EPA Focused Feasibility Study; Lead in Residential Soils and Lead and Arsenic in Residential Dust; Community Soils OU

Transcription

1 ANACONDA SMELTER NPL SITE EXECUTIVE SYNOPSIS: EPA Focused Feasibility Study; Lead in Residential Soils and Lead and Arsenic in Residential Dust; Community Soils OU April 2012 Arrowhead Foundation

2 Contents Acronyms.. ii Introduction.1 Focused Feasibility Study Goals.2 Suggested Alternatives..3 Comparison Criteria.5 Conclusion 7

3 i Acronyms CPMP DEQ DPS EPA FFS ICs Mg/kg* OU Ppm* PRG Community Protective Measures Program Department of Environmental Quality Development Permit System Environmental Protection Agency Focused Feasibility Study Institutional Controls milligram per kilogram Operable Unit parts per million Preliminary Remediation Goals * Note: ppm and mg/kg are equivalent when measuring quantities of lead in soil. ii

4 Executive Synopsis: EPA Focused Feasibility Study on Lead in Residential Soils and Lead and Arsenic in Residential Dust; Community Soils Operable Unit, Anaconda Smelter NPL Site Introduction In 2002, the U.S. Environmental Protection Agency (EPA) and the Montana Department of Environmental Quality (DEQ) approved a remedial action work plan for found arsenic concentrations in the community soils of the Anaconda Smelter Superfund Site. Since then, the sampling and cleanup of arsenic concentrations for the Community Soils Operable Unit (OU) have also identified high concentrations of lead in some residential yards, as well as concentrations of lead and arsenic in interior residential dusts. Out of 147 yards sampled for lead during arsenic remediation, it was found that 63% of yard components (individual components within all yards sampled) had lead concentrations above 400 milligrams per kilogram (mg/kg) also referred to as parts per million (ppm). Similarly, 66% of all yards had an average lead concentration level above 400mg/kg. While there is no established action level for lead, the nation-wide Superfund Lead-Contaminated Residential Sites Handbook (EPA 2003) establishes 400mg/kg as the beginning range for concern in soil lead concentrations. The handbook also includes a high range, not-to-exceed level of 1,200mg/kg. The EPA notes that lead exposure can be very hazardous to pregnant women and children up to 7 years old. Yard Components Yard Averages* 63% have lead concentrations above 400mg/kg 66% of yards have an average lead concentration exceeding 400mg/kg - 20% of components exceed 800mg/kg - 8% components exceed 1,200mg/kg - 10% of yards exceed 800mg/kg - 1% of yards exceed 1,200mg/kg * N = 142, not 147. Entire yard data only available for 142 yards. 1

5 Focused Feasibility Study Goals The EPA has compiled a Focused Feasibility Study (FFS) on Lead in Residential Soils, and Lead and Arsenic in Residential Dust (2012) in order to add the process of lead remediation to the Smelter area s 1996 Community Soils OU (currently addressing only arsenic). The study uses lead levels based on the Lead Handbook as well as Anaconda site-specific preliminary remediation goals (PRGs) of 400mg/kg, 500mg/kg, 700mg/kg, and 1,200mg/kg as examples of cleanup levels for evaluating remediation alternatives. Three feasible cleanup alternatives are analyzed and put forward for the ultimate remediation of our community residences. These alternatives will direct the EPA and the Department of Environmental Quality in their adoption of a preferred alternative for remediation. Each remediation alternative attempts to address: 1. lead in surface and subsurface soils; 2. lead and arsenic in interior, accessible attic dust; and 3. how the alternative will affect current Institutional Controls (local services overseeing requirements/opportunities for individuals). The EPA notes that non-mining lead (lead-based paint, lead pipes, lead solder, etc.) may account for a significant percentage of lead contamination, and, though outside EPA jurisdiction, needs to be addressed for long-term remediation success. 2

6 Suggested Alternatives Alternative 1 identified by the FFS is No Further Action. This alternative provides no additional cleanup of lead in soils or dust, but relies on current Institutional Controls (ICs), such as the Development Permit System, to manage the development of unremediated properties. It does provide continued development for the Community Protective Measures Program (CPMP) established in the 1996 Community Soils OU decision, which promotes the dissemination of information to homeowners, realtors, and developers. Alternative 2 identified by the FFS is Limited Remediation with Expanded ICs. This alternative addresses lead in soils with action to remove 0-2inches of surface soil if the average lead concentration of the unremediated property exceeds its site-specific PRG. Also, all yard components (including components from properties previously remediated for arsenic) with a lead concentration greater than 1200mg/kg would be removed and replaced to the maximum depth of 12 inches. Here, subsurface soils that are greater than the site-specific PRG, but that are less than 1200mg/kg would remain in place. Alternative 2 addresses household dust with sampling and remediation if lead concentration PRG or arsenic action levels are exceeded. Institutional Controls play a major role, and involve amending the existing program for arsenic in dust to include lead, as well as adding requirements to obtain a permit for renovations involving possible exposure to dust, and strengthens the CPMP mechanism for the dissemination of information. Expanded ICs also provide for a Multipathway program to address non-mining lead contamination (paint, pipes), and a voluntary blood monitoring program to identify additional sources of lead exposure. Funds for the Multipathway program, however, would not be provided by the EPA, as the program exceeds EPA reach, and would require another funding source(s). Alternative 3 identified by the FFS is Complete Remediation with Current ICs. Alternative 3 calls for the complete cleanup of all yard components that exceed lead PRG to a depth of 12 inches. This alternative focuses on all contaminated yard components, rather than focusing on average lead concentration per yard. Additional sampling would be conducted on unremediated yard components of properties previously remediated under the arsenic soils cleanup. This alternative takes the most stringent action on lead in residential soils. Paint and interior dust sampling would occur concurrently with soil sampling, and dust remediation would include cleanup of accessible interior dusts if the lead PRG and arsenic cleanup levels are exceeded. Mitigation of lead paint, if found, would be encouraged prior to remediation, however, this mitigation would not be funded by the EPA as paint is a non-mining source. IC changes for alternative 3 include the amendment of arsenic programs to include lead, strengthening the CPMP for information dissemination, and amending the permit system to include attic dust sampling before renovations. 3

7 Alternative 1 No Further Action No additional cleanup of lead in soils or dust relies on current ICs to manage unremediated property development continues CPMP development, such as getting information on potential exposure to homeowners, realtors, developers Alternative 2 Limited Remediation with Expanded ICs Cleanup of 0-2" of soil if yard average exceeds lead PRG, plus Removal and replacement of yard components with lead greater than the maximum 1,200 mg/kg level Leaves subsurface soils with lead less than the 1,200mg/kg maximum in place Interior accessible dust sampled concurrently with soil, and remediated if lead concentration PRG or arsenic action level is exceeded Expands ICs with: renovation permit requirements; improving information on potential exposure (CPMP); and adds a Multipathway Program to address non-mining lead contamination issues (no funding provided) Alternative 3 Complete Remediation with Current ICs Cleanup of all yard components exceeding lead PRG to a depth of 12" Interior accessible dust sampled concurrently with soil, and remediated if lead concentration PRG or arsenic action level is exceeded Calls for lead-based paint abatement (no funding provided) Expands ICs with: renovation permit requirements; and improving information on potential exposure (CPMP) ICs Institutional Controls CPMP - Community Protective Measures Program PRG- Preliminary Remediation Goals. Site-specific Lead PRG levels: 400, 500, 700 or 1,200mg/kg 4

8 Comparison Criteria The EPA will consider the above options looking at 9 criteria for comparison. The following are the FFS evaluations of each alternative to criteria. In regards to the Protection of Human Health and the Environment, Alternative 1 is not protective. Alternative 2 is protective, remediating 0-2 of surface soil if the yard average exceeds lead PRG, and further remediating 12 of soil in yard components exceed 1,200mg/kg. Alternative 3 is the most protective, remediating all yard components that exceed the lead PRG to a depth of 12 inches. In Compliance with Relevant federal and local Requirements, all of the alternatives comply. In Long-term Effectiveness, Alternative 1 ranks least effective. Alternative 2 is effective, but ranks lower than Alternative 3 because subsoil (2 and deeper) contaminants are left in place if lead concentration is less than the maximum 1,200mg/kg. Alternative 3 is the most effective with 12 of soil removal being conducted if any component exceeds the site s lead PRG. In the Reduction of Toxicity, Mobility, or Volume through Treatment, all alternatives rank low due to the absence of actual treatment to the lead contaminants. In Short-term Effectiveness, Alternative 1 has a low effect with contaminants remaining. Alternatives 2 and 3 are both effective and have similar implementation times. Alternative 2 would take approximately 2-4 years for completion, and Alternative 3 would take 3-6 years. Considering Implementability, Alternative 1 has no new implementation issues. Alternative 2 ranks most difficult in Implementability, as it requires additional funding sources for a costly Multipathway Program. Alternative 3 ranks highest in implementation, though obliges a local solution for lead-paint abatement. Looking at Cost to the EPA, Alternative 1 incurs no additional costs. Alternative 2 is estimated at $2,920,000 - $4,670,000, but this does not include costs for non-mining aspects such as the Multipathway Program, and IC components such as permits and public information. Alternative 3 estimates $3,290,000 - $4,960,000, but also does not include costs for the IC components or a lead-paint abatement solution. The criteria of State Acceptance and Community Acceptance have yet to be determined. 5

9 Nine Criteria for Alternative Selection 1. Protection of Human Health and the Environment Alternative 1: Not protective Alternative 2: Protective Alternative 3: Most protective 2. Compliance with Relevant Requirements Alternatives 1, 2, 3 all comply 3. Long-term Effectiveness Alternative 1: Least effective Alternative 2: Effective Alternative 3: Most effective 4. Reduction of Toxicity, Mobility, or Volume through Treatment Alternatives 1, 2, and 3: all rank low. No treatment utilized 5. Short-term Effectiveness Alternative 1: Low effect Alternative 2: Effective with 2-4 years completion time Alternative 3: Effective with 3-6 years completion time 6. Implementability Alternative 1: No new implementation issues Alternative 2: IC components (Multipathway program) require funding Alternative 3: Ranked highest in implementability 7. Cost Alternative 1: No additional costs Alternative 2: $2,920,000 - $4,670,000 estimated. Not including Multipathway program costs to be met by county Alternative 3: $3,290,000 - $4,960,000 estimated. Not including lead-paint abatement costs to be met by county 8. State acceptance Alternative 1, 2, and 3: To Be determined 9. Community acceptance Alternative 1, 2, and 3: To Be Determined 6

10 Conclusion A preferred alternative will be selected by the EPA/DEQ in Proposed Plan to amend the standing 1996 Community Soils OU Record of Decision, and at that time will be distributed for public comment. The alternative may be one of the 3 alternatives put forth here, a combination of them, or an entirely new alternative based on discussion and evaluation. Local feedback and an issued community position, therefore, would be valuable in the overall process of reflecting community opinion. 7

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