feasibility study for residential areas (ou-1)feasibility study for residential areas (ou-1) st....

FEASIBILITY STUDY FOR RESIDENTIAL AREAS (OU-1) St. Francois County Mined Areas (Big River Mine Tailings Site), Missouri July 6, 2011 Prepared by:

730 17th Street, Suite 925 Denver, Colorado 80202

Feasibility Study for Residential Areas (OU-1) St. Francois County Mined Areas (Big River Mine Tailings Site) July 6, 2011

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TABLE OF CONTENTS Page

1.0 INTRODUCTION................................................................................................... 1 1.1 Report Organization .................................................................................. 1 1.2 Definitions.................................................................................................. 3

2.0 SITE CHARACTERISTICS ................................................................................... 4 2.1 Site Description and Physical Setting........................................................ 4 2.2 Exposure Pathways and Constituent of Concern ...................................... 6 2.3 Nature and Extent of Contamination ......................................................... 6 2.4 Scope of the Feasibility Study ................................................................. 12

3.0 IDENTIFICATION OF REMEDIAL ACTION OBJECTIVES ............................... 14 3.1 Remedial Action Objectives..................................................................... 15 3.2 Identification of Applicable or Relevant and Appropriate Requirements . 15

3.2.1 Potential Chemical-Specific ARARs ............................................ 17 3.2.2 Potential Location-Specific ARARs.............................................. 17 3.2.3 Potential Action-Specific ARARs ................................................. 17 3.2.4 Other Guidance To Be Considered (TBC)................................... 27 3.2.5 Data Needs.................................................................................. 27

4.0 REMEDIAL ACTION TECHNOLOGY SCREENING AND ALTERNATIVE DEVELOPMENT................................................................................................. 27 4.1 Technology Identification and Screening................................................. 27

4.1.1 No Action ..................................................................................... 29 4.1.2 Institutional Controls .................................................................... 29 4.1.3 Public Health Actions................................................................... 32 4.1.4 Containment ................................................................................ 33 4.1.5 Soil Removal................................................................................ 34

4.2 Remedial Alternative Development ......................................................... 34 4.2.1 Alternative 1 – No Action ............................................................. 35 4.2.2 Alternative 2 – Soil Removal with 12-inch Subgrade Visual

Barrier .......................................................................................... 35 4.2.3 Alternative 3: Soil Removal with 24-inch Excavation.................. 36

5.0 REMEDIAL ALTERNATIVE EVALUATION ....................................................... 37 5.1 Threshold Criteria .................................................................................... 37 5.2 Primary Balancing Criteria....................................................................... 38

5.2.1 Short-Term Effectiveness ............................................................ 38 5.2.2 Long-Term Effectiveness/Permanence ....................................... 39 5.2.3 Reduction of Toxicity, Mobility, or Volume through Treatment .... 39 5.2.4 Implementability........................................................................... 40 5.2.5 Cost ............................................................................................. 40

5.3 Modifying Criteria..................................................................................... 41 5.4 Individual Remedial Alternative Evaluation ............................................. 41

5.4.1 Alternative 1 – No Action ............................................................. 41 5.4.2 Alternative 2 – Soil Removal with 12-inch Subgrade Visual

Barrier .......................................................................................... 41 5.4.3 Alternative 3 – Soil Removal with 24-inch Excavation................. 44


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TABLE OF CONTENTS (cont) Page

5.5 Comparative Analysis of Alternatives ...................................................... 49

5.5.1 Threshold Criteria ........................................................................ 49 5.5.2 Short-term Effectiveness ............................................................. 49 5.5.3 Long-term Effectiveness and Permanence.................................. 54 5.5.4 Reduction of Toxicity, Mobility, or Volume through Treatment .... 54 5.5.5 Implementability........................................................................... 54 5.5.6 Cost ............................................................................................. 54 5.5.7 Modifying Criteria......................................................................... 55

6.0 RECOMMENDED ALTERNATIVE ..................................................................... 55 7.0 REFERENCES.................................................................................................... 55

LIST OF TABLES Table 1 Residential Yard Status after Interim and Halo Removal Actions ................... 8 Table 2 Yard Soil Lead Distributions by Community within the Response Area .......... 8 Table 3 Number of Yards with Designated Areas above 400 ppm lead..................... 13 Table 4 Calculation of Yards Reduction based on EPA’s Pre-ROD Removal............ 13 Table 5 Yard Statistic Extrapolation Percentages for Potential Yards........................ 14 Table 6 Summary of Potential Chemical-Specific ARARs.......................................... 18 Table 7 Summary of Potential Location-Specific ARARs........................................... 19 Table 8 Summary of Potential Action-Specific ARARs............................................... 23 Table 9 Summary of Remedial Technologies and Process Options .......................... 30 Table 10 Detailed Cost Estimate, Alternative 2 - Soil Removal with 12-Inch

Subgrade Visual Barrier ................................................................................ 45 Table 11 Detailed Cost Estimate, Alternative 3 - Soil Removal with 24-Inch

Excavation..................................................................................................... 50 Table12 Summary of Comparative Analysis of Remedial Action Alternatives ............ 52

LIST OF FIGURES

Figure 1 Response Area and Halo, St. Francois Co. Mined Areas ............................... 2 Figure 2 Interim Action or Halo Removal Action Residential Yards............................... 9 Figure 3 Average Surface Soil Lead Concentrations in Yard Quadrant Samples ....... 10 Figure 4 Maximum Surface Soil Lead Concentration in Yard Quadrant Samples....... 11


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LIST OF APPENDICES

A Detailed areas of Figures 2 through 4

B Surface and Subgrade Lead Concentrations in Excavated Areas, Interim and Halo Removal Actions

C Basis of Cost Estimates


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Feasibility Study for Residential Areas (OU-1) St. Francois County Mined Areas (Big River Mine Tailings Site), Missouri

1.0 INTRODUCTION

This Feasibility Study (FS) for the residential areas within the Mined Areas in St. Francois County, Missouri (the Site), has been prepared by NewFields on behalf of The Doe Run Resources Corporation d/b/a The Doe Run Company (Doe Run). Doe Run has completed this FS for Residential Areas in fulfillment of one of the requirements of an Administrative Order on Consent (AOC) Docket No.VII-97-F-0002, dated January 29, 1997, entered into with the United States Environmental Protection Agency (EPA). The AOC identified three potential subjects for the scope of the FS; at EPA’s request, this FS addresses “residential cleanup to reduce children’s blood lead levels.”

This FS is consistent with the National Contingency Plan (NCP) (EPA 1994b) and EPA Guidance for Conducting Remedial Investigation/Feasibility Study (RI/FS) under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) (EPA 1988a).

Two removal actions have been conducted at the Site. Interim and Halo Removal Actions were conducted pursuant to EPA Docket No. CERCLA-7-2000-0015, dated April 7, 2000 and EPA Docket No. CERCLA-7-2004-0167, effective date March 30, 2004, respectively. Soils with elevated lead levels were removed from selected residential yards and child high use areas (CHUAs) based on locality, presence of a child with elevated blood lead levels, and lead yard soil concentrations. This FS focuses on the remaining residential yards containing soil lead levels exceeding 400 ppm.

The residential area within the Site has been called the Response Area in the previous two removal actions. This terminology has been maintained in this FS for consistency. Figure 1 presents the Site/Response Area as well as the area of the Response Area known as the Halo.

1.1 Report Organization

The organization of this FS is as follows:

• Section 1 introduces the CERCLA process and required deliverables.

• Section 2 summarizes the results of the two previous residential yard sampling programs and removal actions within the Site.

• Section 3 presents the site-specific remedial action objective (RAO) and the applicable or relevant and appropriate requirements (ARARs) for development of remedial alternatives.

Elvins/Rivermines

National

Doe Run

Federal

Leadwood

Desloge

Bonne Terre

Hayden Creek

LegendHalo - 100 ft from ShaftsHalo - 1000 ft from SmeltersHalo - 500 ft from TPondsHalo - 500 ft from Chat Piles

0 6,000 12,000 18,000 24,0003,000Feet

Response Area

Shafts

Smelters

Chat Piles

Tailing Ponds

Historic Railroads (inactive)

Railroad

World Street Map St. Francois Co. Mined Areas

Figure 1Response Area and Halo



• Section 4 summarizes the process of identifying and screening general response actions, technology types, and process options for use in the development and screening of alternatives.

• Section 5 presents the detailed analysis of the remedial alternatives selected from the screening process and documents the evaluation of the relative performance of each alternative and then compares the alternatives.

• Section 6 presents the recommended alternative.

• Section 7 presents the references cited in this document.

1.2 Definitions

The following definitions are provided to reduce redundancy and to ensure the reader has a clear understanding of the terms used in this report.

Response Area – the residential area depicted on Exhibit B of the Halo AOC Statement of Work (reconstructed in Figure 1). This is the EPA-designated study area for the proposed remedial action and is the area of the county where yards were addressed in the previous response actions.

Halo – that portion of the Response Area that is within 500 feet of chat and tailings waste, 1,000 feet from four identified smelters/calciners, and 100 feet from mine shafts and depicted on Exhibit A of the Halo AOC Statement of Work (reconstructed in Figure 1).

Interim Action – a sampling and removal action program conducted by Doe Run, pursuant to Administrative Order on Consent, Docket No. CERCLA-7-2000-0015, which characterized yard soil and blood lead concentrations within St. Francois County, Missouri. The yard soil sampling results collected pursuant to this program are a large part of the basis for soil concentrations used in the Halo Removal Action and in this FS.

Halo Removal Action – A sampling and removal action program conducted by Doe Run, pursuant to Administrative Order on Consent, CERCLA-7-2004-0167, effective date March 30, 2004 (referred herein as the Halo AOC). This removal action was primarily conducted within the Halo.

EBL child – a child under 72 months of age whose blood lead concentration is elevated, greater than or equal to 10 µg/dL.

Best efforts – “Best efforts” are used to obtain permission from a homeowner for either sampling or removal. Best efforts are defined in Section IX of the Halo AOC as an initial visit, a follow-up telephone call, and a certified letter to the present owner of the property requesting an access agreement to permit access to the property to conduct the activities required under a removal action.



Child High Use Area (CHUA) – A play and recreational area frequented by children and not part of a residential yard (e.g., park, apartment or school playground, or daycare yard).

BRMTS Repository – the corrective action management unit (CAMU) located at the Big River Mine Tailings Site (BRMTS), in Desloge, Missouri. This BRMTS Repository is an EPA-approved repository for the excavated residential yard soils from the Interim and Halo Removal Actions. The BRMTS Repository is still open and is expected to accept other residential yard soils from within the Response Area. Other CAMUs within the Site may also be approved to accept residential yard soil. General requirements for the operation, maintenance, and closure of the BRMTS Repository are described in the CAMU Approval Memorandum (EPA 2001) and in the Repository Operation Manual (NewFields 2003).

2.0 SITE CHARACTERISTICS

2.1 Site Description and Physical Setting

The Site is located in southeastern Missouri entirely within St. Francois County, approximately 70 miles south of St. Louis. The topography is hilly with several hundred feet of relief with altitudes ranging from about 700 to 1,000 feet above mean sea level (msl). The climate in St. Francois County is continental with cold winters and hot summers. Annual precipitation is approximately 40 inches with a rainy season in fall and winter. Average annual snowfall is 13.7 inches. Prevailing winds are from the south and west-northwest (NewFields 2006).

St. Francois County is located in a historic mining area called the Old Lead Belt. The Old Lead Belt is on the northeastern edge of the Precambrian igneous core of the St. Francois Mountains. This area is one of the world’s largest lead mining districts, having produced more than nine million tons of pig lead (HUD et al. 1997). The first recorded mining in St. Francois County occurred at Mine-a-Gabore between 1742 and 1762. The important discoveries of disseminated lead in the Bonne Terre, Leadwood, and Flat River areas occurred in 1864. The introduction of the diamond drill in 1869 facilitated the discovery of additional reserves and output from the mines increased dramatically in the late 1800s. Mine output from St. Francois County peaked in 1942 when the concentrate equivalent of 197,430 tons of lead was produced. Mining ceased in the Old Lead Belt in 1972 with the closing of the Federal mine (NewFields 2006).

The Bonne Terre area is known for surface and shallow mineralized zones as evidenced by the many hand dug mines in the Bonne Terre Mines National Historical Site (Bonne Terre 2010). Extensive mining activities in St. Francois County and that the operations of such orphan companies as the Central Lead Co., Flat River Lead Co., Union Lead Co., Columbia Lead Co., Derby Lead Co., Irondale Lead Co., Baker Lead Co., and Boston-Elvins Lead Co. have left lead contamination in various places throughout the county, and former activities of these companies and that of the even earlier mining activities (Flat



Mines ca. 1820, Bogy Mine ca. 1765, “Butcher Diggings” ca. 1820) used shallow workings that did not go into bedrock, indicated the potential for the presence of lead in the soil above the bedrock throughout the area. The name “Rivermines” indicates multiple mining activities in and along the Flat River.

It has been estimated that some 250 million tons of mill waste, tailings and chat, were produced in the Old Lead Belt from ore milling and beneficiation processes. The chat has been used extensively as aggregate for ballast in railroads, aggregate in concrete and asphalt, and fill. Some chat is used today as aggregate and fill. Tailings have been used as agricultural amendments due to the lime content.

The AOC identified eight designated mining areas: • Desloge (aka Big River Mine Tailings) • Federal (aka St. Joe State Park) • Leadwood • Bonne Terre • National Lead Site • Elvins (aka Rivermines) • Hayden Creek • Doe Run Lead Company Site (not associated with The Doe Run Company).

Past ore extraction, milling, separation, and smelting conducted in the area has resulted in elevated lead levels in soils in some areas. Blowing dust from the chat piles and tailings may provide additional opportunity for lead exposure, though the RI concluded that particulate deposition of lead from the mill waste piles is not the only contributor to yard soil lead at this Site (NewFields 2006). The use of leaded gasoline, lead solder, lead-based paint, and other lead-containing products has contributed to increased lead in soils (HUD et al. 1997). Mechanical distribution by third parties is also observed in the Site via the use of chat in road bed construction, in ballast for railroads, and as de-icing materials for roads.

Within the Site are the incorporated towns of Desloge, Bonne Terre, Park Hills, Leadwood, and Leadington and the unincorporated towns of Doe Run, Frankclay, Wortham, Gumbo, and East Bonne Terre. The population within the Site is roughly 30,000 according to the 2000 Census.

While the exact number of residential yards within the Site or Response Area is unknown, based on the 2000 census data, EPA (2010a) provided an estimate of 7,036 occupied houses within the Response Area excluding the houses within the town of Doe Run. During the Interim Action, the town of Doe Run was canvassed by the Blood Lead Sampling team and there were 93 residences within the town. Therefore, the number of residential yards within the St. Francois County Mined Areas’ Response Area is estimated to be 7,129 yards.



2.2 Exposure Pathways and Constituent of Concern

Lead in soil is considered to be the primary constituent of concern for the residents within the Site (HGL 2009). Primary exposure pathways are incidental ingestion of lead in surficial soils and inhalation of lead in dust generated from surface soil. Therefore, the exposure pathways of concern for adult and child residents are incidental ingestion of soil and dust in and about the home and yard.

The human health risk assessment (HHRA) for residential areas (HGL 2009) indicated that an action level for lead in residential areas should be lower than 400 ppm. Doe Run provided a series of memoranda demonstrating to EPA that some of the assumptions made in the HHRA were overly conservative and that the existing remedial action limit of 400 ppm is protective of St. Francois County’s children and other sensitive populations (Gradient 2010, NewFields 2010, NewFields and Gradient 2010, and Doe Run 2010). The FS action cleanup level for total lead in soils for the Response Area has been established at 400 ppm. This action level is based on the residential preliminary remediation goal (PRG) accepted by the EPA as being protective of sensitive residential receptors within St. Francois County (EPA 2010b). This was the same action level used in the Halo Removal Action.

Missouri Department of Health and Senior Services (MDHSS) reports that the percent of elevated blood lead in children less than 6 years of age in St. Francois County has dropped from 12 percent reported in the 2000 calendar year to 1 percent in the 2010 calendar year (MDHSS 2003, 2011).

2.3 Nature and Extent of Contamination

In 2000, extensive surface soil sampling was initiated as part of the Interim Action at residential yards surrounding the milling waste piles. Residential yards were sampled for lead in soil using an x-ray fluorescence spectrometer (XRF), beginning closest to the mine waste sources and then radiating outward. Composite samples of the top one-inch of soil were collected from each of the four quadrants of the yard (front left, front right, back left, back right) and the drip line from each house. The results of the program are presented in the Removal Action Report for Interim Action (NewFields 2004b).

In anticipation of the expiration of the Interim Action, Doe Run volunteered and EPA agreed to replace the Interim Action with the Halo Removal Action. The Halo Removal Action, which began on April 1, 2004, was conducted within the areas jointly called the “Halo” around the six major mine sites located in St. Francois County. The Halo Removal Action included sampling of yards within the Halo that had not previously been sampled during the Interim Action and sampling of any identified yard outside of the Halo but within the Response Area for which an EBL child resided.



At the end of the Interim Action (March 30, 2004), 1,955 yards/CHUAs had been sampled and 563 homeowners had refused sampling, for a 78 percent sampling rate. As of January 31, 2011, 2,057 residential yards and 12 CHUAs had been sampled and 532 property owners had refused yard soil sampling with a final residential yard sampling refusal rate of 21 percent. For the FS, it is projected that sampling will be attempted at 4540 residential yards. All sampling is voluntary and a 21 percent refusal rate is anticipated.

The Interim Action was designed to identify residences where soil removal or other actions may be required. Yards and areas within yards with soil lead concentrations greater than 2,000 ppm were removed. These actions were referred to as "interim actions" since they were taken prior to EPA’s issuance of long-term remedies that address elevated blood-lead levels in St. Francois County. The Halo Removal Action focused on the removal of lead contaminated residential soil within the identified Halo around the mined areas and only addressed yards outside the Halo if an EBL child was identified.

Yard soil remediation practices were consistent between the Interim and Halo Removal Actions. If a portion of the yard qualified for yard soil removal, the soil was removed to a depth of one foot. The subgrade soils were screened with an XRF; and if subgrade soil concentrations were above 400 ppm, then a visual barrier was placed across the subgrade. The excavation was backfilled with clean soil (less than 240 ppm lead). Figure 2 presents the areal distribution of these remediated yards (Note: Appendix A includes Figures 2a through 2g which depict different portions of Figure 2 in a magnified view to allow the reader to distinguish individual yard classifications; this appendix provides similar magnified views for all other figures presented in this report). Excavated soils were transported in covered trucks to the BRMTS Repository where they were stockpiled for use in the revegetation of mine wastes. Table 1 presents a summary of residential yard status as of January 2011.

As reported in the draft RI (NewFields 2006), full areal extent of elevated yard soil at the Site has not been determined. Due to the varied nature of mine waste migration from source areas, i.e., wind erosion, surface runoff, and mechanical movement, lead levels in all the surface soils at this Site cannot be predicted. Surface soil sampling in residential yards indicates that high levels of lead contamination extends significantly further from the mine waste piles than the RI air modeling or deposition sampling have predicted. Figure 3 presents the average lead concentration of the yard quadrants within the Response Area and Figure 4 presents the maximum lead concentration in the yard quadrants (see Appendix A for magnified versions of these figures in the identified subfigures). These figures show the varied nature of the lead concentrations within the Response Area. Some portion of the yard soils (yard quadrant, drive way, garden, play area, or drip zone) was above 400 ppm lead in 87 percent of all yards sampled (up through January 2011), or 84 percent when elevated drip zones only yards are excluded.

Table 2 presents a summary of the yards with elevated (greater than 400 ppm) lead concentrations within the Site by community.



Table 1 Residential Yard Status after Interim and Halo Removal Actions

Yard Status (1) Number of Yards Halo Response

Area

No Action - original surface soil < 400 ppm) 308 (2) 12% 88%

No Further Action surface soils now less than 400 ppm or property owner has refused full yard removal) 442 (3) 72% 15%

Yard with some Interim Action but still have some surface soils greater than 400 ppm 188 --- 100%

Yards with no Interim Action with surface soils greater than 400 ppm 1,113 (4) --- 100%

Estimated Number of Remaining Yards to be sampled (5) 4,540 --- 100% Notes: (1) Status based on surface soil sampling as of January 2011. For surface soil to be designated “<400 ppm” all

samples (excluding drip zone) must be less than 400 ppm (not just the average of the four yard quadrants). Status includes that all driveways or other separately sampled areas of the yard are also <400 ppm.

(2) 70 yards do have drip zones greater than 400 ppm lead. (3) 8 of these yards had the owner refuse soil removal from a portion of the yard (2 yards were elevated drip

zone only yards). 55 yards have refused full yard removal; 14 of these 55 yards have refused a further (full) yard soil remediation during the Halo Removal Action but had some yard removal during the Interim Action and therefore would not be expected to be included in the remedial action conducted as part of this FS.

(4) This yard statistic does not include the yards which refused full yard soil remediation during the Halo Removal Action or the 6 other yards no longer are classified as residential properties as they are commercial or undeveloped lots. Does include the one yard for which the property owner provided removal access during the Interim Action but would never clear the yard of personal property (such as cars) to allow removal crews access to the soil. Does include the 300 yards EPA is planning to remediate in 2011.

(5) Calculated: Total yard (7,129) – 2051 (sampled residential yards) – 6 (sampled vacant lots or rezoned commercial) – 532 yards which homeowners have refused sampling. See Cost Assumptions (Appendix C) for determination of total yards.

Table 2 Yard Soil Lead Distributions by Community within the Response Area

Driveways (DW) Yard Quads(1)

% of Elevated Yards by Number of Elevated

Quadrants Community Number Sampled

<400 >400 1 2 3 4

% of Yards with

Elevated Drip

Zones

% of Yards with

Elevated DW

% of Yards with

Gravel DW

%of Gravel

DW with Elevated

Lead Bonne Terre 311 8% 92% 7% 9% 17% 66% 86% 10% 18% 56% Desloge 459 27% 73% 17% 16% 20% 47% 63% 6% 8% 67% Doe Run 60 12% 88% 11% 25% 30% 34% 68% 23% 25% 93% Frankclay 54 48% 52% 46% 21% 25% 7% 59% 15% 17% 89% Gumbo 1 100% 0% -- -- -- -- 0% 0% 100% 0% Leadwood 210 27% 73% 31% 27% 13% 29% 73% 26% 35% 75% Park Hills 894 10% 90% 12% 17% 26% 44% 79% 16% 19% 84% Wortham 57 39% 61% 46% 37% 11% 6% 40% 23% 32% 72% All Sampled Yards (2) 2,046(2) 17% 83%(3) 15% 17% 22% 45% 74% 14% 19% 76%

Notes: (1) Status based on quadrant yard surface soil sampling. Some of the <400 yards have hot spots such as

driveways, gardens or identified child play areas with elevated yard soils >400 ppm. (2) Total number of yards is based on the yards listed in this table. Eleven yards (11) have been excluded as

they were either later converted into commercial properties, vacant, or were sampled as common areas for large apartment complexes.

(3) Yard statistic does not match the 84% statistic stated above because isolated hot spot yards (yards for which the yard quadrants are <400 ppm but a hot spot is greater than 400 ppm) are not counted. Also, 11 yards not included in the total as noted in footnote #2.

Federal

Leadwood

Desloge

Bonne Terre

Hayden CreekElvins/Rivermines

National

Doe Run

Legend

Removal Action StatusCompleted RemovalPartial RemovalRefused Complete Halo RemovalNo Action - Non-Residential

ShaftsSmeltersChat PilesTailing PondsHalo - 100 ft from ShaftsHalo - 1000 ft from SmeltersHalo - 500 ft from TPondsHalo - 500 ft from Chat Piles

Response Area

0 8,500 17,000 25,500 34,0004,250Feet

Source: Base reconstructed from Halo AOC’s Exhibits A and B

Figure 2Interim and Halo Removal Actions

Residential YardsSt. Francois Co. Mined Areas

Elvins/Rivermines

National

Doe Run

Federal

Leadwood

Desloge

Bonne Terre

Hayden Creek

LegendYard Quadrant Average Lead

Paved Yard/Non Yard<400 ppm400-1,200 ppm>=1,200 ppmShaftsSmelters

Chat PilesTailing PondsHalo - 100 ft from ShaftsHalo - 1000 ft from SmeltersHalo - 500 ft from TPondsHalo - 500 ft from Chat PilesResponse Area

0 10,000 20,000 30,000 40,0005,000

Feet


Figure 3Average Surface Soil Lead Concentrations

in Yard Quadrant SamplesSt. Francois Co. Mined Areas

Average concentration of the yard quadrant samples: Front Yard Left (FL), Front Yard Right (FR), Back Yard Left (BL), and Back Yard Right (BR).

Elvins/Rivermines

National

Doe Run

Federal

Leadwood

Desloge

Bonne Terre

Hayden Creek

LegendYard Quadrant Maximum Lead

Paved Yard/Non Yard Area<400 ppm400 -1,200 ppm>=1,200 ppmShaftsSmelters


0 10,000 20,000 30,000 40,0005,000

Feet


Maximum concentration of the yard quadrant samples: Front Yard Left (FL), Front Yard Right (FR), Back Yard Left (BL), and Back Yard Right (BR).

Figure 4Maximum Surface Soil Lead Concentrations




Subgrade confirmation sampling results from the excavation depth of 12 inches from the Interim and Halo Removal Actions were initially used to assess the nature of the lead concentrations with depth. The subgrade lead measurements were taken in situ at a minimum of 5 locations per yard quadrant and 3 locations per hot spot until 2007. From 2007 the subgrade lead measurements have been taken using a horizontal composite sample collected similarly to the surface soil sample (5-part horizontal composite with each aliquot collected from the subgrade surface to one inch below subgrade). All subgrade surfaces were cleared of loose soil prior to either in situ measurements or aliquot collection to ensure the measured lead concentration represented the subgrade. The yard quadrants and the isolated hot spot areas have been classified into three subgrade lead concentration categories (less than 400 ppm, between 400 and 1,200 ppm, and greater than 1,200 ppm) using either the average of the in situ subgrade measurements or the subgrade composite sample result. Appendix B presents the paired surface soil and subgrade lead concentrations and categories for the remediated yard soils. Comparisons of the surface soils when classified similarly to the subgrade lead concentration categories indicate a significant number of yards increase in lead concentration with depth.

Surface soil lead concentrations and the subgrade lead concentrations at the one foot excavation base were reviewed to determine extrapolation statistics for future work in the Response Area. EPA and Doe Run agreed that additional information regarding lead concentrations with depth was needed and a subsurface soil investigation was conducted in 2011. To ensure that the study provided data for the entire Response Area rather than just near the mine waste piles, 58 yards were randomly selected from the Response Area and 45 of these yards provided new surface soil data in addition to the subsurface data. The results of the subsurface soil investigation are presented in Subsurface Soil Investigation in Residential Areas, St. Francois County Mining Areas (NewFields 2011). Based on the report, 7 percent of the areas which will require yard soil removal will have lead concentrations greater than 1,200 ppm in the 12 inch subgrade soils.

2.4 Scope of the Feasibility Study

To determine the scope of the remediation to be addressed in this FS, the number of yards, which still have surface soil lead concentrations greater than 400 ppm, needs to be determined. As discussed and presented above in Table 1, 1,301 residential yards have been sampled and are known to have surface soil lead concentrations greater than 400 ppm (excluding yards with elevated yard soil within the drip zone only). These yards are defined for this FS as “known yards.” These yards are all located within the Response Area but outside of the Halo. The known yards will be used to extrapolate potential areas of remediation in residential yards which have not been sampled to date. Of these 1,301 yards, EPA has identified 300 yards which will be remediated prior to the final Record of Decision; therefore, the number of known yards in the FS cost estimates is 1,001.



As yards have been remediated based on sampled area rather than by property, Table 3 has been prepared based on the 1,301 known yards which were sampled but not fully remediated as part of the Interim or Halo Removal Actions (Halo yards are not included in this statistics). .

Table 3 Number of Yards with Designated Areas above 400 ppm lead

Additional Areas or Hot Spot (1) Yards Driveway Garden Play Area One Yard Quadrant 218 18 6 15 Two Yard Quadrants 242 16 8 27 Three Yard Quadrants 328 25 18 26 Four Yard Quadrants 488 54 39 77 Additional Area (Hot Spot) only (1) 25 15 4 5

Notes: (1) Hot Spots are areas of the yard that can be identified for specialized uses, such as driveways,

vegetable gardens, child play areas (including swing sets and sandboxes) that have soil concentrations >=400 ppm.

EPA is planning to conduct soil removal at identified CHUAs and 300 of the known yards included in Table 3 prior to the Record of Decision (ROD). Based on the variation in the 372 yards identified by EPA to potentially be included in the action, the number of known yards was reduced by 300 yards with 89 percent from the 4 quad properties and 11 percent for the 3-quad properties. Table 4 summarizes the excavation areas in the known yards and the 372 identified yards, as well as the assumed reduction calculated for the 300 yards.

Table 4 Calculation of Yards Reduction based on EPA’s Pre-ROD Removal

All Known Yards EPA Potential

Pre-ROD Yards (372 identified yards)

Yards Assumed to be part of the 300 and subtracted from the “all known yards”

Removal Requirements

Yards DW GD Yards DW GD Yards DW GD 1 Quad 218 18 6 0 2 Quad 242 16 8 1 3 Quad 328 25 18 41 9 4 33 7 3 4 Quad 488 54 39 330 36 26 267 29 21 Other 25 15 4 0

The statistics for the original “known yards” (Table 3) are converted to percentages in Table 5.

As presented in Table 1, 4,540 residential yards are estimated to require sampling to determine whether the yard soils will require removal (greater than 400 ppm lead). As there is no discernable pattern to estimate yards with elevated lead concentrations in the unsampled residential yards of the Response Area, the 84 percent rate observed in all the previous sampling is used to predict the number of “potential” yards yet to be sampled that will require removal action and is assumed to be 3,012 yards. The


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percentages presented in Table 5 are used in this FS to estimate remedial requirements of the potential yards.

Table 5 Yard Statistic Extrapolation Percentages for Potential Yards

Additional Areas or Hot Spot (1,2) Yards Driveway Garden Play Area One Yard Quadrant 17% 8% 3% 7% Two Yard Quadrants 19% 7% 3% 11% Three Yard Quadrants 25% 8% 5% 8% Four Yard Quadrants 38% 11% 8% 16% Additional Area (Hot Spot) only 2% 1.2% 0.3% 0.4%

Notes: (1) Hot Spots are areas of the yard that can be identified for specialized use, such as driveways, vegetable

gardens, child play areas (including swing sets and sandboxes). (2) Percentage of additional areas is the percentage of the yards within the quadrant category that has an

elevated additional area or Hot Spot with exception of Additional Area Only category which is the percentage of all yards sampled that have that category of hot spot with no yard quadrant soil elevated.

For any yard that has 3 or 4 yard quadrants with surface soil greater than 400 ppm lead, any identified garden or play area was assumed to fall within one of the quadrants to be remediated and therefore was not assessed separately. However, if only one or two yard quadrants are elevated, it was assumed that the garden or play area may not fall within that quadrant(s) and therefore the garden and/or play areas were evaluated as a separate area.

The following assumptions, based on the 2011 subsurface soil investigation, were made regarding lead concentrations with depth in portions of the yard for which soil removal is required:

• Twelve (12) percent of the excavated areas will have subgrade concentrations greater than 400 ppm after a 12-inch excavation

• Seven (7) percent of the excavated areas will have subgrade concentrations greater than 1,200 ppm after a 12-inch excavation.

• Five (5) percent of the excavated areas will require excavation to 18 inches before subgrade concentrations are less than 1,200 ppm

• Two (2) percent of the excavated areas will require excavation to 24 inches and it is assumed the subgrade concentration would still be greater than 1,200 ppm.

3.0 IDENTIFICATION OF REMEDIAL ACTION OBJECTIVES

This section of the FS presents the Remedial Action Objectives (RAOs) established to address lead in residential soil and identifies applicable or relevant and appropriate requirements (ARARs) with which a selected remedial action must comply.



3.1 Remedial Action Objectives

The overall cleanup goal for the residential portion of the Site is to protect human health. As discussed previously, soil with lead concentrations above 400 ppm in residential yards will be addressed by the remedial action. Residents are assumed to be the primary population potentially exposed to soil under the current and reasonably anticipated future land uses. For the Site, the specific RAO is to:

Limit exposure to lead in soil such that no child or similarly exposed children have more than 5 percent probability of having a blood lead level higher than 10 micrograms/deciliter from such exposure. This soil lead level of 400 ppm is based on the IEUBK model and the site-specific blood lead study (EPA 2010b, Gradient 2010, NewFields and Gradient 2010, and Doe Run 2010).

This objective is consistent with EPA's (1994a) guidance that EPA should "…limit exposure to soil lead levels such that a typical child or group of similarly exposed children would have an estimated risk of no more than 5 percent of exceeding the 10 μg/dL blood lead level." Under this scenario, it is assumed that acceptable exposure point concentration (EPC) protective of this sensitive subpopulation could be reasonably assumed to be protective of other sensitive receptors. EPA has set the EPC at 400 ppm (EPA 2010b).

MDHSS (2011) reports that the percent of elevated blood lead in children tested less than 6 years of age in St. Francois County for the 2010 calendar year is 1 percent. County statistics indicate the percent of elevated blood leads in the county statistics have been less than 5 percent since 2006 (MDHSS 2011). However, the EPA’s cleanup goal is that no child or similarly exposed children should have greater than a 5 percent probability of having an elevated blood lead level (EBL). The state average for EBLs was 1 percent in 2010.

3.2 Identification of Applicable or Relevant and Appropriate Requirements

As part of the FS and in accordance with the NCP, 40 CFR 300.415(j), ARARs were evaluated to ensure that all requirements are met for the scope of work to be performed. As specified in the NCP, remedial alternatives must satisfy two “threshold” criteria specified in order to be eligible for selection: 1) the remedy must be protective of human health and the environment; and 2) the remedy must meet (or provide the basis for waiving) the ARARs identified for the action.

Federal standards, requirements, criteria or limitations that are determined to be legal ARARs must be met by remedial actions, as required by CERCLA (Section 121(d)(2)(A)). Also, State ARARs must be met if they are more stringent than Federal requirements. ARARs are designed to assure that potential remedial actions at a site are protective of human health and the environment, cost-effective, and use permanent solutions, alternative treatment technologies or resource recovery technologies to the



maximum extent practicable (EPA 1988a). The Superfund Amendments and Reauthorization Act (SARA) requires that any hazardous substance or pollutant remaining on a site must meet the level or standard of control that is established by the ARARs for that site, unless the ARAR is waived.

Applicable requirements are defined by the NCP as those cleanup standards, standards of control, and other substantive environmental protection requirements, criteria, or limitations promulgated under Federal or State law that specifically address a hazardous substance, pollutant, contaminant, remedial action, location, or other circumstances at a site (40 CFR 300.5).

Although a requirement may not be applicable as a matter of law, it may still be relevant and appropriate. A requirement is deemed relevant and appropriate if it regulates or addresses problems or situations sufficiently similar to those encountered such that it is well suited to that particular site. Determination of whether a requirement is relevant and appropriate is site-specific and determined by professional judgment based on the characteristics of the remedial action, the hazardous substances present at the site, and the physical circumstances of the site and of the release. In some cases, only a portion of a requirement may be deemed relevant and appropriate (EPA 1988b).

Compliance with all requirements found to be applicable or relevant and appropriate is required under SARA. A waiver from an ARAR may be obtained under certain circumstances (CERCLA Section 121(d)(4)). Other CERCLA statutory requirements, such as the requirement that remedies be protective of human health and the environment, cannot be waived. CERCLA Section 121(d)(2)(A) specifically limits the scope of state ARARs to standards, requirements, criteria, or limitations under environmental or facility siting laws that are promulgated and more stringent than Federal requirements.

ARARs are grouped into three categories:

• Chemical-Specific

• Location-Specific

• Action-Specific.

The NCP identifies a fourth category of information termed “to be considered” (TBC) when evaluating appropriate remedial action goals or approaches. This fourth category generally includes Federal and State advisories, criteria or guidance that are not ARARs, and while not legally binding may be useful in developing CERCLA remedies (see 40 CFR 300.400(g)(3)).

The following sections provide a discussion of those requirements that have significant potential to be applicable or relevant and appropriate to remedial actions at the Site.



3.2.1 Potential Chemical-Specific ARARs

Chemical-specific requirements are based on health- or risk-based concentration limits or discharge limitations in environmental media (i.e., water, soil, air) for specific hazardous chemicals. These requirements may be used to set cleanup levels for the chemicals of concern in the designated media or to set a safe level of releases where releases occur as part of the remedial activity.

Sources for potential target cleanup levels include selected standards, criteria, and guidelines that are typically considered ARARs for remedial actions conducted under CERCLA. Potential chemical-specific ARARs are presented in Table 6. No chemical-specific ARARs have been identified that directly relate to development of RAOs. However, they are pertinent to how the remedial action may be implemented.

3.2.2 Potential Location-Specific ARARs

Location-specific ARARs are restrictions placed on the types of remedial activities that may be implemented at particular site locations. The location of a site may be an important factor in determining the potential impact of remedial actions on human health and the environment. These ARARs may restrict or preclude certain remedial actions or they may apply only to certain portions of a site. The only potential location-specific State ARARs identified for the Site were related to management of the waste materials. Potential Federal and State location-specific ARARs for the Site are presented in Table 7.

3.2.3 Potential Action-Specific ARARs

Action-specific ARARs are usually technology or activity-based requirements or limitations on actions taken with respect to hazardous substances. These requirements are triggered by the remedial activities selected to accomplish a remedy. Because there may be several alternative actions for any site, different requirements may be established. The action-specific requirements do not in themselves determine the remedial alternative; rather, they indicate how a selected alternative should be implemented to achieve the requirement. Table 8 lists and describes potential Federal and State action-specific ARARs. The regulations on these tables represent potential action-specific ARARs for activities generally encountered in hazardous substance site remediation (e.g., generation, transportation, storage, disposal, etc.). Regulations regarding worker health and safety such as Occupational Safety and Health Administration (OSHA) requirements are not included because they are not environmental requirements and are therefore not technically ARARs.

Table 6 Summary of Potential Chemical-Specific ARARs

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Standard, Requirement

or Criteria Applicable

Relevant and

Appropriate Citation Description Comment

FEDERAL Hazardous Waste Criteria

Potentially

--

40 CFR 264

Establishes criteria for use in determining hazardous wastes and disposal requirements. Excavated soil would be classified as D008 hazardous waste if the lead concentration from the TCLP test was greater than 5.0 mg/L.

Would be applicable if hazardous wastes are generated and disposed of off-site at a RCRA Facility. All excavated yard soils would be disposed of in an onsite CAMU. This regulation would potential apply if any of the wastes were disposed of off-site.

National Ambient Air Quality Standards (NAAQS)

No

Yes

40 CFR Part 50

Establishes ambient air quality standards for certain “criteria pollutants” to protect public health and welfare. Standard is:

1.5 microgram lead per cubic meter (µg/m3) maximum – arithmetic mean averaged over a calendar quarter.

NAAQS are implemented through the New Source Review Program and State Implementation Plans (SIPs). The Federal New Source Review Program addresses only major sources. Emissions associated with the remedial action would be limited to fugitive dust emissions associated with earth moving activities during construction. These activities will not constitute a major source. Therefore, attainment and maintenance of NAAQS pursuant to the New Source Review Program are not applicable. However, the standards relating to lead are relevant and appropriate.

STATE Missouri Ambient Air Standards

Yes

--

Missouri Code of State Regulations (CSR) 10 CSR 010-06.010

Missouri uses the NAAQS as the state standards for airborne emissions.

The NAAQS air quality standards for particulates, as PM10, are 50 µg/m3 (annual geometric mean) and 150 µg/m3 (24 hour), as PM2.5 they are 15 µg/m3 (annual geometric mean) and 65 µg/m3 (24 hour).

The NAAQS emission limit for lead is 1.5 µg/m3 averaged over a three-month period.

Relevant and appropriate to actions that generate fugitive dust at individual properties and the staging area.

Table 7 Summary of Potential Location-Specific ARARs

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Relevant and


FEDERAL Archaeological and Historic Preservation Act

No

No

16 USC Sec. 469

Establishes procedures to provide for preservation of historical and archaeological data that might be destroyed through alteration of terrain as a result of a Federally licensed activity or program.

Area to be part of soil remedial activities is not believed to contain any historical or archaeological resources due to residential nature of Site and shallow depth (<2 ft) of excavation activities to be performed (if necessary).

Archaeological Resources Protection Act

No

No

16 USC Secs. 470 aa - mm

Requires permits for any excavation or removal of archaeological resources from public or Indian lands. Provides guidance for federal land managers to protect such resources.

Activities will not take place on public land or Indian land.

National Historic Preservation Act

No

No

16 USC Sec. 470 36 CFR Part 800 Executive Order 11593, May 3, 1971

Requires Federal agencies to take into account the effect of any Federally assisted undertaking or licensing on any district, site, building, structure, or object that is included in or eligible for Register of Historic Places.

Area to be part of soil remedial activities is not believed to contain any feature that would be eligible for registration as a historic place due to residential nature and location of Site.

Historic Sites, Buildings, and Antiquities Act

No

No

16 USC Secs. 461 - 467, 470h-2(f)

Requires Federal agencies to consider the existence and location of landmarks on the National Registry of Natural Landmarks to avoid undesirable impacts on such landmarks.

Area to be part of soil remedial activities is not believed to contain any National Natural Landmarks due to residential nature and location of Site.

Fish and Wildlife Coordination Act

No

No

16 USC Secs. 661 - 666

Requires any Federal agency or permitted entity to consult with the U.S. Fish and Wildlife Service and appropriate state agency prior to modification of any stream or other water body. The intent of this requirement is to conserve, improve, or prevent loss of wildlife habitat and resources.

Area to be part of soil remedial activities is not believed to directly impact any stream or water feature. However, streams adjacent to properties could be potentially affected by runoff from remedial activities.

Fish and Wildlife Conservation Act

No

No

16 USC Secs. 2901 - 2912

Requires Federal agencies to utilize their statutory and administrative authority to conserve and promote conservation of non-game fish and wildlife species.

Area to be part of soil remedial activities is not believed to directly impact any stream or water feature. However, streams adjacent to properties could be potentially affected by runoff from remedial activities.





Relevant and


Endangered Species Act

No

No

16 USC Secs. 1531-1544 50 CFR Parts 17, 402

Requires that Federal agencies ensure that any action authorized, funded, or carried out by the agency is not likely to jeopardize the continued existence of any threatened or endangered species or destroy or adversely modify critical habitat.

Area to be part of soil remedial activities is not believed to directly impact any critical habitat. Remedial activities will be restricted to residential properties and are not expected to adversely impact listed species.

Federal Migratory Bird Treaty Act

No

No

16 USC Secs. 703 - 712

Prohibits taking of any migratory bird.

Area to be part of soil remedial activities is not believed to directly impact any critical habitat. Remedial activities will be restricted to residential properties and not expected to adversely impact migratory birds.

Executive Order on Floodplain Management

No

No

Executive Order No. 11988

Requires Federal agencies to evaluate the potential effects of actions they may take in a floodplain to avoid, to the maximum extent possible, the adverse impacts associated with direct and indirect development of a floodplain.

Remedial activities to be performed are comprised of restoration of residential properties. As such, no additional development within the floodplain is anticipated beyond that previously performed during the original development of the property.

Executive Order on Protection of Wetlands

No

No

Executive Order No. 11990

Requires Federal agencies to avoid, to the maximum extent possible, the adverse impacts associated with the destruction or loss of wetlands and to avoid new construction in wetlands, if a practicable alternative exists.

Remedial activities to be performed are comprised of restoration of residential properties. As such, no adverse impacts on wetlands are anticipated.

Farmland Protection Policy Act

No

No

7 USC Sec. 4201 et. seq.

Protects significant or important agricultural lands from irreversible conversion to uses that result in its loss as an environmental or essential food production resource.

Remedial activities to be performed are comprised of restoration of residential properties and are not expected to impact agricultural lands. As such, no loss of environmental or essential food production resources is anticipated.





Relevant and


RCRA – Location Standards for Hazardous Waste Facilities

Potentially

--

42 USC Sec. 6901 40 CFR 264.18

Requires that any hazardous waste facility located within the 100-year floodplain be designed, constructed, operated, and maintained to avoid washout. Also, contains requirements for locating facilities away from seismically active zones. Because most mining and mill wastes are explicitly excluded from RCRA regulations, these requirements are only TBCs for the Site.

All excavated yard soils will be disposed of in an onsite CAMU – BRMTS Repository. This unit, located on a designated mine area, is managed in accordance with the CAMU Approval Memorandum dated December 12, 2001 and the Operation Manual (NewFields 2003).

Rivers and Harbors Act

No

No

33 CFR Secs. 320 - 330

Requires preapproval of the US Army Corps of Engineers prior to placement of any structures in waterways and restricts the placement of structures in waterways.

Area to be part of soil remedial activities is not believed to directly impact any navigable stream or water feature or necessitate placement of any structures within these features.

STATE Missouri Hazardous Waste Regulations

--

Potentially

10 CSR 25-7.264 - 270

Hazardous waste disposal areas shall not be placed within a 100-year floodplain or wetland. Provisions related to placement and management of hazardous waste units.

Relevant and appropriate to actions that generate hazardous waste. All excavated yard soils will be disposed of in an onsite CAMU – BRMTS Repository. This unit, located on a designated mine area, is managed in accordance with the CAMU Approval Memorandum dated December 12, 2001 and the Operation Manual (NewFields 2003).

Missouri Metallic Minerals Waste Management Act

--

Yes

10 CSR 45

Actions involving placement of metallic mineral waste shall be performed according to permit.

All excavated yard soils will be disposed of in an onsite CAMU – BRMTS Repository. This unit, located on a designated mine area, is managed in accordance with the CAMU Approval Memorandum dated December 12, 2001 and the Operation Manual (NewFields 2003).





Relevant and


Missouri Solid Waste Regulations

Potentially

--

11 CSR 80-11.010

Actions involving solid waste disposal areas shall not cause degradation to wetlands or jeopardize existence of endangered or threatened species protected under the Endangered Species Act of 1973 or violate any requirement under the Marine Protection, Research, and Sanctuaries Act of 1972.

Relevant and appropriate to actions that generate solid waste. All excavated yard soils will be disposed of in an onsite CAMU – BRMTS Repository. This unit is managed in accordance with the CAMU Approval Memorandum dated December 12, 2001 and the Operation Manual (NewFields 2003).

Table 8 Summary of Potential Action-Specific ARARs

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Action Applicable Relevant

and Appropriate

Citation Description Comment

FEDERAL Hazardous and Solid Waste: Criteria for Classification of Solid Waste and Disposal Facilities and Practices

Yes

--

40 CFR Part 257

Establishes criteria for use in determining solid wastes and disposal requirements.

Excavated soil is a solid waste.

1. Criteria for

Classification of Hazardous Waste and Disposal Facilities and Practices

Potentially

--

40 CFR Part 264

Establishes criteria for use in determining hazardous wastes and disposal requirements.

All excavated yard soils will be disposed of in an onsite CAMU – BRMTS Repository. This unit, located on a designated mine area, is managed in accordance with the CAMU Approval Memorandum dated December 12, 2001 and the Operation Manual (NewFields 2003). This regulation would potential apply if any of the wastes were disposed of off-site.

2. Hazardous

Materials Transportation Regulations

Potentially

--

49 CFR Parts 107, 171-177

Regulates transportation of hazardous materials.

Applicable only if the remedial action involves off-site transportation of hazardous materials. The regulations affecting packaging, labeling, marking, placarding, using proper containers, and reporting discharges of hazardous materials would be potential ARARs.




and Appropriate


Air Emission Control: 1. National

Ambient Air Quality Standards (NAAQS)

No

Yes

40 CFR Part 50

Establishes ambient air quality standards for certain “criteria pollutants” to protect public health and welfare. Standards are:

150 μg/m3 for particulate matter for a 24 hour period;

50 μg/m3 for particulate matter – annual arithmetic mean;

1.5 μg/m3 maximum – arithmetic mean averaged over a calendar quarter.

NAAQS are implemented through the New Source Review Program and State Implementation Plans (SIPs). The federal New Source Review Program addresses only major sources. Emissions associated with the remedial action would be limited to fugitive dust emissions associated with earth moving activities during construction. These activities will not constitute a major source. Therefore, attainment and maintenance of NAAQS pursuant to the New Source Review Program are not applicable. However, the standards relating to particulate matter and to lead are relevant and appropriate.

STATE Hazardous and Solid Waste: 1. Solid waste

determination

Yes

--

Missouri Solid Waste Regulations 11 CSR 80-11

A solid waste is any discarded material that is not excluded by Regulation.

Applicable to soil excavated from residential yards.

2. Determination

of hazardous waste.

Potentially

--

Missouri Hazardous Waste Regulations 10 CSR 25-7.264 - 270

If an extract from a solid waste, tested using the Toxicity Characteristic Leaching Procedure (TCLP, Test Method 1311 in "Test Methods for Evaluating Solid Waste, Physical/ Chemical Methods", EPA publication SW 846), contains concentrations of any of the materials above the listed level (5 mg/L for lead), the waste is considered hazardous.

Applicable to soil excavated from residential yards and disposed of offsite. All excavated yard soils would be disposed of in an onsite CAMU.




and Appropriate


3. Transportation

of Hazardous Waste

Potentially

--

Missouri Solid Waste Regulations 11 CSR 80-11

Rules regarding Transportation of Hazardous Substances.

Applicable only if the remedial action involves off-site transportation of hazardous materials. The regulations affecting packaging, labeling, marking, placarding, using proper containers, and reporting discharges of hazardous materials would be potential ARARs.

Air Emission Control: 1. Particulate

emissions during excavation and backfill.

Yes

--

Missouri Code of State Regulations 10 CSR 010-06

Missouri air pollution regulations require persons that emit fugitive particulates to minimize emissions through use of all reasonable precautions. In addition, no visible fugitive dust transport is allowed beyond the lot line of the property where the emissions originate.

Applicable to actions that entail excavation, moving, storing, transportation of redistribution of soil.

2. Ambient Air

Standard for Total Suspended Particulate Matter

No

Yes


Missouri uses the NAAQS as the state standards for airborne emissions. The NAAQS air quality standards for particulates, as PM10, are 50 μg/m3 (annual geometric mean) and 150 μg/m3 (24 hour), as PM2.5 they are 15 μg/m3 (annual geometric mean) and 65 μg/m3 (24 hour).

Remedial activities will not constitute a major source and therefore regulations are not applicable. Relevant and appropriate to actions that generate fugitive dust at individual properties and the staging area.

3. Ambient Air

Standards

No

Yes


Missouri uses the NAAQS as the state standards for airborne emissions. Excavation and backfill of soils could potentially cause emission of hazardous air pollutants. The NAAQS emission limit for lead is 1.5 μg/m3 averaged over a three-month period.

Relevant and appropriate to actions that generate fugitive dust at individual properties and the staging area.




and Appropriate


Storm water Controls: 1. Storm water

NPDES Permit

No

Yes

Missouri Clean Water Commission 10 CSR 020-06

Missouri has established General NPDES Storm Water Permit for a land disturbance site such as would be encountered during the soil remedial action at the Site. The permit requires the establishment of best management practices (BMP) to control runoff.

This project is being performed under CERCLA as an Emergency Removal Action and therefore does not require a permit. However, the substantive requirements of the Missouri General Permit will be implemented at the site including CBMP, routine inspections and record keeping.



3.2.4 Other Guidance To Be Considered (TBC)

For the Site, guidance TBC that may be potentially applicable is related to location standards for hazardous waste facilities. As the BRMTS Repository or CAMU that is expected to be used to accept the excavated soils is a mine tailings pile and all beneficiation mining wastes are explicitly excluded from RCRA hazardous waste regulations, these regulations are not enforceable but should be considered as part of the best management practices for the Site.

3.2.5 Data Needs

The SOW requires that data needs be identified that are necessary to make ARAR determinations or evaluate the ability of an alternative to comply with ARARs. No data needs have been identified that are necessary for evaluating the remedial alternatives. Yard sampling of the estimated 4,540 yards will need to be conducted to satisfy data needs associated with implementation of the remedy.

4.0 REMEDIAL ACTION TECHNOLOGY SCREENING AND ALTERNATIVE DEVELOPMENT

Consistent with EPA’s Guidance for conducting an FS (EPA 1988a), this section includes a summary of the identification and screening of remedial technologies followed by the development of remedial action alternatives to achieve the RAO.

4.1 Technology Identification and Screening

Based on Site conditions and the RAO, several General Response Actions (GRAs) were identified. GRAs are general categories of remedial activities (e.g. no action, institutional controls, containment, etc.) that may be taken, either singly or in combination, to satisfy the requirements of the RAO.

Following this, remedial action technologies and process options to be considered under each GRA were identified that would be applicable to the Site. The purpose of an FS is to systematically evaluate every potential technology. However, as removal actions have been in progress at the Site since 2000, this FS focuses on proven technologies based on similar contamination scenarios at other sites. Similar sites in Missouri provide examples of potential available remedies for residential soil with elevated lead concentrations including the Time-Critical Removal Actions at the Viburnum Trend Haul Road Site and at the St. Joe Minerals Corp. – Viburnum Site and in residential areas of the Jasper County Superfund Site near Joplin, Missouri. Additionally the Superfund Lead-Contaminated Residential Sites Handbook (EPA 2003) was used as a primary guidance document.



GRAs that are pertinent to the remedial action include: • No action • Institutional Controls • Public Health Actions • Containment • Soil removal.

Following the identification of the pertinent remedial technologies and process options under each GRA, the technologies and process options were evaluated for effectiveness, implementability, and relative cost. The remedial action technologies and process options that remained following the screening were carried forward for consideration in the development of remedial action alternatives. The overall goal is to narrow the focus to a subset of options consisting of only the most viable remedial alternatives. Factors considered for each evaluation are as follows.

Effectiveness Evaluation. The primary measure of effectiveness used in this evaluation is the degree to which a process option would contribute to achievement of the RAO. Other effectiveness criteria include:

• The capacity to handle the estimated areas or volumes of soils to be cleaned up

• Potential impacts to human health and the environment during the construction and implementation phase

• The demonstrated reliability with respect to the Contaminants of Concern (COCs) and conditions at the site.

Process options may also be evaluated on the basis of effectiveness relative to other processes within the same technology type.

Implementability Evaluation. Technically inapplicable and infeasible remedial technologies were eliminated from further consideration during the initial screening process described in the previous section. The technical and administrative feasibility of implementing a technology or process option is further considered during this final evaluation. Some of the administrative and technical aspects of a technology’s implementability considered during this screening step include the following:

• Anticipated community acceptance (in particular compatibility with residential yard use)

• Availability of treatment, storage, and disposal services

• The availability of resources to implement the technology.

Cost Evaluation. The cost analysis is performed on the basis of information contained in EPA guidance documents, experience in costing similar projects, independent estimates, and engineering judgment. Those process options providing similar



effectiveness at significantly higher relative costs are eliminated from further consideration at this screening level. Relative cost evaluations between process options were only performed where they were necessary to facilitate the screening process. Detailed costs are provided for all retained options in Section 5.0.

The identified remedial technologies and an evaluation are summarized on Table 9 and discussed in the following subsections.

4.1.1 No Action

No Action would entail performing no additional remedial activities beyond what was already been accomplished under the Interim and Halo Removal Actions. The NCP requires that a No Action alternative be retained as a baseline against which other alternatives can be compared in the detailed analysis; and therefore, no action is retained without screening.

4.1.2 Institutional Controls

Institutional Controls are non-engineering mechanisms that provide the means by which Federal, State and local governments or private parties can prevent or limit access to or use of contaminated environmental media, the use of areas impacted by COCs, and/or to ensure the integrity and maintenance of engineered remedial components. Institutional Controls may be applied on a stand-alone basis or implemented in conjunction with other response actions as part of an overall site remedy.

Types of land use controls are: (1) local land use regulations (such as subdivision ordinances or zoning regulations implemented by local governments for the purpose of protecting the health, safety and general welfare of the people by limiting access); (2) easements created by a grant from a property owner to another party prohibiting the property owner from conducting certain activities that may have the potential to cause a health threat; and (3) restrictive covenants, which are written restrictions or requirements placed on the title to real property that pass with the property and bind both current and future owners of the property to prohibit activities which may have the potential to cause a health threat.

Land use controls are typically used in situations where current use is something other than residential and RAOs are developed to protect workers or visitors. Controls that prevent future residential land use can, in these situations, achieve the requirements of risk-based RAOs. Because the Site is already residential, in order to achieve the RAO, land use controls would need to restrict common activities that are associated with incidental exposure to soil and dust. It is likely that land use controls would not be acceptable to individual residents and would be difficult to implement and monitor. Additionally, they may not be effective in protecting human health. However, this option is retained for the development of remedial alternatives.

Table 9 Summary(1) of Remedial Technologies and Process Options

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General Remedial

Action (GRA) Remedial

Technology Process Options Effectiveness Implementability Screening Results/Comments

No action No action - (2) - - Retained as required by NCP.

Institutional Controls

Land Use Controls

Local Land Use Regulations

Easements Restrictive Covenants

Would not be protective because land use is already residential and would require restrictions on common activities.

Would likely not be accepted by community since common activities would be restricted.

Eliminated from further consideration.

Education Educational Materials

Effective in modifying behavior patterns that contribute to possible exposure.

Readily implementable.

Retained - already performed during the Interim Removal Action for many yards and can be implemented during sampling for future characterized yards..

Monitoring Biomonitoring for lead (elevated blood lead testing)

Could be used to direct environmental sampling activities.

Readily implementable. Soils above health risk based standards are being removed; therefore the applicability of additional biomonitoring as it relates to soil is not considered further. Existing state biomonitoring can be used to prioritize yearly yard removals, as performed under the Halo Removal Action

Public Health Actions

Sampling and Response

Environmental Sampling and Response Program

Would be effective in addressing residual risks by identifying sources of and preventing unacceptable exposures.

Readily implementable. Sampling of the properties within the Response Area that have not been sampled for determination of whether the yards should be included as part of the remedial action.

Containment Covering Rock Geosynthetic Asphalt Concrete Multimedia/Soil

Barriers would generally be effective in preventing direct contact with contaminated soil. Effectiveness would be increased if used in conjunction with other options.

Surface cover would not be compatible with residential yard use.

Installation of a cover is not retained at this time.

Surface Control

Soil Grading Not effective. - Not retained at this time.

Table 9 Summary(1) of Remedial Technologies and Process Options

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General Remedial

Action (GRA) Remedial

Technology Process Options Effectiveness Implementability Screening Results/Comments

Containment (cont.)

Surface Control (cont.)

Vegetation Not effective as a stand-alone option, but could be part of a comprehensive alternative.

Could be implemented in a residential yard setting.

Vegetation is retained for further consideration in conjunction with other remedial options. Tilling and grading are

Tilling Not effective as yard lead soil concentrations do not consistently decrease sufficiently with depth based on subgrade concentrations observed during the Interim and Halo Removal Actions.

Could be implemented in a residential yard setting. However, equipment access, presence of utilities and tree roots and tilling depth (maximum 6 inches) would limit yards that could benefit from this technique.

Not retained at this time.

Removal Excavation Effective in removing contaminated soil.

Implementable in a residential yard setting.

Retained.

On-site

Effective in preventing contact with excavated contaminated soil.

Implementable – BRMTS Repository used in the Interim and Halo Removals and is available for future yard removals.

Retained for further consideration.

Removal/ Disposal

Disposal

Off-site Effective in preventing contact with excavated contaminated soil.

Implementable-suitable off-site disposal facilities are currently used to accept waste from mining operations in the area. However, distance to nearest landfill used for disposal (Butler County) is over 100 miles from Site.

Not retained at this time due to the availability of the BRMTS and the long distance to the nearest landfill.

NOTES:

(1) Per CERCLA guidance relative cost evaluation is only performed to evaluate process options providing similar effectiveness. This was performed following detailed evaluation.

(2) Evaluation not performed if not required for screening purposes.



A common purpose of institutional controls is to protect the integrity of a remedy. In residential lead cleanups this may mean using institutional control to prevent penetration into subsurface soil that remains at depth. The primary concern for protecting a remedy is typically uncontrolled excavation where a clean soil cap may overlie subsurface soil concentrations that are still above the action level. Therefore EPA (2003) states it is important to select ICs that are relevant to excavators. Examples of potentially effective ICs are local digging or drilling permits and “One Call” or “Miss Utility” systems. As not all excavations within a residential yard would conducted in a manner that would alert these local governmental systems, informational devices (visual barrier) that provide to the property owner information or notification that residual or capped contamination remain on-site are useful at modifying behaviors to minimize the potential for unacceptable exposure. Examples include placing a property on a state contaminated properties registry, developing deed notices, and providing periodic lead-education advisories to residents (EPA 2003).

4.1.3 Public Health Actions

Public health actions could entail a program targeting specific subpopulations at risk and/or specific behavior that could potentially cause higher exposure. Actions may include education; biomonitoring; and environmental sampling, public health referrals and engineering response to protect health.

Educational Materials

The deployment of educational materials was implemented during the investigation performed during the Interim and Halo Removal Actions as required under their respective AOCs. Additionally, educational materials have been used at other similar sites to assist in managing risks and preventing or minimizing exposures associated with specific subpopulations and activities that are very infrequent, or that are suspected to be from multiple sources. Educational materials can be used to raise overall community awareness of the potential health risks, to inform the community about behaviors and activities that result in exposure, to inform the community on how to reduce or prevent exposures, and to provide information about public health resources. Consequently, this option is retained for the development of remedial alternatives and will be included in all action alternatives.

Biomonitoring

Biomonitoring programs (such as blood lead testing) have been implemented successfully at other similar sites and would potentially be appropriate at the Site for identifying higher than normal exposures that result from reasonable maximum exposure behavior and/or sources other than soil, as well as for evaluation of the effectiveness of other remedial action engineering and response components.



During the Interim Action a blood lead testing program was implemented to help identify yards for removal priority. During the Halo Removal Action, this priority system continued but the source of the identification of the EBL children was through the Missouri Department of Health and Senior Services (MDHSS) and the county health departments.

At properties to be addressed as part of this remedy, the remaining lead in residential surface soils above 400 ppm will be removed. Confirmation sampling of the backfill source(s) will be conducted to ensure that post remedial action objectives are met. Consequently, continued monitoring of sensitive receptors will not be necessary as the EPC will be reduced below risk-based levels. As a result, biomonitoring has not been retained.

Environmental Sampling and Response

Environmental sampling has been retained for the estimated 4,578 properties within the Response Area that have not been sampled as part of the Interim Action. Yards with soils greater than 400 ppm will be included as part of the remedy.

4.1.4 Containment

Containment actions entail isolating the COCs by physical means. Containment technologies include covering and surface control.

Covering

Containment of residential soils may be achieved by installation of engineered covers to prevent direct contact. There are a variety of available engineered cover designs, including simple soil, rock/gravel, geosynthetic, asphalt, concrete and multimedia (for example, soil-synthetic membrane, soil-synthetic membrane-clay caps, etc.). As the Site is residential in nature, the application of a cover would restrict normal activities and would not be compatible with residential yard use. As a result, application of a cover is not retained as an option in the development of remedial alternatives.

Surface Control

Surface controls may include soil grading, vegetation or tilling. Soil grading typically entails contouring the ground surface to potentially reduce exposure. Vegetation consists of seeding appropriate grass, legume or shrub species to provide a stand of vegetation that will reduce erosion and stabilize soils. Tilling includes mechanically turning over and mixing of the upper soil column such that contaminant levels at the surface are reduced. Grading would not be implementable in residential yards due to existing use requirements. Vegetation would not be effective as a stand-alone solution but could be used as a component of a tilling and restoration alternative.



Tilling includes mechanically turning over and mixing the upper soil column such that contaminant levels at the surface are reduced or in conjunction with other treatment technologies such as phosphate amendment. Tilling with revegetation may be a viable stand-alone alternative in cases where contaminant concentrations are close to cleanup goal levels and decrease with depth. It would not be effective as a stand-alone solution in situations where similar levels and/or relatively high levels of contamination exist throughout the tilling depth. Subgrade measurements during the Interim and Halo Removal Actions indicate lead concentrations at depth are typically greater than 400 ppm; therefore, tilling would not likely be effective and has not been retained.

4.1.5 Soil Removal

Conventional open cut excavation of shallow soils is typically conducted by means of small earthmoving equipment. This technology was used during the Interim and Halo Removal Actions and is therefore applicable to Site conditions and retained for further evaluation.

Disposal was used during the previous removal actions and therefore is applicable to Site conditions and is retained for further evaluation. Under the soil removal action the soils would be excavated and disposed of on-site at either the BRMTS Repository or CAMU or another similar on-site facility if the BRMTS Repository is closed.

4.2 Remedial Alternative Development

Cleanup of residential yards with elevated lead levels has been performed at many sites across the United States. The EPA generally considers only two remedial actions to be protective long-term remedial actions at residential properties (EPA 2003):

• Excavation of contaminated soil followed by placement of a soil cover barrier if contaminated soils remain

• Placement of a soil cover barrier without any excavation.

The EPA (2003) recommends that a minimum of 12 inches of clean soil be used to establish an adequate barrier from contaminated soil in a residential yard for human health protection. The cover-only option is not viable for the existing residential yards of the Response Area because of grade issues. Therefore, the soil removal is considered the only viable process option. As a 12-inch cover is considered protective for typical activities of children and adults in residential properties, with the exception of gardening, the minimum excavation of 12 inches of yard soil with replacement by clean fill is generally consider protective and meets the RAO (EPA 2003).

EPA (2003) recommends full removal of contaminated soils as it allows for the remediated yard to be returned to unrestricted use. However, as described above, the subgrade soils at one foot typically contain lead concentrations above the action level (400 ppm) and in many cases may exhibit higher lead concentrations than the surface



soil. Consequently, 94 percent of the yards remediated under the Interim and Halo Removal Actions have a visual barrier placed at the subgrade level. As such the remediated yards are considered protective but do not have unrestricted use.

The following basic conceptual remedial alternatives have been identified for the Site, using EPA’s (2003) Handbook as well as with experience gained onsite and at other lead contaminated residential sites:

• Alternative 1: No Action

• Alternative 2: Soil Removal with 12-inch Subgrade Visual Barrier

• Alternative 3: Soil Removal with 24-inch Excavation.

The conceptual alternatives are described in more detail in the following subsections. Surface soils (0 to 1 inch) will be sampled at all residential yards within the Response Area that were not sampled as part of the Interim or Halo Removal Actions and access is provided by the homeowner. Drip zones, driveways, vegetable gardens, and other distinct areas such as play area and/or parking areas will be sampled separately from yard quadrant samples. Sampling will be conducted in accordance with the work plans prepared for the Interim and Halo Removal Actions (NewFields 2000 and 2004a). Health education materials will be distributed to all residential homes as part of the sampling access procedures.

All CHUAs (e.g., parks, schools, playgrounds, day care centers, etc.) with lead concentrations greater than 400 ppm in surface soils have been identified or in the process of being identified by EPA in the Response Area. These CHUAs will be addressed in EPA’s 2011 Pre-ROD removal action (EPA 2011). Therefore, no CHUAs have been specifically included in this FS.

4.2.1 Alternative 1 – No Action

No Action would entail performing no additional remedial activities beyond that performed. The NCP requires that a No Action alternative be retained as a baseline against which other alternatives can be compared in the FS analysis.

4.2.2 Alternative 2 – Soil Removal with 12-inch Subgrade Visual Barrier

Under this Alternative 2, accessible surface soils in residential yards with lead concentrations greater than 400 ppm would be removed to a depth of 12 inches and confirmation sampling (subgrade to 6-inch depth) would be performed to document the lead concentrations at the base of the excavation. Should lead concentrations at the subgrade be greater than 400 ppm, a visual barrier/marker will be placed prior to backfilling with clean fill. This alternative adopts the removal practices conducted under both the Interim and Halo Removal Actions. Based on results of the Interim and Halo



Removal Actions using a 1-inch subgrade sample, these yards or areas of a yard requiring visual barriers are the norm with only approximately 6 percent not requiring the visual barrier; however, the subsurface soil investigation (NewFields 2011) would indicate that only 12 percent would require a visual barrier if the subgrade confirmation sampling was conducted to 6 inches below subgrade. Vegetable gardens with soil lead levels exceeding 400 ppm would be excavated to a maximum of 24 inches and restored with 24 inches of clean soil. Garden subgrades (at 24 inches) will also be sampled prior to clean fill placement and the visual barrier will be placed if subgrade concentrations are greater than 400 ppm.

Conventional open cut excavation will be conducted using small excavators and wheel loaders. The excavated soils will be disposed of at the BRMTS Repository or similar onsite facility. Excavated areas would be backfilled with clean soil and the area restored to its original use. This alternative is expected to require approximately 1,247,000 cubic yards of clean top soil as backfill.

Excavated yard areas will be seeded with lawn grass mixture, with the exception of gravel areas which will be topped with clean gravel. Flower and vegetable garden areas will be left unseeded.

As soils above the 1,200 ppm will probably be left at depth greater than 12 inches and above the action level of 400 ppm at any residential yard for which the property owner refuses yard soil removal or potentially at any residential yard for which the property owner refuses yard soil sampling, the exposure to yard soils with elevated lead concentrations can not be fully eliminated. Therefore, institutional controls, such as excavation notification and/or permitting and informational devices (e.g., periodic lead-education and/or excavation advisories), should be devised. Specific institutional controls would be developed through a partnership of interested citizens and representatives of the federal, state, and local governments.

4.2.3 Alternative 3: Soil Removal with 24-inch Excavation

Under this Alternative 3, accessible surface soils in residential yards with lead concentrations greater than 400 ppm would be removed to a depth of 12 inches and confirmation sampling (subgrade to 6-inch depth) would be performed to document the lead concentrations at the base of the excavation. Should subgrade soil lead concentrations be greater than 1,200 ppm, excavation would continue in 6 inch lifts down to 24 inches and a second subgrade confirmation sampling will be performed. Should lead concentrations at the subgrade after removing 24 inches of soil be greater than 1,200 ppm, a visual barrier/marker will be placed prior to backfilling with clean fill. Based on results of the subsurface soil investigation, approximately 7 percent of the remediated areas of a yard are expected to require additional excavations, and 2 percent could require subgrade visual barriers.



Vegetable gardens with soil lead levels exceeding 400 ppm will be excavated to a maximum of 24 inches and restored with 24 inches of clean soil. Garden subgrades (at 24 inches) will also be sampled prior to clean fill placement and a visual barrier will be placed if subgrade concentrations are greater than 1,200 ppm.

As described in Alternative 2, conventional open cut excavation will be conducted using small excavators and wheel loaders. The excavated soils will be disposed of at the BRMTS Repository or similar onsite facility. Excavated areas would be backfilled with clean soil and the area restored to its original use. This alternative is expected to require over 1,280,000 cubic yards of clean top soil as backfill.

Excavated yard areas will be seeded with lawn grass mixture, with the exception of gravel areas which will be topped with gravel. Flower and vegetable garden areas will be left unseeded.

As visual barriers will be place in approximately 2 percent of the yards indicating subsurface soils above 1,200 ppm are present and soils above the action level of 400 ppm will remain at any residential yard for which the property owner refuses yard soil removal or potentially at any residential yard for which the property owner refuses yard soil sampling, the exposure to yard soils with elevated lead concentrations can not be fully eliminated. Therefore, institutional controls, such as excavation notification and/or permitting and informational devices (e.g., periodic lead-education and/or excavation advisories), should be devised. Specific institutional controls would be developed through a partnership of interested citizens and representatives of the federal, state, and local governments.

5.0 REMEDIAL ALTERNATIVE EVALUATION

This section provides a detailed analysis of the remedial alternatives developed in Section 4.2. The alternatives are evaluated to ensure that the selected remedial alternative will be protective of human health, comply with or include a waiver of ARARs, be cost-effective, utilize permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable, and address the statutory preference for treatment as a principal element.

5.1 Threshold Criteria

The threshold criteria are so called because they must be satisfied for an alternative to be carried forward in the remedy selection process. The two threshold criteria include overall protection of human health and the environment and compliance with ARARs. The specific factors comprising the threshold criteria are described in the following paragraphs.



Overall Protection of Human Health and the Environment

This criterion is the final and determining assessment of an alternative’s ability to satisfy the protectiveness requirement. To be deemed protective, an alternative must meet the RAOs, reduce risks to acceptable levels, comply with ARARs, and generally satisfy the balancing criteria.

Compliance with ARARs

Compliance with ARARs is a judgment based on an alternative’s ability to satisfy a comprehensive list of applicable or relevant and appropriate state and federal statutory and regulatory requirements. To satisfy this criterion, the actions prescribed under an individual alternative must be capable of reducing the level of COCs to applicable numerical limits known as chemical-specific ARARs. In meeting the chemical-specific ARARs, an alternative must do so while complying with action-specific and location-specific ARARs. The detailed analysis may also include an evaluation with respect to an alternative’s compliance with other appropriate criteria, advisories, and guidance to be considered, referred to as TBCs. The potential ARARs and TBCs are presented in Section 3.2 for evaluating the alternatives for compliance.

If both threshold criteria are not satisfied, an individual alternative cannot be considered for selection as the site remedy with one exception. This exception consists of provisions contained in the NCP for waiving compliance with ARARs under certain site-specific circumstances that would prevent the ARARs from being achieved (40 CFR Part 300.430(f)(1)(ii)(C)).

5.2 Primary Balancing Criteria

The evaluation of the overall protection of human health and the environment is based on a composite of factors assessed under the evaluation criteria. The criteria specifically considered are: short-term effectiveness, long-term effectiveness and permanence, implementability, cost, and compliance with ARARs.

5.2.1 Short-Term Effectiveness

This evaluation criterion addresses the effects of the remedial alternative during the construction and implementation phase until the remedial objectives are met. Alternatives are evaluated with respect to their potential effects on human health and the environment during implementation of the remedial action. As specified in the CERCLA guidance, the short-term impacts of each remedial alternative are assessed considering the following factors:

• Short-term risks that might be posed to the community during implementation of remedial action



• Potential impacts on workers during remedial action and the effectiveness and reliability of protective measures

• Potential environmental impacts of the remedial action and the effectiveness and reliability of mitigative measures during implementation

• The time until protection is achieved.

5.2.2 Long-Term Effectiveness/Permanence

Evaluation of long-term effectiveness and permanence considers the risks remaining after the response objectives have been met. Factors considered, as appropriate, include the following.

• Magnitude of residual risk remaining from untreated waste or treatment residuals remaining at the conclusion of the remedial activities.

• Adequacy and reliability of controls. This factor assesses the adequacy and suitability of controls, if any, that are used to manage untreated wastes that remain at the site. The long-term reliability of management controls for providing continued protection are also assessed, including the potential need to replace technical components of the alternative, and the potential exposure pathway and the risks, should the remedial action need replacement.

5.2.3 Reduction of Toxicity, Mobility, or Volume through Treatment

The NCP states a preference for remedies that reduce toxicity, mobility, or volume of hazardous constituents through treatment. This criterion addresses the extent to which the proposed remedy relies on treatment to address the RAOs. Factors used in deciding if an alternative meets the statutory preference for a treatment-based remedy include the following:

• The extent to which contaminants are destroyed through treatment

• The reduction in total mass of contaminants

• The irreversibility of reductions in contaminant mobility

• The reduction in total volume of contaminated materials

• The type and quantity of treatment residuals.

In applying this criterion, it is emphasized that metal contaminants cannot be truly destroyed by treatment. In addition, EPA has modified the applicability of this criterion at mining-related sites through OSWER Directive No. 9355.0-26. Among other things, this directive states that engineering controls, such as containment, are generally more appropriate than treatment technologies at large sites characterized by high-volume, low-toxicity mining and mill wastes. The concepts contained in this directive are expected to be applied as modifying factors in the assessment of alternatives under this criterion.



5.2.4 Implementability

This criterion addresses the technical and administrative feasibility of implementing each remedial alternative and the availability of various services and materials required during its implementation. As specified in the CERCLA guidance, the evaluation of implementability includes three categories of analysis: technical feasibility, administrative feasibility, and availability of services and materials.

5.2.5 Cost

For each alternative, a -30 to +50 percent cost estimate is developed in accordance with procedures in the Remedial Action Costing Procedures Manual (EPA 2000). Cost estimates for each alternative are based on conceptual engineering and design and are expressed in terms of 2011 dollars. The cost estimate for a remedial alternative consists of four principal elements.

• Remedial action cost – Remedial action cost consists of direct (construction), indirect (non-construction and overhead) costs, and costs associated with the implementation of health educational materials. Direct costs include the cost for equipment, labor, and materials incurred to develop, construct, and implement a remedial action, including the sampling of the 4,540 yards within the Response Area that were not sampled as part of the Interim or Halo Removal Actions. Indirect costs are expenditures for engineering, financial, and other services that are not actually a part of construction but are required to implement a remedial alternative. These items are included in the detailed cost analysis.

• Operation and maintenance cost – Operation and maintenance (O&M) cost refers to post-remedial action cost items necessary to ensure the continued effectiveness of a remedial action. For the alternatives under consideration in this FS, there are no O&M activities other than periodic review. Long-term actions, such as distribution of health education materials, are considered to be a component of the remedial action.

• Cost for a 5-year review – Section 121(c) of CERCLA, as amended, states that a 5-year review of a remedial action is required if the remedial action results in hazardous constituents remaining on-site. While EPA has stated that subsurface soil concentrations between 400 and 1,200 ppm does not constitute “hazardous constituents remaining on-site”, they have indicated that after 5 years the potential for recontamination should be assessed. Therefore, 5-year review of remedial action has been included in both alternatives. Given the large number of yards expected in the remedial action, the periodic reviews are expected to consist of 5-year progress reports prepared in anticipation of incorporation into a final remedial action report. No periodic costs beyond the removal action (7 years) have been included.



• Present worth analysis – This analysis is used to evaluate the remedial action and O&M costs of a remedial alternative based on its present worth. A present worth analysis compares expenditures for various alternatives where those expenditures occur over different time periods. By discounting all costs to a common base year, the costs for different remedial action alternatives can be compared based on a single cost figure for each alternative. The total present worth for a single alternative is equal to the full amount of all costs incurred through the end of the first year of operation (capital cost), plus the series of expenditures in following years reduced by the appropriate future value/present worth discount factor. This analysis allows the comparison of remedial alternatives on the basis of a single cost representing an amount that, if invested in the base year and disbursed as needed, would be sufficient to cover all costs associated with the remedial action over its planned life. A discount rate of 7 percent is assumed for base calculations (EPA 1993). The discount rate represents the anticipated difference between the rate of inflation and investment return.

5.3 Modifying Criteria

Modifying criteria include State Acceptance and Community Acceptance. State acceptance is a judgment as to the level of State support, reservations, or opposition to proposed remedial actions. Community acceptance addresses possible citizen concerns expressed during the public comment period. In accordance with EPA Guidance (1988a), the final assessment of State and Public Acceptance is presented in the ROD after the State and public have commented on the completed FS and proposed plan.

5.4 Individual Remedial Alternative Evaluation

5.4.1 Alternative 1 – No Action

The No Action alternative provides a baseline for the evaluation of other alternatives in accordance with the NCP. No additional protective measures would be taken for the no-action option. As noted previously, soils have been removed from 585 residential properties within the Site (complete and partial removals).

The No Action alternative does not meet the requirements of the RAO and does not provide protection of human health for residential properties with only interim action (partial removal) and no previous action.

5.4.2 Alternative 2 – Soil Removal with 12-inch Subgrade Visual Barrier

This alternative considers the removal of Site surface soils in yards with lead concentrations greater than 400 ppm. Accessible soils would be removed to a maximum



depth of 12 inches and confirmation sampling performed to document that remaining soil concentrations are below 400 ppm. Areas that have subgrade soil concentrations greater than 400 ppm would have a visual barrier placed prior to placement of clean fill per the procedures required under the Halo Removal Action. Institutional Controls would be implemented at properties greater than 1,200 ppm at 12 inches, additionally a county-wide education or notice of the presence and meaning of the visual barrier would be conducted.


Alternative 2 would meet the requirements of the RAO by removal of all soil with lead concentrations above 400 ppm within the upper foot of soil and backfilling with clean material. This would prevent direct contact with soils with lead concentrations above 400 ppm. The alternative would provide a high level of protection of human health under typical direct contact exposures of children and adult residents, although there would be increased short-term risks associated with transportation of excavated soil and clean backfill.


ARARs relating to the generation of fugitive dust and lead concentrations in ambient air would be applicable to actions performed to implement Alternative 2. Although the potential exists for dust generation during soil excavation, transport and backfilling activities, engineering controls would be readily implementable and effective to achieving compliance with the applicable regulations. ARARs relating to the characterization, transport and disposal of solid wastes would be applicable and would be met by standard construction and transportation practices. Alternative 2 would therefore meet the requirements of all ARARs.

Short-term Effectiveness

The short-term risk to the community and workers during implementation of this alternative would be low.

Risks would be posed to members of the community due to the operation of heavy equipment in the residential areas and by truck traffic associated with transportation of excavated soil from the residential site and import of clean backfill. As a screening level estimate, a total of approximately 207,900 dump truck trips would be needed to transport the excavated soil to the BRMTS Repository and to transport the clean backfill soil to the site (about 1,247,300 cubic yards of excavated soil and an equal amount of backfill transported in 12 cubic yard capacity trucks). The injury and fatality rates for accidents involving large trucks in 2007 (FMCSA 2008) were 33.4 per 100 million vehicle miles driven and 2.02 per 100 million vehicle miles driven, respectively. Assuming a transport distance of 4 miles to the BRMTS Repository and 6 miles to the backfill source, application of the 2007 statistics predicts that there would be a 35 percent probability that one of the trucks would be involved in an accident that injures someone (72,171 accidents) and a 2.1 percent chance of a fatality (4,365 people). The increase truck



traffic can also potentially increase the road damage to residential streets and side streets.

Based on the current activities in Madison County, which has a similar climate, the weather limits the construction season to February through November (10 months). EPA reports that the average number of properties/crew/ construction season in Madison county is 80 properties per year. Therefore, to perform the 4,013 estimated soil removals in 7 years, as requested by EPA, the average number of yards per year would be 574 and would require 8 to 9 crews operating. As Alternative 2 is an excavation to a known depth the number of days per yard could be predicted and therefore less of an impact on the community as a whole with respect to noise and traffic.

Long-term Effectiveness and Permanence

This alternative would provide a high degree of long-term effectiveness and protection under typical direct contact exposures of children and adult residents because accessible soils with lead concentrations above 400 ppm within the upper foot of soil would be removed from the Site and replaced with clean backfill. However, potential for future risk exists in the yard if the homeowner or utility company were to excavate deeper than one foot in any yard for which a visual barrier had been placed. This visual barrier provides protection to the primarily adult receptor as it alerts the excavator to the presence of elevated lead soils. Additional institutional controls will be implemented to ensure that subsurface soil greater than 1,200 ppm will not be disturbed. Without Institutional Controls this alternative may not provide long-term protection because there is no limit on the concentration of lead at the 12 inches or deeper.

Reduction of Toxicity, Mobility, or Volume through Treatment

No reduction in toxicity, mobility, or volume through treatment would result from implementing this alternative.

Implementability

Alternative 2 would be implementable with standard equipment and services, and trained personnel would be readily available for this type of work. The construction technologies required to implement this alternative are commonly used and widely accepted. Adequate disposal facilities are available in the area, as are suitable sources of clean backfill. However, it is noted that the amount of soil (1,247,300 cubic yards) needed to backfill the prescribed excavations under this alternative is a possible obstacle to its implementability. The farther the soil borrow areas are located from the Response Area, the more costly this alternative would become.

Removal is a reliable technology, and no future remedial actions within remediated yards are expected to be required because surface soils of concern would be removed from the Site. A small potential for recontamination exists for any yard with soils greater than



400 ppm left at depth but only in yards that undergo post-remediation excavations; however, visual barrier is present to alert the excavator of the presence of elevated lead concentrations.

Cost

The present net worth cost for Alternative 2 is approximately $97.7 million. Detailed information on the unit rates, quantities and assumptions used in the development of the costs are presented in Table 10. See Appendix C for description of the cost assumptions and Table C-1 for the present worth evaluation at other discount rates than 7 percent.

Under this alternative hazardous constituents are left in subsurface soils of the residential yards, therefore a 5-year review will be required. It is assumed that 5 percent of the properties remediated after 5 years will be resampled to assess the potential for recontamination due to elevated lead concentrations (greater than 400 ppm) left at depth. After initial seeding and watering, all lawn care will be the responsibility of the property owner. Therefore, no ongoing costs are associated with this Alternative. Due to the long implementation period for this Alternative (7 years), review of remedial activities and actual costs as well as documentation is expected to be conducted after five years and retained in a 5-year progress report that can later be incorporated into the Final Remedial Action Report.

Modifying Criteria

State and public acceptance is expected as this alternative has been conducted within the community for the last 10 years.

5.4.3 Alternative 3 – Soil Removal with 24-inch Excavation

This alternative considers the removal of Site surface soils in yards with lead concentrations greater than 400 ppm. Accessible soils would be removed to a depth of 12 inches and confirmation sampling performed to document that remaining soil concentrations are below 1,200 ppm. Areas that have subgrade soil concentrations greater than 1,200 ppm would be removed until a total depth of 24 inches is obtained. If lead concentrations below 1,200 ppm are reached, no visual barrier is required. If the 24-inch subgrade soils contain lead concentrations greater than 1,200 ppm, then a visual barrier will be placed prior to backfill. Institutional controls, similar to Alternative 2, would be required for those yards with visual barriers. Under normal circumstances, lead concentrations between 400 and 1,200 ppm left below a 12-inch layer of clean soil would be will be brought to the surface in large enough quantities that would present a significant risk (ATSDR 2000). Five year progress report would be conducted to verify levels at remediated properties.

Est. per each costing unit

Costing Unit Quantity Unit Unit Cost Total Cost

CAPITAL COSTS

SamplingSampling and Analysis

Access 4,540 properties 148 days $680.00 $100,640Education Materials 4,540 properties 4,540 property $1.50 $6,810Sampling 3,587 properties 180 days $1,700.00 $306,000Sampling Analysis 36 days $1,700.00 $61,200XRF 1 XRF $15,500.00 $15,500Calibration Samples to Analytical Laboratory 897 samples 897 sample $28.00 $25,116Data Management 4,540 properties 227 hours $95.00 $21,565Result Letter Mailing 3,587 properties 150 letters per 24 mailings $711.00 $17,064Best Effort Letters for Sampling Refusal 954 properties 48 letters per 20 mailings $909.00 $18,180

SUBTOTAL DIRECT CAPITAL COSTS - Sampling $572,075Sampling

Mob/Demob 10% $57,208Engineering/Administration Costs 10% $57,208Health & Safety 3% $17,162

SUBTOTAL INDIRECT CAPITAL COSTS - Sampling $131,577

TOTAL ESTIMATED CAPITAL COST SAMPLING $703,652

RemovalInterim Action Sampled Yards (Known Yards)

Removal Access 1,001 propertiesAccess and Property Documentation 100% 1,001 properties 1,001 properties $75.00 $75,075Best Effort Letters for Refusals 14% 140 letters 140 letters $5.50 $770

Excavation & Placement of Clean Fill 1,001 properties Even though 14% of all yards are expected to refuse access, the cost assumes 100% participationYard Quadrants/Areas 2,471

One Quad 218 properties 3,000 654,000 SF $2.87 $1,876,980Two Quads 242 properties 6,000 1,452,000 SF $2.11 $3,063,720Three Quads (yards reduced by 2011 yards) 295 properties 9,000 2,655,000 SF $2.11 $5,602,050Four Quads (yards reduced by 2011 yards) 221 properties 12,000 2,652,000 SF $1.63 $4,322,760

DrivewayWith yard quads

One Quad 18 areas 1,000 18,000 SF $2.87 $51,660Two Quads 16 areas 1,000 16,000 SF $2.11 $33,760Three Quads (yards reduced by 2011 yards) 18 areas 1,000 18,000 SF $2.11 $37,980Four Quads (yards reduced by 2011 yards) 25 areas 1,000 25,000 SF $1.63 $40,750

Only 15 areas 1,000 15 LS $2,870.00 $43,050Garden (assumes 24 inch depth excavation) Gardens are assumed to be located in excavated quads in properties with more than two quads removed; therefore,

With yard quads Only 12 to 24 inch excavation included when 3 or 4 yard quadrants are remediatedOne Quad 6 areas 625 3,750 SF $5.74 $21,525Two Quads 8 areas 625 5,000 SF $4.22 $21,100Three Quads (yards reduced by 2011 yards) 15 areas 625 9,375 SF $2.11 $19,781Four Quads (yards reduced by 2011 yards) 18 areas 625 11,250 SF $1.63 $18,338

Only 4 areas 625 4 LS $2,870.00 $11,480Play Area

With yard quads Play areas are assumed to be located in excavated quads in properties with more than two quads removedOne Quad 15 areas 150 2,250 SF $2.87 $6,458Two Quads 27 areas 150 4,050 SF $2.11 $8,546

Only 5 areas 150 5 LS $2,870.00 $14,350Final Close-out documentation 1,001 properties 1,001 properties $75.00 $75,075Lawn Watering (Known Yards) 1,001 properties 7,420,050 SF 2,315,056 gallons $2.60 /1000 gal $6,019

Non-Interim Action Sampled Yards (Potential) Percent estimates based on the above known yardsRemoval Access 3,012 properties Assumes 84% of sampled properties will require some soil removal

Access and Property Documentation 100% 3,012 properties 3,012 properties $37.50 $112,950Best Effort Letters for Refusals 14% 421 letters 421 letters $5.50 $2,316

Excavation & Placement of Clean Fill 3,012 properties Even though 14% of all yards are expected to refuse access, the cost assumes 100% participationYard Quadrants/Areas 8,581 quads

One Quad (17%) 17% 512 properties 3,000 1,536,000 SF $2.87 $4,408,320Two Quads (19%) 19% 572 properties 6,000 3,432,000 SF $2.11 $7,241,520Three Quads (26%) 26% 783 properties 9,000 7,047,000 SF $2.11 $14,869,170Four Quads (38%) 38% 1,144 properties 12,000 13,728,000 SF $1.63 $22,376,640


One Quad 8% 40 areas 1,000 40,000 SF $2.87 $114,800Two Quads 7% 40 areas 1,000 40,000 SF $2.11 $84,400Three Quads 8% 62 areas 1,000 62,000 SF $2.11 $130,820Four Quads 11% 125 areas 1,000 125,000 SF $1.63 $203,750

Only 1.2% 36 areas 1,000 36,000 SF $2.87 $103,320Garden (assumes 24 inch depth excavation) Gardens are assumed to be located in excavated quads in properties with more than two quads removed; therefore,

With yard quads Only 12 to 24 inch excavation included when 3 or 4 yard quadrants are remediatedOne Quad 3% 15 areas 625 9,375 SF $5.74 $53,813Two Quads 3% 17 areas 625 10,625 SF $4.22 $44,838Three Quads 5% 28 areas 625 17,500 SF $2.11 $36,925Four Quads 8% 45 areas 625 28,125 SF $1.63 $45,844

Only 0.3% 9 areas 625 9 LS $2,870.00 $25,830Play Area

With yard quads Play areas are assumed to be located in excavated quads in properties with more than two quads removedOne Quad 7% 35 areas 150 5,250 SF $2.87 $15,068Two Quads 11% 62 areas 150 9,300 SF $2.11 $19,623

Only 0.4% 12 areas 150 12 LS $2,870.00 $34,440

Item/Description Quantity

Table 10

Detailed Cost Estimate

St. Francois County Mined Areas - Residential Feasbility StudyAlternative 2 - Soil Removal with 12-Inch Subgrade Visual Barrier

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Costing Unit Quantity Unit Unit Cost Total CostItem/Description Quantity

Table 10

Detailed Cost Estimate

St. Francois County Mined Areas - Residential Feasbility StudyAlternative 2 - Soil Removal with 12-Inch Subgrade Visual Barrier

Final Close-out documentation 3,012 properties 3,012 properties $75.00 $225,900Lawn Watering (Potential Additional Yards) 3,012 properties 25,759,350 SF 8,036,917 gallons $2.60 /1000 gal $20,896

SUBTOTAL DIRECT CAPITAL COSTS - Known Yards $15,351,226SUBTOTAL DIRECT CAPITAL COSTS - Potential Additional Yards $50,171,181

SUBTOTAL DIRECT CAPITAL COSTS - Removal $65,522,407

Interim Action Sampled Yards (Known Yards)Mob/Demob 10% $1,535,123Engineering/Administration Costs 10% $1,535,123Construction Management Costs 10% $1,535,123Health & Safety 3% $460,537

Non-Interim Action Sampled Yards (Potential)Mob/Demob 10% $5,017,118Engineering/Administration Costs 10% $5,017,118Construction Management Costs 10% $5,017,118Health & Safety 3% $1,505,135

SUBTOTAL INDIRECT CAPITAL COSTS - Known Yards $5,065,905SUBTOTAL INDIRECT CAPITAL COSTS - Potential Additional Yards $16,556,490

SUBTOTAL INDIRECT CAPITAL COSTS - Removal $21,622,394Scope and Bid Contingencies - Removal only 35% $30,500,680

TOTAL ESTIMATED CAPITAL COST REMOVAL $117,645,481

TOTAL ESTIMATED CAPITAL COST (SAMPLING AND REMOVAL) $118,349,133

ANNUAL O&M COSTSNone

PERIODIC COSTSFive-Year Review $75,156Sampling and Analysis = resampling surface soils at remediated properties (5 years x 574 yards/yr) at a 5% rate $20,156

Access 144 properties 1 days $680.00 $680.00Sampling 144 properties 8 days $1,700.00 $13,600.00Sampling Analysis 2 days $1,700.00 $3,400.00Calibration Samples to Analytical Laboratory 36 samples 36 sample $28.00 $1,008.00Data Management 144 properties 8 hours $95.00 $760.00Result Letter Mailing 144 properties 1 mailings $708.14 $708.14

Summary of Removal Action to date 1 $55,000Remedial Action Report $75,000 $75,000

TOTAL ESTIMATED PERIODIC COST $150,156

TOTAL NON-DISCOUNTED COST $118,499,289

TOTAL PRESENT WORTH $97,719,000(7% rate of return, 30 year period)

NOTES:Cost Assumptions are provided in Appendix ATotal Present Worth calculation presented in Table A-1

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Alternative 3 would meet the requirements of the RAO by removal of all soil with lead concentrations above 400 ppm within the upper foot of soil and backfilling with clean material. This would prevent direct contact with soils with lead concentrations above 400 ppm. The alternative would provide a high level of protection of human health, although there would be increased short-term risks associated with transportation of excavated soil from and clean backfill to the site.


ARARs relating to the generation of fugitive dust and lead concentrations in ambient air would be applicable to actions performed to implement Alternative 3. Although the potential exists for dust generation during soil excavation, transport and backfilling activities, engineering controls would be readily implementable and effective to achieving compliance with the applicable regulations. ARARs relating to the characterization, transport and disposal of solid wastes would be applicable and would be met by standard construction and transportation practices. Alternative 3 would therefore meet the requirements of all ARARs.

Short-term Effectiveness

The short-term risk to the community and workers during implementation of this alternative would be low.

Risks would be posed to members of the community due to the operation of heavy equipment in the residential areas and by truck traffic associated with transportation of excavated soil off site and import of clean backfill. As a screening level estimate, a total of approximately 213,300 dump truck trips would be needed to transport the excavated soil to the BRMTS Repository and to transport the clean backfill soil to the site (about 106,700 cubic yards of excavated soil and an equal amount of backfill transported in 12 cubic yard capacity trucks). The injury and fatality rates for accidents involving large trucks in 2007 (FMCSA 2008) were 33.4 per 100 million vehicle miles driven and 2.02 per 100 million vehicle miles driven, respectively. Assuming a transport distance of 4 miles to the BRMTS Repository and 6 miles to the backfill source, application of the 2007 statistics estimates that there would be a 36 percent probability that one of the trucks would be involved in an accident that injures someone (76,010 accidents) and a 2.2 percent chance of a fatality (4,597 people). The increase truck traffic can also potentially increase the road damage to residential streets and side streets.

Based on yearly yard rates presented above, it was assumed that the removal action would take 7 years to complete. As Alternative 3 has a sample dependent depth criterion, the individual yard soil removal may take longer (3 to 6 days per yard to complete) than Alternative 2 and may increase the impact on the community with respect to noise and traffic.



Long-term Effectiveness and Permanence

This alternative would provide a high degree of long-term effectiveness and protection under typical direct contact exposures of children and adult residents because accessible soils with lead concentrations above 400 ppm within the upper foot of soil would be removed from the Site and replaced with clean backfill. However, potential for future risk exists in the yard if the homeowner or utility company were to excavate deeper than one foot in large areas of any yard for which subgrade is greater than 400 ppm but less than 1,200 ppm (ATSDR 2000). This alternative would be more protective than Alternative 2 because soil greater than 1,200 ppm at 12 inches will be removed and therefore small excavations into the potentially elevated lead soils (between 400 and 1,200 ppm) would not be as likely to mix with surface soils to lead concentrations greater than 400 ppm (ATSDR 2000). A visual barrier will be left in the subsurface soil (24 inches) if lead concentrations remain above 1,200 ppm. The potential for recontamination of shallow surface soils (less than one foot) due to mishandling of this subsurface soil is low, as the probability of deep excavations within established yards are not high, and the risk is acceptable to EPA but will require quantification during the 5-year progress report.


No reduction in toxicity, mobility, or volume through treatment would result from implementing this alternative.

Implementability

Alternative 3 would be implementable with standard equipment and services, and trained personnel would be readily available for this type of work. The construction technologies required to implement this alternative are commonly used and widely accepted. It is assumed that adequate disposal facilities are available in the area, as are suitable sources of clean backfill.

The amount of top soil (1,280,000 cubic yards) needed to backfill the prescribed excavations under this alternative is a possible obstacle to its implementability. The farther the soil borrow areas are located from the Response Area, the more costly this alternative would become.

Removal is a reliable technology, and no future remedial actions would be required because soils of concern would be removed from the Site.

Cost

The present net worth cost for Alternative 3 is approximately $107.6 million. Detailed information on the unit rates, quantities and assumptions used in the development of the



costs are presented in Table 11. See Appendix C for description of the cost assumptions and Table C-2 for the present worth evaluation at other discount rates than 7 percent.

After initial seeding and watering, all lawn care will be the responsibility of the property owner. Therefore, no ongoing costs are associated with this Alternative. Under this alternative hazardous constituents may left in subsurface soils of the residential yards, therefore a 5-year review will be conducted. It is assumed that 5 percent of the properties remediated after 5 years will be resampled to assess the potential for recontamination due to elevated lead concentrations (greater than 400 ppm) left at depth. Due to the long implementation period for this Alternative (7 years), review of remedial activities and actual costs as well as documentation is expected to be conducted after five years and retained in a 5-year progress report that can later be incorporated into the Final Remedial Action Report.

Modifying Criteria

The State and public are expected to accept Alternative 3.

5.5 Comparative Analysis of Alternatives

This section contains a comparative analysis of Alternatives 2 and 3. The No Action Alternative is not protective of human health and is not evaluated.

The first stage of the analysis, presented in Section 5.4, summarizes and comparatively analyzes each alternative’s achievement of the threshold criteria of overall protectiveness and compliance with ARARs, as required by the NCP. The second stage of analysis involves a discussion of the relative advantages and disadvantages of the alternatives with respect to balancing criteria. This comparison is presented in detail in the following sections and is summarized on Table 12.

5.5.1 Threshold Criteria

Both action alternatives meet the threshold criteria and thus can be further evaluated.

5.5.2 Short-term Effectiveness

Alternative 2 has a slightly higher level of short-term effectiveness than Alternative 3. Both alternatives have been assumed to take 7 years until time of protection for the community is reached; however, Alternative 2 has the higher potential for reducing that time frame due to the shorter time required at each yard and thus shorter time to protection for the individual residents.


Costing Unit Quantity Unit Unit Cost Total Cost

CAPITAL COSTS

SamplingSampling and Analysis

Access 4,540 properties 148 days $680.00 $100,640Education Materials 4,540 properties 4,540 property $1.50 $6,810Sampling 3,587 properties 180 days $1,700.00 $306,000Sampling Analysis 36 days $1,700.00 $61,200XRF 1 XRF $15,500.00 $15,500Calibration Samples to Analytical Laboratory 897 samples 897 sample $28.00 $25,116Data Management 4,540 properties 227 hours $95.00 $21,565Result Letter Mailing 3,587 properties 150 letters per 24 mailings $711.00 $17,064Best Effort Letters for Sampling Refusal 954 properties 48 letters per 20 mailings $909.00 $18,180

SUBTOTAL DIRECT CAPITAL COSTS - Sampling $572,075Sampling

Mob/Demob 10% $57,208Engineering/Administration Costs 10% $57,208Health & Safety 3% $17,162

SUBTOTAL INDIRECT CAPITAL COSTS - Sampling $131,577

TOTAL ESTIMATED CAPITAL COST SAMPLING $703,652

RemovalInterim Action Sampled Yards (Known Yards)

Removal Access 1,001 propertiesAccess and Property Documentation 100% 1,001 properties 1,001 properties $75.00 $75,075Best Effort Letters for Refusals 14% 140 letters 140 letters $5.50 $770

Excavation & Placement of Clean Fill 1,001 properties Even though 14% of all yards are expected to refuse access, the cost assumes 100% participationYard Quadrants/Areas 2,471

One Quad 218 properties 3,000 670,350 CF $2.87 $1,923,905Two Quads 242 properties 6,000 1,488,300 CF $2.11 $3,140,313Three Quads (yards reduced by 2011 yards) 295 properties 9,000 2,721,375 CF $2.11 $5,742,101Four Quads (yards reduced by 2011 yards) 221 properties 12,000 2,718,300 CF $1.63 $4,430,829


One Quad 18 areas 1,000 18,450 CF $2.87 $52,952Two Quads 16 areas 1,000 16,400 CF $2.11 $34,604Three Quads (yards reduced by 2011 yards) 18 areas 1,000 18,450 CF $2.11 $38,930Four Quads (yards reduced by 2011 yards) 25 areas 1,000 25,625 CF $1.63 $41,769

Only 15 areas 1,000 15,375 CF $2.87 $44,126Garden (assumes 24 inch depth excavation) Gardens are assumed to be located in excavated quads in properties with more than two quads removed; therefore,

With yard quads Only 12 to 24 inch excavation included when 3 or 4 yard quadrants are remediatedOne Quad 6 areas 625 7,500 CF $2.87 $21,525Two Quads 8 areas 625 10,000 CF $2.11 $21,100Three Quads (yards reduced by 2011 yards) 17 areas 625 10,625 CF $2.11 $22,419Four Quads (yards reduced by 2011 yards) 41 areas 625 25,625 CF $1.63 $41,769

Only 4 areas 625 4 LS $2,870.00 $11,480Play Area

With yard quads Play areas are assumed to be located in excavated quads in properties with more than two quads removedOne Quad 15 areas 150 2,306 CF $2.87 $6,619Two Quads 27 areas 150 4,151 CF $2.11 $8,759

Only 5 areas 150 5 LS $2,870.00 $14,350Final Close-out documentation 1,001 properties 1,001 properties $75.00 $75,075Lawn Watering (Known Yards) 1,001 7,420,050 SF 2,315,056 gallons $2.60 /1000 gal $6,019

Non-Interim Action Sampled Yards (Potential) Percent estimates based on the above known yardsRemoval Access 3,012 properties

Access and Property Documentation 100% 3,012 properties 3,012 properties $37.50 $112,950Best Effort Letters for Refusals 14% 421 letters 421 letters $5.50 $2,316

Excavation & Placement of Clean Fill 3,012 properties Even though 14% of all yards are expected to refuse access, the cost assumes 100% participationYard Quadrants/Areas 8,581 quads

One Quad (17%) 17% 512 properties 3,000 1,574,400 CF $2.87 $4,518,528Two Quads (19%) 19% 572 properties 6,000 3,517,800 CF $2.11 $7,422,558Three Quads (25%) 26% 783 properties 9,000 7,223,175 CF $2.11 $15,240,899Four Quads (37%) 38% 1,144 properties 12,000 14,071,200 CF $1.63 $22,936,056


One Quad 8% 40 areas 1,000 41,000 CF $2.87 $117,670Two Quads 7% 40 areas 1,000 41,000 CF $2.11 $86,510Three Quads 8% 62 areas 1,000 63,550 CF $2.11 $134,091Four Quads 11% 125 areas 1,000 128,125 CF $1.63 $208,844

Only 1.2% 36 areas 1,000 36,900 CF $2.87 $105,903Garden (assumes 24 inch depth excavation) Gardens are assumed to be located in excavated quads in properties with more than two quads removed; therefore,

With yard quads Only 12 to 24 inch excavation included when 3 or 4 yard quadrants are remediatedOne Quad 3% 15 areas 625 18,750 CF $2.87 $53,813Two Quads 3% 17 areas 625 21,250 CF $2.11 $44,838Three Quads 5% 28 areas 625 17,500 CF $2.11 $36,925Four Quads 8% 45 areas 625 28,125 CF $1.63 $45,844

Only 0.3% 9 areas 625 9 LS $2,870.00 $25,830Play Area

With yard quads Play areas are assumed to be located in excavated quads in properties with more than two quads removedOne Quad 7% 35 areas 150 5,381 CF $2.87 $15,444Two Quads 11% 62 areas 150 9,533 CF $2.11 $20,114

Only 0.4% 12 areas 150 12 LS $2,870.00 $34,440

Item/Description Quantity

Table 11

Detailed Cost EstimateAlternative 3 - Soil Removal with 24-Inch ExcavationSt. Francois County Mined Areas - Residential Feasbility Study

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Costing Unit Quantity Unit Unit Cost Total CostItem/Description Quantity

Table 11

Detailed Cost EstimateAlternative 3 - Soil Removal with 24-Inch ExcavationSt. Francois County Mined Areas - Residential Feasbility Study

Final Close-out documentation 3,012 properties 3,012 properties $75.00 $225,900Lawn Watering (Potential Additional Yards) 3,012 properties 25,759,350 SF 8,036,917 gallons $2.60 /1000 gal $20,896

SUBTOTAL DIRECT CAPITAL COSTS - Known Yards $15,754,487SUBTOTAL DIRECT CAPITAL COSTS - Potential Additional Yards $51,410,366

SUBTOTAL DIRECT CAPITAL COSTS - Removal $67,164,854

Interim Action Sampled Yards (Known Yards)Mob/Demob 10% $1,575,449Engineering/Administration Costs 15% $2,363,173Construction Management Costs 15% $2,363,173Health & Safety 3% $472,635

Non-Interim Action Sampled Yards (Potential)Mob/Demob 10% $5,141,037Engineering/Administration Costs 15% $7,711,555Construction Management Costs 15% $7,711,555Health & Safety 3% $1,542,311

SUBTOTAL INDIRECT CAPITAL COSTS - Known Yards $6,774,430SUBTOTAL INDIRECT CAPITAL COSTS - Potential Additional Yards $22,106,458

SUBTOTAL INDIRECT CAPITAL COSTS - Removal $28,880,887Scope and Bid Contingencies - Removal only 35% $33,616,009

TOTAL ESTIMATED CAPITAL COST REMOVAL $129,661,751

TOTAL ESTIMATED CAPITAL COST (SAMPLING AND REMOVAL) $130,365,403

ANNUAL O&M COSTSNone

PERIODIC COSTS

Five-Year Review $75,156Sampling and Analysis = resampling surface soils at remediated properties (5 years x 574 yards/yr) at a 5% rate $20,156

Access 144 properties 1 days $680.00 $680.00Sampling 144 properties 8 days $1,700.00 $13,600.00Sampling Analysis 2 days $1,700.00 $3,400.00Calibration Samples to Analytical Laboratory 36 samples 36 sample $28.00 $1,008.00Data Management 144 properties 8 hours $95.00 $760.00Result Letter Mailing 144 properties 1 mailings $708.14 $708.14

Summary of Removal Action to date 1 $55,000Remedial Action Report $75,000 $75,000

TOTAL ESTIMATED PERIODIC COST $150,156

TOTAL NON-DISCOUNTED COST $130,515,559

TOTAL PRESENT WORTH $107,618,000(7% rate of return, 30 year period)

NOTES:Cost Assumptions are provided in Appendix ATotal Present Worth calculation presented in Table A-2

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Table 12 Summary of Comparative Analysis of Remedial Action Alternatives

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Evaluation Criterion Alternative 2 – Soil Removal with 12-inch Subgrade Visual Barrier

Alternative 3 – Soil Removal with 24-inch Excavation

Threshold Criteria Overall Protection of Human Health

Meets the requirements of the RAOs Meets the requirements of the RAOs

Compliance with ARARs Complies with ARARs Complies with ARARs Primary Balancing Criteria Short-Term Effectiveness Low level of short-term effectiveness because of risks to

workers and the community during implementation – particularly associated with operation of heavy equipment and truck transportation in residential areas. However, the shorter time until protection (2 to 4 days) makes this alternative preferable to Alternative 3 for short term effectiveness.

Low level of short-term effectiveness because of risks to workers and the community during implementation – particularly associated with operation of heavy equipment and truck transportation in residential areas. Longer time until protection (3 to 6 days) is achieved as potential deeper excavations with double confirmation sampling extends individual yard remediation period.

Long-Term Effectiveness and Permanence

Expected to be effective over the long-term. Highest possible level of long-term effectiveness for risks associated with typical direct contact activities with soil because all soils with lead above levels of concern within the top 12 inches would be removed. However, soils greater than 12 inches deep could contain lead at unlimited concentrations, but the visual barrier along with institutional controls will alert homeowners who dig deep excavations to use caution.

Expected to be the most effective over the long-term. High possible level of long-term effectiveness for risks associated with typical direct contact activities with soil because all soils with lead above levels of concern within the top 12 inches would be removed. However, soils greater than 12 inches deep could contain lead concentrations greater than 400 ppm but less than 1200 ppm; without a marker these soils could easily be mixed with clean fill should homeowner/utility worker do any deep excavation within the yard. Lead levels less than 1,200 ppm at 12 inches are considered protective by ATSDR under normal small yard excavations (tree planning or small utility repair (ATSDR 2000)..


No reduction in toxicity, mobility, or volume through treatment would result.

No reduction in toxicity, mobility, or volume through treatment would result.

Implementability Readily implementable Readily implementable. Cost $118.5 million (Present Worth $97.7 million) $130.5 million (Present Worth $107.6 million)

Table 12 Summary of Comparative Analysis of Remedial Action Alternatives

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Evaluation Criterion Alternative 2 – Soil Removal with 12-inch Subgrade Visual Barrier

Alternative 3 – Soil Removal with 24-inch Excavation

Modifying Criteria State Acceptance State acceptance is a judgment as to the level of State support, reservations, or opposition to proposed remedial actions.

The state has not reviewed the FS and therefore acceptance is known Public Acceptance – While the public also has not reviewed the FS some anticipated comments are provided for the analysis.

Readily acceptable but will be more difficult to implement because of the required Institutional Controls.

Expected to be the favored alternative because fewer Institutional Controls would be required.



5.5.3 Long-term Effectiveness and Permanence

Alternatives 2 and 3 would provide a similar level of long-term effectiveness and permanence against risks associated with soils, assuming that excavations greater than 12 inches deep are handled with caution so as to not potentially re-contaminate the surface soils. However, Alternative 2 would require Institutional Controls at potentially 7 percent of all yards remediated since unlimited lead concentrations could potentially remain at 12 inches or deeper, while Alternative 3 would limit the concentration at 12 inches or deeper to less than 1,200 ppm. Alternative 2 would however provide a visual barrier to an additional 5 percent of all yards where the subsurface soils between 400 ppm and 1,200 ppm would remain under either alternative. Alternative 3 has the potential to remove more contaminated soil and therefore reduce risk and the potential source for recontamination. Therefore, Alternative 3 would provide the most long-term effectiveness and permanence.

5.5.4 Reduction of Toxicity, Mobility, or Volume through Treatment

No reduction in toxicity, mobility, or volume through treatment would result from implementing either alternative.

5.5.5 Implementability

Alternatives 2 and 3 would be readily implementable with standard equipment and services. The construction technologies required to implement these alternatives are commonly used and widely accepted.

5.5.6 Cost

Estimated costs for each alternative considered in the comparative analysis are shown below. These costs include direct and indirect capital costs and review costs for 30 years (there are no operation and maintenance costs associated with any of the alternatives).

Remedial Alternative Net Present Worth Cost (Millions)

Alternative 2 Soil Removal with 12-inch Subgrade Visual Barrier 97.7

Alternative 3 Soil Removal with 24-inch Excavation 107.6

All action alternatives meet the threshold requirements of protection of human health and compliance with ARARs.



5.5.7 Modifying Criteria

Public acceptance of either alternative will require the community’s acceptance of the need for further remediation. The county-wide blood levels have decreased dramatically from 12 percent in 2000 to less than 1 percent in 2010 (equivalent to the state average). Both alternatives are expected to have a large impact on the community in terms of constant community disturbance due to the presence of construction crews within residential areas, long duration of the project (7 years), increased large truck traffic and its accompanying noise and potential road damage, increased risk to the community through high probability of accidents, and the decrease in the availability of community resources, such as topsoil.

State and public acceptance of Alternative 2 and Alternative 3 is expected to be roughly equal. The community as a whole may prefer Alternative 3 because it will require less Institutional Controls (2 percent versus 7 percent) and would be more protective over the long term.

6.0 RECOMMENDED ALTERNATIVE

Based on the comparative analysis of alternatives, Alternative 3 is EPA’s recommended alternative based on EPA’s opinion that Alternative 3 provides the greatest long-term effectiveness and permanence and also reduces the need for Institutional Controls while reducing the risk to an acceptable level.

7.0 REFERENCES

USEPA Docket No. VII-97-F-0002, Administrative Order on Consent for Remedial Investigation/Feasibility Study, in the matter of St. Francois County Mining Area, St. Francois County, Missouri, dated January 29, 1997.

USEPA Docket No. CERCLA-7-2000-0015, Administrative Order on Consent, for Removal Action in the matter of St. Francois County Mining Area, St. Francois County, Missouri (“Interim Action”), dated April 7, 2000.

USEPA Docket No. CERCLA-7-2004-0167, Administrative Order on Consent for Removal Action in the matter of St. Francois County Mining Area, St. Francois County, Missouri (“Halo”), effective date March 30, 2004.

Agency for Toxic Substances and Disease Registry (ATSDR), 2000. Health Consultation, Omaha Lead (a/k/a Omaha Lead Refining), Omaha, Douglas County, Nebraska, March 21, 2000.



Bonne Terre, 2010. Bonne Terre Chamber of Commerce website on tourism for Bonne Terre Mines, http://www.bonneterrechamber.com/mx/hm.asp?id=BonneTerreMines.

Center for Disease Control (CDC) National Surveillance Data (1997-2008), http://www.cdc.gov/nceh/lead/data/national.htm webpage: Childhood Lead Poisoning Data, Statistics, and Surveillance, last update June 1, 2009.

Doe Run 2010. Letter regarding “St. Francois County Blood Lead/Soil Lead”, to Gene Gunn, EPA Region 7, from Lou Marucheau, Doe Run, dated March 22, 2010

FMSCA, 2008. 2007 Large Truck Crash Overview, prepared by Analysis Division, Federal Motor Carrier Safety Administration, U.S. Department of Transportation, December. http://www.fmcsa.dot.gov/facts-research/research-technology/report/ 2007LargeTruckCrashOverview.pdf.

United States Environmental Protection Agency (EPA), 1988a. Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA Interim Final. EPA/540/G-89/004, OSWER Directive 9355.3-01. October 1988.

EPA, 1988b. CERCLA Compliance with Other Laws Manual: Interim Final. Office of Emergency and Remedial Response EPA/540/G-89/006, August 1988.

EPA, 1993. Memorandum: Revisions to OMB Circular A-94 on Guidelines and Discount Rates for Benefit-Cost Analysis. OSWER Directive No. 9355.3-20, June 1993.

EPA, 1994a. Memorandum: OSWER Directive: Revised Interim Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities. OSWER Directive 9355.4-12, July 14, 1994.

EPA 1994b. National Oil and Hazardous Substances Pollution Contingency Plan (commonly known as the National Contingency Plan or NCP). 40 Code of Federal Regulations Parts 9 and 300, Final Rule effective date October 17, 1994.

EPA, 2000. A Guide to Developing and Documenting Cost Estimates during the Feasibility Study. OSWER 9355.0-75. EPA/540/R-00/002. July 2000.

EPA, 2003. Superfund Lead-Contaminated Residential Sites Handbook. Prepared by the Environmental Protection Agency Lead Sites Workgroup (LSW), OSWER 9285.7-50, August 2003.

EPA, 2010a. Email from Jason Gunter, EPA, to Kerri Sitler, NewFields, regarding RE: SFC FS (residential homes in the Response Area), dated April 14, 2010.



EPA, 2010b. Letter from Jason Gunter, EPA, to John Carter, The Doe Run Company, regarding Residential Preliminary Remediation Goal for the Big River Mine Tailings, dated May 12, 2010.

Gradient 2010. Memorandum regarding “IEUBK Modeling of St. Francois County Blood Lead and Soil Lead Data” to Lou Marucheau, Doe Run, from Terri Bowers, Gradient, dated February 11, 2010. Provided to EPA in a February 11, 2010 meeting.

HydroGeoLogic, Inc (HGL) 2009. Final Human Health Risk Assessment, Big River Mine Tailings Site, St. Francois County, Missouri. Prepared for US Environmental Protection Agency Region 7 under Architect and Engineering Services Contract EP-S7-05-05, Task Order 0010, July 2009.

HUD, EPA, MDOH, Jasper and St. Francois County Health Departments, Doe Run, and Saint Louis University, 1997. The Jasper – St. Francois Lead Intervention Project. Working together to protect children’s health.

Missouri Department of Health and Senior Services (MDHSS), 2003. ““Blood Lead Screening – Calendar Year: 1997-2001 Lead Testing Data with Census and Housing Info”. Tabulated results for calendar years 1997 through 2001, accessed via MDHSS website on Data & Statistical Reports, http://www.dhss.mo.gov/ChildhoodLead/Cal97-01.pdf, table dated June 24, 2004.

MDHSS, 2011. Blood Lead Screening – Calendar Year, 2010 Calendar Year Data. Table titled “Missouri Department of Health and Senior Services, 2010 Calendar Year Blood Lead Testing Data, January through December 2010, Children Less than Six Years of Age.” Accessed via MDHSS website on Data & Statistical Reports, table dated February 17, 2011. http://health.mo.gov/living/environment/ lead/pdf/Cal10byCounty.pdf.

MDHSS, 2003. “Blood Lead Screening – Calendar Year, 1997-2001 Lead Testing Data with Census and Housing Info,” Tabulated results for calendar years 1997 through 2001, titled “Missouri Department of Health and Senior Services, Childhood Blood Lead Screening and Risk Data”, accessed via MDHSS website on Data & Statistical Reports, http://health.mo.gov/living/environment/lead/pdf/ Cal97-01.pdf, table dated June 24, 2003.

NewFields, 2000. Work Plan for Interim Action, Soil Testing and Removal, Blood Lead Testing, St. Francois County Mine Tailings Sites, July 26, 2000.

NewFields, 2003. Repository Operation Manual, Residential Yard Removal Actions for Interim Action. St. Francois County Mine Tailings Sites, St. Francois County, Missouri, March 14, 2003.



NewFields, 2004a. Work Plan for Halo Removal Action, Surface Soil Characterization and Removal, St. Francois County Mine Tailings Sites. May 28, 2004.

NewFields, 2004b. Removal Action Report for Interim Action, Soil Testing and Removal, Blood Lead Testing, St. Francois County Mine Tailings Sites. May 21, 2004.

NewFields, 2006. Focused Remedial Investigation for Mined Areas in St. Francois County, Missouri. March 3, 2006.

NewFields, 2010. Memorandum regarding “Comments on HGL’s comparison of XRF-derived lead Concentrations to Laboratory-derived Lead Concentrations presented in EPA’s Final Human Health Risk Assessment, Big River Mine Tailings Site, St. Francois County, Missouri”, to John Cater and Lou Marucheau, Doe Run, from Kerri Sitler, NewFields, dated February 18, 2010. Provided to EPA attached to a Doe Run letter to Gene Gunn, EPA Region 7, dated March 22, 2010.

NewFields, 2011. Subsurface Soil Investigation in Residential Areas, St. Francois County Mined Areas. June 13, 2011.

NewFields and Gradient, 2010. Memorandum regarding “Response to additional information on the February 11, 2010 Gradient memorandum regarding IEUBK modeling of St. Francois County blood lead and soil lead data”, to Jason Gunter, Gene Gunn, and Mike Beringer, EPA Region VII, from Kerri Sitler, NewFields, and Terri Bowers, Gradient, dated March 9, 2010. Provided to EPA attached to a Doe Run letter to Gene Gunn, EPA Region 7, dated March 22, 2010.

Appendix A

Detailed Areas of Figures 2 through 4

Federal

Leadwood

Desloge

Bonne Terre

Hayden CreekElvins/Rivermines

National

Doe Run

LegendSub-Figure Location

a - Bonne Terreb - Desloge (BRMTS)c - Park Hillsd - Leadwoode - Elvins/Riverminesf - Federal (St. Joe State Park)g - Doe Run

Sampled Yards ShaftsSmeltersChat PilesTailing PondsHalo - 100 ft from ShaftsHalo - 1000 ft from SmeltersHalo - 500 ft from TPondsHalo - 500 ft from Chat Piles

Response Area

0 8,500 17,000 25,500 34,0004,250Feet


Figure Index to Sub-Figures

St. Francois Co. Mined Areas

Bonne Terre

Legend



Response Area

0 1,600 3,200 4,800 6,400800Feet


Figure 2a:Bonne Terre

Interim and Halo Removal ActionsResidential Yards


Desloge

Legend



Response Area

0 1,400 2,800 4,200 5,600700Feet


Figure 2b:Desloge (BRMTS)



Federal

Desloge

National

Elvins/Rivermines

Legend



Response Area

0 2,300 4,600 6,900 9,2001,150Feet


Figure 2c:Park Hills



Leadwood

Legend



Response Area

0 1,600 3,200 4,800 6,400800Feet


Figure 2d:Leadwood



Elvins/Rivermines

Legend



Response Area

0 1,100 2,200 3,300 4,400550Feet


Figure 2e:Elvins/Rivermines



Federal

Elvins/Rivermines

Legend



Response Area

0 2,000 4,000 6,000 8,0001,000Feet


Figure 2f:Federal (St. Joe State Park)



Doe Run

Legend



Response Area

0 1,700 3,400 5,100 6,800850Feet


Figure 2g:Doe Run



Bonne Terre




0 1,800 3,600 5,400 7,200900

Feet


Figure 3a:Bonne Terre

Average Surface Soil Lead Concentrationsin Yard Quadrant Samples



Desloge




0 1,500 3,000 4,500 6,000750

Feet


Figure 3b:Desloge (BRMTS)




National

Elvins/Rivermines

Federal

Desloge




0 2,500 5,000 7,500 10,0001,250

Feet


Figure 3c:Park Hills




Leadwood




0 1,700 3,400 5,100 6,800850

Feet


Figure 3d:Leadwood




Elvins/Rivermines




0 1,100 2,200 3,300 4,400550

Feet


Figure 3e:Elvins/Rivermines




Elvins/Rivermines

Federal




0 2,400 4,800 7,200 9,6001,200

Feet


Figure 3f:Federal (St. Joe State Park)




Doe Run




0 2,000 4,000 6,000 8,0001,000

Feet


Figure 3g:Doe Run




Bonne Terre




0 1,800 3,600 5,400 7,200900

Feet


Maximum concentration of the yard quadrant samples: Front Yard Left (FL), Front Yard Right (FR), Back Yard Left (BL), and Back Yard Right (BR). Figure 4a:

Bonne TerreMaximum Surface Soil Lead Concentrations


Desloge




0 1,500 3,000 4,500 6,000750

Feet


Maximum concentration of the yard quadrant samples: Front Yard Left (FL), Front Yard Right (FR), Back Yard Left (BL), and Back Yard Right (BR). Figure 4b:

Desloge (BRMTS)Maximum Surface Soil Lead Concentrations


National

Elvins/Rivermines

Federal

Desloge




0 2,500 5,000 7,500 10,0001,250

Feet


Maximum concentration of the yard quadrant samples: Front Yard Left (FL), Front Yard Right (FR), Back Yard Left (BL), and Back Yard Right (BR). Figure 4c:

Park HillsMaximum Surface Soil Lead Concentrations


Leadwood




0 1,700 3,400 5,100 6,800850

Feet


Maximum concentration of the yard quadrant samples: Front Yard Left (FL), Front Yard Right (FR), Back Yard Left (BL), and Back Yard Right (BR). Figure 4d:

LeadwoodMaximum Surface Soil Lead Concentrations


Elvins/Rivermines




0 1,100 2,200 3,300 4,400550

Feet


Maximum concentration of the yard quadrant samples: Front Yard Left (FL), Front Yard Right (FR), Back Yard Left (BL), and Back Yard Right (BR). Figure 4e:

Elvins/RiverminesMaximum Surface Soil Lead Concentrations


Elvins/Rivermines

Federal




0 2,400 4,800 7,200 9,6001,200

Feet


Maximum concentration of the yard quadrant samples: Front Yard Left (FL), Front Yard Right (FR), Back Yard Left (BL), and Back Yard Right (BR). Figure 4f:

Federal (St. Joe State Park)Maximum Surface Soil Lead Concentrations


Doe Run




0 2,000 4,000 6,000 8,0001,000

Feet


Maximum concentration of the yard quadrant samples: Front Yard Left (FL), Front Yard Right (FR), Back Yard Left (BL), and Back Yard Right (BR). Figure 4g:

Doe RunMaximum Surface Soil Lead Concentrations


feasibility study for residential areas (ou-1)feasibility study for residential areas (ou-1) st....

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