UNITED STATES ENVIRONMENTAL PROTECTION AC

REGION 8

999 18W STREET - SUITE 300

DENVER, CO 80202-2466

http://www.epa.gov/region08

2028008

Ref: 8EPR-SR.

ACTION MEMORANDUM

SUBJECT:

FROM:

THROUGH:

TO:

Request for Time-critical Removal Action at the Pine

Canyon Township Residential Area of the International

Smelting and Refining Site, Tooele County, Utah

Joshua Knight, RPM

Dale Vodehnal, Director•fVCJ W \J<S^

^

Superfund Remedial Program

Steven D. Hawthorn, Supervise

Emergency Response, Team

Doug Skie,

Preparedness, Assessment rgency Response Program

Max H. Dodson, Assistant Regional Administrator

Office of Ecosystems Protection & Remediation

Site ID#: 086Y

Category of Removal: Time-Critical, Potential

Responsible Party-Lead (PRP-Lead)

I. PURPOSE

The purpose of this Action Memorandum is to request and document

approval for the proposed Removal Action described herein for

oortions of residential neighborhoods at the International

Smelting and Refining Superfund Site (UTD093120921) in Pine

Canyon, Tooele County, Utah (IS&R Site) . The area of the IS&R

Site addressed by this Removal Action comprises the Pine Canyon

Township residential area (Pine Canyon Township or Site). The

Removal Action will involve excavation of soils containing

elevated levels of lead and arsenic from residential properties

at the Site.

 For the identified residential properties, the top

18 inches of existing soil will be excavated and transported

Page 1 of il

Printed on Recycled Paper
• • off-site for disposal. Permeable geotextile filter fabric will

be placed on the sub-grade and covered with clean fill, • Surface

features will be replaced or returned as nearly as possible-to

"as was" condition. ; .

Conditions existing at the Site present an endangerinent. to human

health and the environment and meet the criteria for initiating a

Removal Action under 40 C.F.R. Section 300.415 (b) (2) of the

National Contingency Plan (NCP) . The actions discussed in this

memorandum are anticipated to require less than 12 months to

complete.

Based on the nature of the Site conditions 'and response, there

are no nationally, significant or precedent-setting issues

associated with this Removal Action. '

II SITE CONDITIONS AND BACKGROUND ; .

Ai

 gj+g_ Description

I. Removal Site Evaluation .

The IS&R Site was placed on the National Priorities List

(NPL) on July 27, 2000. The IS&R Site consists of lands

impacted by historic smelting and milling activities

from the IS&R facility. One Operable Unit (OU 1)

currently encompasses th e entire site. .. .

A Remedial Investigation/Feasibility Study (RI/FS) is

currently underway at the IS&R Site. The RI/FS is being.

performed by a potentially responsible party (PRP),

Atlantic Richfield-Company (AR),. under the '

Administrative Order on Consent for Remedial

Investigation/Feasibility Study, EPA Docket No. CERCLA08-2001-12 (RI/FS Order). The investigation of the Pine

Canyon Township was completed in June 2004.. The

investigation found that approximately 20 residential

yards have soils above the 580 ppm lead health-,

protective cleanup .level established by EPA for this

: Site.. . . •: ; . . •'.'.'.. .

The area to be remediated under this Removal Action, the

pine Canyon Township residential area, is owned by

individual residents. This Removal Action is expected

to be conducted by AR under a Unilateral Administrative

Order for Removal Action (UAO) .

 !

Page 2 of 11
2 . Physical location

The IS&R Site is located near Pine Canyon and the city

of Tooele, Utah, approximately 30 miles southwest of •

Salt Lake City, in Tooele County, Utah. The IS&R Site

is located in Sections 7, 18, 19, and 30 of .T3S-R3W and

Sections 12, 13, 14, 23, and 24 of T3S-R4W, 'Salt Lake

Meridian. The IS&R Site is roughly bounded by the

Oquirrh mountains to the east, rural residential and

farmland on the north and south, and Pine Canyon

Township and the city of Tooele. to the west. This

Removal Action will address the Pine Canyon Township

area of the IS&R Site. A depiction of the IS&R Site

with the location of the proposed actions is presented:

in Figures 1 & 2 (attached). .

• i

3. Site Characteristics

Copper smelting, began at the IS&R Site in 1910. The

smelter had a capacity of 4,000 tons of copper, ore per

day. Two years later, copper ore supplies declined and

the International Smelter & Refining Company (TS&R) , the

then-owner of the facility, built a lead smelter. In

1914, The Anaconda Company (Anaconda) purchased the IS&R

subsidiary. Over, several years the owners added a leadzinc sulfide flotation mill and a slag treatment plant

for lead and zinc recovery. Copper production ceased in

1946' when the copper smelter closed'. Lead smelting

ceased in early 1972. An estimated 650,000 tons per

year of tailings, slag and flue dust were produced

during early operations at the IS&R Site. AR is the

current owner of the Site and corporate successor to

IS&R and Anaconda. •

Reclamation work at the Site was performed in 1986 under

a voluntary agreement between AR and the State of Utah.

.The reclamation included demolition of all buildings at

the Site, consolidation .of the waste material, and a

covering of the majority of the waste material.

The IS&R Site covers about 1,200 acres, not including

the Pine Canyon Township. The IS&R Site includes.

approximately 330 acres of tailings, 27.5. acres of

metal-contaminated slag, 13 acres of settling ponds,

about 50 acres of landfills and 125 acres of smelting

wastes. The remaining acreage consists of open areas,

mostly unimpacted by smelter operations, and the- Pine

Canyon Township residential area. Investigations

Page 3 of 11
indicate the presence of arsenic,, cadmium, copper, lead,

mercury and zinc in the soils, tailings and slag.

The Township of Pine Canyon (formerly Lincoln)' 'is

located on the western edge of the IS&R Site and

comprises approximately 2 square miles including

approximately 100 residential properties. .Approximately

200 people live in the Pine Canyon area, including

approximately 20 children under the. age of 14.

From December 4, 2001, to June 13, 2004, AR, -under EPA

oversight in connection with the RI/FS Order, performed

soil sampling activities in the Pine Canyon township

residential area to define the areal extent of

contamination. These sampling efforts identified .

elevated concentrations of contaminants of concern,

including lead and arsenic, in the yard soils of various

residences. AR also performed sampling, of dust in

several residences. The results of these sampling

activities are included in reports submitted to EPA,

entitled "Data Summary Report - Work Area No. 10, dated

June 2002, Addendum No. 1 to Data Summary Report - Work

Area No. 10, dated September 2002, and Lincoln

• Residential Sampling, all prepared by Anderson

Engineering Company, Inc., and accepted by EPA on June

12, 2002, October. 18, 2002, and June 23, 2004,

respectively (collectively referred to as Sampling

Reports) .

 : .:.•' .

i .

As described in the. Sampling Reports, soil sample

results from 2002-2004 from the Pine Canyon Township

showed elevated levels of lead ranging from "Non-Detect"

to approximately 1880 mg/kg (1880| parts per million

(ppm)) in residential yards. Arsenic was detected in

levels of up to 150 ppm. Lead levels in samples of

household dust collected in Pine Canyon in 20.02-4 ranged

from 93 to 369 mg/kg. |

i - .

Two residents have shown unacceptable levels of blood

lead at or above 10 micrograms per deciliter, the level

of concern indicated by the American Academy of

Pediatrics. - i

In June 2003, EPA completed a risk assessment entitled

"Baseline Human Health Risk- Assessment for the

International Smelting and Refining Site Tooele County,

Utah (Final)". USEPA, Region 8, June. 2003 ("EPA Risk

Assessment'') for the Pine Canyon Residential Area based

t

Page 4 of 11

 :i
on the Sampling Reports. Healthrbased action levels

were established by EPA based on the EPA Risk

Assessment * • •' •

4. Release or threatened please into the environment

of a hazardous substance or pollutant or contaminant

Lead and arsenic are 'the primary contaminants of concern

with regard to human health in Pine Canyon. Lead .and

arsenic are hazardous substances as defined .by CERCLA

Section 101 (14). These hazardous substances were

released into local soils by historic smelting and

milling activities and were transported to the

residential areas by surface runoff and aereal

deposition from stack emissions. Lead and arsenic in

soils present a risk of incidental ingestion. The

levels of lea'd and arsenic reported in the Sample

Reports are above the—health-protective residential soil

lead cleanups/levels (actppn levels) determined by EPA

for the Site (580 ppm) ana soil arsenic cleanup levels

for the Sit4 (100 ppm)./ These action levels are

consistent w,ith action levels determined by EPA at other

Utah Super fund sites. ...-"

. 5. NPL status

The Site is currently listed on the NPL.

B. n+Ver Actions to Date

1. Previous Actions

No prior soil removal or similar remedial actions have

been taken for the Pine Canyon Township residential

area. .'•'• •

A Preliminary Assessment/Site Investigation (PA/SI) wascompleted in 1984 for the IS&R Site by the Utah

Department of Environmental Quality (UDEQ), with

additional expanded SI work completed in 1995 and 1996.

. in July 2000, EPA listed the IS&R Site, on the NPLDuring the years 1986-1987, AR performed reclamation

work at the IS&R Site to control potential risks to

health and the environment. The reclamation work

included: the removal of remaining buildings and

Page 5 of 11
structures; consolidation of waste materials;

construction of storm water controls; and,. placement of

cover soil over the majority of disturbed areas..

i

2. Current Actions ;

The current proposed Removal Action will address all the

risks posed in the Pine Canyon Township residential area

that were reported in the Remedial Investigation.

• The Remedial Investigation for the IS&R Site'is

currently underway and is scheduled to be completed in

November 2004. The Feasibility Study is estimated to be

completed in April 2005.

Ct state and Local Authorities' Roles.

UDEQ is the support agency for oversight of the Remedial

Investigation and Feasibility Study at the IS&R Site.

UDEQ was actively involved in the preliminary

investigations and will continue to play a vital support

role in this Removal Action. Both the Township of Pine

Canyon and the County of Tooele are aware of the current

Site conditions and are supportive of the actions taken

to date. . .

III. THREATS TO PUBLIC HEALTH OR WELFARE .OR THE ENVIRONMENT, AND

STATUTORY AND REGULATORY AUTHORITIES

A. Threats to Public Health or Welfare

Conditions at the Site present an imminent and substantial

endangerment to human health and the environment and. .meet

the criteria for initiating a Removal Action under 40 C.F.R.

section 300.415(b) (2) of the NCP.' The following factors

from Section 300.415(b) (2).o f the NCP, form the basis for

EPA's determination, of the threat presented and the

appropriate action to be taken: j •

i •

Actual or potential exposure to nearby human '

populations, animals or the food chain from

hazardous substances or pollutants or contaminants;

(iv) High levels of hazardous substances or pollutants,

largely at or near the surface of residential soils,

that may migrate. i

Because the properties in question are already being used as

residences, there is a significant, immediate potential for

continued exposure of human population to unacceptable

Page 6 of 11
levels of lead and arsenic in surface soils. EPA ..

toxicologist Susan Griffin, Ph.D., DABT, has reviewed the

data and supports EPA's determination of action levels for

this proposed Removal Action. . • ;. •

to the Environment

The primary threat identified is exposure to human

populations. Pets, and to a lesser degree wildlife, would

be affected as they come into direct contact with the

contamination within the residential areas.

IV. ENDANG DETERMINATION

The actual or threatened releases of hazardous substances, from

this Site, if

 not

 addressed by implementing the response action

selected in this Action Memorandum, may present an imminent and

substantial endangerment to public health or welfare or the

environment.

V PROPOSED ACTIONS AND ESTIMATED COSTS

A proceed Actions

1. Action description

The primary objective of this Removal Action is to

mitigate the threats posed by contaminated soils which

are present at the Site. The Removal Action .consists of

Site Stabilization, Removal and Disposal, and Site

Restoration. .The details of this Removal Action will be

presented to the PRP in order to develop a Work Plan

acceptable to EPA. The Work Plan is anticipated to be

included with the UAO expected to be issued to AR for

tnis Site.

The work includes: , ,

- Categorization and inventory of soils as necessary for

the approximately 20 residences within the Pine Canyon

residential area;

•- Disposal of the contaminated soil at properly designed

on-site repository; and

_ Restoration of the excavated areas with clean soil;

restoration of properties to previous site conditions.

_ Bottom-of-excavation sampling to be utilized for

future institutional control purposes.

Page 7 of 11
Subsequent actions will be performed to the extent

necessary to protect human health or the environment and

to mitigate the threat of release of hazardous

substances present. . j

2. Contribution to Remedial Performance

This Removal Action is consistent with the long--term •

remedial action anticipated to be taken at the IS&R

Site. This Removal Action will complete the cleanup for

the Pine Canyon Township residential area portion, of the

IS&R Site; therefore, no further/remedial action is

anticipated to be required for this portion of the' IS&R

Site. • ; ' .:••; • ".. _

3. Description of Alternate Technologies .

Alternative technologies- were developed based -on the ',

intended and actual, land use designation in -the Pine

Canyon Township: residential. Two options were

considered and evaluated based on overall protection to

human, health and the environment, short and long-term

effectiveness, implementability and cost. .

(1) Excavate all soils (0-18 inches below ground surface

(bgs)) above lead remediation (waction"> .level and

backfill with clean topsoil. '

(2) Cover all soils (0-18 inches bgs) above lead

remediation level with clean topsoil. .-

4 . Engineering Evaluation/Cost Analysis (EE/CA)

An EE/CA is not required for this action. As discussed

in paragraph 3, above, two options were considered and

evaluated based on overall protection to human health

and the environment, short and long term effectiveness,

and implementability. Alternatives were based on the

intended-and actual residential land use in Pine Canyon.

The chosen option is Alternative 1, Excavation and

Backfill for Contaminated Soils, based on its-superior

protection of human health and the environment '

consistent with the residential cleanups that -have been

performed at other Utah sites. ;

5. Applicable or Relevant and Appropriate Requirements

(ARARa) .

This Removal Action will attain, to the extent

practicable, considering the exigencies of the :

P.age 8 of 11
situation, all applicable or relevant and appropriate

Federal, State or local standards, criteria or

regulations . (ARARs) , whichever are more stringent, for

this Removal Action. A proposed list of ARAR?.

identified for this Removal Action, is presented in

Figure 3 (attached). The PRP may. provide additional

ARARs for this Action, subject to EPA approval.

6. Project Schedule

The cleanup will be conducted in the 2004 construction

season and completed within approximately 12 months

after its initiation.

B. ggjfcimated Costs

EPA anticipates that the entire cost of the Removal will be

borne by AR, including oversight costs (to be billed

subsequent to completion of this Removal Action.) Oversight

will be conducted primarily by the US Bureau of Reclamation

in coordination with the EPA and UDEQ Remedial Project

Managers. The estimated costs of EPA performing the

proposed action are as follows:

Extramural

Mob-Demobilization . $5,000

Labor 750,000

Equipment 32,000

General Subcontracts 35,000

Analytical

Travel '2°

Subtotal . . $996,000

Large Subcontracts .

Disposal 770,000

Acquire Fill & Soil 240,000

All Transportation - -510,000

Subtotal $1,520,000

BOR Design Plat (s) 10,000

START Sampling . 10,000

Subtotal $20,000

Total $2., 536, 000

Extramural Contingency (20%) $507,200

Extramural Total $3,043,200

EPA Costs $1°°' 000

Total Cost . $3,143,200

Page 9 of 11
ThPse estimates do not include pre-judgement interest or indirect

«*Q do not take into account other enforcement costs,

including Department of Justice costs. The estimates are for

^?,,«?rative purposes only and their use. is not intended to

1

iia?P anv rights for responsible parties. ! Neither the", lack of

"®*i costs estimates nor deviation of actual costs from this

estimate will affect the United States' right to cost recovery.

VI EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED

OR NOT TAKEN |

if no removal action is taken or if action! is delayed, the ^ •

?H*nts in the Site will continue to be exposed to high levels

•

r

?

S

^a2 and arsenic, the residential contamination would

continue to present an unacceptable risk to the current

residents.

VII. OUTSTANDING POLICY ISSUES

I

None j

VIII. ENFORCEMENT ,

This work is being conducted .through the uU of EPA CERCLA .

This

 wo** authority. A Confidential Enforcement Memorandum-is

^heTas Attaint 1. EPA anticipates: that the potentially

Snnlible party for the Site, AR, will complete the work under

a

eUnilateral Administrative Order to be issued subsequent; to this

Action Memorandum. . . j

IX. RECOMMENDATIONS . |

TV^C, decision document represents the selected Removal Action for

?£i international Smelting and Refining Site in Pine Canyon,

5 no rnuntv, Utah. The selected Removal Action was- developed

^rdance with CERCLA, as amended, and is not inconsistent

with the NCP? This decision is based on the administrative •

record for the Site.

renditions at the Site met the NCP criteria for a removal set -

f

 ti at 40 C.F.R. section 300.41.5 (b) (2) alid I recommend your

approval of the proposed PRP-lead Removal Action.

Date:

Approve:

Max H. Dodson . !

Assistant Regional Administrator

Office of Ecosystem Protection and Remediation

i

Page 10 of 11 !
Disapprove: _ _ . Date:.

Max H. Dodson .

Assistant Regional Administrator : • • '.-

Office of Ecosystem Protection and Remediation

Attachments:

Figure 1 -

 MaP of IS&R site

Figure 2 - Detailed map of IS&R Site showing residential areas

Figure 3 - Applicable or Relevant and Appropriate Requirements

Attachment 1 ~ Confidential Enforcement Addendum .

Page 11 of 11
.

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Figure 3

Applicable or Relevant and Appropriate Requirements (ARARs)

International Smelting and Refining Action Memorandum

Table 1-Chemical Specific ARARs

y

asties

. generated during the removal actions wi 11 be identified and listed as

261 hazardous wastes, as appropriate.

CFR Part"

50

Listing of

Hazardous waste

Nationa AM alternatives win meet tne emission standards or this regulation.l Amoient

Air Quality

Standards (NAAQS)

TATE:

ikd Rjlb-2-1 identification and

Listing of

Hazardous waste

tastes generated during the removal actions win oe identified ana listed as

hazardous wastes, as appropriate.

All alternatives will comply with storm water runoff requirements to protect surrace

neater bodies

RJ17-2 surface water

Protection

RemoWTof"contaminated soil would promote protection or ground water. Repository

will be constructed to not be near groundwater, so action is expected to comply witn

this standard. ^ , ,

Emissions from the excavation and disposal operations win meet we standards

this regulation. Removal actions are not expected to cause significant «*-**

emissions.

UAC" Ril7-b

UAC R315-8-6

Ground water T1!

Quality Protection

Rule ;

UAC R307-

201-1(1)

Eini ssi on Standards

- visible Emissions

UAC R307-20S Emission standards:

Fugitive Emissions

and Fugitive Dust

Fugitive dust wi.. __ _

excavation, disposal, and soil covering.

controlled during ground disturbing activities sucn as

Page 1 of 7
Table 2 - Action Specific ARARs

FEDERAL:

Generation of

Hazardous waste

Closure

surface water

Control

Staging Piles

Criteria for

Classification

of solid waste

Disposal and

Practices

Resource

conservation and

Recovery Act, 40

CFR Parts 262

and 263

40 CFR 264

Subpart G

40 CFR 264.310

40 CFR

264.554(d)

40 CFR 264.554

40 CFR 257.3

Requirements for hazardous

vaste generators and for

tazardous waste

transporters

Requirements for post

closure that ensure

prevention of dermal and

ingest ion exposure and

contaminant transport.

Surface water control

measures required for

staging piles

Requirements for staging

piles

Regulates classification

and disposal of solid

waste.

land! ing and transportation of hazardous wastes will

be performed in compliance with this ARAR.

if contaminated soils above PRGs will remain in place,

actions, such as placement of soil covers, must be

taken to prevent dermal and ingestion exposure and

contaminant transport. The materials going into

repository are being consolidated in an area of

contamination.

All removal alternatives using staging piles will

operate run-on/run-off controls to protect human

health and the environment.

All removal alternatives using staging piles will

address temporary storage of remediation wastes 1n

piles during removal activities.

All alternatives will manage the solid waste in

accordance with these regulations.

STATE: ^

corrective

Action cleanup

Hazardous waste

Generator

Closure and

Post-Closure

UAC uii-m

UAC R315-1

Cleanup standards.

Contaminated soi i removal

regulations

Closure Regulations

The removal alternatives win employ appropriate

measures to control or remove contaminant sources and

will utilize soil cleanup standards that are

protective of public health and the environment.

Handling and transportation or nazardous wastes win

be performed in compliance with this ARAR. _^^

Closure will DC performed to minimize mninteiiain.c «iu

threat to human health and the environment.

Alternatives leaving contaminated soil in place or

disposing of contaminated soil 1n an on-site

repository will conduct 30-year post-closure care if

Page2of 7 Mf 7.WM
utanl

Emissions UAC R307-405-6

UAC R307-413-2

UAG R307-401-6

RcgulationsTfor the

emission Into the air

„.. alternatives Will prevent emissions or aTT

contaminants in significant quantities. All

alternatives will meet applicable emission

requirements of R307 and the Utah State Implementation

Plan. .

if emissions exceed the de minimis standards, then

compliance with R307-401-6 is required.

soiia ana

Hazardous

Definitions

I UAC RilS-l solid and Hazardous waste

Definitions and References

lApplicable definitions and references can be found in

\this regulation.

waste PIles

Landti MS

owner

Responsibility

for

Solid waste

UAC Rili-8-lZ

UAC RJ15-B-14

UAC R315-301-3

Establishes requirements

for waste piles to prevent

contaminant migration to

adjacent subsurface soil,

groundwater or surface

[water.

cTos and

installation ot Landfills

solid waste disposal

requlrements

ese measures will b£ taken, including installation

of appropriate liners and leachate collection systems

as necessary.

These standards are ;

applicable to alternatives

that involve the generation

of solid waste and the

disposal of that waste in

an on-site repository. They

are relevant and

appropriate to alternatives

that involve placement of a

cover over contaminated

soil that remains In place.

These regulations wi 11 be followed for any disposal of

waste. ^_^__^__ ^_

wastes generated during the removal activities

will be managed and disposed in accordance with the

Utah Solid waste Permitting and Management Rules and

the Utah solid and Hazardous waste Act. ure

Post-Closure

UAC R315-302-3 Closure wi 11 be performed to minimize maintenance and

threats to human health and the environment.

industrial son a

waste Facility

Requirements and

Landfill ing

Standards

Ground Water

Monitoring

Requirements

UAC

UAC R315-304

UAC RiliRegulations for leaving

contaminated soil in place

or dispose of contaminated

soil at an on-site

repositon

regulations for placement

of contaminated soil

Alternatives ml comply with tnese standards.

Alternatives involving the placement of solid wastes

in an on-site repository must comply with the ground

water monitoring requirements of the rule unless the

criteria of UAC R315-302-l(2)(e)(vi) or R315-308-K3)

.are met for an exception or waiver.

Page 3 of 7 MO* Julr7.M04
PIlesUsec

Storage and

reatment

Regulations tor storage 01

remediation wastes in piles

more than 90 days

ATT removal alternatives tnat store remediation wastes

n piles more than 90 days will comply with the

applicable requirements of this standard.

Cleanup and

Risk-Based

Closure standard

UAC RJli-lOl Appropriate site

management, such as

corrective action, post

closure care, and

institutional controls is

required based on

Page4of 7
Table 3 - Location-specific ARARs

FEDERAL:

For all alternatives, measures would DC taken to preserve

historic properties and minimize harm to National Historic

Landmarks. '

lationai Historic

Preservation! Act

36 CFR Part 800

40 CFR part

Historic project owned or

controlled by Federal

agency.

>aeological and'Historic

Preservation Act

4U CFR Part b.iUllc)

16 use Section 469 .

can water Act section

40 CFR Part 230,

33 CFR Part 230,

33 CFR Parts 320-330

40 CFR Part 6, Appendix A

Executive order 11990

40 CFR 6.302Ca")

it any removal activity vnn cause irreparable loss or

destruction of significant cultural resources, data recovery

and preservation activities will be conducted in accordance

with these requirements KB Wetlands

40 CFR

40 CFR 257.8

For all alternatives, measures would be taken to avoid

adverse effects, minimize potential harm, and preserve and

enhance wetlands, to the extent possible, if wetland impacts

do occur, measures would be taken to restore or mitigate

wetlands.

Actions taken witnin 1UOyear floodplain

For all alternatives, activities wouia eitner occur outsiae

the 100-year floodplain or designed and maintained to prevent

washout of the soil covers. Floodplain regulations are

Relevant and Appropriate to on-site activities related to 1nsitu waste closure or movement and consolidation of

remediation waste within the area of contamination. These

regulations are applicable to activities involving generation

or placement of solid waste.

PaoeSof 7

WT7.M04
rotection ofFloodplains

40 CFR 6, Appendix A);

ish and wildlife

.oordination Act (16 USC 661

t seg.)

0 CFR 6.302(b) & (g)

Executive order 11988

(Floodplain Management

Regulations)

within floodplain, natural

streams, and bodies of

water.

usc 1531 et

40 CFR 6.302(n)

Migratory Bird Treaty Act

(16 use §§ et

>li cable

For all alternatives, measures would be taken to avoid

adverse, effects, minimize potential harm, restore and

preserve natural and beneficial values of floodplains. Fish

and wildlife habitats in natural streams and bodies of water

would be protected as necessary. Compliance with the

consultation requirements of the fish and wildlife provisions

would occur.

Protection or endangered

species and migratory

birds

ppncaoie to an alternatives, if endangered species or'

migratory birds are present at the site.

STATE:

UAC RJ15-J02-1

IUlb-8-2.

Location standards ror

disposal facility

Solid waste management tacitity wi1 1 be located in accordance

with this regulation. These regulations are applicable to

activities involving generation or placement of solid waste. ^^"^^^•"Tr*^""TMTT^TM^^^"^ff^'^^^^^'^^^"""^T^*"""1

^^"^""^"•"^~*—^"^^^^•^•^*TM"^—^^"•^^"^•TM"-"^TMTM'—^*""*—^•^TMl

Fiooapiains For all alternatives, activities would either occur outside

the floodplain or designed and maintained to prevent washout

of the soil covers. Floodplain regulations are Relevant and

Appropriate to on-s1te activities related to in-sltu waste

closure or movement and consolidation of remediation waste

within the area of contamination. These regulations are

applicable to activities involving generation or placement of

Page 6 of 7 Mud: My 7.2004
-r'

Table 14-4 - To Be Considered (TBC) Material

Clarification tb the

1994 Revised Interim

Soil Lead Guidance for

CERCLA sites and RCRA

corrective Action

Facilities

OSWER Di rective

#9200.4-27?

August 1998

centers ror Disease

Control and Prevention

(CDC) Guidance for

determining soil lead

action levels

office of Solid waste and Emergency Response (OSWER) recommends that the

integrated exposure uptake and biokinetic (IEUBK) model be used as the

primary tool to generate risk-based soil cleanup levels at lead sites for

current or future residential land use. in selecting management

strategies, it Is OSWER's preference to seek early risk reduction with a

combination of engineering controls (actions which permanently remove or

treat contaminants, or create reliable barriers to mitigate the risk of

exposure; and non-engineering response actions (such as education and

health intervention programs). As a given project progresses, OSWER

recognizes the NCR preference for permanent remedies and emphasizes

selection of engineering over non-engineering remedies for long-term

response actions.

"Preventing Lead

Poisoning in Young

Children: A statement

by the Centers for

Disease control",

October 1991

CDC recommends that tnere snouia oe no more than a !> percent chance tnat

children aged 1 to 3 have blood levels higher than 10 ug/dL.

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