Document ID 810873 RECORD OF DECISIONDocument ID 810873 RECORD OF DECISION DECLARATION STATEMENT SITE NAME AND LOCATION Sand Creek Industrial Site Commerce City, Colorado Operable

Document ID

810873

RECORD OF DECISION

DECLARATION STATEMENT

SITE NAME AND LOCATION

Sand Creek Industrial SiteCommerce City, ColoradoOperable Unit No. 5Colorado Organic Chemical and Gallagher Property Shallow Soils

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected remedy for remediation of shallow soils, fromOperable Unit Five (OU5) of the Sand Creek Industrial NPL Site in Commerce City,Colorado. The remedy was developed in accordance with the ComprehensiveEnvironmental Response, Compensation, and Liability Act of 1980 (CERCLA), as amendedby the Superfund Amendments and Reauthorization Act of 1986 (SARA) and the NationalContingency Plan. This decision is based on the Administrative Record for this site. TheState of Colorado has not yet concurred with the selected remedy. The State postponesconcurring until completion of on-site pilot testing of the selected remedy.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from this site, if not addressed byimplementing the response action selected in this Record of Decision (ROD), may presentan imminent and substantial endangerment to public health, welfare, or the environment.

DESCRIPTION OF SELECTED REMEDY

The selected remedy for OU5 addresses shallow soils contaminated with pesticides andmetals in the Colorado Organic Chemical Company area at the site. This is the secondROD for this site which consists of six operable units. This response action, whencompleted will be the final response action for the Colorado Organic Chemical Companyarea surface and subsurface soils. Response actions addressing the remainder of the entiresite and the groundwater underlying the entire Sand Creek Industrial site will be addressedin separate Record of Decision documents. The ROD for OU1 addressed subsurface soils,OUs 3 and 6 concern a landfill on the site, OU4 will address the site wide groundwatercontamination and OU2 addresses the L.C. Corporation acid pits.

«. *

The selected remedy will.address the principal threats posed by the shallow soils and willprotect groundwater resources and prevent direct contact risks through the treatment anddisposal of contaminated soils. The remedy will ensure the long-term protection for thepublic and the environment through treatment of hazardous substances. The selectedremedy, soil washing, is an innovative treatment technology and is determined to be themost appropriate remedy for the operable unit. Elements of the selected remedy are:

• Excavation of contaminated surface soils which are contaminated in excessof action levels described in Table 7.

• Soil washing of the excavated soil to treatment levels described in Table 8.• Incineration of wastewater.• Backfill of the treated soil.• Grading and revegetating the soil.

STATUTORY DETERMINATIONS

Consistent with CERCLA as amended by SARA and the National Contingency Plan, I havedetermined that the selected remedy for Operable Unit No. 5 of the Sand Creek IndustrialSite is protective of human health and the environment. I have also determined that theremedy complies with Federal and State requirements that are legally applicable or arerelevant and appropriate to the remedial action, and is cost effective. The selected remedyutilizes permanent solutions and alternative treatment technologies to the maximum extentpracticable and satisfies the statutory preference for remedies that employ treatment thatresult in the reduction of the volume, mobility, and toxicity of soil contamination at thesite as a principal element.

Because the selected remedy may possibly result in hazardous substances remaining on siteabove health-based levels for a land use not anticipated for the area, a review of theremediation will be conducted within five years after commencement of the remedial action,to ensure that the remedy continues to provide adequate protection of human health andthe environment.

0Janfe/I. Scherer DateRegional AdministratorEPA Region Vffl

SAND CREEK SUPERFUND SITEOPERABLE UNIT 5

COLORADO ORGANIC CHEMICALAND GALLAGHER PROPERTY

SHALLOW SOILS

September 1990

TABLE OF CONTENTS

RECORD OF DECISION SUMMARY

CHAPTER

I. Site Name, Location and Description

II. Site History and Enforcement Activities

HI. Highlights of Community Participation

IV. Scope and Role of Operable Unit Response Action

V. Summary of Site Characteristics

VI. Summary of Site Risks

VTL Description of Alternatives

Vm. Summary of Comparative Analysis of Alternatives

IX. The Selected Remedy

X. Statutory Determinations

TABLES

1234567

8

FIGURES

123

Exposure PathwaysContaminant Routes and SourcesAssumption Summary for Risk EvaluationExposure Point ConcentrationRisk Characterization Average SoilRisk Characterization Hot Spot SoilChemicals of Concern, Maximum Soil Concentrations,Desired Removal Efficiency and Action Levels For OU5Treatability Variance Requirements

Sand Creek. SiteLocation and Boundaries of COC AreaSand Creek Operable Unit No. 5 - Soil Volume

APPENDICES

PAGE

i4

4

7

8

10

20

23

31

33

121314151617

2134

2•39

AB

ARARSResponsiveness Summary

Record of Decision

Sand Creek Industrial SiteColorado Organic Chemical Company Area

Operable Unit No. 5

Decision Summary

I. Site Name, Location, and Description

This Record of Decision (ROD) describes the remedial action for hazards for OU5, locatedwithin and immediately adjacent to the Colorado Organic Chemical Company (COC)property. The hazards addressed in this remedial action are shallow soils contaminatedwith pesticides and metals.

The OU5 area is located within the Sand Creek Industrial Site, a site listed on the NPL inDecember 1982. The Sand Creek Industrial Site is located in Commerce City, a city northof Denver, Colorado (Figure 1). The site and surrounding area are industrialized andcontain trucking firms, petroleum and chemical production/supply companies, warehouses,small businesses, and several residences. The site study area is bounded on the north bySand Creek, on the south by 48th Avenue, and on the east by Ivy Street. The westernboundary is approximated by Colorado Boulevard, and Vasquez Boulevard. Figure 2illustrates the location and boundaries of OU5.

Within the Sand Creek Industrial Site study area, there are approximately 13 residenceswith a total population of about 25. The day use population, however, reaches severalhundred due to the business and industrial nature of the study area. Water users within thesite study area are served by the South Adams County Water and Sanitation District(SACWSD). Private wells exist on the site; however, this water is used for industrial andirrigation purposes.

Treated groundwater is the source of water supply to the SACWSD. Production wells arelocated north (downgradient) of the study area. Approximately 30,000 customers inCommerce City and Adams County are served by the SACWSD,

OU5 is located above the 100-year floodplain of Sand Creek. The majority of OU5 islocated on a bench of relatively flat terrain that slopes down to railroad tracks to the northand rises to an alluvial terrace to the south.

The Sand Creek Industrial Site lies within the vicinity of three other Superfund sites;Woodbury Chemical, Chemical Sales, and Rocky Mountain Arsenal.

SITfLOCATION—N-

C O L O R A O 0

ROCKY (MOUNTAINARSINAU

COMMIRCICITY

: 3 4

SANO CREEKINDUSTRIAL SITE

INTERNATIONALAIRPORT

COtf AX AVS

I

BUCKLER-AIR NAT. GUARD

BASE

Figure 1 sit« Location. Sand Cr««k Induttrial Sit*

Figure 2 Sand Crr 'Industrial Silo

II. Site History and Enforcement Activities

The Colorado Organic Chemical Company plant was first operated at OU5 by TimesChemical in the 1960s to manufacture pesticides. The company name was later changedto Colorado International Company (CIC). In 1968, a fire destroyed three buildings at theCIC plant. An inspection of CIC by Tri-County District Health Department personnel inJune 1974 indicated unsatisfactory waste management practices and unsatisfactory workersafety conditions.

In March 1976, the Colorado Department of Health (CDH) conducted a Geld inspectionat CIC. The inspectors observed several hundred 55-gallon drums containing pesticidesstored at various places across the COC area. They observed washwater, storm drainage.and boiler feed water draining into a common surface drainage that flowed off propertytowards Sand Creek. CIC was cited for storage and handling violations. A fire occurredat CIC in December 1977, releasing parathion fumes over northeast Denver. The State ofColorado issued an Emergency Cease and Desist Order against CIC to clean up the COCproperty and adjacent areas contaminated by the fire. CIC declared bankruptcy and re-opened the operations as Colorado Organic Chemical (COC). COC operations wereessentially the same as CIC operations.

Soil sampling at COC in early 1978 revealed high levels of organophosphate pesticides,chlorinated hydrocarbons, and thermally-altered pesticides. The State filed a preliminaryinjunction against COC/CIC to clean up the residues of the fire. Some contaminated soilwas removed in October 1978.

COC was cited for unsafe drum storage and improper storage areas under RCRAregulations in 1980. Samples of surface liquids collected during the inspection revealed thatsurface water discharge contained pesticides (dieldrin, heptachlor, DDE, and DDT),inorganics (chromium and arsenic), and other organics (chlorinated benzenes and phenols).

Subsequently, EPA filed a number of complaints against COC for other ResourceConservation and Recovery Act (RCRA) violations. In 1982, a Consent Agreement andFinal Order were issued for the RCRA case. In March 1983, EPA referred to theDepartment of Justice the matter of COC's RCRA violations and violation of the previoussettlement In June of 1983 a spill of the herbicide 2, 4-D resulted in an additionalCompliance Order to clean up the spill and to comply with previous orders. EPA issueda CERCLA 106 Order in March 1984 for cleanup of the site. Between April andSeptember 1984, removal action was taken pursuant to those orders by COC, which resultedin the removal of drummed wastes and product, contaminated soil, and fencing of the site.

HI. Highlights of Community Participation

All requirements for public'participation in Section 113(k) (2) (B) (i-v) and 117 ofCERCLA were satisfied during the remedial action process.

Community relations activities for tr..- Sand Creek site began in April 1985 when EPAdistributed an introductory fact sheet to residents, businesses, and agencies in the area. Thefact sheet described the site and explained the Superfund process, with emphasis on theRemedial Investigation/Feasibility Study (RI/FS). In the next few months, EPA personnelattended a public meeting organized by Citizens Against Contamination; they also compileda list of people who owned property in the study area.

EPA mailed a second fact sheet in November 1985. This fact sheet provided informationtypically requested during investigation and cleanup of hazardous waste sites. That samemonth, EPA also provided a report on water contamination for another public meeting ofCitizens Against Contamination. l

In January 1986, EPA contacted property owners and Commerce City officials to informthem of activities at the site. In the spring, EPA prepared a photo display illustrating theRI/FS process.

Because South Adams County ground-water contamination and its effects on householdsupplies were of concern, EPA surveyed South Adams County residents about their wateruse habits during April 1987. Later that year, EPA spoke with residents and businessesnear the site to check the status of methane venting systems near the 48th and Holly landfilllocated in the Sand Creek Industrial Superfund Site listed on the NPL, now pan of SandCr:ek OU3. The landfill owners had installed these systems after an explosion in 1977resulting from a buildup of methane that had migrated from the landfill.

A Remedial Investigation report describing the extent of contamination within the COCarea was released for public review in March 1988. In May 1988, EPA contacted propertyowners to obtain permission to sample and monitor soils on those properties.

In October 1988, EPA met with Commerce City officials to inform them of plans for thesite. The Commerce City representatives also gave their reactions to the cleanup methodsbeing considered.

In January 1989, the Feasibility Study (FS) which focused primarily on the COC area wascompleted, and a remedial alternative was proposed. The remedial action initially proposedwould have involved: excavation and off-site incineration of the most highly contaminatedsurface soils; vacuum extraction of VOCs above the ground-water table; and demolitionand off-site disposal of the contaminated tanks and buildings in the COC area.

EPA took several measures to announce the proposed remedial alternative choice and toseek comments and questions from the public on the Feasibility Study. First, EPA madecopies of the FS Report available to the public in the Adams County Public Library, theColorado Department of Health, and the EPA Region VIII library in downtown Denver.At the same time, EPA mailed its third fact sheet, which described a proposed plan as wellas four other remedial alternatives that had been evaluated. Third, EPA announced apublic comment period during which the public was invited to submit comments andquestions. The comment period originally ran from January 13 to February 13, but at therequest of the potentially responsible panics (PRPs), EPA extended the period to February

22. Fourth, EPA conducted a public meeting on January 31 to describe the results of theRI/FS and answer questions from the public. EPA published a press release and a publicnotice in each of the Commerce City newspapers, The Commerce Qty Sentinel and TheCommerce City Beacon, announcing all of these activities.

In response to public comment and subsequent re-examination of the site, a FS Addendumwas completed in July 1989 which presented two additional and innovative remedialtechnologies for potential use on the contaminated surface soils in the COC area: biologicaltreatment and soil washing. It was concluded from the FS Addendum that treatabilitystudies would be required before implementing either of the additional alternatives.

EPA made copies of the FS Addendum report available to the public and mailed its fourthfact sheet describing the new proposed plan. The remedy selected in the new proposed planincluded: excavation and off-site incineration of approximately 1,000 cubic yards (CY) ofshallow soils highly contaminated with HOCs ( .5 ft and > 1000 ppm); vacuum extractionof the volatile organic compounds in the subsurface soils above the ground-water table;demolition and off-site disposal of the contaminated tanks and buildings; and eitherbioremediation or soil washing for the shallow soils contaminated with HOCs above actionlevels. It was proposed that excavation and off-site disposal of the contaminated surfacesoils be retained as a contingency remedy, since the implementation of bioremediationand/or soil washing depended upon the results of treatability studies to be: performedsubsequent to a Record of Decision. An absence of proven bioremediarion and/or soilwashing results on soils contaminated with similar compounds further warranted retentionof the off-site disposal option.

EPA provided a public comment period in effect from July 19 through August 21, 1989during which the public was invited to submit comments and questions regarding the FSAddendum and the new proposed plan. EPA conducted another public meeting on August1 to describe the new remedial alternative and answer questions from the community. Pressreleases and public notice were again published in The Commerce Cirv Sentinel and TheCommerce City Beacon announcing all these activities.

Only the City of Commerce City responded in writing, and there was limited comment onthe selected remedy during the August 1 public meeting. The primary concern of the Cityof Commerce City was that the COC property be remediated to residential-use standards.A Record of Decision was subsequently prepared which addressed only the highlycontaminated surface soils and the subsurface soils contaminated with volatile organiccompounds. The decision was to implement the preferred alternative which consisted ofvacuum extraction of VOCs, demolition and off-site disposal of the contaminated tanksand buildings and excavation and incineration of highly HOC contaminated soils.

Remedial action alternatives.for the remaining contaminated surface soil were addressedin a second feasibility study (FS OU5) which incorporated results from treatability tests.A proposed plan which was prepared arid sent out to the public on July 30, 1990. A publicmeeting was held August 9th, at 7:00 PM at the Commerce City community room inCommerce City. A responsiveness summary addressing the public's comments on OU5 wasprepared and is attached to this Record of Decision.

IV. Scope and Role of Operable Unit Response Action

During the course of the remedial investigation, conducted from 1984 to 1988, EPAdetermined, in accordance with 40 CFR Section 300.68(c), of the 1985 NCP that theFeasibility Study should be divided into operable units in order to remediate site-specificproblems. This conforms with sections 300.5 and 300.430 of the new NCP (March 8, 1990).

Originally, the Sand Creek Industrial Site was divided into four operable units accordingto the type of contamination present, type of media affected, and physical characteristicsof the units. The four original operable units are described below:

Operable Unit No. 1 • Soils contaminated by pesticides, volatile organics,arsenic, and chromium in the Colorado Organic Chemical(COC) area; contaminated buildings and tanks in theCOC area;

Operable Unit No. 2 - Contaminated soils and ground water in the vicinity ofthe LC. Corporation property;

Operable Unit No. 3 - Gaseous emissions, contaminated surface water andground water in the vicinity of the 48th Avenue and HollyStreet Landfill; .

Operable Unit No. 4 - Contaminated ground water underlying the entire NPLsite.

As discussed in section III, treatabiliry tests were required to determine the potentialeffectiveness of the bioremediation and/or soil washing options for soils contaminated withHOCs above health based action levels. In an effort to expedite remediation while thetreatability studies were being performed, the original scope of the remediation describedin the OU1 proposed plan was reduced. Accordingly, OU1 was reduced in scope to includeonly the most highly contaminated surface soils, the tanks, buildings and other structures;and the VOC contaminated subsurface soils. A new operable unit, OU5, was defined toaddress the remaining pesticide and metals contaminated surface soils.

The redefinition of operable units will not reduce the overall plan for remediation at theSand Creek Industrial Site. OUs 2, 3 and 4 remain unchanged. As of the date of thisROD, the Sand Creek Industrial Site has been subdivided into the six operable unitsdescribed below:

Operable Unit No. 1 - .Within the COC area, excavation of 10 CY of soils highlycontaminated with pesticides (concentrations > 1,000 ppmHalogenated Organic Compounds); subsurface soilcontaminated with volatile organic compounds; andcontaminated buildings and tanks;

Operable Unit No. 2 -





Contaminated soils and ground water in the vicinity ofthe L.C. Corporation property;

Contaminated surface water and ground water (Class IIaquifer) in the vicinity of the 48th Avenue and HollyStreet Landfill;

Contaminated ground water underlying the entire site;

Within the COC area surface soils contaminated witharsenic, chromium and pesticides (concentrations <1,000 ppm Halogenated Organic Compounds).

Gaseous emissions from the 48th Avenue and HollyStreet Landfill.

This Record of Decision addresses remediation of Operable Unit No. 5. Remediation ofthe remainder of the site will be addressed in separate decision documents.

The purpose of the response action for OU5 is to protect surface water and ground-waterresources, and address the principal threat in this OU by preventing direct contact withcontaminated soils by the public and site workers. This decision represents the secondremedial action decision for this NPL site, and upon completion, will allow the COC areato be returned to industrial use.

V. Summary of Site Characteristics

Contaminant Characteristics

The contaminants of concern at the Sand Creek Site OU5 include the metals; chromium,arsenic, and the pesticides dieldrin, heptachlor, 2,4' -D, 4-4 DDT, and chlordane. Most ofthe contamination present in concentrations above action levels is localized in hot spotsidentified during the remedial investigation. Analytical results of soil samples indicatedchlorinated pesticides are present in concentrations above action levels in the surficialand/or shallow soils throughout the OU5 area. High concentrations of arsenic have beendetected in surficial and shallow soils on the COC property and the northern portion ofOU5 in localized hot spots within areas contaminated with pesticides above action levels.Figure 3 shows the approximate areal extent of contamination at the 0-1', l'-3', and 3'-5'depth. The soil volumes to be remediated are defined by the action levels for dieldrin andheptachlor. These compounds present the greatest risk based on their toxicities. Thesecompounds are also reflective of the total areal extent of the other compounds. Therefore,the remaining compounds would be inherently remediated during the clean-up activitiesfocused on the soil volumes for dieldrin'and heptachlor.

8

LEGEND

Buildings andLoading Docks

ACTION LEVEL SCENARIO

,•.. ; ktdutirlil • Uaa Slandarda•'* 0-1 loot depth In

lri<lu»"l"'-u«» standard.1-3 teal depth Interval

3-5 IMI depth Interval

SOIL VOLUME

1.000 yd3

3.667 yd'

2.0SO yd1

Figure 3

SAND CREEK OPERABLE UNIT NO 5Extent of Dieldrin and Hepiachlor

Concentrations AboveAction Levels

N

TOTAL VOLUME I3.mydj

Affected Matrices Characteristics

Operable Unit No. 5 has been defined as contaminated soils not addressed by OU1 at theCOC areau The OU5 soils include surface soils contaminated with arsenic, chromium, andpesticides (< 1,000 ppm HOCs). The contaminants are found distributed in many locationsthroughout the site, mostly in localized hot spots. The surface soil is found to containhigher concentrations of pesticides than soils at depth.

The volumes of soil to be remediated were calculated for the compounds which present thegreatest health risk. Those compounds were found to be dieldrin and heptachlor. Totalsoil volume calculated for remediation of both compounds in the reasonable maximumexposure scenario is approximately 14,000 cubic yards. Soil volumes for other compoundswere not calculated separately since they are addressed in the soil volumes for dieldrin andheptachlor.

Potentially Exposed Populations

The current population at risk of exposure consists of industrial workers at the site andsurrounding business locations. The risk assessment for the site delineates the exposurepathways and presents the potential health risks to the industrial worker. Currently, thereare no residences within the site boundaries and a relatively minor population of less than25 residences exists in the area. The nearest residents are located three quarters of a milefrom the site. The City of Commerce City presently has this area designated for industrialuse through the year 2010, consistent with present and historic use for the surroundingarea.

Migration Pathways

The potential migration pathways for the contaminants include surface water run off,airborne distribution and groundwater migration. Surface water runoff is the most probablepathway due to the fact the surface soils are the most highly contaminated. Airbornedistribution would be possible during any high construction activities occurring at the sitebut otherwise would not be considered a major migration pathway since the contaminantsare not highly volatile and natural vegetation covers much of the site. Groundwatermigration is not a primary concern due to the tendency of the contaminants of interest toadhere to soil particles. Downward movement of contaminants would occur slowly withwater infiltration rates common to the area.

VI. Summary of Site Risks

An Endangerment Assessment (EA) for OU1 was conducted for the Sand Creek site (COM1988) to evaluate the risks posed by the presence of contaminated soils in the COC area.The results of the 1988 EA were used in the OU1 ROD.

The 1990 EA for OU5 utilizing the Risk Assessment Guidance (July, 1989) identified anumber of chemical compounds that because of health risks, are chemicals of concern forOU5. The chemicals of concern identified in the initial RI/FS (CDM 1987) were used inpreparing the OU5 endangerment assessment which incorporated new data obtained during

10

OU1 remedial design activities. New action levels and soil volumes were a result of thiseffort.

The objectives of the risk assessment were to identify chemicals of concern, define exposurepathways; determine exposure point concentrations, estimate human intakes, identify knownhazards for each chemical of concern, and determine a carcinogenic and noncarcinogenicrisk for the chemicals of concern.

The chemicals of concern were first identified in the original 1988 site wide endangermentassessment The selection process for chemicals of concern was originally presentedseparately for each medium. For the OU5 risk assessment, only contaminants identified aschemical of concern for soils were addressed. These chemicals of concern are; arsenic,chromium, chlordane, 2-4D, 4,4-DDT, dieldrin, and heptachlor.

The exposure pathways were identified in the risk assessment and are summarized in tables1 and 2. The exposure route for wind erosion air-borne paniculates is inhalation. Theexposure routes for direct contact with soil are ingestion and dermal absorption.

The site assumptions used for the risk calculations including route, medium, group,frequency, and duration are summarized in Table 3. The assumptions used for humanintake including; age, ingestion, inhalation, exposed skin, body weight, and time on-siteare also included in Table 3. Although the Reasonable Maximum Exposure Scenario forthe area is industrial, risk calculations were made for industrial and residential scenariosfor comparison purpose. The City of Commerce City has previously asked for thiscomparison.

In order to address areas affected by high concentrations of pesticides and averageconcentrations of pesticides, the data were separated into "hot spot" contamination andaverage contamination.

Hot spot contamination represents a potential maximum exposure for the chemicals presentat high concentrations. Both maximum and average concentrations were used in riskcalculations. Exposure point concentrations for the site average and hot spots weredetermined from the combined data sets of OU1 and OU5. These values are presented inTable 4.

Best estimates of the average exposure concentrations were determined by the 95%confidence level of the arithmetic mean for each chemical of concern. Hot spots valueswere determined from analytical results for the high concentration areas. These values arepresented in Table 4. These values were then used in the calculations shown on Tables5 and 6. Table 5 shows that the site aver :e risk is within the EPA's acceptable risk rangeTable 6, however, shows that the hot spo^ on the site fall outside EPA's acceptable riskrange of 10"4 to 10'*. As was shown in Figure 3, the hot spots comprise most of the OU5area, thus requiring remediation. Soil concentrations for non carcinogenic and carcinogenicrisks of 10"* are also presented on the tables. By obtaining the soil concentrations throughremediation, the excess lifetime cancer risk from combined exposure to all compoundswould be within the'EPA acceptable 10"*-10"' range. Without remediation of the hot spots,the baseline site risk presented by the hot spots would be 2.41xlO"3, outside the acceptablerisk range.

11

TABLE 1

EXPOSURE PATHWAYS IN OU5

Reasonable Maximum Exposure Scenario: Industrial

SOURCE

COCFacility

RELEASEMECHANISM

SpillsLeaks

RELEASE TRANSPORTMEDIUM MEDIUM

Soil SurfaceSoils

EXPOSUREPOINT

EntireSite

ContaminatedSoil

WindErosion,DustGeneration

Air AirborneParticulates

EntireSite

ContaminatedSoil

VehicularTraffic

Air AirborneParticulates

EntireSite

12

TABLE 2

CONTAMINANTS, ROUTES AND SOURCESOF EXPOSURES TO BE ADDRESSED IN THE RISK ASSESSMENT

CONTAMINANTS EVALUATED

METALS

ArsenicChromium

RECEPTOR

Worker

Child

INSECTICIDES

Chlordane4,4' -DDTDieldrinHeptachlor

EXPOSURE ROUTES AND SOURCES

ROUTE

InhalationIngestionDermal Contact

InhalationIngestionDermal Contact

HERBICIDES

2,4-D

SOURCE

Air/ParticulatesSoilSoil

Air/PaniculatesSoilSoil

13

TABLE 3

ROUTE

Inhalation

Ingestion

DermalContact

ASSUMPTION SUMMARY

MEDIUM GROUP

Airborne ChildrenSoil

AirborneSoil

AirborneSoil

Soil

Soil

Soil

Soil

Soil

Soil

Worker

Resident

Children

Worker

Resident

Children

Worker

Resident

FOR RISK EVALUATIONS

FREQUENCY DURATION

40 Davs 5 Hrs 5 YearsYear Day

170 Davs 8 Hrs 30 YrsYear Day

183 Days Age 70 YrsYear Specific

40 Davs 5 YearsYear

240 Davs 30 YrsYear

365 Davs 70 YrsYear

40 Davs 5 YearsYear

240 Days 30 YrsYear

365 Davs 70 YrsYear

Intake Assumptions

Afi£

0 - 11-66 - 9 .9-1111- 17

IngestionRate mg/day

0.0200100100100 -

InhalationRate mVhr

.21

.21

.801.00

. 1.05 -

ExposedSkin ResidentialSurface Body TimeArea m2 Weight kg On Site Hrs

0.0 16 20036 16 200.49 25 160.62 35 160.50 50 14

Adult 100 1.05 0.50 70 14

14

TABLE 4

EXPOSURE POINT CONCENTRATIONS

(Hot Spot)Surface(a) Surfacefbl(ppm) (ppm)

Arsenic 18.04Chromium 55.64Chlordane 20.94 355.00Dieldrin 3.95 343.00DDT 89242,4-D 1.16 38.00Heptachlor 3.70 10.20

a. 95% confidence level of the arithmetic mean.b. Maximum concentration.

15

• IK CMMCtf 111*110» 101 BM» Off 11 IMMIION Of Mil (IMDUtUlM Table 5 Site Average

COmU*

ArionlcCkr-l-

OKMICt

O.l«r*n.

».«••4.4- k»l

• l*l*ln

"""'""•'

••i»r4 Into*

(«C**B l|f*l

- 0

o>

m conn,**,.•oncorcln*«*mlc Corilnoiintc l*v*l of Ih*

•uoan Inloto MMMM Inlet* *«H Cone.

factor foclor ArllhMiic W*on

|kf/k« oky) «k«/kf*y» (*•/»•>

«.19I «7 4.tif 07 18.04

t.w n 4.«« or « M

.191 «7 4.irt or ?0.94

.Iff »7 4.CK 07 1 14

.191 «f 4.«K 07 89.24

>9f 07 4.0W «r I.9S.194 «F 4. 0?t 07 1.70

: Coablntd Cipo«ur«

••» Conccr ll«k: Combined Cipovurc

ooDO

0>P""*»

fic««t llf«llM toll Cone. toll Cone.

Ctironic Monrorcin. IndivloWl 8**o4 On tM*ol On

Chronic too* Ifftctm: Cwrtnooonlc •oncorcln. 184

Do** •«. «w 70 r Hoiord Iratei I Uk tUk CortliMjinlc

(•V/tfl/doy) (•v/lf/cfay) <Oa«r/tfO) |Do«* • ojl*) faoj/tg) •!•* (o«/kfl|

I.49C 01 7.7M 04 1 AW 02 1.4K M 41. IN 8.991

1. 711 01 2.741 01 1.0M 02 HC 1)51.499 K

1.971 01 .421 04 1.7M 01 1.891 M 8.224 8.18J

1.09104 .44f 07 LOW 04 K 4224.211 K

8.IM 01 .191 01 1.48f 81 1.27f-81 I). Ml I.US

S.rif 04 .191 04 7.47(02 2.14f 81 8.114 8.811

1.471 04 .49(04 4.911 01 4.49(04 11.141 8.111

4.04C-OI

1.89t 01

•isc cMUucini/Ati(» rot %tm cifcit IWXSIIOM or ton <INDUSI»IM umim Table 6 Hot Spots

••ncwclfwftnlc C*rclnof*nlc Hoi SpotMUM* Intake Nu»an Intake Sell Cone.

factor factor Mmliua Cone.

• *MCMIC<

ArMttlc -' t.5»f-0f 4.071 orChrottua 9.191-Of 4.07C or

OMMICf

CMevdane .191 -Of 4.071 or HVOO?.«•• • .191 -or 4.o7f or IB. oo4.4> MI .191 or 4.o7t or•Itldrln .J9I Or 4.071 or 341.00•fotachlor .19€ Or 4.07(-or 10.70

••lord Indti: Coattlntd fnpo«ur«

fic*«t llfttla* Cancer Milk: Coatilntd (*po«ur«

"D

08o o

&

C»fe*» llfctio* Soil Cone. Soil Cone.Chronic Hnncarcln. Individual >Mtd On iMad Oh

StAchronlc DM* tll«ct«: Carclnoftnle Noncarcln. 10-ADM* »v. over TO y Haiard lnd»* IUk *i«k Carclniainlc

0.00f*00 O.OOT«00 O.OM*00 O.OOC«00 W.770 « . . - •O.OOt'OO 0.00t*00 0.001*00 NC tSit.499 NC

J.llf 04 1.4W 04 ).S6T*00 I.MC-04 0.274 1.914i.^n -o^ i.Mt-n i.^n-oi NC 0274.212 NC0.00f*00 0.001*00 0.001*00 O.OW«00 1t.)AI r.JU).77f M 1. lot 04 6.44f«OQ 2. 211-01 0.156 O.ltt

9. MK 04 4.101 06 1.971-02 I.KI-OS H.W1 O.MI

1.701 »01

2.4IE 01

\ .

The general hazards associated with the chemicals of concern for OU5 are shown below:

Arsenic

Arsenic is associated with an increased incidence of lung, liver, bladder, and skin cancer ininuividuals exposed via drinking water and with an increased incidence of lung cancer inoccupationally exposed workers. EPA has classified arsenic in Group A--HumanCarcinogen.

Acute effects of arsenic are generally seen only following a large dose. Acute arsenicpoisoning due to ingestion is manifested in gastrointestinal disturbances. The intensity andonset of symptoms is determined by the physical form, purity and time since last eaten.Symptoms of acute poisoning are tightness of the throat, difficulty in swallowing, and violentabdominal pain. Arsenic consumption can also lead to severe high blood pressure andwidespread damage to the central nervous system (CNS). Death may result from cardiacfailure. In less severe cases of occupational exposure, recovery often occurs and may becomplete or show signs of chronic poisoning. Lethal doses of arsenic range between 70 and180 ug. Chronic and subchronic exposures to arsenic generally affect many of the sameorgan systems as those affected by acute exposure. In most cases, effects can be seen onlyafter chronic low dose exposure. The skin is one of the prime targets of chronic exposures.

Chromium

Chromium is an essential micronutrient and is not toxic in trace quantities. High levels ofsoluble chromium(VI) and chromium(III) produce kidney and liver damage. Chromium istransported across the placenta and concentrated in the fetus. Chronic inhalation exposuremay lead to respiratory damage. Occupational exposures to chromium compounds causesevere skin problems and inflammation of the larynx and liver. EPA has classifiedchromium(VI) in Group A - Human carcinogen based on epidemiological studies ofworkers exposed to chromium(VI) via inhalation.

Pesticides

All the pesticides at the Sand Creek Operable Unit No. 5 can be classified as chlorinatedhydrocarbons. The environmental and biological persistence of chlorinated hydrocarbonpesticides presents the special problem of chronic mammalian toxicity resulting fromrepeated low-level exposure to these compounds.

Chlordane

Chlordane has been used for control of insects and agricultural use. In recent years, it hasbeen extensively used to control household pests and for certain insects. The principal toxiceffects in humans following-acute and .chronic exposures to chlordane include centralnervous system excitation, immune system deficiencies and blood disorders. Chlordane hasnot been a common cause of poisoning. All established cases have been associated withgross exposures. In most instances, including those with fully recovery, convulsionsappeared within 0.5 to 3.0 hours after consumption or after dermal exposure.

18

Following ingestion, some people experienced nausea and vomiting before signs of centralnervous system over-activity. EPA's Carcinogen Assessment Group (CAG) has classifiedchlordane in Group B2 - Probable Human Carcinogen.

4.4'-DDT

4,4'-DDT has been shown to be carcinogenic to mice, primarily causing liver tumors, butalso causing lung tumors and lymphomas. 4,4'-DDT is also a reproductive toxin, causingreduced liter size, reduced growth of offsprings, and fetal death. Chronic exposure causesadverse effects to the liver and central nervous system. Acute exposure to large doses orchrome exposure to lower doses may cause seizures. 4,4'-DDT is bioconcentrated andstored in the fat tissue of most animals. In studies of workers occupationally exposed to4,4'-DDT by inhalation, no increased incidence of cancer was reported (Ortelee 1958, Lawset al. 1967).

Experimental and accidental exposures have revealed that a single dose of 10 mg/kgproduces illness characterized by vomiting, headache, and confusion. Acute poisoningscause a slight decrease in red blood cells and obvious neurological effects. 4,4'-DDT hasbeen classified by EPA's Carcinogen Assessment Group (CAG) in Group B2--ProbableHuman Carcinogen.

2.4-Dichlorophenoxyacetic Add

2,4-D is not believed to cause cancer, but has been shown to produce weak mutageniceffects in cultured cells, and to cause birth defects in rats, mice, and hamsters.Considerable uncertainty exists regarding the toxicity of 2,4-D to human; the minimal toxiccase may be as low as 80 mg/kg, with an average oral dose likely to be fatal estimated tobe 400 mg/kg. Based on clinical data, poisoning can occur following dermal exposure orconsumption. The principle acute symptoms are vomiting, fever, diarrhea, and profoundmuscle weakness. Pathological changes have also occurred in the gastrointestinal tract,liver, lungs, and kidneys. No known chronic human health effects exist.

Dieldrin

Dieldrin can be absorbed by humans from the gastrointestinal tract following ingestion ofthe pesticide, and absorbed through the skin following skin exposure. Dieldrin affects thecentral nervous system, producing incoordination, headache, gastrointestinal disturbances,and convulsions. EPA has classified dieldrin in Group B2 -Probably Human Carcinogen.

Heptachlor

The human toxic effects of heptachlor have not been well documented. Animal studiesindicate that heptachlor causes the same kind of illness as that produced by similarpesticides such as chlordane. It has also been shown to cause chromosomal mutations.However, no lethal genetic changes were produced when male mice received large dosesof the pesticide. The deleterious effects of chromosomal changes in humans in inconclusive.

EPA's Carcinogen Assessment Group has classified heptachlor in Group B2-ProbableHuman Carcinogen.

Exposed Population and Site Risk

The Sand Creek site is highly industrialized. The day use population may reach severalhundred. The City of Commerce City has projected future land use for the area asindustrial Therefore, the maximum reasonable exposure scenario for the site is consideredto be for the industrial worker. The risk to the industrial worker was calculated for eachexposure pathway, inhalation, ingestion and dermal. The ingestion pathway was consideredto present the greatest risk. Table 7 shows a comparison of the 10'* action levels to themaximum and average concentrations found at the site.

The exposure scenarios presenting the highest risk at OU5 is incidental ingestion ofpesticide (HOC) contaminated soils. Other exposure scenarios for the site (inhalation ofcontaminated dust and inhalation of compounds volatilizing from the soil) generally presentlower risks.

Two chemicals of concern, dieldrin and heptachlor, were chosen as driver compounds forOU5 remediation due to their carcinogenicity and concentrations present at the site. If onlythese two compounds were to be removed from the targeted surficial soils, a 2.7x10"'carcinogenic risk (ingestion pathway) would remain on-site for industrial workers. Whilethis is within the acceptable risk range, it is important to note that the soils exceedingdieldrin and heptachlor remediation goals largely include the extent of contamination fromother identified carcinogenic chemicals of concern (4,4'DDT, chlordane, arsenic, andchromium concentrations did not present a site risk outside of the acceptable 10"*-10"9

range). Therefore, the remediation alternative selected in this ROD will result in theremoval or reduction in concentration of these chemicals of concern to below the 2.7x10~5 carcinogenic risk for industrial workers.

VII. Description of Alternatives

The detailed analysis of remedial alternatives, presented in the feasibility study for OU5,resulted in the development of four alternatives for site remediation. These alternativesare summarized below.

Alternative No. 1 - No Action

The No Action alternative is presented as a basis for comparison with the otheralternatives. Under no action, soil would remain contaminated with toxic chemicals and therisks described above would remain. No action could be considered feasible only if theother alternatives could not substantially reduce toxicity, mobility, volume, or the health riskassociated with the site. Selection of the no action alternative would require monitoringof ground-water for thirty years to evaluate movement of contaminants from the site. ThePublic Health Evaluation (PHE) would be performed at 5-year intervals as is requiredunder CERCLA/SARA when contaminated material is left on site. Operation andmaintenance costs of approximately 20,000 per year are projected for periodic sampling

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TABLE 7

CHEMICALS OF CONCERN, MAXIMUM AND AVERAGE SOIL CONCENTRATIONS,AND HEALTH BASED ACTION LEVELS FOR OU5

Chemicals ofConcern

Arsenic

Chromium

Dieldrin

Heptachlor

Chlordane

2-4 D

44 DDT

MaximumConcentration

ppm

1170

66

343

76

355

15,000

203

AverageConcentration

ppm

18.04

55.64

3.95

3.70

20.94

1.16

89.24

Action Levels Based onCarcinogenic

Riskppm

0.155

0.553

Action levels for 10"* risk.

By remediating the soils to the carcinogenic risk levels for Dieldrin and Heptachlor, theoverall site risk is lowered to the acceptable risk range of lO'MO"'.

21

inspection, and performing the PHE. Assuming a monitoring period of 30 years thisequates to a present worth cost of $604,000.

Alternative No. 2 - Capping/Institutional Controls

Alternative No. 2 would involve reducing the areal extent of contaminated soil byexcavating approximately 140,000 cy of the surface soil contaminated above industrial useaction levels listed in Table 7, placing the excavated soil in a designated area ofcontamination, and constructing a cap over the entire contaminated area. The cap,constructed of a three-layer design to comply with RCRA requirements, would preventdirect contact with contaminated soil, minimize airborne emissions, and minimize surfaceinfiltration (thereby protecting ground-water resources). Alternative No. 2 would beconsidered on-site containment.

Land use restrictions would be required to ensure long-term maintenance of the cap andto prevent activities that would disturb the cap or result in contact with or release ofcontaminated soil. The long-term effectiveness or permanence is questionable becausecontainment does not permanently address the contamination and the cap may ultimatelyfail. Also, because no treatment would occur, toxicity and volume of contaminants wouldnot be reduced. Because contaminants are left on-site, monitoring of ground-water wouldbe required for thirty years, and re-evaluation of the PHE would be performed at 5- yearintervals. Land use would be restricted to industrial use. Institutional controls would beimplemented to maintain the integrity of the cap. Without restricting the land use of thecapped area it is highly likely the cap would fail. Restriction of on-site digging and wellinstallation would be probable institutional controls required to maintain the cap. Theestimated present worth cost to construct a cap at OU5 is approximately 2,547,170. Tneestimated cost for maintenance of the cap is $70,000/yr.

Alternative No. 3 - Off-site Landfill Disposal

Alternative No. 3 involves excavation of approximately 14,000 cy of the contaminated soilwith concentrations above action levels identified in Table 7, transport and disposal at anoff-site hazardous waste landfill, backfilling the excavated area with clean soil andrevegetation of the site. Mobility of contaminants would be reduced through off-sitecontainment. Long-term effectiveness is considered to be high. A PHE would be requiredevery 5 years based on CERCLA section 121(c). The estimated present worth cost foralternative No. 3 is $4,903,000. Annual O & M costs of $67,000 are expected for short-term monitoring during remediation activities.

Alternative No. 3 was originally proposed as a contingency remedy to augment thepreferred remedy, which is an innovative technology, and in the event that the pilot test forthe selected remedy (Alternative No. 4) demonstrates that field scale soil washing is notsuccessful. However, since the development of the FS and proposed plan, additionalrequirements regarding the application of Land Disposal Restrictions to AlternativeNumbers 3 and 4 became apparent. This information indicates that off-site disposal of soilsin a hazardous waste landfill cannot occur without treatment prior to disposal. Therequired treatment for soils with most of the contaminants found at OU5 is incineration,which is the BDAT for most contaminants in the soils. Rough estimates for incineration

22

are currently S 1,000 per cubic yard of soil. This would raise the cost of Alternative No. 3by approximately $14,000,000. The total cost of Alterative No. 3 would be approximately$22,000,000. EPA decided to drop Alternative No. 3 as a contingency to the selectedremedy at this time, based upon confidence in the selected remedy and the difference incosts resulting from the different soil volumes to be incinerated.

Alternative No. 4 - On-Site Soil Washing Treatment of Contaminated Soil/Off-SiteIncineration and Disposal of Soil Washing Residuals

Alternative No. 4, involves excavation and treatment on site by soil washing ofapproximately 14,000 cy of surface soil with concentrations above health risk-basedindustrial action levels listed in Table 7, Excavated areas would be backfilled with treatedsoil, and revegetated. The contaminated liquids generated during soil washing would betreated off-site in accordance with Land Disposal Restrictions (LDRs) with residualsdisposed of in a subtitle C landfill.

Soil washing treatment of hazardous substances is an innovative technology. Therefore,bench scale treatability tests were performed to evaluate the effectiveness of the processand aid in designing the treatment system. Toxiciry and volume of the contaminated soilswould be reduced through treatment (soil washing) and destruction (incineration of liquidsand residual soils). This alternative offers a permanent solution for the site. Ground-watermonitoring would be required for 30 years following completion, and the PHE would bere-evaluated after 5 years. After additional field testing and design Alternative No. 4would take approximately 9-12 months to implement and 2-3 years to complete. Theestimated present worth cost is $4,490,734. Annual operation and maintenance costs areexpected to be $20,000 per year. This alternative will comply with the LDRs through aTreatability Variance for the contaminated soil and debris.

VIII. Summary of Comparative Analysis of Alternatives

This section presents a comparison of alternatives using nine component criteria. Thesecriteria, are set forth in OSWER Directive 9355.3-02 and the NCP (40 CFR 430(e)(9)(iii).

1. Overall protection of human health and the environment

2. Compliance with ARARs•

3. Long-term effectiveness and permanence

4. Reduction of toxiciry, mobility, or volume through treatment

5. Short-term effectiveness

6. . Implementability\

7. Cost

23

8. State acceptance

9 Community acceptance

CRITERION 1: PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT

Alternative No. 1 • No ActionUnder the No Action alternative, no remediation would take place and risk to public healthand the environment would not be reduced, eliminated, or controlled. Toxiciry, mobility,and volume of contaminants would be unchanged. Thirty-year monitoring of ground waterwould be required. Re-evaluation of the PHE at 5-year intervals would be necessarybecause material contaminated above health based action levels would be left on site.

Alternative No. 2 - Capping/Institutional ControlsThe cap would protect human health to the extent that it eliminates exposure via dermalcontact, ingestion, and inhalation. It would also reduce the potential for leaching ofcontaminants into ground water. Because contaminants would be left on-site, reevaluationof the PHE would be required at 5-year intervals to evaluate the continued effectivenessof the cap, assess the remaining risks and develop necessary corrective actions to reduce therisk if warranted.

Alternative No. 3 - Off-Site Disposal of SoilsAlternative No. 3 provides a high degree of protectiveness of human health and theenvironment. Contaminated soils would be excavated and removed from the site,eliminating the health threat that the contaminated soils presently pose through directcontact and potential migration to ground water. A portion of the risk would be transferredto an off-site landfill that is designed and managed to contain the contaminants.

Alternative No. 4 • On-Site Washing Treatment of Contaminated Soil/Off-Site Incinerationand Disposal of Soil Wash ResidualsAlternative No. 4, the soil washing alternative, provides a high degree of protectiveness tohuman health and the environment The contaminated soil would be excavated and treatedon-site with a soil washing process. Once soils are treated to acceptable health risk-basedaction levels, they would be backfilled and the site revegetated. Residuals from the soilwashing process would be incinerated off-site and disposed of in a RCRA Subtitle ClandMll. This alternative would reduce the health threat posed by direct contact to levelswhich would safely allow reuse of the OU5 area* as an industrial area.

CRITERION 2: COMPLIANCE WITH ARARs

CERCLA Section 121 requires selection of a remedial action that is protective of humanhealth and the environment. The determination of protectiveness is based on complianceof the selected remedy with ARARs and/or health-based action levels.

Applicable "requirements are those cleanup standards, standards of control, and othersubstantive environmental protection requirements, criteria, or limitations promulgatedunder Federal or State law that specifically address a hazardous substance, pollutant,contaminant, remedial action, location, or other circumstance at a CERCLA site.

24

Relevant and appropriate requirements are those cleanup standards, standards of control,and other substantive environmental protection requirements, criteria, or limitationspromulgated under Federal or State law that, while not "applicable" to a hazardoussubstance, pollutant, contaminant, remedial action, location, or other circumstance at aCERCLA site, address problems or situations sufficiently similar to those encountered atthe CERCLA site that their use is well suited to the particular site.

The ARARs for the alternatives described above are set forth in Appendix A. The tablesof ARARs in the appendix present the Federal and State chemical, location and actionspecific ARARs and those regulations to be considered as they apply to the alternatives 1-4.

Alternative No. 1 - No ActionThe no action alternative at OU5 does not attain ARARs, cleanup goals, or other humanhealth and the environment protection requirement.

Alternative No. 2 - Capping/Institutional ControlsCapping could be performed in compliance with ARARs. ARARs include OSHA workerprotection regulations, ambient air quality standards for paniculate and vapor emissionsand Colorado noise abatement standards. The cap would be constructed to comply withsubstantive and technical requirements of RCRA During cap construction Federal CleanAir Act National Air Quality Standards and State of Colorado Air Quality Regulationsnecessitate the control of vapor and paniculate emissions.

Alternative No. 3 - Off-Site Landfill Disposal of SoilsAll ARARs pertaining to Alternative No. 3 can be attained. ARARs include LDRs for off-site treatment and disposal, OSHA worker protection regulations, paniculate and vaporemission regulations, RCRA regulations, including LDR, and the rules and regulationsgoverning the transportation of hazardous materials within Colorado. Federal Clean AirAct National Air Quality Standards and State of Colorado Air Quality Regulationsnecessitate the control of vapor and paniculate emissions.

Alternative No. 4 • On-Site Washing Treatment of Contaminated Soil/Off-Site Incinerationand Disposal of Soil Wash ResidualsThe ARARs associated with the soil washing alternative pertain to excavation, stockpiling,demolition, soil washing, and backfilling activities for on-site operations, and hazardouswaste transport, incineration emissions and LDRs for on-site and off-site activities. Duringon-site activities, dust generation, excavation and incineration noise, and vapor emissionswould be of concern. Workers would have to follow OSHA health and safety regulationsduring all phases of remedial action. Federal Clean Air Act National Air Quality Standardsand State of Colorado Air Quality Regulations necessitate the control of vapor andpaniculate emissions. This alternative will comply with LDRs for soil and debris througha treatability variance. * .

25

LDR Comparative Analysis

Alternatives 2, 3, and 4 were evaluated for to application of the Land Disposal Restrictions(40 CFR 268, Subpan D) to which, generally, require excavated soils to be treated usingthe "best demonstrated available technology," or BOAT, prior to being "placed" on the landor disposed of outside the area of contamination.

The NCP addresses EPA's policy regarding the Land Disposal Restriction's (LDR's)treatment standards as applied to soil and debris and their utility at CERCLA sites. EPAis of the belief that treatment standards developed pursuant to the RCRA LDR programare, generally, inappropriate or unachievable when applied to contaminated soil and debrisbecause BDAT treatment may yield little benefit over other treatment methods. Atreatability variance to utilize a different treatment method other than BDAT is available.A Federal Register Notice dated October 10, 1989 (54 FR 41566) was issued by EPA priorto the final NCP (March 8, 1990), concerning the use of LDR's in Superfund sites. TheFinal NCP also addressed the same concerns and policy. The consideration of alternativeswas in conformance with this Notice and the Final NCP (which deals expressly withtreatability variances) and the need not to undertake a case by case demonstration thatBDAT standards are inappropriate. The principle reason., that BDAT would beinappropriate is the complexity of the soil and debris mixtures resulting in interference withtreatability.

Under the NCP, to evaluate the need for the treatability variance it is necessary to conductan evaluation of the following factors. It is first necessary to determine if restricted RCRAhazardous wastes are present and compare the Superfund contaminants of concern (fromthe baseline risk assessment) with BDAT constituents requiring control so that allconstituents for which remediation may be required are identified. The next considerationis to evaluate whether remedial alternatives involve "placement" to determine applicabilityof the LDR's and then whether the treatment will ensure that the respective technologyprocess will attain the appropriate treatment levels either through the LDR treatmentstandard or a treatability variance alternative treatment level. In accordance withSuperfund goals, reduction of 90% or greater for Superfund primary contaminants ofconcern should be attained. The alternatives presented in this ROD were evaluated underthis process.

Alternative 2 requires excavation of soils and construction of a cap over the contaminatedarea. Consolidation of soils on-site would not constitute placement and thus the LDR'swould not be triggered.

Alternative 3 requires excavation and placement in an off-site hazardous waste landfill. Thesoil would need to be treated on-site or off-site prior to placement in the landfill. BDATfor contaminants in the soils includes different and conflicting treatment technologies.Therefore, a treatability variance would be necessary..

Alternative'4 requires excavation of soil,to be treated by soil washing and placement of theclean soils back to the place from which it was excavated. It also requires that thecontaminated soil washing wastewater resulting from the soil washing process be removedfrom the site, incinerated, and placed in a landfill off-site. A treatability variance is

26

required when the soils treated by soil washing are replaced on-site. The resulting wastewater will be largely a mixture of highly contaminated (over 1,000 mg/£) fluids, silts, andclays and will be taken off-site for incineration and disposal, as required by BOAT forCalifornia list fluids.

CRITERION 3: REDUCTION OF TOXTCITY. MOBILITY. OR VOLUME

Alternative No. 1 - No ActionNo reduction in toxicity, mobility, or volume would be achieved under the No Actionalternative. Contaminants would continue to move from the site, affecting surface water,ground water, and soils.

Alternative No. 2 • Capping/Institutional ControlsThe capping alternative would not reduce toxicity or volume because the waste would notbe treated. Mobility would be reduced to the extent that the cap prevents surface waterand soil movement from the site and to the extent that the cap prevents infiltration ofwater and potential movement of contaminants to ground water. A significant reductionin mobility is expected for the capping alternative.

Alternative No. 3 • Off-Site DisposalAlternative No. 3 would achieve a significant reduction in toxicity, mobility, and volumethrough transferring soils to a facility designed to contain hazardous wastes. The potentialfor movement of contaminants into groundwater beneath OU5 from the surface soils wouldbe eliminated.

Alternative No. 4 • On-site Washing Treatment of Contaminated Soil/Off-Site Incinerationand Disposal of Soil Wash ResidualsThe soil washing alternative would significantly reduce the toxicity and volume and mobilityof contaminants on-site and by eliminating the source of surface soil contaminants.

CRITERION 4: LONG-TERM EFFECTIVENESS AND PERMANENCE

Alternative No. 1 - No ActionBecause contaminants would continue to move from the site, posing a potential healththreat, the No Action alternative would not provide a long-term or permanent solution.Continued monitoring of the. site would provide data on how natural attenuation andchemical degradation would reduce the threat to human health and the environment andthe time period to reduce the threat.

Alterative No. 2 • Capping/Institutional ControlsCapping is not considered a permanent solution because wastes would remain untreated onsite. Long-term effectiveness for protection of human health and the environment wouldbe related to maintenance and monitoring the effectiveness of the cap. Long-termmaintenance of the cap could provide control of contaminant movement and prevent riskof direct contact with contaminants and exposure to airborne emissions. With propermaintenance, the cap would be effective in preventing leaching of contaminants into theground water.

27

Alternative No. 3 - OfT-Site Disposal of SoilsAlternative No. 3 cannot be considered a completely permanent environmental solution.because contaminants and incinerator residuals would be transferred to an off-site facility.Alternative No. 3 would provide long-term effectiveness for protection of human health andthe environment at the site.

Alternative No. 4 - On-Site Washing Treatment of Contaminated Soil/Off-Site Incinerationand Disposal of Soil Wash ResidualsThis alternative would achieve significant long-term effectiveness and permanence throughthe soil washing process which would extract chemicals of concern from less contaminatedsoils and achieve acceptable health risk-based levels on-site. This would provide apermanent solution for the site. Off-site landfilling of all incinerated residuals wouldeffectively immobilize any remaining contaminants, and long-term risks would be negligible.

CRITERION 5: SHORT-TERM EFFECTIVENESS

Alternative No. 1 - No ActionThe No Action alternative would not provide any short-term effectiveness.

Alternative No. 2 - Capping/Institutional ControlsThe success of alternative No. 2 to achieve short-term effectiveness is related to the degreethat production of airborne particulates and vapor is controlled during remediation, tominimize exposure risk to workers and the surrounding populace. The degree of short-termrisks would be less than that of other alternatives due to a relatively quick constructionperiod. Air monitoring during implementation would be required to evaluate risk andinstitute any corrective action.

Alternative No. 3 - Off-Site Disposal of Residuals and SoilsEffectiveness presented by alternative No. 3 would be less than that of the no actionalternative. Implementation time would be reduced because there would not be a needto construct a landfill or backfill soils into it. The off-site landfill would have the necessaryfacilities and pollution control equipment to contain soils and prevent emissions duringtreatment/disposal.

Alternative No. 4 • On-Site Washing Treatment of Contaminated Soil/Off-Site Incinerationand Disposal of Soil Wash ResidualsRemediation of soils at the COC area employing soil washing would take approximately 2-3 years to complete. Workers and the nearby community could potentially be exposed toslightly elevated risks during soil handling and treatment activities. These risks, however,can be reduced to acceptable levels by instituting protective and preventative measures. Asite-wide air monitoring program would be in operation during remedial activities with thisalternative.

28

CRITERION 6: IMPLEMENT ABILITY

Alternative No. 1 - No ActionThe No Action alternative is readily implementable.

Alternative No. 2 • Capping/Institutional ControlsThe cap alternative is highly implementable using standard construction techniques. Thealternative poses some logistical problems associated with the presence of a building,railroad, underground pipeline, and other utilities adjacent to the site. Detailed planningwould be required to address reconstruction or rerouting of these rights-of-way.

Alternative No. 3 • Off-Site Disposal of Residuals and SoilsThe construction aspects of Alternative No. 3 are highly implementable using standardconstruction techniques and equipment Implementability of landfill disposal would bedependent on the capacity of these facilities at the time of remedial action. Theseproblems could result in a delay in remedial action, but do not preclude off-site disposal.

Alternative No. 4 • On-site Washing Treatment of Contaminated Soil/OfT-Site Incinerationand Disposal of Soil Wash ResidualsThis alternative combines incineration, containment, and soil washing technologies. Thelimited staging and operations space at OU5 would necessitate a phased construction andtreatment approach. Off-site land disposal is implementable with standard techniques andequipment, but is dependent on the capacity of these facilities at the time of remedialaction. Although soil washing has been successfully demonstrated with certain types ofcompounds, its effectiver in treating the area's complex mixture of contaminants isuncertain. Bench scale treutabiliry test results of the OU5 soils indicates effective removalof the contaminants is dependent upon the soil washing solution chemistry to determineif all the contaminants can be removed and to aid in designing the treatment system. Apilot test would be necessary to determine actual implementability.

CRITERION 7: COST

Alternative No. 1 - No ActionThe cost of the No Action alternative is due primarily to site operations and maintenancewhich includes periodic sampling, inspection, groundwater monitoring and performance ofa PHE at 5-year intervals. Annual cost is estimated at $20,000 and present worth cost over30 years is estimated at $604,000.

Alternative No. 2 • Capping/Institutional ControlsThe estimated present worth cost for construction of a cap at OU5 is approximately$2,547,170. This cost includes construction, O&M, and periodic monitoring. Annual O&Mcosts are expected to be $67,000.

Alternative No. 3 - Off-site Disposal of Residuals and SoilsThe estimated present worth cost for Alternative No. 3 is $4,903,000 plus approximately$14,000,000 to accommodate off-site incineration prior to disposal in accordance with LDRs.The cost assumes disposal at an in-state landfill, and the cost may be higher if transport out

29

of state is required. Annual O&M costs are expected to be $67,000 per year duringremediation activities.

Alternative No. 4 - On-Site Washing Treatment of Contaminated Soil/Off-Site Incinerationand Disposal of Soil Wash ResidualsCosts associated with the soil washing alternative are uncertain since this is an innovativetechnology. The estimated present worth cost for this alternative is $4,490,739 for anindustrial scenario. Annual O&M costs are expected to be similar to alternative 3 atapproximately $70,000 per year.

CRITERION 8: STATE ACCEPTANCE

The State has not yet concurred with the selected remedy. The State postpones concurringuntil completion of on-site pilot testing of soil washing. The State has indicated apreference for the alternative in correspondence with EPA. The correspondence is attachedto this ROD following the Responsiveness Summary.

Alternative No. 1 - No ActionThe State finds this alternative unacceptable due to continued exposure to the public,potential contamination of surface and groundwater, and lack of usability of the site.

Alternative No. 2 • Capping/Institutional ControlsThe State is not in favor of this alternative because the contaminated soil will remain on-site and require long-term maintenance of the cap to ensure protection of public health andcontainment of the waste. The land use will be excessively restrictive.

Alternative No. 3 - Off-Site Disposal of Residuals and SoilsThe State finds this alternative acceptable as it fulfills all the remedial objecti\.3.

Alternative No. 4 - On-Site Washing Treatment of Contaminated Soil/Off-Site Incinerationand Disposal of Soil Wash ResidualsThis alternative is preferred by the State because it fulfills all the remedial objectives andin addition minimizes waste. As the projected cost of this alternative is speculative, theState will re-evaluate this alternative as compared to alternative No. 3 when new costfigures become available.

CRITERION 9: COMMUNITY ACCEPTANCE

Comments in writing were received from four parties, the State of Colorado, the City ofCommerce City, one of the Potentially Responsible parties, and a trust set-up by the samePRP. The City and others who attended the August 9, 1990, pubic meeting were inagreement with EPA's preferred and contingency remedy.

The former property owner and the trust set-up by the former prope.rty owner believe thatcapping will lequately remedy the health risk presented by the site.

Specific comments received by the EPA are listed and responded to in the ResponsivenessSummary (Appendix B).

30

Alternative No. 1 • No ActionThe community would prefer an alternative that reduces the risk present at the COC area.

Alternative No. 2 - Capping/Institutional ControlsCommunity acceptance of capping is expected to be greater than for no action but less thanthat for a treatment alternative. However, one Potentially Responsible party indicated thatcapping would be the least expensive method of addressing the problem.

Alternative No. 3 - Off-Site Disposal of Residuals and SoilsAlternative No. 3 would be acceptable to the local community and the City of CommerceCity. Contaminants would be removed, and the health threat would be reduced such thatcertain uses of the land would be permissible.

Alternative No. 4 - On-Site Washing Treatment of Remaining Contaminated Soil/OfT-SiteIncineration and Disposal of Soil Wash ResidualsIt was indicated that this alternative would be preferred by the City of Commerce City sincecontaminants would be removed, and the health threat would be reduced to permitindustrial use of the land.

DC The Selected Remedy

Based on consideration of the requirements of CERCLA and the NCP, the detailedevaluation of the alternatives, a statutory preference for treatment, and public comments,EPA has selected Alternative No. 4 on-site soil washing of contaminated soil/off-siteincineration and disposal of soil wash residuals.

Specifically, the selected remedy is composed of the following elements:

Excavation of surface soil contaminated above the action levels listed for theprimary contaminants of concern in Table 7.

Soil washing of the excavated soils in an on-site treatment unit to the actionlevels listed in Table 7.

Off-site incineration of soil washing wastewater.

Replacement, grading, and re-vegetation of the area.

Excavation of the approximately 14,000 CY of contaminated surface soil will beaccomplished using standard construction implements (backhoes, bulldozers, etc.). Theexcavated soil will be placed in a hopper on the soil washing unit. The soil washing unitwill likely be mounted on flat-bed truck trailers and be composed of several washing andsoil separating units. The soil is separated into various size particles to simplify the washingprocess and increase the overall efficiency. Typically, the very fine (small) panicles are notwashed very efficiently or separable from the wastewater due to their physical characteristicsand are taken off-site for incineration.

31

The remaining products from the soil washing process are the larger soil panicles treatedto action levels, and the waste water. The treated soil will then be replaced on-site and re-vegetated. The alternative would take approximately 9-12 months to implement and 2-3years to complete. The estimated present worth cost is $4,490,734. Annual O&M costs areexpected to be $20,000 per year.

Because hazardous material may remain on-site above health base levels for a land use notanticipated, a Public Health Evaluation and will be performed every 5 years for the purposeof Devaluating the hazards posed by the site and assuring that the remedy remainsprotective.

The public will likely observe some excavation activities and increased truck traffic near52nd Avenue and Dahlia Street under this remedial effort. There will also likely beadditional fencing, storage of equipment, and some decontamination activities (truckwashing) visible from Dahlia Street.

Land Disposal Restriction Treatability Variance for the Selected Remedy

Alternative 4 concerns excavation of soil to be treated by soil washing and placement of theclean soils back to the place from which it was excavated. It also requires that thecontaminated soil washing wastewater resulting from the soil washing process be removedfrom the site, incinerated, and placed in a landfill off-site. A treatability variance isrequired when the soils treated by soil washing are replaced on-site. The resulting wastewater will be largely a mixture of highly contaminated (over 1,000 mg/O fluids, silts, andclays and will be taken off-site for incineration and disposal, as required by BDAT forCalifornia list fluids.

Alternative 4 is the selected remedy premised upon the results of treatability studies whichprovided technically sound reasons to believe soil washing will perform effectively. Thisinnovative technology has not been tested on-site and treatment standards are not availablesince actual performance data is not available to indicate that LDR treatment standards canbe meet consistently for all soils and debris. Though it is believed soil washing will achievereduction of contamination to levels demonstrated on Table 7, it is necessary to seek atreatability variance due to the absence of performance data.

The need for the treatability variance resulted from a determination that restricted RCRAwastes were present on OU5 which were compared with the Superfund constituents ofconcern. The alternatives were evaluated to identify if "placement" would occur todetermine if the technology will attain LDR treatment standards, or if necessary, alternativetreatment levels established by a treatability variance. The presence of restricted RCRAwastes, the need for placement, and the decision to employ soil washing resulted in theneed for a treatability variance for this selected alternative. During implementation of thisremedy periodic analysis using the appropriate testing procedure will be undertaken toensure alternate treatment levels for the BDAT constituents requiring control are beingattained and thus can be land disposed without further treatment.

32

Remediation Goals

The excavation of the contaminated soils above the health based action levels listed inTable 7 will be guided by sampling during excavation, and accomplished through the useof standard construction equipment. The soil will be treated to the treatment levels listedin Table 8, which represents a combination of health based action levels and treatabilityvariance action levels for the chemicals of concern, which ever is more stringent.

The intention of the remediation effort is to return the area to industrial use as plannedfor by the City of Commerce City. This can be accomplished, as described in the Summaryof Site Risk section of this document, by excavation and treatment of dieldrin andheptachlor contaminated soils to the action levels listed in Table 7 (and repeated below inTable 8). However, in compliance with LDRs and the preamble of the NCP with respectto the use of treatability variances at Superfund sites, the treated soils cannot be replacedon-site until the chemicals of concern have been treated to treatability variance levels.Health based action levels for dieldrin and heptachlor are more stringent than thetreatability variance levels, and will therefore be used. However, the soils contaminatedwith the remaining chemicals of concern will be treated to the treatability variance levelsindicated in Table 8 prior to replacement on-site.

The wastewater resulting from the soil washing process will be a mixture of solvents, silts,and fine clays, all contaminated above 1,000 mg/£ HOCs. Since this fluid is a LDR"California list" waste which requires incineration prior to disposal, the remedial action willbe performed accordingly.

Ground water on-site will be monitored for thirty years and a Public Health Evaluation(PHE) will be performed every five years following remediation. The net present worthfor the selected remedy is $4,490,000 and implementation will take approximately 9-12months.

X. Statutory Determinations

EPA's responsibility at Superfund sites is to select and implement remedial actions that areprotective of human health and the environment. In addition. Section 121 of CERCLAprovides several other statutory requirements and preferences. These statutes specify thatthe selected remedial action for the site must comply with applicable or relevant andappropriate environmental standards established under Federal and State environmentallaws unless a waiver is granted. The selected remedy must also be cost effective and utilizepermanent treatment technologies or resource recovery technologies to the maximum extentpracticable. The statute also contains a preference for remedies that permanently orsignificantly reduce the volume, toxicity, or mobility of hazardous substances. The followingsections discuss how the selected remedy for Sand Creek OU5 meet these statutoryrequirements.

33

TABLES

TREATMENT LEVELS

Compound

Dieldrin

Heptachlor

Arsenic

Qiromium

Chlordane

2,4-D

4,4-DDT

Action Level Rational

0.155 ppm Health Based

0.553 ppm Health Based

90-99% reduction Treatability Variance

0.5-6.0 (TCLP) Treatability Variance



0.5-20 (TWA) Treatability Variance

TCLP Toxicity Characteristic Leaching Procedure.TWA: Total Waste Analysis.

34

1. Protection of Human Health and the Environment

This remedy will reduce the direct contact threat currently posed by soils and will minimizethe possibility of future adverse effects on ground-water quality by treatment of the mostconcentrated sources of waste above the water table and restricting the area to industrialuse through institutional controls. There are some short-term risks associated with theselected remedy during soil handling operations, but these can be minimized with protectiveand preventative measures such as dust control measures.

2. Attainment of ARARs

Remedial actions at Sand Creek (OU5) will be undertaken in accordance with all applicableor relevant and appropriate requirements (ARARs).

Any regulation, standard, requirement, criterion, or limitation under any federal or stateenvironmental law may be either applicable or relevant and appropriate to a remedialaction, but not both.

Criteria, advisories and guidelines that are not law may be used to ensure protectivenessin the absence of ARARs, or when ARARs are not sufficient. These criteria, advisories,and guidelines fall in the "to be considered" (TBC) category and can be used to ensureprotection.

ARARs may be classified into three general categories:

o Chemical-specific - related to the level of contamination allowed for a specificpollutant in various environmental media (i.e., soil, water, and air),

o Location-specific - related to the presence of a special geographical (e.g.,floodplain or wetland) or archeological area at or near the site, and

o Action-specific - related to a method of remedial action identified as analternative for the site (e.g., disposal requirements or incineration standards).

The selected remedy of on-site soil washing of contaminated soil/off-site incineration anddisposal of soil wash residuals would comply with all applicable or relevant and appropriatechemical-, location-, and action-specific requirements (ARARs). The primary ARARspertinent to the selected remedy are summarized below.

o Chemical-specific ARARs

Land Disposal Restrictions - Threshold concentrations for treatabiliryvariance for Alternative No. 3. .

BOAT for all alternatives.

35

o Location-specific ARARs

None

o Action-specific ARARs

Federal

A PHE must be performed at least every 5 years (CERCLA 121(c))

Occupational Safety and Health Act (OSHA)

The requirements of 29 USC Sections 651-678, and 29 CFR 1910.120 whichregulates worker health and safety, must be followed.

Land disposal restrictions 40 CFR 268 Subpart D.

State of Colorado

CRS Section 25-123-101, et. seq. must be adhered to maintain compliancewith the State of Colorado noise abatement requirements.

6 CCR 1007-3 Part 99 will need to be followed. This regulation requiresnotification of hazardous waste activities when hazardous waste is generated.

The manifest requirements of 6 CCR 1007-3 Part 262 Subpart B must befollowed for off-site transportation of hazardous waste.

The pre-transport regulations of 6 CCR 1007-3 Part 262.30, .31 and .33 mustbe adhered to for off-site transportation of hazardous waste.

An EPA identification number must be obtained for transporting of hazardouswaste per the requirements of 6 CCR 1007-3 Part 263.11 (A).

CCR 1001-3 Section VIB will be followed to regulate air emissions.

Appendix A presents the ARARs and TBCs for Sand Creek OU5. The ARARs as theyare pertinent to each of the four alternatives noted in the last column of the table.

3. Cost Effectiveness

The selected remedy is cost effective in mitigating the risk posed by contaminated soils ina reasonable period of time. .To provide further assurance that cost effectiveness is pan ofthe choice of remedial action, a cost benefit analysis will be performed as part of the resultsof the pilot test. The selected 'remedy effectively and permanently reduces contaminationto acceptable levels.

36

4. Utilization of Permanent Solutions and Alternative Treatment Technologies orResource Recovery Technologies to the Maximum Extent Practicable

US EPA and the State of Colorado believe the selected remedy represents the maximumextent to which permanent solutions and treatment technologies can be utilized in a cost-effective manner for the final remedy at the Sand Creek site. Of the alternatives that areprotective of human health and the environment and comply with ARARs, US EPA andthe State have determined that the selected remedy provides the best balance of trade offsin terms of long-term effectiveness and permanent reduction in toxiciry, mobility or volumeachieved through treatment, short-term effectiveness, implementability, cost, also consideringthe statutory preference for the treatment as a principal element and considering state andcommunity acceptance. .

5. Preference for Treatment as a Principal Element

By washing the contaminated soil with solvents and water, the selected remedy satisfies thestatutory preference for remedies that employ treatment of the principal threat whichpermanently and significantly reduces toxicity, mobility or volume of hazardous substancesas a principal element.

Responsiveness Summary

The Responsiveness Summary is found in Appendix B of this document.

37

TABLE IARARs FOR SANO CREEK OU5

CONTAMINANT SPECIFIC ARARs AND TBCs

Standard. Requirement,Criteria, or LMUUon CMatfon : toscripllon

AppacaMaorRelevant andAppropriate Comment

Appliesto

Alternative

Federal ARARi

National Primary Drinking Water 40 CFR Part HIStandard*

LOR Tieatmenl Standards

DWdrin

40 CFR 148

40 CFR 148 P037

Establishes health-based standards lor No/Nopublic water systems (maximumconlaminanl levels)

Establishes BOAT treatment standards lor Yes/Yeswaslewaler and non waslewaler andeffective dales

Non waslewater waslewaler Yes/Yes

Total TCLP Total TCLP

0/13mg/lBOAT*Incneiation

OOl/mo/C NABiological liealmenl orwet air oxidation Mowedby carbon adsorption

Effective data 8/B/DO

'3.4

'3.4

Heptachlor 40 CFR 148 P059

Arsenic 40 CFR 148D004

Non waslewaler WaslewalerTolal TCLP Total TCLP0066 NA 00012 NA

0066(heplachkxepoxide)BOATIncineration

Non waslewalerTolal TCLPN/A 50

BOATViliificalion

0016

BOATBiological treatment orwet air oxidation fotowedby caibon adsorptionWaslewalerTolal TCLP50NA

BOATChemical piecipilalion

Yes/Yes Effective dale B/B/90 '3.4

Yes/Yes Effective dale 5/B/B2 nonwastewater.5/6/90 waslewaler

TABLE IARARs FOR SAND CREEK OU5

CONTAMINANT SPECIFIC ARAHs AND TBCs

Standard. Requirement.Criteria, or Limitation Citation

Federal ARAB*

Description

Applicable OfRelevant andAppropriate Comment

Applieslo

AN amative

ChkxdMie 40 CFR 148 V036

2.40 40 CFR 148 DOI6

DOT 40 CFR O06t

2.40 40 CFR V240

Non waslewaler WaslewaterTola) TCLP013 NABOATIncineiation

Tolal TCLP0 0033 NABOATBiological treatment wetair oxidation followed bycarbon adsoiplion

Yes/Yes Effective data 8/000 '3.4

Non waslewaler WaslewalerTolal TCLP10 NABOATIncineration

Yes/YesNo numberdevelopedBOATInc inera t ion orblodegredallon orchemical oxidation

Effective data 8/8/90 '3.4

Non waslewaler WaslewalerTolal TCLP0087 NA

BOATIncineration

Tolal TCLPNA00039 O.PTJOT0.0039 P Pt)OT0023 O.PDOO0023 P.PDOO0031 O.POO60031 P.PDOLBOATBiological treatment orwet air oxidation lolowedby carbon adsorption

Yes/Yes Effective data 8/B/90 3. 4

Non waslewaler Waslewaler Yes/YesTolal TCLP10 NABOATIncineialion

Tolal TCLP071 NABOATBiological liealmenl orwet air oxidation lolowedby caibon adsoiplion

Effective dale 8/8/90 '3. 4

TABIE 1AHARs i SAND CREEK OU5

CONTAMINAN1 tiltCtfIC ARAHs AND TBCs

Standard. Requirement.Criteria, or IWuiion CJUtoo Description

Applicable orRelevant andAppropriate Comment

Appkaslo

Alternative

Federal ARARs

Chromium 40 CfR 148 0007

Vasle Strewn Treatment/Disposal

aeon A* Ad

Clean Water Act.Section 30tB40 CFR 122 44(a)40 CfR 125.100

Clean Water ActSection 310

CAA. Bat 17340 CFR 52 21(fl

Non WaslewalerTotal TCLPN/A 50BOATChromiumreductionlolowed byslabtfitalion

WaslewalerTotal TCLP50 NABOATChromiumreductionlolowed byprecipitation anddewalering

Yes/Yes Effective dale WOO

Control ol direct discharges Irom pointsources via wa&le water liealiutmltechnologies.

Direct discharge ol treated waste streamsto on site suilace water.

Stationary sources which emil >tOOtons/yr. ol any legulaled polulanl.

No/No

No/No

No/Yes

No site runoff lo • surface water body viaditch. cuNert. storm sewer, or othermeans.

No on site surface water.

II emits > 100 Ions per year ol air polulanl.

TABIE I (continued)ARARs FOR SAND CREEK OU5

LOCATION SPECIFIC ARARs AND TBCs

Standard. Requirement.Criteria, or Limitation ClUUon Description

Applicable orRelevant andAppfopnale Commanl

Applieslo

Alternative

Federal ARAB?

National Historic Preservation Act

Mcheological and HistoricReservation Act

Historic Sties. Buildings and.tatiquilies Act

ish and Wildlife Coordination Act

itdangered Species Act

lean Water Act

oodplain

40 USC Sec. 470

40 CFR Sec. 6 30l(b)

36 CFR Part 800

16 USC Sac. 469

40 CFR Sec. 6301 (c)

16 USC Sec. 461 467

40 CFR Sec 6301 (a)

16 USC Sec 661466

40 CFR Sec 6 302(g)

16 USC 153150 CFR Part 20090 CFR Part 401

33 USC Sec. 125113/6

40 CFR 264 I B(b)40 CIM 141 5

Requites Federal agencies lo take inlo No/Noaccount the ellecl ol any Federatty-assisled undertaking or licensing on anydistrict, site, building, structure. 01 objectthai is included m or eligible lor inclusionin the National Register ol Historic Places.

Establishes procedures lo provide lor No/Nopreservation ol historical and archeologicaldata which might be destroyed throughalteration ol terrain as a result ol a Federalconstruction protect or a Fed. Hylicensed activity or program.

Requires Federal agencies lo consider the No/Noexistence and location ol Landmarks onthe National Registry ol Natural Landmarkslo avoid undesirable Impacts on eachLandmark.

Requires consultation when Federal No/Nodepartment or agency proposes orauthorizes any modification ol any streamor other water body and adequateprovision lor protection ol fish and wildkleresources.

Requires action lo conserve endangered No/Nospecies within critical habits upon whichendangered species depend. Includesconsultation with Department ol Interior.

Ofsifjii (ucilihus lo prevent washout ol No/Nohuiaiduus waste.

The remedy does not etlect any district,sue. building, structure, or object listed onor eligible for the National Register.

The remedy does not effect historical orarcheological data.

The remedy does not effect any NaturalLandmark.

Alternatives developed wi not modifysti earns.

No endangered species are present on theCOC site.

Not in lloodpldin.

TABLE I (continued)ARARs FOR SAND CHEEK OU5

LOCATION SPECIF 1C ARARs AND 1BC»

Standard. Requirement.Criteria, or llmttaliori Citation Description

Applicable orRelevant andAppcopnale Comment

Applieslo

Alternative

Federal ARAB*

Dredge « F* Requirements (Section404)Clean Water Act. Section 404 -

Executive Order on FloodplainManagement

Wilderness Act

40 Cf R. Part 640 CFR 264. Sutopart B

40 CFR 257 31 (a)16 DSC 661Executive Order 11988

40 CFR Part* 230. 23133 CFR Paris 320 330

Exec. Order No 11.968

40 CFR Sec. 6.302(b)Appendix A

16 USC Sec 113150 CFH 3S.I

Avoid adverse eltecls. minimize harm and No/Noavoid incompatible development.

Requires permits for discharge ol dredged No/Noor Itf material into navigable waters.

Requires Federal agencies lo evaluate the No/Nopotential eflecls ol actions they may lakein a floodplain to avoid, to the maximumextent possible, the adverse impactsassociated with diiecl and indueddevelopment ol a floodplain.

Administer federally owned wilderness No/Nouie<t lo leave it ununpacled.

Not in toodptabv

A permit is not required lor on siteCERCLA response aclions. butsubstantive requirements would be met ian alternative developed would involvedischarge ol dredged or M material intonavigable waters. This is not anticipated.

II an alternative developed thai would•fleet a toodplain this would beapplicable. Operable Unit No. 11s locatedoutside ol the 100-year loodplain.

No wilderness area on she or adjacent tosite.

National Wfcttle Reluge System 16 USC Sec 66850 CFR Part 27

Restricts activities within a National WildlileHeluye.

No/No No wilderness area on site or adjacent losite.

Scenic River Act

Coastal Zone Management Act

16 USC Sec 127140 CFR Part b.302(e)

16 USC Sec. 1451

Prohibits adverse eflecls on scenic river. No/No

Conduct activities in accordance with No/Noslate approved manayi-munl program.

No scenic river In area.

Area is not in coastal lone.

TABIE t (continued)ARARs FOR SAND CREEK OU5

LOCATION SPECIFIC ARARs AND TBCs

Standwd. Requirement.Criteria, or Limitation Citation Description

Applicable orRelevant andAppropnate Comment

Appliesto

Alternative

Federal ARARs

Wetlands Executive Older 1199040 CFfl. Part 6

Avoid impacts and construction Inwetlands, pieserve and enhance.'

Stale ARARs

Requirements lot Siting ol HazardousWast* Disposal Silas

Colorado Hazardous WasteManagement Regulations

Regulations Pertaining to Solid WasteDisposal Sites and Facilities

Colorado State Historical Society

6 CCR 10072, PI II.Sections 2.1. 2.4. and2.5

6 CCR 1007 3

6 CCR 1007 2.Sections I 3 2. 21.2 2.2 . 4 . 4 1 . 6 1

Sections 2460201.202. 211; Sections 24801 101.102. 103. 104.108

Geologic/Hydiologic conditions must Ves/Noassuie waste isolation bom exposurepathways lor 1000 years. Suing mustassute short and long term protection olhuman health and environment.

Siting is resliicled in vicinity ol recent Yes/Nolaulting. No hazardous waste disposalcan occur in a 100 year floodplaln.Disposal inlo or below surface water andground water is prohibited

Siting must maximize wind protection and Ves/Nominimize upslreani drainage area. No solidwaste disposal can occur in a 100 yearfloodpluin. Disposal into or below surfacewater and ground water is prohibited.Impoundment design Is controlled by asite's location in relation to the upper mostaquifer and by water quality in the aquifer.

Sites within stale or federal historic No/Nopieservaliun areas will be required topreserve historic character.

Applicable U an on-site hazardous wastedisposal laciMy to planned. NotAnticipated.

Applicable tf an on site hazardous wastedisposal facility la planned.

Applicable M on-stle solid waste disposalfacility Is contemplated..

No regulated sites.

Federal ARARs

TABIE I (continued)ARABs FOR SAND CREEK OU5

ACTION SPECIFIC ARARs AND TBCs

Standard. Requirement.Criteria, or LbwUiton • CJUMon Description

Applicable orRelevant andAppropriate Common!

Applieslo

Interim Treatment Standards lor Soiland Debris. TBC July 27. 1990

Occupational Safety and Health Ad . 29 USC Sec. 6S1 «78

Hazardous Materials TransportationAct

Hazardous Materials TransportationRegulations

Land Disposal Regulation

Capping

Land Treatment

Corrective Action lor Solid WasteManagement Units

49 use Sec. 1601tau49 CFR Parts 107.171-177 also 40iCFR 262

40 CFR 268. SubpartD. 55 FR 67604762.3/B/90

40 CFR 264 3IO(a)(b)40 CFR 264.117lo 12040 CFR 264.2M(b)

40 CFR 264 271. 273.276. 276. 282

Proposed regulation 55FR307U8

BDAT standards have not been developed TBClor the P and U wastes present in OU5soils.

Regulates worker health and salety.

Standards lor cap placement.

Yes/No

Regulates transportation ol hazardous Yes/Nomaterials.

Regulates movement and placement ol Yes/Nosoils.

No/Yes

RCRA hazardous waste being treated or No/Yesplaced in another unit.

TBC

Under 40 CFR Section 30038.retirements ol this Act apply lo alresponse acttvlUm under the NCR.

Applicable only * an aftemativa developedwould involve transportation ol hazardousmaterials.

Applicable lo wastes shipped off site.

II Alternative 2 selected.

II Alternative 3 selected.

2. 3. 4

•3. 4

'3.4

»'i. 3. 4

TABLE 1 (continued)ARARs FOR SAND CREEK OU5

ACTION SPECIFIC ARAHs AND TBCs

Standard. Requirement,Criteria, of Limitation CMalJon Descfiplion


Appliesto

Alternative

Stale ARARa

Rules and Regulations Governing theTransportation ol Hazardous MaterialsWithin Colorado

Colorado Noise Abatement Statute

Colorado Wildlife Enlorcemenl andPenalties

Wfcftfe Commission Regulations

General Closure

•lallonary Emissions Sources; GeneralXMitrofs (or remedwl activities

4 CCR 723 18.HMT 19

Sections 2512101,012.103. 104.105.106.108

Sections 33 6 101.102,103.104.105.108.109.110.111.113.114.118.117.119.120.124.126.128. 129. 130

2 CCR 406 0. Articles I.III. IV. V. VI. VII. VIII. IX.X. XI

6 CCR 10073. Pail264.111

5 CCR 1101 5. SectionIVO

5 CCH 1001 5. SectionIVO

Establishes sp« lie requirements lor the Yes/Notransportation ol hazardous matenals.especially legarding labeling andplacarding.

Establishes standards lor conliotting Yes/Nonoise.

Prohibits specific actions in order to Yes/Noprotect witdlile.

Establishes specific requirements lor the Yes/Nopiulection ol wildkle.

Colorado Hazardous Waste Management Yes/NoRegulations. Must minimize the need lorfurther maintenance; conliol. minimize oreliminate (to the extent needed lo protecthuman health and environment) the post-closuie escape ol hazardous wastes,hazardous waste constituents, leachale.contaminated rainfall, or wastedecomposition products to ground water,suitace water, or the atmosphere.

Source cannot cause emissions to exceed Yes/Noany attainment area ol any NAAQS.

Source cannot mlerlere with attainment Yes/Noanil fiiiiinlciiiincu ol any Stale NAAUS.

Applicable H hazardous material Is *3.4transported otl-rte.

Applicable lo aNemaUves thai would 92. 3. 4generate noise.

Relevant and appropriate lor protecting 12. 3. 4wildMe near the Me during constructionactivities.

Relevant and appropriate lor protecting *3. 3. 4wildkle near the sKe during constructionactivities.

COC generated and managed corrosive 12. 3. 4hazardous wastes and spiled commercialchemical products. COC generated andmanaged RCRA hazardous wastes afterNovember IB. I960.

COC site Is In a non attainment area. Thesite could be considered a major source Hit emits more than 100 Ions/year of CO orVOCs.

COC site is in a non-attainment area


ACTION SPECIFIC ARARa AND T8Cs

Standard. Requirement.Criteria, or Umilalton Citation Description

Applicable orRelevant andAppropriate Commanl

Appliesto

Alternative

Stale ARARs.

Stationary Emission Sources; Generalcontrols to remedial activities

Tank Closure

ConUbiM Closure

5CCR 10013. SectionUIO

SCCR tOOt 3. SectionH

SCCR 1001 -4. Section2A

6 CCR 10073 Part264187

6 CCR 10073 Part264.178

Closure ol hazardous waste 6 CCR 10073. Partmanagement facilities (MWMF): 264.1II

Minimize fugitive dust emissions. Yes/No

No emissions exceeding 20% capacity are Yes/Noalowed.

Design action to provide odor tree Yes/Nooperations.

AJ hazardous wastes and residues must Yes/Nobe removed horn tanks, discharge conliolequipment and discharge confinementslrucluies.

All hazardous wastes and residues must Yes/Nobe removed from containment system. ifany. Remaining containers, liners, bases,and soil containing or conl<iniinaied wilhresidues must be decontaminated orremoved.

General closure, as above. Includes Yes/Nowaste management lacfciies. waste pfes.surface impoundments and lank systems.

DemoMkx) and construction activities,storage and handkng operations, and haulroads.

Specific sources may have otherlimitations.

Commercial chemical products In u.^sbecome hazardous wastes when closurebegins. See dean closure requirementsfur generalor/Uansporter requirements.COC managed their hazardous wastes ontanks.

Commercial chemical products In tanksbecome hazardous wastes when closurebegins. See dean closure requirement]for generator/transporter requirements.

Closure performance standards.

#2. 3. 4

'2. 3, 4

'2. 3. 4

TABLE I (continued)ARARs FOfl SAND CREEK OU5

ACTION SPECIFIC ARAfla AND TBCs

Standard. Requirement.Criteria, or Limitation ClUIJon Description


Applieslo

Alternative

Stale AflAflg

Closing in place (capping) 6 CCR 10073.26OtO(a)

Part

6 CCR 10073.2t>4.3tO(b)

6 CCR 10073.264 301 (c)

Pan

Part

Closure ol HWMF: 6 CCR 1007 3. Part264 301 (d) and (e)

Design and conslrucl cover lo: Yes/No

Provide long term minimization olmigration ol liquids Ihiough the cap.

• Function with minimum maintenance.

• Piomole drainage and minimize eiosionor abrasion ol Hie cover.

• Accommodate selling and subsidenceto maintain the cover's integrity.

• Have a permeability less than or equal loIhe permeability ol ihe bottom knei ornaluial sub soils present.

Cap Integrity must be maintained and Yes/Norepaired as necessary. Leak detection,leachale collection, an ' . achale removalsystems must be operated andmaintained. Surveyed benchmarks mustbe protected and maintained.

Run on control must be designed and Yes/Noconstructed to prevent flow onto the capdunng construction. The peak dischargefront at least a 100-year storm must becontrolled.

Runoff control must be designed and Yes/Noconstructed lo collect and control Iherunofl (rom a 100 year 24 hour storm, bothduiing cap construction and maintenance.Collection/holding facilities associated with 'run on and lun oil control must liedubiijned lo expediliously mamlaincapacity alU-r ilonns.

Spilled commercial chemical products aremixed with »oto. Design, construction andmonitoring requirements described hereinalso apply lo caps placed over bedwastes.

«2

Also applies lo run on control during fixedwasle disposal eel construction

Also applies to fixed wasle eel. liner andcap construction.

«2

<a>2

10

TABIE I (conlinued)ARARs FOR SAND CREEK OU5


Standard. Requirement.Criteria. or limitation ClUtion Description


Appliesto

Alternative

Stale ARARs

ft CCR 10073. Part During construction, cap systems musl be264.303(a) Inspected lor uniformity, damage and

imperfections. Synthetic membranes muslbe inspected to ensure light seams andioJnls and the absence ol tears, puncturesor blisters. Soil based and admixed capsmust be inspected lor holes, or otherstructural nonconformities thai may causeany increase m the peimeability ol the cap.

Yes/No Also applies to bed waste eel. Knar and @2cap construction.

6 CCR 10073. Part264.309

Closure ol HWMF: 6 CCR 10073. Part264.81(4 Part 264 iU)

Part 264 97|a)

The exact location and dimension. Yes/Noincluding depth, ol disposal cells musl beshown on site maps relative topermanently surveyed benchmarks Thecontents ol each eel and location ot eachhazardous waste type musl also beshown.

Implement a ground water detection Yes/Nomonitoring program to ensure lhal thegiound water protection standard iscomplied with. Concentrations olhazardous constituents cannot exceed:

• table values, or

• background levels, where no table valueis specified.

Ground water monitoring musl consist ol Yes/Noa sufficient number ol wels withappropriate depths and locations to yieldsamples capable ol deteimining background walei quality add water qualitypassing a point ol compliance.

Also applies to bad waste disposal celland caps.

Witt also apply to waste treatment/on sitedisposal alternatives like bation and soilwashing or Incineration. H residues cannotbe deksled.

»2. 3. 4

Existing we* Idd wi need lo be reviewedduring remedial design.

12. 3. 4

11



Standard. Requirement,Criteria, or Limitation Ctutton Descnplion


Applieslo

Alternative

Slale ARARi

Closure of HWMF:

dosing In place (capping)

Clean Closure Removal with off sitedisposal

Part 264.97(c). (d) and

Part 264 97(h)

6 CCR 1007. Part 2.Sections 2.4. 1-2.4.5

6 CCR 1007 2. Part 2.Section 2.3 7

6 CCR 1007 2. Part 2.Section 2.4.H

6 CCR 1007 2. Part 2.Sections 2.4 9. 2 4 10

6 CCR 10073. Part264.117

6 CCR 10073. Part264.111

5 CCR lOOt 9. SectionIIDI and 2

Ground water weds must be cased in amanner ensuring wen Integrity, andsampled using methods ensuringsample/analysis integrity.

Ground water sail.,. .1 must be collectedand analyzed at a frequency that allows forvakd statistical analysis.

Design tacitly to prevent long term adverse•fleets on ground water, surface water, airquality, public health, and the environment.

Design mnotf control system withsufficient capacity lo prevent adverseeffects on ground water, surface water, airquality, public health, and the environment.

Close facility to assure prevention ol long-tarn adverse effects.

Monitor ground water, surface water, andviiiu quality control Uuiiig construction.

iisl closure use of property as10 prevent cover damage.

Restrict inecei-.

General closure, as above.

VOC source can emu . more than 450ttis/hour 01 3000 Ibs/day ul VOCi willimitapplying reasonably available conlioltechnology (MAC I)

Yes/No

Yes/No

Yes/No

Yes/No

Yes/No

Yes/No

Yes/No

Yes/No

Yes/No

Existing we! fMd and any additional waitplaced at the ail* must be assessed.

Applicable lo ground water sampling al thesite.

Part 2 of the Slale solid waste regscontains siting and design criteria forhazardous waste disposal sites bo* alterJuty I. 1961.

«2. 3. 4

»2. 3. 4

'2. 3. 4

»2

12

To estimate son volumes, containmentconcentrations above which cleanup witoccur are set al background or the valueconespondmg lo on* excess cancer Inone million cases.

Soils al COC also have VOCs in themDosiijn lo use RACT is made alter ahealth based risk assessment using a"

TABl E 1 (continued)ARAHs FOR SAND CREEK OUS


Standard. Requirement.Criteria,or UmMalion Citation Description

Slale ARARs

Applicable orRelevant andAppro--riale Comment

Applisslo

Alternative

Notification

Manifests

« CCR 10073. Part264.114

fi CCR 1007 3. Part 99

6 CCR 10073. Part262. Subpart B

Pro-Iran sport Requirements 6 CCR 10073. Part262.3. .31. and .33

Dispose ol or decon al tacitly equipment Yes/Noand structures by removing al hazardouswastes and residues.

Any person who generates or transports Yes/Nohazardous wastes must fete a noiidcaiionol hazardous waste activity belorebeginning such activity.

A manifest must be prepared by a Yes/Nogenerator belore * Is ottered lortransportation olf site. The manliest mustidentify the lacity permitted lo handle thewaste described thereon, and maydesignate an attemalive laofcly. Themanifest format must be consistent withthose offered by the consignment(destination) stale or generator stale,respectively. Generator must sign themantfesl. obtain the signature ol the initialtransporter, retain one copy, and giveremaining < -s to the miltal transporter.

A generalui most package the waste In Yes/Noaccordance wrth PUG or DOT regulationsMI 40 CPR Parts 173. 176 and 179 Eachpackage must be labeled or marked Inaccordance with PUC or DOT regulationsin 49 CFR Part 172 For containers ol HOgallons or less, maikings must comply withrequirements ol 40 CFR 172.304. Thegeneialoi must placard, or oiler placardslo the MUU..I liansporter. in accordancewith 49 CFH Hart 172 SubpaM F.

II lank content*, containers andcontaminated soils aie being shipped oil-site as part ol closure activities.

For oil site transportation.

*2. 3. 4

3. 4

3. 4

For oil site transportation.

I.I

TABLE I (continued)ARARs FOR SAND CREEK OU5


Standard. Requirement.Criteria, or LbniUlion ClUUon Description


Appliesto

Alternative

Slate ARAfla

Transportation

Clean Closure (lemoval with oil sitedisposal)

6 CCR 1007 3. Part263.11(a)

6 CCR 10073. Part26320

Transportation 6 CCR 10073. Part263. Subpart C

Clean closure (removal with liealmenlin tanks)

6 CCR 10073. Part26419l|a)

A transporter must not transport Yes/Nohazardous wastes without an EPA IDnumber.

A transporter may not receive hazardous Yes/Nowaste from • generator unless H isaccompanied by • manifest Thetransporter must sign and dale themanifest, acknowledging acceptance, andmust leave on copy with the generator.Upon delivery to the designated lacikty.the transporter must obtain the dale ofdelivery and the signature ol theowner/operator. The transporter mustretain one copy ot the signed manifest.

II a discharge ol hazardous waste occurs Yes/Nodurmg transportation, the transporter mustlake appropriate Immediate action toprotect human health and environment.1 he transporter must report the dischargeand ultimate resolution to PUC. DOT andCOM. The transporter must clean up thedischarge or lake other appropriate actionso that the discharge no longer presentsa hazard to human health or environment.

Tanks must have sufficient shell strength. Yes/Nofoundation slienglh. structural support.and lor closed tanks, pressure controls toassure that they do not collapse orrupture.

For off tile transportation.

For oft site transportation.

For oft site transportation. *3. 4

Soils wil be milled with fixing agents orsod washing solvents in tanks.

14

TABLE 1 (continued)ARARs FOR SAND CHEEK OU5


Standard. Requirement,Criteria, or Limitation Citation Description

Applicable orRelevant andAppropriate Cornmenl

Applieslo

Alternative

Stale ARARs

6 CCR 10073. Pad264.1S2(a}

Wastes and other material (e.g.. treatmentreagents) that are incompatible with thematerial ol construction of the lank mustnol be placed in the lank, unless rt isprotected Irom accelerated corrosion,erosion, or abrasion Ihiouijh the use ol aninner liner or coaling i. ..I is compatiblewith lank contents and that is tree olleaks, cracks, holes, or other deterioration,or through alternative means o( protection.

Yes/No Applicable V incompatible wastes areplaced in tanks.

Clean ctosuie (removal with liealmentIn tanks)

8 CCR 10073. Part264IB2<b)

6 CCR 10073. Part264.l94(a)(l 3)

6 CCR 10073. Part264.tU4(a)(4)and(5)

6 CCR 10073. Part2 6 4 3 4 1 ; P a r t100 22|c)(3) and (4)

Overfilling must be prevented by including Yes/Nocontrol methods or. lor uncoveied tanks,maintenance ol • sufficient tree board loprevent overtipping by wave or windaction, or by precipitation.

Daily Inspections must be conducted on Yes/NooverUkng control equipment, lank Integrity,monitoring equipment, and the tevci olwastes in uncoveied tanks.

Weekly inspections must be conducted on Yes/Nothe construction materials ol above groundtanks and ot the area around them lorobvious signs ol lank deterioration andleakage.

Analyze the waste leed. Yes/No

Applicable V waste b placed In tanks.

Applicable H wast* ia placed In tanks

>pplicab!e H waste to placed In tanks.

Additional waste analyses wi be neededdunng remedial design.

TABLE 1 (continued)AHARs FOR SAND CREEK OU5


Standard. Requirement.Criteria, or UrmUlion CMaUon Description


Appliesto

Ah amative

Clean closure (removalIncineration on -site)

with

Clean closure (removal withincineration on site)

Part 264.340 No further requirements, except waste No/Noanalyses and closure, apply to Incineratorsthat only burn wastes listed as hazardoussolely by virtue ol the characteristic orIgnJtabiUy. coaosMly. or both; or thecharacteristic ol reactivity it the wastes wilnot be burned when other hazardouswastes are present in the combustionzone; end <• the waste analysis shows thatthe wastes contain none of the hazardousconstituents listed In Appendix VIII whichmight reasonably be expected to bepresent.

Performance standards lor incinerators:

6 CCH 1007 3. Part • Achieve a destruction and removal Yes/No264.343(a)(l) efficiency ol 99.99 percent for each

principal organic hazardous constituent Inthe waste <eed and.

• 999999 percent for F020. F02t, F022. Yes/NoF023. F026. F027 wastes.

6 CCR 10073. Part264 343(a)|2) and Part264.343(b)

6 CCR 10073. Part264 343(c) also. 5 CCR1001 8. Section III C I

Hazardous wastes al COC are Isled forloxKity and acute toxicity. not IgruUbily orcorrostvUy alone.

Applicable if waste Is Incinerated

II waste Is a F020. F02I. F022. F023.F027.or F029 waste.

• Reduce hydrogen chloride emissions loIB kg/hr or t percent of the HCI in theslack gases before entering any pollutionconliol devices.

- Emissions of paniculate matter cannot Yes/Noexceed 0.08 grains per diy slandaid cubicfool when collected for the amount ofoxygen in the slack gas.

6 CCfl t007 3. Pail Opeiate witluti specilieil tiiuils duiiny Yes/No264.34b(c) slaitup diid

General capacity kmilalion also applies lonew incmerHtion sources.

TABLE I (continued)ARARs FOR SAND CREEK OUS


Standard. Requirement.Criteria, or Umltallon CJUUon Description

AppicableorRelevant andAppropriate Comment

Applieslo

AlleiTialive

Slate ARARs

Clean closuie (removal withbicjneraiion on-sile)

Clean closure (removal withbtdneratton on-sile)

Part 264.345(d)

Part 264.374

6 CCR 10073. Part264347(a)

Part 264.347(b)

Part 264.347(c)

Part 264 351

5 CCR lOOt 3. SectionV1B

5 CCR 1001 3. SectionIDA

Control fugitive emissions from the Yes/Nocombustion zone.

Monitoring ol various parameters during Yes/Nooperation ol the incineialor is required.These parameters include:

• Combustion temperature. Yes/No

• Waste leed rale.

• An Indicator ol combustion gas velocity-

• Cartoon monoxide.

• Waste and exhaust emissions uponrequest.

Daily visual inspections ol incinerator and Yes/Noassociated equipment.

Operate with an automatic leed culofl Yes/Nosystem; inspect weekly.

At closure, all hazardous waste and Yes/Noresidues, including ash. scrubber water,and scrubber sludge must be removedbom the site.

Sources can emit no more than 2 Ions/day Yes/Nool suNur dioxide.

Comply with particulale kmilalions. Yes/No

Speciftc sources may have otherkmilalions. Us* best available controltechnology.

Functions ol heal Input. Applies to theoperation ol lud burning equipment.

\f

Standard. Requirement.Criteria, or Limitation Citation

TABLE t (continued)AflARs FOR SAND CREEK OU5


Description

Applicable ofRelevanl andAppfopriale Comment

Appliesto

Alternative

Sine ARARs

Emission of mauls from Indneralors

On site disposal ol Irealmenl residues 0 OCR 1007-3. Part260.22(a)

On site disposal ol treatment residues 6 CCR 1007 2. Part 2.Section 2.4.1 2.4.5

Part 2. Section 2.4 6

Part 2. Section 2.S.3

Part 2. Section 24.9.2.4.10

On site disposal ol treatment residues Part 2. Section 2.4.8

Part 2. Section 2.47.2 5 5

Colo. Air Quality Control Commission TBCRegulation IB. Section 6.

Ambient air quality standards lor Stale ol TBCMassachusetts. Currently used asguideline lor Stale ol Colorado.

A demonstration must be made that the Yes/Nowaste no longer meets any ol the criteriaunder which it was ksied as hazardousunder Part 261. Subpart O.

Design facility to prevent long-term adverse Yes/Noeffects on ground water, surface water, airquality, public health, and the environment.

Protect the (unction and integrity ol liner(s) Yes/No

Isolate wastes lor 1000 years. Yes/No

monitor ground water, surface water, and Yes/Noprovide quality control during construction.

Close facility to assure prevention ol long- Yes/Noterm adverse effects.

Design leachate and runotl control system Yes/Noto prevent adverse effects on groundwater, surface water, air quality, publiclicallh. and (lie environment.

The ambient air quality standard (or lead Ist .5 ug/m (avg. monthly modeled standard).

The Slate has metals emissions guidelinesol 0.0003 ug/m lor cadmium. 0.69 ug/mchromium, and 0.18 ug/m lor nickel.

II the waste Is tstad wHh coda V. thepetition must demonstrate that theresidues do not contain the constituent(app. 7) that caused It to be listed, usingthe appropriate app. 7 test method: or thewaste does not me«t the criterion ol Part261.1 f(a)(3). considering the factors in 40CFH Parts 26l.11(a)(i) through (xi).

Part 2 ol the Stale aoKd waste regscontains stung and design criteria forhazardous waste disposal sites buM alterJuly 1. 1981. These requirements areapplicable M a luuardous waste disposalsite Is butt.

III

TABLE 1 (continued)AflAHs FOR SANO CREEK OUS

ACTION SPECIFIC ARAB* AND TBCs

Standard. Requirement.Criteria, or UmttaUon_ Glutton Description


Appliesto

Alternative

Slate ARARs

« CCR 1007 3. Part264301(a)(t)

On site disposal o( treatment residues 6 CCR 10073. Part264.301 (a)(2)

6 CCR 10073.264.30t(c)(d)(e)

Part

Use kner which prevents waste migration Yes/Nokilo adjacent soil, ground water, surfacewater, or liner ttsefl during the active kfe olthe landliN. including closure.

Design and construct Kner lo preventlaiture due la pressure gradients, contactwith wastes, climate, and stress olInslalalion and daily operations.

The kner must be placed on a foundationthai wM provide support and resistance lopressure gradients above and below theliner, lo prevent failure due lo settlement,compression or uplift.

The kner must cover al areas likely lo bein contact with waste or leachate.

Instal leachale coleclion system above Yes/Nothe kner that the depth ol jeachate on thekens does nol exceed thirty centimeters(one fool). The system must beconstructed of materials that arecompatible with wastes and leachale inthe landlil. and thai have sufficientstrength lo prevent colapse underpressures exerted by overlying wastes,caps and equipment. The system must bedesigned and operated lo (unction withoutclogging.

Construction run-on and runoff control Yes/Nosystems capable of handling (he peakdischarge ol a 100-year 24 hour slorm.Associated collection and holding facilitiesmust be designed to expediiiouslymaintain system capacity alter storms.

I!)

TABLE 1 (continued)ARAB* FOR SAND CREEK OU5


Standard. Requirement.Criteria, or Limitation Citation Description


Appyes10

Alternative

Slale ARARs

6 CCR 10073. part264.303(a)

On she disposal ol treatment residues 6 CCR 1007*3. Part264.309

6 CCr Part 264.90SubpartF

6 CCR Part 264.312.264.313.317

6 CCR 10073. Part264310(a)

During conduction, liners must be Yes/NoInspected lor uniformity, damage andimperfections. Synthetic membranes mustbe inspected to ensure tight seams andJoints and the absence ol tears, puncturesor blisters. Soil based and ad mixed capsmust be Inspected.

The exact location and dimensions Yes/NoIncluding depth, ol disposal eels must beshown on stte maps relative lopermanently surveyed benchmarks. Thecontents ol each eel and location ol eachhazardous waste type must also beshown.

Conduct a ground water monitoring and Yes/Noresponse program, including correctiveaction, as required.

Comply with special requirements lor Yes/Noignilable, reactive. Incompatible wastes,and F020. F021. F022. F023. F026. F027wastes.

Design and constiucl cover lo: Yes/No

• Provide long term minimization olmigration ol liquids through the cup.

• Function with minimum maintenance.

• Promote diainage and minimize erosionor abrasion ot (he cover

• Accommodate settling and subsidence lomaintain Iliu cover's inluijiily.

Substantive standards lor Inspection areapplicable.

TABLE 1 (continued)AHARs FOR SAND CREEK OU5


Standard. Requirement.Criteria, or LMUIIon Citation Description


Applesto

Alternative

Stale ARARs

On site disposal of treatment residues 6 CCR 1007-3. Part264.3 tO(b)

6 CCR 1007 2. Section2.1.2

6 CCR 1007 ? Section42

• Have a permeability less than or equal lothe permeability ol the bottom kner ornatural subsets present.

Cap Integrity must be maintained andrepaired as necessary. Leak detection,leachale colectton. and leachale removalsystems must be operated andmaintained Surveyed benchmarks mustbe protected and maintained

Disposal sites shal comply duringoperations with applicable rules andregulations ol the water and air qualitycontrol commissions, and with localxoning laws and ordinances.

Ground water shal be protected frompoNulion by leachale. Permanentdiversions shall control run-on and runoffdom the tOO year event. Facility designshal address geologic hazards. Groundwater monitoring wet* shal be designedin accoi dance with applicable staleengineer's rules and regulations. Sufficientamounts ol cover must exist on-site or bereadily available ort site Cap design mustdemonstrate that two feel of cover Issufficient to establish vegetation andisolate wastes alter closure. Adequateamounts ol water must be available forconduction

Yes/No

Yes/No

Yes/No Compliance with these design standardsIs demonstrated by providing the datacalled for In 6 CCR 1007 2. Sections 43through 4.8.

TABit \ (continued)ARARs FOR SAND CREEK OU5


Standard. Requirement.Criteria, or Limitation Citation Description


Appliesto

Alternative

State ARAB?

On-site disposal ol treatment residue*

6 OCR 1007 2. Section2.1

6 CCR 1007-2. Section2.2

Chemical. Physical and BiologicalTreatment (Soil Washing andBiological Treatment)

General requirements lor IgnHaWe.reactive, or incompatible wastes •

40 CFR 265.400

40 CFR 265.17(b)

Waste pUe 40 CFR 264 251

Operations shal control odors and prevent Yes/Norodent and insects by being adequatelycovered. Nuisance conditions shal beminimized Wastes shal be placed asdensely as practicable. Disposal sitesshal be adequately fenced.

During operations, run-on shal be diverted Yes/Notorn the working area. Ground water shalbe monitored regularly upgradienl anddowngraded ol the facility. Operationsshal cease when high wind warnings areverified. Hazardous wastes and sludgesshal not be disposed during operations.

Chemical, physical or biological treatment Yes/Nool hazardous waste must comply withSection 265.17(b).

Where speciftcaly required by othersections, of this part, the treatment,storage, or disposal ol ignitable or reactoewaste, and the mixture ol commingling olincompatible wastes, or incompatiblewastes and materials, must be conductedso that it does not:

Produce unconlroled toxic mists, fumes,dusts, or gases in sufficient quantities tothreaten human health; produceuncontrolled flammable lumes or gases insufficient quantities to pose a risk of tire orexplosions.

Use a siiujle liner and leachale collection Yes/Nosystem.

These are minimum operating standardsmandated by the atalue.

these are additional operation standardsfor solid waste disposal sites.

Would be applicable V biological or soilwashing treatment I* performed.

Would be applicable H biological or soilwashing treatment to preformed.

Would be applicable il waste is held in awaste pile piior to treatment.



Standard. Requirement,Criteria, or UmiUUon Citation Descriplion


Appliesto

Alternative

Slate ARARs

Transportation (ON site) 40 CFR 107.17M77

November IS. 1965Federal Register

Standards a\AppHcable to iterators 40 CFR Part 262ol Hazardous Wastes

Requirements for Miscelaneous Units 5 2 F R 4 6 9 4 6(December 10. 1987)Subpart x ol Part 264

Regulates transportation ol hazardous Yes/Nomaterials (Department ol Transportation)

Superlund Ofl site Policy Yes/No

Regulations lor Transporting Hazardous Yes/NoWastes:

Before an owner or generator disposes olany hazardous waste, he must obtain •detailed chemical and physical analysis ola representative sample ol the waste. Ala minimum, this analysis must contain althe Information which must be known to(real, store, or dispose of the waste inaccordance with Part 265 and Part 268.

A RCRA permit Is not required for on site Yes/NoCERCLA action; however, therequirements ol the permit must b met.The Subpart x permit requirements includebut is not limited to:

(a) Prevention ol any releases that mayhave adverse effects on human health orthe environment due to migration of wasteconstituents in the ground water orsubsurface environment, considering:

(t) The volume and physical and chemicalcharacteristics of the waste in the unit,including its potential for migration throughsoil, liners, or other containmentstructures;

(2) The hydiologic and geologicchaiaclenslics of the unit and surrounding

'3.4

Applicable H waste Is treated In amiscellaneous unit.

State ARAR?

TABLE t (continued)ARAHs FOR SAND CREEK OU5

ACTION SPECIFIC ARARs AND TBCa

Standard. Requirement.Criteria, or UniUlion Citation Description


Appliesto

Alternative

area;

(3) The existing quality of ground water.Including other sources ol contaminationand their cumulative impact on the groundwater;

(4) The quality and direction of ground-water flow;

(5) The proximity to and withdrawal ralesol current and potential ground-waterusers;

(6) The patterns of land use In the region;

(7) The potential (or depoaj on ormigration of waste constituents Intosubsurface physical structures, and Intothe root zone of food chain crops andolher vegetation:

TABLE 1 (continued)ARABs FOR SAND CREEK OU5

ACTION SPECIFIC AftARs AND TBCs

Standard. Requirement.Criteria, or LbniUllon Cftatton Description


Applieslo

Altemalrve

Stale ARAB?

(8) The potential for health risks caused byhuman exposure to waste constituents;and

(9) The potential lor damage lo domesticannuls, wildlife, crops, vegetation, andphysical structure caused by exposure lowaste constituents;

(b) Prevention ol any releases that mayhave adverse edecls on human health orthe environment due to migration ol wasteconstituents In surface water or wetlandsor on the soil surface considering;

(1) The volume and physical and chemicalcharacteristics ol the waste in the unit;

(2) The effectiveness and reliability ofcontaining, confining, and coHeclingsystems id structures in preventingmigralioi.

(3)The hydrologlc characteristics of theunit and the surrounding area, includingthe topography of the land around theunit;

(4) The patterns ol precipitation in theregion;

(5) The quantity, quality, and direction olground water How;

(6) The proximity ol the unit lo surfacewalurs; adverse effects on tiuiivdii health01 the environment; consulting.

TABLE 1 (continued)ARARs FOfl SAND CREEK OU5


Standard. Requirement,Criteria, or Limitation Citation Description


Appliesto

Alternative

Stale ARAR j

(7) The current and potential uses olnearby surface waters and any other waterquality standards established lor thosesurface waters;

(8) The existing quality of surface watersand surface soils, including other sourcesol contamination and their cumulativeImpact on surface waters and surfacesoils;

(8) The patterns ol land use In the region;

(10) The potential lot health risks causedby human exposure to waste constituents;and

(11) The potential (or damage to domesticanimals, wlkfife. crops, vegetation, andphysical structures caused by exposure towaste constituents.

(c) Prevention of any release that mayhave adverse elfecls on human health orthe environment due to migration of wasteconstituents In (he air. considering;(1) The volume and physical and chemicalcharacteristics of the waste in the unit.Including its potential (or the emission anddisposal ol gases, aerosols andparticulars;

(2) The effectiveness and reliability olsystems and structures to reduce orprevent emissions of hazardousconstituents lo the air;

TABII .onlinued)ARAHs FOR -AND CHEEK OU5


Standard. Requirement.Crtlerta. or LlmlUlion Citation Description


Applieslo

Alternative

Stale ARARs

Colorado Ak Quality Control Act 5 CCO 100t 9

5CCR 1001 5. Reg 3.Section II

5CCR 1001 5. Reg 3.Section IV D

(3) The operating characteristics ui theunit;

(4) The atmospheric, meteorologic. andtopographic characteristics ol the unit andthe surrounding area;

(5) The existing quality ol the air. includingother sources ol contamination and theircumulative impact on the air;

(6) The potential lor health risks caused byhuman exposure lo waste constituents;and

(7) The potential lor damage to domesticanimals, wridhle. crops, vegetation, andphysical structures caused by exposure lowaste constituents.

Establishes regulations to controlemissions ol VOC's (new and existingsources).

File APEN including estimation ol emissionrales.

Source cannot cause an exceedance Inany attainment area ol any NAAQS.

Yes/No

Yes/No

Yes/No

Apply reasonably available control t2.3.4technology (RACT) In ozone non-attainment area.

Applies lo al sources Including existing t2. 3. 4unless specifically exempt.

TZ4-C08008-CR-03723

SAND CREEK INDUSTRIAL SUPERFUND SITE

OPERABLE UNIT NO. 5

COMMERCE CITY, COLORADO

RESPONSIVENESS SUMMARY

September 1990

This community relations Responsiveness Summary for Operable Unit No. 5 (OU5)

of the Sand Creek Industrial site contains the following sections:

A. Overview. The overview briefly describes the site and summarizes

the public's major comments on EPA's Feasibility Study (FS) and

preferred alternative for OU5.

B. Summary of Community Involvement. This section gives a history of

EPA's community relations activities at the site.

C. Summary of Comments Received During Public Comment Period. This

section categorizes oral and written comments received concerning

the FS and EPA's preferred alternative, and provides EPA's responses

to those comments.

D. Remaining Concerns. This section describes concerns about the FS

and tells how EPA will address them.

E. Previous Community Relations Activities at the Site. This table

lists by chronological order the community relations activities that

have occurred to date. • • . - . .

A. OVERVIEW • ' •

• «

The Sand Creek Industrial site is located in Commerce City, city north of

Denver, Colorado. The site and surrounding area are primarily occupied by

trucking firms, petroleum and chemical supply/production companies, warehouses,

and small businesses. There is a small residential population in the study area

and the area adjacent to the northeast border of the site.

The site contains the following fou. nown potential source areas, all of which

are now inactive: the Oriental Refinery, the Colorado Organic Chemical (COC)

property, th« L.C. Corporation acid pits, and the 48th and Holly Landfill.

Contaminants found on the site include pesticides and herbicides, volatile

organic compounds (VOCs), and arsenic. To expedite the study and cleanup of che

contaminated areas, EPA has divided the Sand Creek site into six operable units.

The operable units were established based on the presence of different types of

contaminants or contaminated media, different source areas, and/or physical

constraints. This responsiveness summary presents comments on EPA's FS and the

preferred alternative for cleaning up contaminated soils in Operable Unit "o.

5 (OU5), which consists of the surface soils contaminated with pesticides and

metals found in the vicinity of the adjacent Colorado Organic Chemical plant

property (COC), the Gallagher property (former Oriental Refinery), and the

Colorado and Eastern Railroad property.

•Comments were received from the City of Commerce City, the original owner -f the

COC property, a Trust set up by the owner, the State of Colorado and s. small

number of individuals present at the public meeting. The majority of the

comments were focused on the issues of permanency of the cleanup and any land

use restrictions.

B. SUMMARY OF COMMUNITY INVOLVEMENT

f

Community relations activities for the Sand Creek Industrial site began in April

1985, when EPA distributed an introductory fact sheet to residents, businesses,

and agencies in the area. The fact sheet described the site and explained their

Superfund process, with'emphasis on .the RI/FS. Following the distribution of

the fact sheet, EPA attended a public meeting organized by Citizens Agains.c

Contamination, a local group concerned about the site, and compiled a list of

people who owned property on the site.

EPA mailed a second face sheet in November 1985. Written in quescion-and-

ansver format, this fact sheet provided information typically requested during

investigation and cleanup of hazardous waste sites. That same month. EPA also

provided a report on water contamination for a second public meeting held by

the Citizens Against Contamination organization.

In January 1986, EPA contacted property owners and Commerce City officials to

keep them informed of activities at the site. In the spring, EPA prepared a

photo display illustrating the RI/FS process.

A Remedial Investigation report describing the extent of contamination within

the COC area was released for public review in March 1988. In May 1988, E?A

contacted property owners to obtain permission to sample and monitor soils on

those properties.

In October 1988, EPA met with Commerce City officials to keep them informed of

plans for the site. The Commerce City representatives also provided their

reactions to the cleanup methods being considered.

In January 1989, the FS was completed and a remedial alternative was chosen.

EPA took several measures to announce the choice and to seek comments and

questions from the public. First, EPA made copies of the FS Report available

to the public in the Adams County Public Library, the Colorado Department of

Health, and EPA's own library in downtown Denver. At the same time, EPA mailed

its third fact sheet, which described the Proposed Plan as well as four other

remedial alternatives that had been evaluated. Third, EPA announced a public

comment period during which people were invited to submit comments and questions.

The comment period originally ran from January 13, to February 13, but at the

request of some commentators, EPA extended the period to February 22. Fourth,

EPA conducted a public meeting on January 31 to describe the results of the RI/FS

and answer questions from the public.. EPA'published a press release and a public

notice in each of the Commerce City newspapers, The Commerce City Sentinel and

The Commerce City Beacon, announcing all of these activities.

EPA made copies of the FS Addendum report available Co che public and mailed

its fourth face sheet describing the new proposed plan. The remedy selected in

the new proposed plan included: excavation and off-site incineration of

approximately 1,000 cubic yards (CY) of highly HOC-contaminated shallow (<5 ft)

soils; vacuum extraction of the volatile organic compounds in the subsurface

soils above the ground-water table; demolition and off-site disposal of che

contaminated tanks and-buildings; and either bioremediation or soil washing for

the surface soils contaminated with HOCs with the goal of returning the sice co

residential use. It was proposed that excavation and off-sice disposal of the

contaminated surface soils be retained as a contingency remedy, since the

implementation of bioremediation and/or soil washing depended upon che results

of treatabilicy studies to be performed subsequent to a Record of Decision. An

absence of proven bioremediation and/or soil washing results on soils

contaminated with similar compounds further Warranted retention of che off-sice

disposal option.

EPA announced a public comment period in effect from July 19, through August 21,

1989 during which the public was invited to submit commencs and quescions

regarding the FS Addendum and the new proposed plan. EPA conducted another

public meeting on August 1, 1989, to describe the proposed plan and answer

questions from the community. Press releases and public notice were again

published in The Commerce Citv Sentinel and The Commerce Cicv Beacon announcing

all these activities.

Only the City of Commerce City responded in writing, and there was limited

comment on the selected remedy during the August 1 public meeting. The primary

concern of the City of Commerce City was that the COC property be remediated to

residential-use standards. A Record of Decision was subsequently prepared which

addressed only the highly contaminated soils. Remedial design of OU1 was

initiated following ROD signature. Samples of the COC area were collected during

design stages. Analytical resul'ts from that sampling period were evaluated in

an endangerment assessment prepared for OUS. New action levels and soil volumes

were calculated using all the OUS data.

Remedial alternatives previously identified and screened for the COC area through

the initial RI/FS (COM, 1989) and Feasibility Study Addendum for OU1 (SAIC, 1989)

were utilized in the FS for OUS. Costs of selected alternatives were revised

based on the refined soil volume information. A proposed plan and FS for OUS

were released to the community for public comment in July 1990.

C. SUMMARY OF COMMENTS RECEIVED DURING PUBLIC COMMENT PERIOD

Comments raised during the public comment period on the FS and proposed plan

are summarized below. The comment period was held from July 27 to August 27,

1990. The comments are categorized by relevant topics.

Remedial Alternative Preferences

Each of the commentors on the FS and proposed plan expressed a preference for

specific alternatives. ,

Comment 1. The City of Commerce City feels that Alternative No. 4, on-site soil

washing with off-site disposal of residuals, would be an acceptable

cleanup alternative if specific concerns are addressed. The city's

concerns included implementing an air monitoring and dust supervision

program during remediation, a restriction of access during

remediation and a notification plan for the city should any threat

to public health and safety occur.

EPA Response: EPA's policy is that applicable and/or relevant and appropriate

Federal and' State laws be applied to Superfund remedies to ensure adequate

protection of public health, welfare and the environment. In this case, specific

laws regarding air emissions and particulates will apply during remediation

activities. The requirements outlined on these laws will be met. The ARARs are

delineated in Appendix B of the Record of Decision. Additionally, site access

will be restricted to those involved with the remediation effort.

Comment 2. The City feels that alternative *3 off-site disposal would not assure

a permanent solution to the hazards at the site due to EPA's

inclusion of "institutional controls" in the proposed plan.

EPA Response: EPA believes that institutional controls will not alter the City's

planned use of Che area. EPA intends to return Che sice to industrial use based

on Che City's Comprehensive Plan for 1985 Co 2010 and Che historical use of the

area. Implementation of land use restrictions will require the cooperative

efforts of State, County, and City official to be successful.

Comment 3. Comments submitted by Holland & Hart on behalf of its client First

Interstate Bank, trustee for the Philip C. Mozer Trust indicate thac

they believe capping is the more appropriate remedial alternative

for the soils at the COC site. Holland & Hart believe that capping

would be a permanent remedy, is cost effective and protective of the

environment and human health. Holland & Hart do not believe the

information presented in the FS on the soil washing alternative is

sufficient to allow full development and evaluation of the treatment

technology, to support remedial design, and to reduce the cost and

performance uncertainties for this treatment alternative to

acceptable levels.

EPA Response: EPA believes that in spite of the significant uncertainties

associated with soil washing, it is the best alternative given the preference

for treatment under CERCLA and the permanency of the remedy. EPA believes that

capping is not acceptable because ic does not reduce coxicicy, mobility, or

volume of the waste, and is not a permanent remedy. EPA plans to further

determine the effectiveness, implementability and cose associated with soil

washing through on-site pilot testing. Should Che piloc test indicate that soil

washing would not be appropriate for full scale remediation of the site, the

alcernative for off-sice disposal will be implemented. Holland & Hart did not

comment on the off-site disposal alternative.

Commenc 4. Holland & Hart believe chat coses associaced with capping ace coo

high and question the need for run-off controls.

EPA Response: EPA has included long-term maintenance and operation costs to

the capping alternative since it would likely fail without proper operation and

maintenance. A drainage system of some type is necessary for run-off even in

a semi-arid environment.

Technical Questions/Concerns Regarding Remedial Alternatives

Comment 5. Some technical comments regarding the actual risks posed by the

contamination of the site were made during the public meeting by a

few individuals. Mr. Philip Mozer read a prepared speech concerning

site risk. The speech is included in the appendix to this

Responsiveness Summary along with the other comment letters.

EPA Response: EPA conducted a health risk assessment following the methodology

of the EPA Risk Assessment Guidance. This methodology has been used on CERCLA.

sites nationwide. The methodology takes into account the toxicity of the

contaminants, the exposure frequency and duration, the pathways of exposure and

the potential exposure receptors. A risk level ... then calculated to determine

an acceptable contamination range for an overall site risk of 10"* to 10**. The

exposure scenarios which Mr. Mozer questioned are further explained in the risk

assessment as to their relevancy in the risk calculations. Since the comments

raised were of a general nature and discuss issues :reated in the endangerment

assessment, the commentor will be will be directed to that document.

Comment 6. A question was raised about the use of bio-remediation as a viable

alternative.

*

EPA Response: EPA' has conducted- a preliminary study on the use e. bio

remediation. It became apparent through this effort that the technology was not

developed to a point of implementation in a treatability study or remedial

action. Further discussion of EPA's efforts to evaluate bio remediation can be

found tn the OU5 FS, pg 3-2.

D. REMAINING CONCERNS

CfllBBfiTITi 7. Mr. David Busby, the Mayor of Comaerce City commenced on future land

use and who would be liable for the property in the future.

EPA Response: According to CERCLA, for as long as the site is on the NPL and

possibly longer, the liability is open.

Comment 8. Mr. Reis from the Sierra Club asked about a determination as Co che

extent of ground water contamination.

EPA Response: EPA indicated that the groundwater contamination problem has noc

yet been fully investigated and will be on the agenda for next year.

Comment 9. Mayor Busby also asked about pesticide migration in groundwater and

dust contact during remediation.

EPA Response: There has not been evidence of a significant amount of groundwacer

contamination from the pesticides at the COC property. The pesticides are noc

very mobile through the soil and tend to adsorb to the soil particles. The

greater threat is from direct contact with the soil. Concerning dust concrol

during remediation, EPA will implement dust control measures which meet Scace

requirements.

E. COMMUNITY RELATIONS ACTIVITIES., -. . . **.'„• sEr^j.-isTfc-jyV irs.--'-" ->•*•'• • -••••

• April 1985 • EPA mailed an introductory fact sheet about the site

to residents, businesses, agencies, and others (including PRPs) on

. • the mailing list. •'-• "vvr • --—;?:- :

• Augusc 27, 1985 - EPA met wich PRPs.

• September 1985 - EPA participated in a public meeting organized by

Citizens Against Contamination.

• October 1985 - EPA developed a comprehensive list of property owners'

names and addresses.

• November 1985 • EPA mailed another fact sheet providing answers to

questions typically asked during investigation and cleanup of

hazardous waste sites.

• November 1985 - EPA provided information on water contamination for

a public meeting organized by Citizens Against Contamination.

• January 1986 - EPA contacted property owners to inform them of site

activities. EPA also contacted public officials.

• April 1986 - EPA prepared photos for use in a display illustrating

the RI/FS process.

• February 1987 - EPA updated its list of property owners.

• April 1987 - EPA surveyed residents about water use habits.

• November 1987 • EPA contacted residents and businesses to identify

and check the status of methane venting systems near the site.

'. " ": '.* •** '

• May 1988 • EPA requested and received access permission for soil

sampling on certain properties.

October 24, 1988 - EPA made a presentation to Commerce City officials

to inform them of progress and plans at the site, and to obtain cheir

reactions to the potential remedial alternatives developed during

Che Feasibility Study (FS).

January 6, 1989 - EPA mailed a third fact sheet describing the

Proposed Plan for OU1. Also on the same date, EPA made the FS for

OU1 available to the public at the information repositories listed

in the Proposed Plan.

January 1989 - EPA issued notice of a public comment period on che

FS and Proposed Plan.

January 31, 1989 - EPA held a public meeting at Commerce City Hall

to describe the results of the RI/FS and to respond to questions and

comments. Approximately 16 people attended, not including EPA or

contractor personnel.

January-February 1989 - EPA extended its public comment period on

the Proposed Plan from January 13-February 13 to January 13-February

22, as requested by some PRPs.

March-August 1989 - EPA re-evaluated alternatives and issued an

Addendum Co Che FS. A new Proposed Plan was issued in July 19P"1.

The public comment period extended through mid-August. A public

meeting was held August 1, 1989.

A Record of Decision was prepared in September 1989 which addressed

v , highly contaminated »oil; VOC's, and structures....;., :.••-•* •;. -.-n-; <•• •:..;': t». ~" ' . - • '' •

An FS and proposed plan for OU5 was prepared and released for public

comment in July 1990. »A public meeting was held August 9, 1990.

The public comment period extended through August 27, 1990.

10

CITY* SlTl Vtt^ COMMERCE CITYcolo«»do

__________^_ people 6

Office of theMayor

August 16, 1990

Mr. Brian PinkowskiRemedial Project ManagerU.S. Environmental Protection Agency999-lSth StreetDenver, Colorado 80202

Re: Commerce City's Comments on EPA's Proposed Remediation Plan forOperational Unit 5 at Sand Creek Superfund Site

The City has reviewed the preferred remedial proposal by EPA for"cleaning up" Operable Unit 5 at the Sand Creek Superfund site andprovide the following comments for your review:

1. The City feels that Alternative No. ^, EPA's preferred plan ofOn-Site Soil Washing with Off-Site Disposal of Residuals, wouldbe an acceptable and viable cleanup alternative, if the followingareas/concerns are addressed:

a. A reliable and effective air monitoring program should beinstituted on the site to ensure that surroundingareas/populace are not exposed to hazardous materials as aresult.of the remediation process.

b. An effective dust suppression program should be developedand implemented to ensure that the surrounding area andpopulace is protected from fugitive emissions.

c. The operable unit should be fenced off to restrict accessduring remedial activities. .' '

i

d. The Ci ty should be immedia te ly n o t i f i e d of any th rea t topubl ic heal th and safety which occurs or may develop d u r i n gthe course of remediation of the un i t .

The C i ty also has reviewed E P A ' s proposal to implement A l t e r n a t i v eNo. 3 (Off-Site Landfill Disposal and "Institutional Contro ls") ifpilot tests reveal that soil wash ing is i n e f f e c t i v e . The C i ty has the

Mr. B r i a n P i n k o w s k i c

A u g u s t 1 6 , 1990Page 2

fo l lowing reservat ions /comments concern ing the imp lemen ta t i on ofAl te rna t ive No. 3:

1. The Ci ty feels that essent ia l ly , the Ian w o u l d not assure apermanent solution to the hazards at t.ie si te, as ind ica ted bythe E P A ' a inclusion of " inst i tut ional controls" in the plan. Whywould any type of controls be necessary if the remedia t ion t r u l ywas a permanent , so lu t ion? It is fe l t that " ins t i tu t iona lcontrols" are not in keeping wi th S A R A ' s in tent to ar r ive atpermanent solutions to Supe r fund sites.

r

2. The C i t y believes t ha t " ins t i tu t iona l controls" carry w i t h the r r ;the s t igma of poss ib le f u t u r e hea l th risks and c o n t i n u i n g legaland economic p r o b l e m s .

3 . EPA should r e - e v a l u a t e / i n v e s t i g a t e other remedial methods ( suchas v i t r i f i c a t i o n , o f f - s i t e inc ine ra t ion , or b ioreraedia t ion ) toe f f e c t a c l eanup of the s i te . It is bel ieved that through the useof . these or o ther types of t r e a t m e n t technologies , a f eas ib l ec leanup p lan can be deve loped , e l imina t ing the need forrestr icted " ins t i t u t iona l con t ro l s . "

As M a y o r of Commerce C i t y , I wou ld l ike to take the o p p o r t u n i t y tot h a n k you and your o r g a n i z a t i o n . f o r past and f u t u r e e f f o r t s tosuccessful ly remedy the c o n t a m i n a t e d soils at the Sand Creek site. 'Please feel free to contac t me or the C i t y M a n a g e r , Steve C r o w e l l , i fyou need addi t iona l i n f o r m a t i o n .

S incere ly ,

Dav id R . D . B u s b yMayor

cc: Jane 0. RussoCommuni ty Re la t ions Coordinator

HOLLAND & HARTATTORNEYS AT L*W

SUlTt 2900

C2V.O8AOC SWINGS DCNVIR CO».O«AOOASPf N MAILING *OO«SSBILLINGS *O 6OX8749BOSE 3CNVCI CCXOIAOC J020I

0 C JCJ: 7>'. 4j42

August 31, 1990

VIA HAND DELIVERY

Mr. Brian PinkowskiRemedial Project ManagerU.S.. Environmental Protection Agency999 Eighteenth StreetSuite 500Denver, Colorado 80202

Re: Sand Creek Industrial Superfund SiteComments on Feasibility Study and Proposed Plan,Operable Unit No. 5, Colorado Organic Chemical soils

Dear Mr. Pinkowski:

These comments on the Feasibility Study and ProposedPlan for operable unit no. 5 at the Sand Creek IndustrialSuperfund Site are submitted by Holland & Hart on behalf ofits client First Interstate Bank, trustee for the Philip c.Mozer Trust. This letter discusses our general commentsregarding the Feasibility Study and Proposed Plan foroperable unit no. 5 and is not intended to address all ofour concerns related to these documents. Many of thecomments we made related to the Draft Feasibility study foroperable unit no. 1 are equally applicable to operable unitno. 5 and are incorporated by reference into these comments.A copy of our comments on operable unit no. 1 datedFebruary 13, 1989 are attached for your convenience.

As with operable unit no. 1, we believe capping is themore appropriate remedia], alternative for the soils at theColorado Organic Chemical ("COC") site, which includes soilswithin operable unit no. 5. EPA recognizes in the operableunit no. 5 Feasibility Study ("FS") that soil contaminationis limited to a depth of 3 to 5 feet and "the contaminantsof interest have relatively high adsorption potential andconsequently will tend to strongly adhere to soil

Mr. Brian PinkowskiAugust 31, 1990Page 2

particles." FS, page 2-7. EPA's own evaluation of theability of the capping alternative to reduce toxicity,mobility or volume states:

A cap reduces the mobility of thecontaminated media and significantlyreduces the risks of dermal contact,inhalation and incidental ingestion ofsoil particles. Capping also reducesthe potential for leaching of soilcontaminants into the ground water byproviding an impermeable layer over thecontaminated soil, which preventssurface water from infiltrating belowthe cap. FS, page 4-6.

These soils contain low concentrations of the constituentsof concern and the constituents are fairly immobile,conditions which are favorable to a capping remedy.

Further, EPA has identified the potential for exposurethrough skin contact or the ingestion of the soil as thegreatest risks posed by these soils. Capping clearly^el initiates both of these potential exposure pathways in amore cost effective manner. Therefore, a cap would beprotective of not only the environment but-also of humanhealth.

EPA has apparently not considered our previous commentsrelated to implementation of a capping alternative. A capis a permanent remedy and maintenance need not be ascontinuous, time-consuming or expensive as implied by the FSreport. The costs associated with placement of a cap havebeen overestimated by requiring extension of the caphorizontally fifty feet around all of the edges,incorporating a drainage layer which is not necessary due toour semi-arid environment, and requiring annual operatingcosts of $70,000. Consequently, EPA has failed torealistically evaluate the viability of a capping remedialaction.

Of significant concern to the Trust is EPA's selectionof alternative 4, on-site soil washing, as the preferredremedial alternative. There is no justification or basis in.the FS report for selecting this alternative. One of thereasons operable unit no. 5 was established was to furtherevaluate the soil washing alternative that had beenconsidered in the operable unit no. 1 Feasibility Studyreport. That report identified certain objectives that


would be evaluated in a treatability study which includedproviding sufficient data to allow full development andevaluation of the treatment technology, to support remedialdesign, and to reduce the cost and performance uncertaintiesfor this treatment alternative to acceptable levels.Operable unit no. 5 has failed to accomplish that task; theresults of the soil washing treatability tests and theinformation provided in the FS simply do not indicate thatsoil washing is a. viable alternative. In fact, "finalresults have not been tabulated" and EPA has made "noquantitative determination of effectiveness" of the soilwashing treatability study. FS, page 3-6. In spite of thesignificant uncertainties, soil washing was still selectedby EPA as the preferred alternative.

Further, it is not possible to evaluate the costestimates presented in the FS due to the limiteddocumentation and information. It appears there is someinconsistency in the costs; in particular, some of the costsfor capping appear to be inflated while costs for the soilwashing alternative may be underestimated. The FS reportstates costs for soil washing are "highly speculative" (FS,page 4-21) , which makes it extremely difficult to determineif soil washing is a cost effective alternative, adetermination required under the Superfund Amendments andReauthorization Act ("SARA"). In addition, EPA exposes itsbias against capping when it states that capping could be"effective in containing the contaminated soil indefinitely"(FS, page 4-8) but then concludes in Section 5 of the FSthat capping is not a permanent remedy. These factorsresult in an incorrect determination that the soil washingalternative is cost effective because its advantagesoutweigh its "slightly" higher costs when compared toalternative no. 2, capping.

There is also limited information regardingimplementation of the capping alternative. The explanationis simply that soils are to be excavated and relocated "on-site". We object to the placement of any contaminated soilsfrom other locations on COC property, if that is EPA'sintent. • • - ' .

t

Capping is the more cost effective and protectiveremedial alternative and should be the alternativeimplemented at the COC site. Capping meets the requirementsof SARA, is more cost effective, and is protective of humanhealth and the environment. Further, the soil washingalternative selected by EPA is simply not supported by the


FS, is inappropriately evaluated in the FS and should not beimplemented at this site.

Please call me if you have any questions regardingthese comments.

Sincerely,

mtjyia S. Leapfor Holland & Hart

cc: William Clemmens, Esq.Mr. Hal WoffordSusan £. Brown, Esq.Mr. John Cork!ePaul D. Phillips, Esq.

C ILKT :9*363

HOLLAND & HARTATTORNEYS VTL.VA

CW~HI.\ 5 L£

February 13, 19S9

3Y H A N D D E L I V E P . Y

M r . Tony .MedranoR e m e d i a l P r o j e c t Mar .agerEPA Region V I I I •999 18th S t ree tS u i t e 50CDenver, Colorado 3C202-24C5

Re: Comaients on Feasibility Study.,Operable Unit No. 1,Colorado Organic Chemical SoilsSand Creek Industrial SiteCommerce City, Colorado

Dear Mr. Vedrano:

Holland & Hart submits t.*5<» following comments or. behalf ofits client First Interstate Sank, trustee for the Phillip C.Moser Trust. We are providing these general comments on thedraft Feasibility Study for Cperable L'nit N'o. 1 which includesthe Colorado Organic Chemical ("CCC") site. We have focused ourcomments on the preferred remedial alternative selected by EPA,and therefore our comments are not intended to address detailedconcerns related to the draft Feasibility Study.

It is our understanding, based on conversations with you,that Alternative Number 4 (off-site incineration and disposal =ta Subtitle C landfill) was the preferred alternative presented =yEPA at the public meeting on January 31, 1939. »e object to tr.eselection of Alternative Number 4 and recommend AlternativeNumber 2 (capping) because it is more consistent with theSuperfund Amendments and Reau^thorization Act. ("SARA") require-ments, and is equally protective of human health and the environ-ment. The draft Feasibility Study recognizes that capping iseffective and reliable, can be easily i:—lemented and is a cor.-cr.remedial alternative at other Sucerfund :tes. Capping is par-ticularly effective where the substances are immobile, as arepesticides and inorganic arsenic, which have been identified a:the CCC property as the constituents of concern.

HOLLAND & HARTVTTCRNE^S AT LAW

February 13, 1939Page 2

The technology and alternative evaluations performed ty E?1

in the draft Feasibility Study endorse the capping remedialalternative because it has been implemented successfully at 2number of other hazardous waste sites (including Superfundsites), provides an immediate and highly effective remedy, iseasily constructed with minimal disturbance to the soil andresults in a significantly reduced risk of exposure to workersand the public during implementation. Capping is also the mos:ccst-effestive alternative, meets the Applicaole and Relevant c:Appropriate .Requirements ("AP.ASs") and can provide permanentremediation.

3ecause the constituents of concern are extremely imr.ooiiethere is little potential for any impact to ground water quality.The executive summary states that the risk assessment regardingground water found the minimum travel time for any of thecontaminants to reach ground water is over 2,000 years. Thisnumber was calculated without .factoring in a cap, which wouldsignificantly reduce the travel times by preventing surface waterfrom infiltrating below the cap. To select Alternative Nurr.irer 4as . .*? preferred alternative because it eliminates the possibil- -icy of ground water contamination places undue emphasis on t.-.epotential for ground water contamination. Test results ccnfir-that the pesticides and arsenic have not migrated to either theshallow or the deep aquifers.

There are few, if any, disadvantages to capping. Cne disad-vantage identified by EPA is the potential restriction to futureland use due to disturbance of the cap. However, capping doesnot restrict all land uses. For example, foundations for build-ings could easily be constructed on pads of fill on top of thecap. The only use restrictions that would be necessary is toprevent excavation of the cap. Another disadvantage identifiedby the draft Feasibility Study is the possible settlement andsubsidence of the cap materials. Settlement and subsidence areonly of concern when a cap is placed over compressible andunconsolidated materials. This is not the situation at the CCCproperty, where the cap would be placed over native soils whicr.would eliminate the potential for significant settling. Erosic-'can be avoided by grading, planting native vegetation andinstalling run-off and run-on controls. - . . . . ,

Further, any concern regarding the horizontal migration ofwater in the vadose zone below the cap could be remedied bykeying in the edges of the cap (including the geomerabrane) to adepth of five feet around the contaminated zone. This method ismore cost effective than extending the cap fifty feet around th*edges.

HOLLAND* HARTVTTORNEYSATLAW


Alternative Number 4 is an inadequate and inappropriateremedy because it does not meet SARA requirements. Cnly 11 to 3%of the contaminated soils would actually be incinerated underthis alternative. The remaining 971 to 991 of the contaminatedsoils would be sent off-site without treatn-nt. -AlternativeNumber 4 is also tr.ree times the cost of Alternative Number 2 andallows workers and the public to be exposed to potentially harm-ful contaminants during excavation, transportation —.drediscosal. Clearly, Alternative Number 4 does not -.atisfy theSARA requirements for reduction of toxicity, mobility or vci-T.e,long-term effectiveness and permanence, implementatility andcost-effectiveness.

EPA assumes certain materials, including soils, build ires,foundations and tanks are "hazardous waste" without any basis forsuch a determination. Because it is assumed that the buildir.cs,foundations and tanks are "hazardous waste," EPA proposes demol-ishing the structures and disposing the materials in a Subtitle Clandfill. The trustee strongly objects to the demolition of anybuildings, foundations, tanns or other structures. EPA has r.stidentified any need or provided an> jstification to remove t-estructures and such additional costs are unwarranted. We dc r.ctbelieve the buildings, foundations and tanks are "hazardouswaste;" to the contrary, they are usacle structures having ecc-nomic value.

EPA has selected a Subtitle C disposal facility (hazardc.swaste facility) for disposal of all buildings, foundations andtanks that are demolisned instead of a Subtitle D disposal facil-ity (solid waste disposal), in spite of the 5190 difference IT.cost per cubic yard. This cost difference is rationalized by E?Abased on savings in time and ease of implementation. The tiresaved by Subtitle C disposal is four days; costs are three tofour times greater. It is incomprehensible how EPA could justifysuch an excessive expenditure of money in-order to save fourdays. EPA assumes the waste would have to be delisted but doesnot explain why these wastes are considered "listed."

Another reason EPA advances in the draft Feasibility Stu-iyfor disposal at a Subtitle C facility is the reluctance ofSubtitle 0 facilities to accept waste from Superfund sites. Thedraft Feasibility Study does not suggest that EPA has contactedor even attempted to contact any Subtitle D facility to inquireas to whether they are willing to accept the wastes associatedwith this operable unit. The decision to use a Subtitle Cdisposal facility is totally unfounded. In addition, EPA antici-pates disposing of all materials and equipment used at the site

HOLLAND & HARTATTORNEYS AT LAW-


as hazardous wastes when materials and equipment used at.Superfund sites are routinely decontaminated and reused.

2,While we advocate implementation of Alternative Numberobject to the placement of contaminated soils from ether loca-tions on COC property. Specifically/ we strongly object to tr.e 'proposal to place 5,000 cubic yards from Subunit IB on CCC crcc-erty. We do not believe EPA has the authority to require t.-.etrustee to permit tr.e disposal of hazardous substances on itsproperty.

In conclusion, Alternative Number 2, capping, meets therequirements of SARA, is more cost-effective, is protective ofhuman health and the environment, and (with the qualificationsnoted above) is the remedy that should be implemented at the CCCsite .

Please feel free to call if you have any questions.

Sincerely,

a S. Leapfor HCLLAMC & HART

C£L:slpcc: Hal R. Wofford

Paul D. Phillips, Esq.Phillip C. MorerSusan Mclntosh, Esq.

STATE OF COLORADOCOLORADO DEPARTMENT OF HEALTH4210 E*»t 11th Avenue T«t»m:Denver. Coloudo 80220-jrib ' J03' "J'*176 lV*'n Bu.W,n,.-o«Phone (303) 320-8333 iMJi 120-iS».Prjrmnjn «j«.0««»«"

iMJi 248*7198 iC'lna luncnon R*)ion4l OHicei

August 20, 1990

Mr. Brian PinkowskiEnvironmental Protection Agency - 8HWM-SR999 18th Street, Suite 500Denver, Colorado 80202-2405

Re: Sand Creek Feasibility Study for OU-5

Dear Brian:

I have reviewed the Feasibility Study for OU-5 and have the following comments.

Page 2-5, 11.4. The proposed cleanup levels of all the contaminants of concern need to beincluded in the FS. The level should be listed for both industrial and residential uses. Adiscussion is also needed detailing how the industrial vs residential senario varies and whyremediation for each use entails different soil volumes.

Page 3-6. Tables are needet. A removal effectiveness for both OCP's and metals. Thissection also needs to be updated to give projected waste material volumes after soil washingwhen available.

Page 4-14. The State Engineers Office has communicated that they have no ability toimplement institutional control to limit well drilling in contaminated areas of groundwater. Also, the SACWSD has not been consistent in requiring relenqushiment of well waterrights upon application for water service. This requirement was only made in the northernarea of OU-2 of Chemical Sale. Because of these problems, this paragraph needs to be revisedto state that continue usage of well water may exist. However, a survey will be undertakento determine the number of well users, if any in.

ARARS's

Aa appendix need to be included in this FS with the complete listing of ARARS's. I havereviewed the ARARS's that are included in the original FS by CDM. There are several airpollution regulations that were not included in these ARARS's. I am enclosing a table givingthese new ARARS's.

LANDBAN. A discussion of landban requirements was included in the original FS for the site.This discussion need to updated in this FS with detail as to how this OU complies with thelandban requirements. '

State Acceptance

Alternative No. 1. The State finds this alternative unacceptable due to continued exposureto the public, potential contamination of surface and ground water, and the lack of usabilityof the site.

Alternative No. 2. The State is not in favor of this alternative because the contaminatedsoil will remain onsite and require long-term maintenance of the cap to ensure protection ofpublic health and containment of the waste. The land use will be excessively restrictive.

Alternative No. 3. The State finds this alternative acceptable as it full/Ills all theremedial objectives.

Alternative No. 4. This alternative is preferred by the State because if fullfUls all theremedial objectives and in addition minimizes waste. As • ' • - projected cost of thisalternative is speculative, the State will reevalauate this alti jiive as compared toalternative No. 3 when new cost figures become available.

Enviromental Epidemiology is currently reviewing the health risk assessment. I hope to havecomments to you by August 30.

Please call if you need clarification on any of these issues.

Candace Thompson, Project M^-aeerHazardous Materials and

Waste Management Division

CT:lh:7690K

Page No.08/I5/9U

STATE OF COLORADOSAND CRKF.K 011-5 ARARS

9/15/90FS REVIEW

STATUTORYAUTHORITY

STATUTORYCITATION

REGULATION REGULATIONCITATION

DKSCHIPTION ORREQUIREMENTS

COMMENTS APPLICABLE/RELEVANT ANDAPPROPRIATE/TO BE CONSID.

Colorado Air CRS 25-7-101 TO Regulation No.Quality Control -512 7Act

5 CCR 1001-9

Colorado Air CRS 25-7-101 TO Regulation IQua1 it,v Control -512 ' StationaryAct Emissions

Source

Colorado Air CRS 25-7-101Quality Control TP-512Act

Regulat ion .'I,StationaryEaiasioiiHSource

Colorado Air CRS 25-7-101 TO Regulation 3,Quality Control -512 Station/tryAct Emissions

Sour«:e

5 CCR lOOI-.'J,Reg I, Sec.I I . A . I

Estnhli stirsregulations tocontrolemissions ofVOC's (new andexistingsources)

<-omp I y w i t hopacily1 i m i tations

5 CCIJ 1001-5, File APEN

Apply APPLICABLEReasonablyA v a i l a b l eControlTechnology(RACT) in ozonenon-attainmentarea

<20 X opacity APPLICABLEemitted,specificsources mayhave otherlimitations

Applies to all APPLICABLEReg :t, Sec. 11

5 CCR 1001-5,Reg 3, Sec.I V.I)

including sourcesest i m a t i o n of includingemissions rates existing unless

specificaIlyexempt

Source cannot APPLICABLEcause anexceednnce inany att a i n m e n tarea of anyNAAQS

Documents

Document ID 810873 RECORD OF DECISIONDocument ID 810873 RECORD OF DECISION DECLARATION STATEMENT SITE NAME AND LOCATION Sand Creek Industrial Site Commerce City, Colorado Operable