Whether the alternative would satisfy the statutory
preference for treatment as a principal element of
the RA.
Reduction of Toxicity, Mobility, or Volume through
Treatment:
o
C-16
-------
Table C.4E
Short-Term Effectiveness Evaluation Summary - Alternative 4
Evaluation Factors for Short-Term
Effectiveness
Evaluation Summary
Short-term risks that might be posed to the
community during implementation of an
alternative
• This alternative would be performed by licensed
contractors who would construct the cover.
• Work zones to protect the community would be
implemented.
• Dust suppression would be used to prevent migration of
contaminated dust in excavation areas.
Potential impacts to workers during
implementation and the reliability of protective
measures taken to minimize these impacts
• Contaminant exposure for construction workers during
construction would be managed using standard H&S
procedures and protocols.
• All workers would be OSHA trained and would be
required to wear appropriate PPE.
• Work zones to protect workers would be implemented.
Potential adverse enviromnental impacts
resulting from implementation of an alternative
and the reliability of the available mitigation
measure during implementation
• No adverse impacts to the enviromnent are expected from
excavation, transport, or disposal of contaminated soil.
• Proper procedures for handling, transporting, and
disposing of contaminated soil would prevent any release
to the enviromnent.
Short-Term Effectiveness Rating:
©
C-17
-------
Table C.4F
Implementability Evaluation Summary - Alternative 4
Evaluation Factors for Implementability
Evaluation Summary
Technical Feasibility
Technical difficulties and unknowns
associated with the construction and
operation of a technology
• Implementation of this alternative
would include standard earthmoving
equipment, depending on site
accessibility.
• Capping in place is very
implementable.
• The proposed technologies have been
readily implemented at other OUs at
the Cherokee County Site.
Reliability of the technology, focusing
on technical problems that will lead to
schedule delays
• The proposed technologies are
reliable and have been readily
implemented at other OUs at the
Cherokee County Site.
Administrative Feasibility
Coordination issues with other office
and agencies during construction or
operations of the remedy.
• This alternative would require
coordination with residents and
property owners to proceed with the
RA.
The ability and time required to obtain
necessary approvals and permits from
other agencies for off-site actions or
discharge scenarios
• Regulatory approval needed for
construction of the cap may be
difficult to obtain given the number
of individual capped areas.
Availability of Goods and
Services
Availability of adequate off-site
treatment, storage capacity, and
disposal capacity and services
• Not applicable as mine wastes and
contaminated soils would be capped
in place.
Availability of necessary equipment
and specialists required to completed
construction of remedy components
• A licensed contractor would be
needed to perform cap construction
and restoration activities.
• Large quantities of clean fill would
be needed to construct the cover.
There may be difficulty in obtaining
adequate volume of clean fill.
Availability of services and materials
plus the potential for obtaining
competitive bids
Availability of prospective
technologies
Implementability Rating:
©
Table C.4G
Cost Evaluation Summary - Alternative 4
Evaluation Factors for Costs
Approximate Cost (Dollars)
Total Capital Costs
$9,071,000
Total Annual O&M Costs
$1,593,000
Total Periodic Cost
$133,000
Total Present Value Cost
$10,550,000
Note: Total costs are for the assumed period of evaluation. Costs are rounded to the nearest $ 1,000.
C-18
-------
Appendix D
Volume Estimations
-------
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-------
Methodology and Assumptions Used for Calculating Estimated Volumes
Estimated volumes were calculated using the information contained in the Remedial
Investigation Report (HGL, 2016). This information is shown in the following volume
calculation worksheets.
Overall Assumptions for Estimating the Volume of Materials Requiring Remediation
1. All chat comprising the former rail bed would be removed.
2. Backfilling will be required to bring the excavation back to natural grade and provide
positive drainage. This includes, at a minimum, six inches of topsoil.
3. Depth of contamination was determined by the following cleanup levels:
Zinc = 4,000 mg/kg Lead = 1,770 mg/kg
At Based on a minimal aerial survey, the portions of the former rail beds that have been
or will be remediated under other OUs was assumed to be minimal.
4. If a height of 0 was given for the rail bed at the test pit location,
the total depth of the contamination found in the test was used to calculate the volume.
5. If no width or height dimensions were given for the rail bed at the test pit location,
the depth of contamination found in the test pit and the average width of the former
rail bed for that segment were used to calculate volume.
6. If there are no test pits along a rail bed segment, the overall average width and
average depth of contamination were used to calculate volume.
7. The overall length of abandoned rail line in Cherokee County is 58.44 miles. Based on an
aerial survey conducted by EPA, the portions of the former rail lines addressed by other OUs
is estimated to be 11.42 miles or 19.54% of the total length. The portions of the former rail line
that are no longer present or have been addressed by other means is 7.87 miles or 13.47%of
the total length.
8. The volume calucations are based on the total length of each line segment, and
so therefore the total length of 58.44 miles. Volumes calculated will be reduced by 33%
to account for the rail lines not included in OU8.
Assumptions for Estimating the Volume of Materials Required for Cap Construction
1. For Alternative 2, it was assumed that there would be approximately 58 small
consolidation areas on the former rail bed with a footprint of 60 feet x 950 feet.
2- For Alternative 4, the average overall width of the former rail bed (17.9 feet) and
a length of 39.15 miles was used to approximate the volume of material needed.
3. Cap will be 12 inches of select fill covered with 6 inches of top soil.
Page D-1
-------
Page D-2
-------
Estimated Volume of Materials Requiring Remediation
Cherokee County Site OU8 Railroads, Cherokee County, Kansas
Alternatives 2 & 3
Segment #
Length
(ft)
Average
Width
(ft)
Adjusted
Average
Thickness
(ft)
Excavation
Top Soil Backfill
Select Fill
(Non-top Soil Backfill)
Volume
(ft3)
Volume
(cy)
Volume
(ft3)
Volume
(cy)
Volume
(ft3)
Volume
(cy)
A
87,658
20.0
2.6
4,558,216
168,823
876,580
32,466
1,192,149
44,154
B
29,601
19.2
3.2
1,818,685
67,359
284,170
10,525
44,402
1,645
C
37,723
17.9
1.9
1,282,959
47,517
337,621
12,504
929,872
34,440
D
45,248
17.9
1.6
1,295,903
47,996
404,970
14,999
911,747
33,768
E
10,082
17.9
2.4
433,123
16,042
90,234
3,342
343,292
12,715
F
12,364
17.9
2.2
486,894
18,033
110,658
4,098
376,484
13,944
G
23,327
17.8
2.2
913,485
33,833
207,610
7,689
345,240
12,787
H
7,934
21.5
2.0
341,162
12,636
85,291
3,159
131,308
4,863
1
18,960
13.8
2.6
680,285
25,196
130,824
4,845
79,632
2,949
J
25,503
10.8
2.6
716,124
26,523
137,716
5,101
349,391
12,940
K
10,174
15.0
3.5
534,135
19,783
76,305
2,826
38,661
1,432
Total for Cherokee
County Superfund
Site abandoned rail
lines
308,574
483,740
101,555
175,636
OU8 Total*
206,745
324,106
68,042
117,676
Notes:
* OU8 total is the total for the reduced by 33% to account for the portions of the former rail beds not included in OU8.
Page D-3
-------
Volume Calculation Worksheet - Alternatives 2 and 3
Cherokee County Site OU8 Railroads, Cherokee County Railroads
Cross-Sectional
Cross-Sectional
Railroad
Adjusted
Thickness of
Area for
Area for
Segment
Width
Height
Contamination
Excavation
Backfill
ID
Test Pit #
(ft)
Height (ft)
(ft)
(inches)
(ft2)
(ft2)
A
13a
9
3
3
6
27
4.5
A
13a
12
0
4
48
48
48
A
13b
50
0
2
24
100
100
A
13c
30
0
3
36
90
90
A
13d
18
0
1
12
18
18
A
13e
1
12
20
20
A
14a
25
0
0.5
6
12.5
12.5
A
15a
9
2
2
0
18
4.5
A
15b
9
2
2
6
18
4.5
A
16a
0
0
0.0
0
A
16b
0
0
0.0
0
A
23a
1
12
20.0
20
A
23b
2
24
40.0
40
A
32a
24
5
5
24
120
12
A
32b
18
12
12
24
216
9
A
33a
18
3
3
24
54
9
A
33b
18
3
3
12
54
9
Average
20
2.5
2.6
15.9
50.3
23.6
Cross-Sectional
Cross-Sectional
Railroad
Adjusted
Thickness of
Area for
Area for
Segment
Width
Height
Contamination
Excavation
Backfill
ID
Test Pit #
(ft)
Height (ft)
(ft)
(inches)
(ft2)
(ft2)
B
24a
12
0
0.5
6
6
6
B
24b
12
0
2.5
30
30
30
B
25a
18
2
2.5
30
45
9
B
25b
20
4
4
42
80
10
B
26a
22
4
4
36
88
11
B
26b
22
4
4
24
88
11
B
27a
23
4
4
12
92
11.5
B
27b
23
4
4
36
92
11.5
B
28a
21
3
3
24
63
10.5
B
28b
24
3
3
24
72
12
B
29a
16
3
3
30
48
8
B
29b
18
3
4
48
72
9
B
30a
19
3
3
24
57
9.5
B
30b
23
3
3
24
69
11.5
B
31a
16
3
3.5
42
56
8
B
31b
18
3
3
36
54
9
Average
19.2
2.9
3.2
29.25
63.3
11.1
Page D-4
-------
Volume Calculation Worksheet - Alternatives 2 and 3
Cherokee County Site OU8 Railroads, Cherokee County Railroads
Railroad
Segment
ID
Test Pit #
Width
(ft)
Height (ft)
Adjusted
Height
(ft)
Depth of
Contamination
(inches)
Cross-Sectional
Area for
Excavation
(ft2)
Cross-Sectional
Area for
Backfill
(ft2)
C
21a
2
24
35.8
35.8
C
21b
2
24
35.8
35.8
c
21c
2
24
35.8
35.8
c
22a
1.5
18
26.85
26.85
Average
17.9
2.2
1.9
22.5
33.6
33.6
Railroad
Segment
ID
Test Pit #
Width
(ft)
Height (ft)
Adjusted
Height
(ft)
Depth of
Contamination
(inches)
Cross-Sectional
Area for
Excavation
(ft2)
Cross-Sectional
Area for
Backfill
(ft2)
D
17a
1.5
18
26.9
26.9
D
17b
2
24
35.8
35.8
D
17c
2
24
35.8
35.8
D
18a
1
12
17.9
17.9
Average
17.9
2.2
1.6
19.5
29.1
29.1
Cross-Sectional
Cross-Sectional
Railroad
Adjusted
Depth of
Area for
Area for
Segment
Width
Height
Contamination
Excavation
Backfill
ID
Test Pit #
(ft)
Height (ft)
(ft)
(inches)
(ft2)
(ft2)
F
19a
2.2
0
39.38
39.38
F
20a
2.2
0
39.38
39.38
F
20b
2.2
0
39.38
39.38
Average
17.9
2.2
2.2
0.0
39.4
39.4
Cross-Sectional
Cross-Sectional
Railroad
Adjusted
Depth of
Area for
Area for
Segment
Width
Height
Contamination
Excavation
Backfill
ID
Test Pit #
(ft)
Height (ft)
(ft)
(inches)
(ft2)
(ft2)
G
12a
36
0
1.5
18
54
54
G
12b
14
0
2
24
28
28
G
9a
10
0
1.5
18
15
15
G
9b
14
2
3
36
42
14
G
9c
15
3
3
36
45
7.5
Average
17.8
1.0
2.2
26.4
36.8
23.7
Cross-Sectional
Cross-Sectional
Railroad
Adjusted
Depth of
Area for
Area for
Segment
Width
Height
Contamination
Excavation
Backfill
ID
Test Pit #
(ft)
Height (ft)
(ft)
(inches)
(ft2)
(ft2)
H
10a
14
2
2
12
28
7
Page D-5
-------
Volume Calculation Worksheet - Alternatives 2 and 3
Cherokee County Site OU8 Railroads, Cherokee County Railroads
H
10b
14
2
2
12
28
7
H
10c
14
2
2
12
28
7
H
11a
44
0
2
24
88
88
Average
21.5
1.5
2.0
15.0
43.0
27.3
Cross-Sectional
Cross-Sectional
Railroad
Adjusted
Depth of
Area for
Area for
Segment
Width
Height
Contamination
Excavation
Backfill
ID
Test Pit #
(ft)
Height (ft)
(ft)
(inches)
(ft2)
(ft2)
I
la
12
2
2
24
24
6
I
lb
13
2
2.5
30
32.5
6.5
I
lc
16
2
2.5
30
40
8
I
8a
14
2
4
48
56
28
1
8b
14
2
2
24
28
7
Average
13.8
2.0
2.6
31.2
36.1
11.1
Cross-Sectional
Cross-Sectional
Railroad
Adjusted
Depth of
Area for
Area for
Segment
Width
Height
Contamination
Excavation
Backfill
ID
Test Pit #
(ft)
Height (ft)
(ft)
(inches)
(ft2)
(ft2)
J
2a
2
24
21.6
21.6
J
3a
10
0
1.5
18
16.2
16.2
J
3b
10
0
1
12
10.8
10.8
J
4a
12
0
3
36
32.4
32.4
J
5a
8
0
2.5
30
27
27
J
5b
14
7
7
36
75.6
7
J
6a
1.5
18
16.2
16.2
J
6b
2
24
21.6
21.6
Average
10.8
1.4
2.6
24.8
27.7
19.1
Cross-Sectional
Cross-Sectional
Railroad
Adjusted
Depth of
Area for
Area for
Segment
Width
Height
Contamination
Excavation
Backfill
ID
Test Pit #
(ft)
Height (ft)
(ft)
(inches)
(ft2)
(ft2)
K
7a
15
3
3
36
45
7.5
K
7b
15
3
4
48
60
15
Average
15.0
3.0
3.5
42.0
52.5
11.3
Page D-6
-------
Volume Calculation Worksheet - Alternatives 2 and 3
Cherokee County Site OU8 Railroads, Cherokee County Railroads
Cross-
Cross-
Railroad
Adjusted
Depth of
Sectional Area
Sectional Area
Segment
Width
Height
Height
Contamination
for Excavation
for Backfill
ID
Test Pit #
(ft)
(ft)
(ft)
(inches)
(ft2)
(ft2)
H
10a
14
2
3
12
42
14
H
10b
14
2
3
12
42
14
H
10c
14
2
3
12
42
14
H
11a
44
0
2
24
88
88
Average
21.5
1.5
2.8
15.0
53.5
32.5
Cross-
Cross-
Railroad
Adjusted
Depth of
Sectional Area
Sectional Area
Segment
Width
Height
Height
Contamination
for Excavation
for Backfill
ID
Test Pit #
(ft)
(ft)
(ft)
(inches)
(ft2)
(ft2)
I
la
12
2
3
30
36
12
I
lb
13
2
3
30
39
13
I
lc
16
2
3
30
48
16
I
8a
14
2
3
48
42
14
I
8b
14
2
3
36
42
14
Average
13.8
2.0
3.0
34.8
41.4
13.8
Cross-
Cross-
Railroad
Adjusted
Depth of
Sectional Area
Sectional Area
Segment
Width
Height
Height
Contamination
for Excavation
for Backfill
ID
Test Pit #
(ft)
(ft)
(ft)
(inches)
(ft2)
(ft2)
J
2a
2
24
21.6
21.6
J
3a
10
0
2
24
21.6
21.6
J
3b
10
0
2
24
21.6
21.6
J
4a
12
0
3
36
32.4
32.4
J
5a
8
0
3.5
42
37.8
37.8
J
5b
14
7
8
36
86.4
14
J
6a
3.5
42
37.8
37.8
J
6b
2
24
21.6
21.6
Average
10.8
1.4
3.3
31.5
35.1
26.1
Cross-
Cross-
Railroad
Adjusted
Depth of
Sectional Area
Sectional Area
Segment
Width
Height
Height
Contamination
for Excavation
for Backfill
ID
Test Pit #
(ft)
(ft)
(ft)
(inches)
(ft2)
(ft2)
K
7a
15
3
4
42
60
15
K
7b
15
3
4
48
60
15
Average
15.0
3.0
4.0
45.0
60.0
15.0
Page D-5
-------
-------
Appendix E
Remedial Alternative Cost Calculations and Data
-------
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-------
Cost Summary Tables
Table E.l Cost Summary, All Alternatives
Table E.2 Alternative 1 - Present Value Analysis
Table E.3 Alternative 2 - Present Value Analysis
Table E.4 Alternative 3 - Present Value Analysis
Table E.5 Alternative 4 - Present Value Analysis
-------
This page was intentionally left blank.
-------
Table E.l
Cost Summary, All Alternatives
Cherokee County Superfund Site OU8
Cherokee County, Kansas
Alternative
Description
Duration,
years
Total Present
Value of Capital
Costs
Total Present
Value of O&M
Costs
Total Present
Value of
Periodic Costs
Total Present
Value of
Alternative
1
No Action
n/a
$0
$0
$103,324
$103,324
2
Source Removal with On-Site
Consolidation and Capping
30
$ 14,250,426
$ 627,533
$ 86,627
$ 14,964,586
3
Source Removal with
Consolidation and Capping at
OU3/OU4 Consolidation Areas
30
$ 15,832,363
$ 179,010
$ 16,697
$ 16,028,070
4
On-Site Capping
30
$ 9,071,027
$ 1,275,238
$ 103,324
$ 10,449,588
E-1
-------
Table E.2
Alternative 1 - Present Value Analysis
Cherokee County Superfund Site OU8
Cherokee County, Kansas
AlliTiialn c 1 - No Action
Year
Annual
O&M Costs
Present
Value of
O&M Costs
Periodic
Costs
Present
Value of
Periodic
Costs
Capital Costs
Present Value
of Capital Costs
Cumulative
Present Value
0
$0
$0
$0
$0
$0
$0
$0
1
$0
$0
$0
$0
$0
$0
$0
2
$0
$0
$0
$0
$0
$0
$0
3
$0
$0
$0
$0
$0
$0
$0
4
$0
$0
$0
$0
$0
$0
$0
5
$0
$0
$22,167
$20,576
$0
$0
$20,576
6
$0
$0
$0
$0
$0
$0
$0
7
Q
$0
$0
$0
$0
$0
$0
$0
O
9
4>U
$0
4>U
$0
4>U
$0
4>U
$0
4>U
$0
4>U
$0
4>U
$0
10
$0
$0
$22,167
$19,100
$0
$0
$19,100
11
$0
$0
$0
$0
$0
$0
$0
12
$0
$0
$0
$0
$0
$0
$0
13
$0
$0
$0
$0
$0
$0
$0
14
$0
$0
$0
$0
$0
$0
$0
15
$0
$0
$22,167
$17,730
$0
$0
$17,730
16
$0
$0
$0
$0
$0
$0
$0
17
$0
$0
$0
$0
$0
$0
$0
18
$0
$0
$0
$0
$0
$0
$0
19
$0
$0
$0
$0
$0
$0
$0
20
$0
$0
$22,167
$16,458
$0
$0
$16,458
21
$0
$0
$0
$0
$0
$0
$0
22
$0
$0
$0
$0
$0
$0
$0
23
$0
$0
$0
$0
$0
$0
$0
24
$0
$0
$0
$0
$0
$0
$0
25
$0
$0
$22,167
$15,277
$0
$0
$15,277
26
$0
$0
$0
$0
$0
$0
$0
27
$0
$0
$0
$0
$0
$0
$0
28
$0
$0
$0
$0
$0
$0
$0
29
$0
$0
$0
$0
$0
$0
$0
30
$0
$0
$22,167
$14,181
$0
$0
$14,181
TOTAL
$0
$103,324
$0
$0
$103,324
E-2
-------
Table E.3
Alternative 2 - Present Value Analysis
Cherokee County Superfund Site OU8
Cherokee County, Kansas
Allcrnalne 2 - Source Rcnim
-------
Table E.4
Alternative 3 - Present Value Analysis
Cherokee County Superfund Site OU8
Cherokee County, Kansas
Allcrnalne 3 -
Source Kemotal with Consolidation and Capping al Ol 3/Ol 4 Consolidation
Areas
Present
Value of
O&M Costs
Present
Year
Annual
Periodic
Value of
Capital Costs
Present Value
Cumulative
O&M Costs
Costs
Periodic
Costs
of Capital Costs
Present Value
0
$0
$0
$0
$0
$15,832,363
$15,832,363
$15,832,363
1
$7,454
$7,344
$0
$0
$0
$0
$7,344
2
$7,454
$7,235
$0
$0
$0
$0
$7,235
3
$7,454
$7,128
$0
$0
$0
$0
$7,128
4
$7,454
$7,023
$0
$0
$0
$0
$7,023
5
$7,454
$6,919
$3,582
$3,325
$0
$0
$10,244
6
$7,454
$6,817
$0
$0
$0
$0
$6,817
7
8
$7,454
$7,454
$6,716
$6,617
$0
$0
$0
$0
$0
$0
$0
$0
$6,716
$6,617
9
$7,454
$6,519
$0
$0
$0
$0
$6,519
10
$7,454
$6,423
$3,582
$3,087
$0
$0
$9,509
11
$7,454
$6,328
$0
$0
$0
$0
$6,328
12
$7,454
$6,234
$0
$0
$0
$0
$6,234
13
$7,454
$6,142
$0
$0
$0
$0
$6,142
14
$7,454
$6,051
$0
$0
$0
$0
$6,051
15
$7,454
$5,962
$3,582
$2,865
$0
$0
$8,827
16
$7,454
$5,874
$0
$0
$0
$0
$5,874
17
$7,454
$5,787
$0
$0
$0
$0
$5,787
18
$7,454
$5,702
$0
$0
$0
$0
$5,702
19
$7,454
$5,617
$0
$0
$0
$0
$5,617
20
$7,454
$5,534
$3,582
$2,660
$0
$0
$8,194
21
$7,454
$5,452
$0
$0
$0
$0
$5,452
22
$7,454
$5,372
$0
$0
$0
$0
$5,372
23
$7,454
$5,293
$0
$0
$0
$0
$5,293
24
$7,454
$5,214
$0
$0
$0
$0
$5,214
25
$7,454
$5,137
$3,582
$2,469
$0
$0
$7,606
26
$7,454
$5,061
$0
$0
$0
$0
$5,061
27
$7,454
$4,987
$0
$0
$0
$0
$4,987
28
$7,454
$4,913
$0
$0
$0
$0
$4,913
29
$7,454
$4,840
$0
$0
$0
$0
$4,840
30
$7,454
$4,769
$3,582
$2,292
$0
$0
$7,060
TOTAL
$179,010
$16,697
$15,832,363
$15,832,363
$16,028,070
E-4
-------
Table E.5
Alternative 4 - Present Value Analysis
Cherokee County Superfund Site OU8
Cherokee County, Kansas
Allcriiiilne 4 - On-Sile C
Present
Value of
O&M Costs
Present
Year
Annual
O&M Costs
Periodic
Costs
Value of
Periodic
Costs
Capital Costs
Present Value
of Capital Costs
Cumulative
Present Value
0
$0
$0
$0
$0
$9,071,027
$9,071,027
$9,071,027
1
$53,100
$52,315
$0
$0
$0
$0
$52,315
2
$53,100
$51,542
$0
$0
$0
$0
$51,542
3
$53,100
$50,780
$0
$0
$0
$0
$50,780
4
$53,100
$50,030
$0
$0
$0
$0
$50,030
5
$53,100
$49,291
$22,167
$20,576
$0
$0
$69,867
6
$53,100
$48,562
$0
$0
$0
$0
$48,562
7
8
$53,100
$53,100
$47,844
$47,137
$0
$0
$0
$0
$0
$0
$0
$0
$47,844
$47,137
9
$53,100
$46,441
$0
$0
$0
$0
$46,441
10
$53,100
$45,754
$22,167
$19,100
$0
$0
$64,855
11
$53,100
$45,078
$0
$0
$0
$0
$45,078
12
$53,100
$44,412
$0
$0
$0
$0
$44,412
13
$53,100
$43,756
$0
$0
$0
$0
$43,756
14
$53,100
$43,109
$0
$0
$0
$0
$43,109
15
$53,100
$42,472
$22,167
$17,730
$0
$0
$60,202
16
$53,100
$41,844
$0
$0
$0
$0
$41,844
17
$53,100
$41,226
$0
$0
$0
$0
$41,226
18
$53,100
$40,617
$0
$0
$0
$0
$40,617
19
$53,100
$40,016
$0
$0
$0
$0
$40,016
20
$53,100
$39,425
$22,167
$16,458
$0
$0
$55,883
21
$53,100
$38,842
$0
$0
$0
$0
$38,842
22
$53,100
$38,268
$0
$0
$0
$0
$38,268
23
$53,100
$37,703
$0
$0
$0
$0
$37,703
24
$53,100
$37,146
$0
$0
$0
$0
$37,146
25
$53,100
$36,597
$22,167
$15,277
$0
$0
$51,874
26
$53,100
$36,056
$0
$0
$0
$0
$36,056
27
$53,100
$35,523
$0
$0
$0
$0
$35,523
28
$53,100
$34,998
$0
$0
$0
$0
$34,998
29
$53,100
$34,481
$0
$0
$0
$0
$34,481
30
$53,100
$33,971
$22,167
$14,181
$0
$0
$48,153
TOTAL
$1,275,238
$103,324
$9,071,027
$9,071,027
$10,449,588
E-5
-------
Site: Cherokee County Superfund Site OU8
Location: Cherokee County, Kansas
Phase: Feasibility Study
Base Year: 2016
Date: 5/6/2016
Description: Capital Costs for Alternative 2
Unit costs are based on the most recent costing efforts for RA at Cherokee County OUs 3 and 4 unless noted below.
Estimated
Unit of
Unit
Project
Item
Description
Quantity
Measure
Cost
Cost
Notes
01 - Initial Activities
$205,855
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
S5.00
S61.715
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
Resused and moved with construction area
08
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 qrubbinq
Demolition
10
Barbed Wire Fence Demolition
3,200
LF
$1.48
$4,736
Assumed at least two per access area @ 25' width, no fences running along former rail bed
03 - Earthwork
$2,075,262
Mine Waste and Contaminated Soil
Assume "on site" means waste is consolidated within 1 mile of its excavation point; and 18% of material
11
Excavation, Haulinq, and Placement - On Site Consolidation
265,800
BCY
$7.39
$1,964,262
remains in place within consolidation areas
12
Excavation, Haulinq, and Placement - Consolidation Area <10 miles
BCY
$8.41
$0
13
Excavation, Haulinq, and Placement -Consolidation Area 10 to 30 miles
BCY
$15.23
$0
14
XRF Confirmation Samplinq
18,500
EA
$6.00
$111,000
Assume on a 50' spacing along centerlineand on each side of rail bed
04 - Restoration
$6,509,949
Import and Place Soil from Off-Site Borrow Sources
General Restoration
15
Select Fill
96,500
ECY
$21.65
$2,089,225
Estimated volume needed to bring the excavations back flush with the ground surface. Assume 18%
16
Top Soil
55,800
ECY
$30.28
$1,689,624
reduction in material quantities for consolidation areas constructed in-place over the former rail bed.
Mine Waste Consolidation Area
17
Select Fill
54,200
ECY
$20.30
$1,100,260
Assume 58 small consolidation areas over rail bed footprint at 60' X 420' w/ max height of 10'. Cap of 12
18
Top Soil
28,000
ECY
$29.75
$833,000
inches select fill and 6 inches of top soil.
19
Finish Gradinq
147
AC
$1,123
$165,259
20
Mine Waste Consolidation Area Boundary Monuments
348
EA
$158.89
$55,294
Seed/Fertilizer/Mulch
21
Seed - Pasture
147
AC
$2,233
$328,690
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 project lenqth 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 Wire Fence
3,840
LF
$4.07
$15,629
Demo lenqth plus 20%.
27
Remove/RepairTemporary 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
Walkinq inspection of all disturbed areas plus miscellaneous topsoil repair and seedinq.
SubTotal:
$8,994,511
32
Bid and Scope Contingency
35%
percent
$3,148,078.84
Scope continqency of 25% and Bid continqency of 10%
33
Project Management
5%
percent
$607,129.49
Based on EPA quidance.
34
Remedial Design
6%
percent
$728,555.39
Based on EPA quidance.
35
Construction Management
6%
ercent
$728,555.39
Based on EPA quidance.
Estimated Construction Total:
$14,206,830
Notes:
AC: Acre; BCY: Bank Cubic Yard; DY: Day; EA: Each; ECY: Embankment Cubic Yard; LF:
Linear Feet; LS: Lump Sum; SY: Square Yard
E-6
-------
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 2
Unit costs are based on the most recent costing efforts for RA at Cherokee County Oils 3 and 4 unless
noted below.
Item
Description
Estimated
Quantity
Unit of
Measure
Unit cost
Project Cost
Notes
Cover Maintenance
01
Repair Eroded Areas
02
Excavation, Hauling, and Placement
700
ECY
$20.30
$14,210.00
03
Reveqetate Cover
1
acre
$2,233.18
$2,233.18
04
Staff Engineer - annual inspection of LUCs
32
per hour
$109.48
$3,503.35
RACER 33220106
Subtotal:
4iis,a«.s3 /
05
Bid and Scope contingency
20%
percent
$3,989.31
Bid and Scope contingency of 10% each.
06
Proiect Management
5%
percent
$997.33
Based on EPA Guidance.
07
Technical Support
6%
percent
$1,196.79
Based on EPA Guidance.
Total O&M Cost
S26.129.95
E-7
-------
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 2
item
Description
Estimated
Quantity
Unit of
Measure
Unit cost
Project Cost
Notes
5 Year Review. Re
porting
01
Staff Engineer
60
per hour
$109.48
$6,568.84
RACER 33220106
02
Project Engineer
20
per hour
$139.21
$2,784.26
RACER 33220105
03
Drafts ma n/CADD
32
per hour
$87.39
$2,796.61
RACER 33220115
04
Project Manager
12
per hour
$169.75
$2,036.97
RACER 33220102
Subtotal:
$14,186.68
05
Bid and Scope contingency
20%
percent
$2,837.34
Bid and Scope contingency of 10% each.
06
Project Management
5%
percent
$709.33
Based on EPA Guidance.
07
Technical Support
6%
percent
$851.20
Based on EPA Guidance.
Total Periodic Costs
S18.584.55
E-8
-------
Site: Cherokee County Superfund Site OU8
Location: Cherokee County, Kansas
Phase: Feasibility Study
Base Year: 2016
Date: 5/6/2016
Description: LUCs for Alternative 2
Item
Description
Estimated
Quantity
Unit of
Measure
Unit cost
Project Cost
Notes
Implementation of LUCs
01
3-man survey crew
8
day
$1,103.60
$8,828.80
02
Staff Engineer
120
per hour
$109.48
$10,864.87
RACER 33220106
03
Project Engineer
40
per hour
$139.21
$4,605.17
RACER 33220105
04
Drafts ma n/CADD
64
per hour
$87.39
$4,625.59
RACER 33220115
05
Project Manager
24
per hour
$169.75
$3,369.15
RACER 33220102
Subtotal:
$32,293.57
06
Bid and Scope contingency
35%
percent
$11,302.75
Scope Contingency of 25%. Bid Contingency of 10%
Total Cost
S43.596.32
E-9
-------
Site: Cherokee County Superfund Site OU8
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
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 Suivey
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
08
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 qrubbinq
Demolition
10
Barbed Wire Fence Demolition
3,200
LF
$1.48
$4,736
Assumed at least two per access area @ 25' width, no fences running along 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 Sampling
18,500
EA
$6.00
$111,000
Assume on a 50' spacing along centerlineand on each side of rail bed
05 - Restoration
$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 project lenqth 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 Wire 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
Inspection and Maintenance
1
LS
$40,000.00
$40,000
Walkinq 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 continqency of 25% and Bid continqency of 10%
33
Project Management
5%
percent
$676,230.90
Based on EPA guidance.
34
Remedial Design
6%
percent
$811,477.08
Based on EPA quidance.
"
$811,477.08
Based on EPA guidance.
Estimated Construction Total:
$15,823,803
Notes:
AC: Acre; BCY: 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 Oils 3 and 4 unless
noted below.
Item
Description
Estimated
Quantity
Unit of
Measure
Unit cost
Project Cost
Notes
Cover Maintenance
01
Repair Eroded Areas
02
Excavation, Hauling, and Placement
140
ECY
$20.30
$2,842.00
03
Revegetate 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
.jSybtaltli
.4l5«i1.0f /
05
Bid and Scope contingency
20%
percent
$1,190.20
Bid and Scope contingency of 10% each.
06
Proiect Management
5%
percent
$142.10
Based on EPA Guidance.
07
Technical Support
6%
percent
$170.52
Based on EPA Guidance.
Total O&M Cost
S7.453.84
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
porting
01
Staff Engineer
12
per hour
$109.48
$1,313.77
RACER 33220106
02
Project Engineer
4
per hour
$139.21
$556.85
RACER 33220105
03
Drafts ma n/CADD
6
per hour
$87.39
$524.36
RACER 33220115
04
Project Manager
2
per hour
$169.75
$339.50
RACER 33220102
Subtotal:
$2,734.48
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
S3.582.17
E-12
-------
Site: Cherokee County Superfund Site OU8
Location: Cherokee County, Kansas
Phase: Feasibility Study
Base 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
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
Drafts ma n/CADD
13
per hour
$92.59
$1,175.99
RACER 33220115
05
Project Manager
4.8
per hour
$179.84
$843.38
RACER 33220102
$6,340.60
06
Contingency
35%
percent
$2,219.21
Scope Contingency of 25%. Bid Contingency of 10%
Total Cost
S8.559.82
E-13
-------
Site: Cherokee County Superfund Site OU8
Location: Cherokee County, Kansas
Phase: Feasibility Study
Base Year: 2016
Date: 5/6/2016
Description: Capital Costs for Alternative 4
Unit costs are based on the most recent costing efforts for RA at Cherokee County OUs 3 and 4 unless noted below.
Estimated
Unit of
Unit
Project
Item
Description
Quantity
Measure
Cost
Cost
Notes
01 - Initial Activities
$205,855
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
Rouqh count of 58, assume I missed 10%
04
XRF Grid Survey
12.343
EA
S5.00
S61.715
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
Resused and moved with construction area
08
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 qrubbinq
Demolition
10
Barbed Wire Fence Demolition
3,200
LF
$1.48
$4,736
Assumed at least two per access area @ 25' width, no fences running along former rail bed
04 - Earthwork
$0
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
BCY
$5.80
$0
13
Excavation, Haulinq, and Placement -Consolidation Area 10 to 30 miles
BCY
$12.57
$0
R.S. Means 2102, Excavator w/CY Bucket,
14
XRF Confirmation Sampling
EA
$6.00
$0
Assume on a 50' spacing along centerlineand on each side of rail bed
05 - Restoration
$5,303,128
Import and Place Soil from Off-Site Borrow Sources
General Restoration
15
Select Fill
ECY
$21.65
$0
16
Top Soil
ECY
$30.28
$0
Mine Waste Consolidation Area
17
Select Fill
142,000
ECY
$20.30
$2,882,600
18
Top Soil
69,000
ECY
$29.75
$2,052,750
19
Finish Gradinq
19
AC
$1,123
$21,374
20
Mine Waste Consolidation Area Boundary Monuments
348
EA
$158.89
$55,294
Seed/Fertilizer/Mulch
21
Seed - Pasture
19
AC
$2,233
$42,512
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 project lenqth 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 Wire 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
Walkinq inspection of all disturbed areas plus miscellaneous topsoil repair and seedinq
SubTotal:
$5,712,428
32
Bid and Scope Contingency
35%
percent
$1,999,349.88
Scope continqency of 25% and Bid continqency of 10%
33
Project Management
5%
percent
$385,588.91
Based on EPA guidance.
34
Remedial Design
6%
percent
$462,706.69
Based on EPA quidance.
35
Construction Management
$462,706.69
Based on EPA guidance.
Estimated Construction Total:
$9,022,780
Notes:
AC: Acre; BCY: Bank Cubic Yard; DY: Day; EA: Each; ECY: Embankment Cubic Yard; LF: Linear Feet; LS: Lump Sum; SY: Square Yard
E-14
-------
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 4
Unit costs are based on the most recent costing efforts for RA at Cherokee County Oils 3 and 4 unless
noted below.
Item
Description
Estimated
Quantity
Unit of
Measure
Unit cost
Project Cost
Notes
Cover Maintenance
01
Repair Eroded Areas
02
Excavation, Hauling, and Placement
1400
BCY
$20.30
$28,420.00
03
Revegetate Cover
2
acre
$2,233.18
$4,466.36
04
Staff Engineer - annual inspection of LUCs
80
per hour
$109.48
$8,758.37
RACER 33220106
.jSybtaltli
/
05
Bid and Scope contingency
20%
percent
$8,328.95
Bid and Scope contingency of 10% each.
06
Proiect Management
5%
percent
$1,421.00
Based on EPA Guidance.
07
Technical Support
6%
percent
$1,705.20
Based on EPA Guidance.
Total O&M Cost
S53.099.87
E-15
-------
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 4
item
Description
Estimated
Quantity
Unit of
Measure
Unit cost
Project Cost
Notes
5 Year Review. Re
porting
01
Staff Engineer
72
per hour
$109.48
$7,882.61
RACER 33220106
02
Project Engineer
24
per hour
$139.21
$3,341.11
RACER 33220105
03
Drafts ma n/CADD
38
per hour
$87.39
$3,320.97
RACER 33220115
04
Project Manager
14
per hour
$169.75
$2,376.47
RACER 33220102
Subtotal:
$16,921.16
05
Bid and Scope contingency
20%
percent
$3,384.23
Bid and Scope contingency of 10% each
06
Project Management
5%
percent
$846.06
Based on EPA Guidance.
07
Technical Support
6%
percent
$1,015.27
Based on EPA Guidance.
Total O&M Cost
S22.166.72
E-16
-------
Site: Cherokee County Superfund Site OU8
Location: Cherokee County, Kansas
Phase: Feasibility Study
Base Year: 2016
Date: 5/6/2016
Description: LUCs for Alternative 4
Item
Description
Estimated
Quantity
Unit of
Measure
Unit cost
Project Cost
Notes
Implementation of LUCs
DESCRIPTION
QTY
UNIT
UNIT
COST
TOTAL
NOTES
01
3-man survey crew
8
day
$1,103.60
$8,828.80
02
Staff Engineer
120
per hour
$125.55
$12,459.71
RACER 33220106
03
Project Engineer
40
per hour
$159.65
$5,281.15
RACER 33220105
04
Drafts ma n/CADD
64
per hour
$100.22
$5,304.57
RACER 33220115
05
Project Manager
24
per hour
$194.66
$3,863.70
RACER 33220102
$35,737.94
06
Contingency
35%
percent
$12,508.28
Scope Contingency of 25%. Bid Contingency of 10%
Total Cost
S48.246.22
E-17
-------
Site: Cherokee County Superfund Site OU8
Location: Cherokee County, Kansas
Phase: Feasibility Study
Base 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
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
Drafts ma n/CADD
13
per hour
$92.59
$1,175.99
RACER 33220115
05
Project Manager
4.8
per hour
$179.84
$843.38
RACER 33220102
$6,340.60
06
Contingency
35%
percent
$2,219.21
Scope Contingency of 25%. Bid Contingency of 10%
Total Cost
S8.559.82
E-13
-------
Alternative 4 Cost Worksheets
-------
This page was intentionally left blank.
-------
Site: Cherokee County Superfund Site OU8
Location: Cherokee County, Kansas
Phase: Feasibility Study
Base Year: 2016
Date: 5/6/2016
Description: Capital Costs for Alternative 4
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
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 higher traffic areas.
03
Temporary Access/Haul Road Improvements
64
LS
$1,500
$96,000
Rough count of 58, assume I missed 10%
04
XRF Grid Survey
12.343
EA
S5.00
S61.715
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
Resused and moved with construction area
08
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 qrubbinq
Demolition
10
Barbed Wire Fence Demolition
3,200
LF
$1.48
$4,736
Assumed at least two per access area @ 25' width, no fences running along former rail bed
04 - Earthwork
$0
Mine Waste and Contaminated Soil
11
Excavation, Haulinq, and Placement - On Site Consolidation
BCY
$7.39
$0
Assume "on site" means waste is consolidated within 1 mile of its excavation point; 60,000 CY of material
remains in place within consolidation areas
12
Excavation, Hauling, and Placement - On/Off Site Consolidation (<10
miles)
BCY
$5.80
$0
13
Excavation, Hauling, and Placement - Off Site Consolidation (10 to 30
miles)
BCY
$12.57
$0
R.S. Means 2102, Excavator w/CY Bucket
14
XRF Confirmation Sampling
EA
$6.00
$0
Assume on a 50' spacing along centerlineand on each side of rail bed
05 - Restoration
$8,294,302
Import and Place Soil from Off-Site Borrow Sources
General Restoration
15
Select Fill
ECY
$21.65
$0
Estimated volume needed to bring the excavations back flush with the ground surface. Assume 20%
reduction in material quantities for consolidation areas constructed in-place over the rail line
16
Top Soil
ECY
$30.28
$0
Mine Waste Consolidation Area
17
Select Fill
205,000
ECY
$20.30
$4,161,500
18
Top Soil
103,000
ECY
$29.75
$3,064,250
19
Finish Grading
217.3
AC
$1,123
$244,002
20
Mine Waste Consolidation Area Boundary Monuments
348
EA
$158.89
$55,294
Seed/Fertilizer/Mulch
21
Seed - Pasture
217.3
AC
$2,233
$485,304
22
Seed - Native
AC
$2,814
$0
23
Seed - Wetland
AC
$2,987
$0
Drainaqe Improvements
24
Drainaqe Swale/Replace Roadway Ditch
6,172
LF
$17.36
$107,137
Assume 2% of project lenqth 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 Wire 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
Walkinq inspection of all disturbed areas plus miscellaneous topsoil repair and seedinq
Subtotal:
$8,703,602
32
Bid and Scope Contingency
35%
percent
$3,046,260.85
Scope continqency of 25% and Bid continqency of 10%
33
Project Management
5%
percent
$587,493.16
Based on EPA guidance.
34
Remedial Design
6%
percent
$704,991.80
Based on EPA quidance.
35
Construction Management
6%
percent
$704,991.80
Based on EPA guidance.
Estimated Construction total:
$13,747,340
Notes:
AC: Acre; BCY: Bank Cubic Yard; DY: Day; EA: Each; ECY: Embankment Cubic Yard; LF: Linear Feet; LS: Lump Sum; SY: Square Yard
E-14
-------
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 4
Unit costs are based on the most recent costing efforts for RA at Cherokee County Oils 3 and 4 unless
noted below.
Item
Description
Estimated
Quantity
Unit of
Measure
Unit cost
Project Cost
Notes
Cover Maintenance
01
Repair Eroded Areas
02
Excavation, Hauling, and Placement
1400
BCY
$20.30
$28,420.00
03
Revegetate Cover
2
acre
$2,233.18
$4,466.36
04
Staff Engineer - annual inspection of LUCs
80
per hour
$109.48
$8,758.37
RACER 33220106
.jSybtaltli
/
05
Bid and Scope contingency
20%
percent
$8,328.95
Bid and Scope contingency of 10% each.
06
Proiect Management
5%
percent
$1,421.00
Based on EPA Guidance.
07
Technical Support
6%
percent
$1,705.20
Based on EPA Guidance.
Total O&M Cost
S53.099.87
E-15
-------
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 4
item
Description
Estimated
Quantity
Unit of
Measure
Unit cost
Project Cost
Notes
5 Year Review. Re
porting
01
Staff Engineer
72
per hour
$109.48
$7,882.61
RACER 33220106
02
Project Engineer
24
per hour
$139.21
$3,341.11
RACER 33220105
03
Drafts ma n/CADD
38
per hour
$87.39
$3,320.97
RACER 33220115
04
Project Manager
14
per hour
$169.75
$2,376.47
RACER 33220102
Subtotal:
$16,921.16
05
Bid and Scope contingency
20%
percent
$3,384.23
Bid and Scope contingency of 10% each
06
Project Management
5%
percent
$846.06
Based on EPA Guidance.
07
Technical Support
6%
percent
$1,015.27
Based on EPA Guidance.
Total O&M Cost
S22.166.72
E-16
-------
Site: Cherokee County Superfund Site OU8
Location: Cherokee County, Kansas
Phase: Feasibility Study
Base Year: 2016
Date: 5/6/2016
Description: LUCs for Alternative 4
Item
Description
Estimated
Quantity
Unit of
Measure
Unit cost
Project Cost
Notes
Implementation of LUCs
DESCRIPTION
QTY
UNIT
UNIT
COST
TOTAL
NOTES
01
3-man survey crew
8
day
$1,103.60
$8,828.80
02
Staff Engineer
120
per hour
$125.55
$12,459.71
RACER 33220106
03
Project Engineer
40
per hour
$159.65
$5,281.15
RACER 33220105
04
Drafts ma n/CADD
64
per hour
$100.22
$5,304.57
RACER 33220115
05
Project Manager
24
per hour
$194.66
$3,863.70
RACER 33220102
$35,737.94
06
Contingency
35%
percent
$12,508.28
Scope Contingency of 25%. Bid Contingency of 10%
Total Cost
S48.246.22
E-17
------- |