Engineering
Evaluation
/
Cost
Analysis
for
a
portion
of
the
Oronogo­
Duenweg
Mining
Belt
Site
Jasper
County,
Missouri
Prepared
by
the
U.
S.
Environmental
Protection
Agency
Region
VII
901
N.
5th
Street
Kansas
City,
Kansas
66101
August
2000
Executive
Summary
Engineering
Evaluation
/
Cost
Analysis
for
a
portion
of
the
Oronogo­
Duenweg
Mining
Belt
Site
Jasper
County,
Missouri
Purpose
The
purpose
of
this
engineering
evaluation/
cost
analysis
(
EE/
CA)
is
to
screen
and
evaluate
removal
action
alternatives
for
controlling
releases
of
contaminants
in
the
Oronogo­
Duenweg
Mining
Belt
Site
(
Site)
in
Jasper
County,
Missouri.
The
Missouri
Department
of
Transportation
(
MDOT)
has
completed
plans
to
construct
a
four­
lane
highway
through
the
Site
from
7th
Street
near
Duenweg,
Missouri,
to
Business
71
Highway
near
Carterville,
Missouri,
through
a
portion
of
the
Site
containing
mining
wastes
contaminated
with
cadmium,
lead,
and
zinc.
At
the
request
of
the
community,
the
Environmental
Protection
Agency
(
EPA)
and
MDOT
are
proposing
to
use
approximately
588,000
cubic
yards
of
metals
contaminated
mining
wastes
for
fill
in
the
highway
construction.
This
EE/
CA
evaluates
alternatives
to
cleanup
of
the
mining
wastes
in
the
vicinity
of
the
proposed
highway.

Scope
and
Objective
of
the
Removal
Action
The
objective
of
this
non­
time­
critical
removal
action
at
the
Site
is
to
mitigate
the
threat
to
public
health
or
welfare
or
the
environment
resulting
from
surface
release
of
metals­
contaminated
material
from
the
mining
waste
piles.
The
removal
action
will
address
the
release
of
material
associated
with
identified
aquatic
and
terrestrial
risk
and
potential
future
human
health
risk
in
the
vicinity
of
the
proposed
highway
construction.
This
removal
action
is
an
interim
(
early)
action
for
cleanup
simultaneous
to
construction
of
the
proposed
highway.
A
remedial
investigation
has
been
completed
and
a
feasibility
study
(
FS)
will
be
completed
in
approximately
12
to
18
months
to
determine
appropriate
cleanup
alternatives
for
the
remainder
of
the
Site.

Removal
Alternatives
Assessment
The
following
two
removal
alternative
are
carried
through
and
assessed
in
this
EE/
CA.

Capping
Under
this
alternative,
approximately
140
acres
containing
approximately
588,000
cubic
yards
of
mining
wastes
would
be
regraded
to
reduce
the
slopes
and
promote
adequate
drainage
of
the
areas.
The
wastes
would
be
capped
with
one
foot
of
soil
cover
to
prevent
direct
exposure
to
the
wastes
and
establish
vegetative
cover.
Storm
water
runoff
controls
and
dust
suppression
would
be
required
during
grading
operations
to
ensure
metals
are
not
released
to
areas
surrounding
the
piles.
Approximately
1613
cubic
yards
of
soil
would
be
require
to
cover
each
acre
for
a
total
of
225,820
cubic
yards.
The
soil
would
be
obtained
from
the
area
surrounding
the
waste
piles
and
ii
would
contain
less
than
240
ppm
lead
and
25
ppm
cadmium.
Since
the
waste
would
be
left
in
place
and
subject
to
disturbance
during
future
development
that
will
likely
occur
in
the
area,
institutional
controls
would
be
required
to
regulate
development
of
the
area.
Total
cost
of
the
alternative
is
estimated
at
$
2,831,737
with
an
annual
operation
and
maintenance
cost
of
$
379,500
for
30
years.
Total
cost
estimated
for
this
alternative
is
$
3,211,237.

Excavation
and
On­
site
Disposal
Under
this
alternative,
the
same
140
acres
and
588,000
cubic
yards
of
wastes
addressed
under
the
capping
alternative
would
be
excavated
and
hauled
into
the
highway
corridor
and
used
as
fill
for
the
construction
of
the
roadway.
The
wastes
will
be
handled
and
placed
by
MDOT
in
areas
requiring
fill
and
compacted
to
construction
specifications.
Additionally,
approximately
one
foot
of
soil
underlying
the
mining
wastes
will
also
be
removed
along
with
the
wastes.
This
soil
will
be
used
to
aid
the
fill
compaction,
as
well
as,
remove
lead
contamination
exceeding
500
ppm
from
the
underlying
soil.
All
mining
wastes
exceeding
1,500
ppm
lead
exposed
in
the
side
slopes
of
the
highway
embankment
would
be
covered
with
one
foot
of
clean
soil.
MDOT
will
be
required
to
comply
with
all
storm
water
runoff
requirements
and
to
suppress
all
fugitive
dust.
The
total
cost
estimate
for
this
alternative
is
$
3,548,313.
Since
the
mining
wastes
will
be
removed
and
disposed
of
under
the
highway,
no
institutional
controls
or
annual
operation
and
maintenance
would
be
required.

Proposed
Removal
Action
The
EPA's
recommended
alternative
is
excavation
of
the
mining
wastes
with
disposal
as
construction
fill
under
the
highway
during
construction.
This
alternative
is
slightly
more
costly
than
capping
but
better
meets
the
remediation
goals
than
the
capping
option.
The
disposal
of
the
wastes
under
the
highway
will
create
a
more
permanent
remedy
without
reliance
on
institutional
controls.
Further,
the
citizens
task
forces
have
voiced
a
preference
for
permanent
disposal
of
the
wastes
instead
of
capping
in
place
which
must
be
dealt
with
during
future
development
of
the
area.
The
preferred
removal
action
of
mining
wastes
in
the
vicinity
of
the
highway
consists
of
the
following
actions:

1.
Excavation
of
the
mining
waste
piles
with
transport
into
the
highway
corridor.
2.
Removal
of
the
top
12
inches
of
soil
beneath
the
excavated
waste
piles.
3.
Incorporation
of
the
mining
wastes
and
underlying
soil
into
the
highway
construction
fill.
4.
Implementation
of
storm
water
runoff
controls
during
excavation
and
disposal
activities.
5.
Dust
suppression
during
excavation
and
disposal
activities.
6.
Placement
of
12
inches
of
clean
soil
cover
on
all
mining
waste
exceeding
1,500
ppm
lead
in
the
highway
side
slopes.
7
Revegetation
of
disturbed
areas.
iii
Since
the
estimated
cost
of
the
proposed
removal
alternative
exceeds
the
statutory
limitations,
a
consistency
waiver
from
the
statutory
limitation
on
cost
is
required
to
conduct
this
action.

Approved:

________________________
________________________
Michael
J.
Sanderson,
Director
Date
Superfund
Division
iv
Table
of
Contents
1.0
Introduction
1
2.0
Site
Characterization
2
2.1
Site
Location
3
2.2
Site
History
6
2.3
Nature
and
Extent
of
Contamination
6
2.4
Risk
Evaluation
7
3.0
Basis
for
Removal
Action
7
4.0
Identification
of
Removal
Actions
8
4.1
Removal
Action
Scope
and
Objectives
8
4.2
Statutory
Limits
on
Removal
Actions
8
4.3
Applicable
or
Relevant
and
Appropriate
Requirements
8
4.3.1
Chemical
Specific
9
4.3.2
Location
Specific
9
4.3.3
Action
Specific
9
4.4
Determination
of
ARARs
9
4.4.1
National
Ambient
Air
Quality
Standards
(
NAAQS)
10
4.4.2
Fugitive
Particulate
Matter
Regulations
10
4.4.3
Surface
Mining
Control
and
Reclamation
Act
(
SMCRA)
10
4.4.4
Storm
Water
Requirements
(
10
CSR
20­
6.200)
11
4.4.5
RCRA
Subtitle
D
Solid
Waste
Disposal
Regulations
11
4.4.6
Determination
of
Non­
ARARs
11
4.4.7
RCRA
Subtitle
C
Hazardous
Waste
Regulations
11
4.4.8
Ground
water
Requirements
12
4.4.9
Other
Criteria
to
Be
Considered
12
5.0
Identification
and
Initial
Screening
of
Removal
Action
Alternatives
12
5.1
Stabilization
and
Treatment
13
5.2
Capping
13
5.3
Excavation
and
Off­
site
Disposal
13
5.4
Excavation
and
On­
site
Disposal
13
5.5
Revegetation
13
6.0
Development
of
Removal
Action
Alternatives
14
6.1
No
Action
Alternative
13
6.2
Capping
13
6.3
Excavation
and
On­
site
Disposal
14
7.0
Analysis
of
Proposed
Removal
Action
Alternatives
15
7.1
Effectiveness
15
7.1.1
Long­
term
Effectiveness
15
7.1.2
Short­
term
Effectiveness
15
7.1.3
Compliance
with
ARARs
16
7.2
Implementability
16
7.2.1
Technical
Feasibility
16
7.2.2
Administrative
Feasibility
16
7.2.3
Availability
of
Services
and
Materials
17
v
7.2.4
State
Acceptance
17
Table
of
Contents
(
continued)

7.2.5
Community
Acceptance
17
7.3
Cost
17
8.0
Recommended
Removal
Action
Alternative
17
9.0
Removal
Schedule
18
Figure
1
­
Site
Location
4
Figure
2
­
Proposed
Highway
Location
5
Table
1
­
Cost
Estimate
for
Capping
Alternative
19
Table
2
­
Cost
Estimate
for
Excavation
and
Disposal
Alternative
19
References
20
1
Engineering
Evaluation
/
Cost
Analysis
for
a
portion
of
the
Oronogo­
Duenweg
Mining
Belt
Site
Jasper
County,
Missouri
1.0
Introduction
The
purpose
of
this
Engineering
Evaluation/
Cost
analysis
(
EE/
CA)
is
to
screen
and
evaluate
removal
action
alternatives
for
controlling
releases
of
contaminants
in
the
Oronogo­
Duenweg
Mining
Belt
Site
in
Jasper
County,
Missouri.
EPA
has
been
coordinating
with
the
Missouri
Department
of
Transportation
(
MDOT)
on
the
construction
of
a
four­
lane
highway
through
a
portion
of
the
Site
containing
mining
wastes
contaminated
with
cadmium,
lead,
and
zinc.
The
MDOT
has
completed
plans
to
construct
a
fourlane
highway
through
the
Site
from
7th
Street
near
Duenweg,
Missouri,
to
Business
71
Highway
near
Carterville,
Missouri.
EPA
and
MDOT
have
entered
into
a
Prospective
Purchasers
Agreement
(
PPA)
for
construction
of
the
highway
through
the
Site.
As
part
of
the
PPA,
MDOT
is
required
to
cleanup
all
mining
wastes
that
fall
within
the
right­
of­
way
of
the
highway.
Additionally,
at
the
request
of
the
community
and
EPA,
MDOT
is
proposing
to
use
approximately
588,000
cubic
yards
of
metals
contaminated
mining
wastes
for
fill
in
the
highway
construction.
This
EE/
CA
is
largely
based
on
the
construction
design
completed
by
MDOT.
Additional
alternatives
are
evaluated
against
using
the
mining
wastes
as
fill
for
highway
construction
for
cleanup
of
the
wastes
in
the
area
to
determine
the
most
appropriate
cleanup
alternative.

The
EPA
and
potentially
responsible
parties
(
PRPs)
investigations
at
the
Site
have
revealed
significant
heavy
metals
contamination
in
the
mining
wastes,
ground
water,
surface
soils,
surface
water,
and
sediments.
Based
on
the
criteria
set
forth
in
Section
300.415(
b)(
2)
of
the
National
Oil
and
Hazardous
Substances
Pollution
Contingency
Plan
(
NCP),
EPA
has
determined
that
the
Site
poses
a
threat
to
public
health
and
the
environment
and
that
a
removal
action
is
necessary
to
reduce
the
threat.
EPA
and
the
PRPs
are
currently
conducting
a
FS
to
address
the
mining
waste
source
materials
at
the
Site.
The
FS
is
expected
to
be
completed
in
late
2001.
This
memorandum
documents
the
need
to
move
forward
with
an
EE/
CA
for
a
non­
time
critical
removal
action
for
a
portion
of
the
Site
in
advance
of
the
completion
of
the
FS
and
Record
of
Decision
(
ROD).
Construction
of
the
highway
is
anticipated
to
begin
prior
to
completion
of
EPA's
ROD.
The
decision
to
proceed
with
this
EE/
CA
is
consistent
with
EPA
guidance
regarding
Superfund
Accelerated
Cleanup
Model
early
actions
and
the
long­
term
remedial
strategy
for
this
Site.

An
EE/
CA
is
required
for
all
non­
time­
critical
removal
actions,
pursuant
to
Section
300.415(
b)(
4)
of
the
NCP,
40
C.
F.
R.
§
300.415(
b)(
4).
This
EE/
CA
provides
background
information
on
the
Site,
evaluates
removal
action
alternatives
for
the
Site,
describes
the
removal
action
alternative
that
EPA
recommends,
and
explains
the
rationale
for
this
recommendation.
Also,
EPA
has
established
an
Administrative
Record
file
for
the
removal
action
at
this
site
which
contains
all
of
the
information
that
EPA
has
considered
or
relied
on
thus
far
in
evaluating
removal
alternatives.
The
Administrative
Record
file
is
available
for
public
review
at
the
following
locations:
2
Joplin
Public
Library
Carl
Junction
City
Hall
300
Main
105
North
Main
Joplin,
Missouri
Carl
Junction,
Missouri
Webb
City
Public
Library
U.
S.
Environmental
Protection
Agency
101
South
Liberty
901
N.
5th
Street
Webb
City,
Missouri
Kansas
City,
Kansas
The
EPA
has
not
made
a
final
decision
on
the
removal
action
to
be
taken
at
this
site.
Publication
of
this
EE/
CA
opens
a
30­
day
public
comment
period
on
the
proposed
removal
action.
EPA
encourages
the
public
to
comment
on
the
alternatives
analyzed
in
this
EE/
CA.
Written
comments
should
be
submitted
to:

U.
S.
Environmental
Protection
Agency,
Region
VII
Office
of
External
Programs
901
N.
5th
Street
Kansas
City,
KS
66101
ATTN:
Hattie
Thomas
After
the
close
of
the
public
comment
period,
EPA
will
issue
an
Action
Memorandum
which
will
present
EPA's
selected
removal
action
and
describe
the
basis
for
that
selection.
In
that
Action
Memorandum,
EPA
may
modify
the
proposed
alternative
presented
in
this
EE/
CA
or
select
other
removal
options,
based
on
public
comments
or
new
information.
Any
comments
on
this
EE/
CA
that
are
received
during
the
comment
period
will
be
addressed
by
EPA
in
a
responsiveness
summary,
which
will
be
attached
to
the
Action
Memorandum.

2.0
Site
Characterization
The
Site
is
part
of
the
Tri­
State
Mining
District,
which
covers
hundreds
of
square
miles
in
southwestern
Missouri,
southeastern
Kansas,
and
northeastern
Oklahoma.
Mining,
milling,
and
smelting
of
lead
and
zinc
ore
date
back
to
1850
and
continued
in
the
district
until
the
1970s.
The
Missouri
portion
of
the
district
accounted
for
more
than
0.2
billion
tons
of
ore,
80
percent
of
which
was
produced
in
Jasper
County.
Processing
of
the
ore
resulted
in
approximately
150
million
tons
of
wastes.
Mining,
milling,
and
smelting
activities
generated
several
types
of
waste
materials
including
mine
wastes
(
waste
rock,
development
rock,
and
overburden),
mill
wastes
(
chat
and
fine
tailings),
and
smelter­
related
materials
(
slag,
fugitive
dust,
and
air
emissions).
Approximately
nine
million
tons
of
mining/
milling
and
smelter
wastes
remain
on
the
surface
at
the
Site
and
contain
residual
heavy
metals,
particularly
lead,
cadmium,
and
zinc.
These
wastes
currently
contribute
metals
contamination
to
surface
soils,
surface
water,
and
ground
water.
Additionally,
most
mining
occurred
underground
at
depths
up
to
400
feet
resulting
in
hundreds
of
mine
shafts,
many
miles
of
mine
adits,
and
vast
underground
voids
throughout
the
Site.
These
mine
openings
create
conduits
for
migration
of
metals
contamination
into
the
ground
water
from
the
surface.
Ground
water
is
used
as
a
source
of
drinking
water
in
the
Site
and
also
recharges
up
to
70
percent
of
surface
water
in
local
streams.
3
2.1
Site
Location
The
portion
of
the
Site
addressed
by
this
EE/
CA
is
located
within
the
Site,
which
is
part
of
the
Tri­
State
Mining
District
and
is
shown
on
Figure
1.
The
Site
lies
within
an
area
bounded
on
the
north
by
the
township
line
between
Townships
29
and
30
North,
on
the
south
by
the
county
line
between
Jasper
and
Newton
Counties,
but
also
including
portions
of
Section
24
Township
27
North
Range
34
West
and
Sections
19
and
20
Township
27
North
Range
33
West
in
Newton
County,
on
the
west
by
the
state
line
between
Missouri
and
Kansas,
and
on
the
east
by
the
range
line
between
Ranges
31
and
32
West.
The
Site
encompasses
several
small­
to
medium­
size
municipalities
and
the
surrounding
unincorporated
areas.
Land
use
varies
from
agricultural
to
urban.
Approximately
60,000
people
live
within
the
Site
boundaries.

The
portion
of
the
Site
covered
by
this
EE/
CA
is
approximately
the
southern
half
of
the
Oronogo­
Duenweg
Designated
Area.
The
location
of
the
proposed
highway
and
the
area
of
the
Site
covered
by
this
EE/
CA
is
shown
in
Figure
2.
4
FIGURE
1
5
FIGURE
2
6
2.2
Site
History
The
EPA
added
the
Site
to
the
National
Priorities
List
(
NPL)
in
1990.
The
NPL
is
the
EPA's
list
of
sites
which
have
the
greatest
contamination
and
pose
the
greatest
threat
to
human
health
and
the
environment.
The
Site
has
been
divided
into
11
separate
designated
areas
(
DAs)
for
investigation
because
of
its
large
area,
about
270
square
miles.
EPA
conducted
a
PRP
search
to
identify
mining
companies
that
may
be
responsible
for
cleanup
of
the
wastes
and
contamination
at
the
Site.
In
1991,
the
EPA
signed
an
Administrative
Order
on
Consent
with
a
group
of
nine
PRPs
to
conduct
a
Remedial
Investigation/
Feasibility
Study
(
RI/
FS)
at
seven
of
the
DAs
of
the
Site
under
EPA
oversight.
EPA
conducted
the
investigations
at
the
remaining
four
DAs
and
completed
a
human
health
and
ecological
risk
assessments.

In
December
1993,
EPA
issued
a
Unilateral
Administrative
Order
(
UAO)
to
the
PRPs
to
supply
bottled
water
to
affected
homes.
In
June
1994,
EPA
issued
a
second
UAO
to
the
PRPs
to
conduct
additional
sampling
of
private
water
supply
wells
and
to
provide
additional
bottled
water
if
wells
were
found
to
exceed
heath­
based
standards.
These
investigations
identified
approximately
100
affected
homes.
Approximately
60
affected
homes
are
currently
being
supplied
bottled
water
by
the
PRPs
and
EPA
supplies
bottled
water
to
approximately
40
homes.
In
July
1998,
EPA
issued
a
ROD
for
installation
of
public
water
supply
systems
to
replace
the
bottled
water
program.
Currently,
Duenweg,
Webb
City,
and
Missouri
American
Water
Company
are
completing
designs
for
installation
of
the
various
systems.
Construction
of
the
supply
lines
are
anticipated
to
begin
in
2001.

The
Missouri
Department
of
Health
(
MDOH)
conducted
an
exposure
study
to
evaluate
health
effects
on
residents
in
the
Site.
The
study,
which
was
released
in
May
1994,
concluded
that
14
percent
of
children
under
the
age
of
seven
years
in
the
study
area
had
elevated
blood­
lead
concentrations.
Additionally,
the
study
concluded
that
the
most
significant
source
of
contamination
resulting
in
elevated
blood­
lead
levels
was
residential
yard
soils.
Following
release
of
the
health
study
in
1994,
EPA
developed
a
strategy
to
prioritize
cleanup
of
residential
yards
at
this
Site.
Initial
work
done
under
the
strategy
identified
numerous
daycare
centers
and
residences
as
having
high
soil
lead
concentrations
at
levels
requiring
immediate
cleanup.
Therefore,
in
January
1995
EPA
issued
an
Action
Memorandum
for
a
time­
critical
removal
which
commenced
cleanup
of
these
daycare
centers
and
residential
yards.
Under
the
time­
critical
removal
action,
EPA
cleaned
up
303
residential
yards
and
seven
daycare
centers.
EPA
issued
a
ROD
for
cleanup
of
residential
yards
in
June
1996
to
follow
the
time­
critical
removal
action.
To
date
approximately
2,100
additional
properties
have
been
remediated.

2.3
Nature
and
Extent
of
Contamination
Investigations
conducted
at
the
Site
by
EPA
and
the
PRPs
showed
the
primary
contaminants
of
concern
are
cadmium,
lead,
and
zinc.
These
contaminants
were
found
in
the
mining
wastes,
surface
soils,
ground
water,
and
surface
water
at
levels
causing
an
unacceptable
risk
to
human
health
and
the
environment.
The
following
table
shows
the
range
of
contaminants
7
detected
in
the
various
media.

Media
Lead
Cadmium
Zinc
Surface
Water
0.001
­
0.002
ppm
0.002
­
0.004
ppm
0.005
­
0.489
ppm
Ground
Water
0.001
­
0.29
ppm
0.001
­
0.22
ppm
0.005
­
21.8
ppm
Smelter
Area
Soil
45
­
10,000
ppm
5
­
150
ppm
600
­
20,000
ppm
Mined
Area
Soil
20
­
39,000
ppm
1
­
288
ppm
57
­
45,400
ppm
Stream
Sediment
15
­
242
ppm
1
­
68
ppm
103
­
4,810
ppm
Mining
Wastes
22
­
24,100
ppm
4
­
644
ppm
466
­
71,500
ppm
2.4
Risk
Evaluation
The
EPA
conducted
a
human
health
risk
assessment
(
HHRA)
which
determined
that
young
children
living
on
or
near
mining
wastes
or
in
the
smelter
zone
were
at
risk
of
elevated
blood­
lead
levels
and
associated
adverse
health
effects.
The
HHRA
determined
that
children
under
the
age
of
seven
years
should
not
reside
on,
or
become
exposed
to
soil
with
more
than
500
parts
per
million
lead.
Additionally,
the
investigations
conducted
at
the
Site
identified
people
living
in
over
100
residences
were
consuming
shallow
ground
water
with
cadmium,
lead,
and
zinc
exceeding
the
health
based
levels.

The
ecological
risk
assessment
(
ERA)
identified
a
significant
risk
to
aquatic
organisms
living
in
the
local
streams.
The
ERA
also
identified
significant
risk
to
terrestrial
organisms
living
near
mining
waste
areas.

3.0
Basis
for
Removal
Action
To
justify
conducting
a
removal
action,
EPA
must
determine
that
the
site
poses
a
threat
to
public
health
or
welfare
or
the
environment,
based
on
consideration
of
the
eight
factors
listed
at
Section
300.415
(
b)(
2)
of
the
NCP,
40
CFR
§
300.415
(
b)(
2).
If,
based
on
those
factors,
EPA
determines
that
a
threat
exists,
a
removal
action
is
justified
in
order
to
abate,
prevent,
minimize,
stabilize,
mitigate,
or
eliminate
the
release
or
threat
of
release
of
hazardous
substances.
EPA
has
evaluated
these
factors
and
determined
that
a
removal
action
is
justified.

Although
human
exposure
to
metals
contamination
in
this
portion
of
the
Site
is
relatively
low
since
the
area
is
sparsely
populated,
and
the
HHRA
did
not
identify
a
risk
to
trespassers,
the
potential
risk
to
future
residents
is
high.
It
is
anticipated
that
once
construction
of
the
highway
is
completed,
development
of
the
area
is
highly
likely.
Since
Jasper
County
currently
does
not
have
planning
and
zoning
regulations
established
for
the
area,
it
is
probable
that
people
will
build
residences
on
contaminated
mining
wastes
and
soils
in
the
vicinity
of
the
new
roadway.
8
9
In
addition,
the
ERA
has
identified
a
significant
risk
to
aquatic
and
terrestrial
organisms
living
at
the
Site.
The
mining
wastes
are
the
source
of
the
risk
due
to
high
metals
concentrations.
Cleanup
actions
are
required
to
remove
the
risk
to
the
environment.

4.0
Identification
of
Removal
Actions
4.1
Removal
Action
Scope
and
Objectives
The
objective
of
this
non­
time­
critical
removal
action
at
the
Site
is
to
mitigate
the
threat
to
public
health
or
welfare
or
the
environment
resulting
from
surface
release
of
metals­
contaminated
material
from
the
mining
waste
piles.
The
removal
action
will
address
the
release
of
material
associated
with
identified
aquatic
and
terrestrial
risk
and
potential
future
human
health
risk
in
the
vicinity
of
the
proposed
highway
construction.
This
removal
action
is
an
interim
(
early)
action
for
cleanup
simultaneous
to
construction
of
the
proposed
highway.
A
remedial
investigation
has
been
completed
and
FS
will
be
completed
in
approximately
12
to
18
months
to
determine
appropriate
cleanup
alternatives
for
the
remainder
of
the
mining
waste
piles
at
the
Site.

4.2
Statutory
Limits
on
Removal
Actions
Section
300.415(
b)(
5)
of
the
NCP,
40
CFR
§
300.415(
b)(
5),
stipulates
that
the
cost
and
duration
of
a
removal
action
conducted
by
EPA
is
limited
to
$
2
million
and
12
months,
unless
an
exemption
to
these
limits
is
obtained.
Section
104(
b)
of
the
Comprehensive
Environmental
Response,
Compensation,
and
Liability
Act
(
CERCLA)
provides
for
two
types
of
exemptions
to
these
statutory
removal
limits:
1)
the
"
emergency"
waiver;
and
2)
the
"
consistency"
waiver.
The
"
emergency"
waiver
provides
additional
funding
or
extends
the
removal
action
time,
when
continued
response
actions
are
immediately
required
to
prevent,
limit,
or
mitigate
an
immediate
risk
to
public
health
or
welfare
or
the
environment.
The
"
consistency"
waiver
provides
an
exemption
to
the
statutory
funding
limits
or
extends
the
removal
action
time
to
implement
a
removal
action
that
is
otherwise
appropriate
and
consistent
with
the
final
response
action
to
be
taken.
In
this
EE/
CA,
one
of
the
factors
considered
in
the
evaluation
of
each
removal
alternative
is
whether
the
removal
can
be
completed
within
the
statutory
limits,
or
whether
the
removal
could
qualify
for
an
exemption
from
the
limits.

4.3
Applicable
or
Relevant
and
Appropriate
Requirements
Section
300.415
(
i)
of
the
NCP
provides
that
fund­
financed
removal
actions
under
CERCLA
Section
104
shall,
to
the
extent
practicable
considering
the
exigencies
of
the
situation,
attain
applicable
or
relevant
and
appropriate
requirements
(
ARARs)
under
federal
or
state
environmental
or
facility­
siting
laws.
Other
advisories,
criteria,
or
guidance
may
be
considered
for
a
particular
site.
10
Under
CERCLA,
as
amended
by
the
Superfund
Amendments
and
Reauthorization
Act,
a
requirement
may
be
either
"
applicable"
or
"
relevant
and
appropriate"
to
a
specific
removal
action,
but
not
both.
Applicable
requirements
are
those
public
and
environmental
health
and
welfare
requirements,
criteria,
and/
or
standards
promulgated
under
federal
or
state
law
that
address
specific
circumstances
or
scenarios
at
a
CERCLA
site.
Relevant
and
appropriate
requirements
are
those
public
and
environmental
health
and
welfare
requirements,
criteria,
and/
or
standards
promulgated
under
federal
or
state
law
that,
while
not
applicable
to
a
specific
site's
circumstances
or
scenarios,
address
problems
or
situations
sufficiently
similar
to
the
circumstances
of
the
release
or
the
response
action
and
are
well­
suited
to
the
site.

In
addition
to
applicable
or
relevant
and
appropriate
requirements,
EPA
and
the
state
may
identify
other
advisories,
criteria,
or
guidance
to
be
considered
for
a
particular
release.
The
"
to
be
considered"
category
consists
of
advisories,
guidance,
or
criteria
developed
by
EPA,
other
federal
agencies,
or
the
state
that
may
be
useful
in
developing
CERCLA
remedies.

ARARs
are
categorized
into
three
main
groups:
chemical,
location,
and
action
specific.
Each
group
is
defined
below:

4.3.1
Chemical
Specific
Requirements
that
set
technology
or
risk­
based
concentrations/
limits
in
various
media.
This
group
can
also
be
used
to
determine
discharge
limits,
treatment
standards,
and
disposal
requirements
for
removal
activities.
Chemical­
specific
ARARs
are
also
used
in
evaluating
the
effectiveness
of
removal
alternatives.

4.3.2
Location
Specific
Requirements
that
provide
a
basis
for
assessing
the
restrictions
during
the
formulation
and
evaluation
of
potential
location­
specific
remedies.
Removal
action
alternatives
may
be
restricted
by
federal
and
state
laws
concerning
proximity
of
sensitive
human
populations
and
environments.

4.3.3
Action
Specific
These
requirements
are
activated
during
the
consideration
of
removal
alternatives.
Action­
specific
requirements
govern
such
categories
as
air
emissions,
treatment
residues,
and
offsite
disposal
policies.

The
ARARs
for
the
proposed
removal
action
for
the
federal
site
are
discussed
in
detail
later
in
this
EE/
CA.

4.4
Determination
of
ARARs
The
following
are
the
ARARs
for
this
removal
action.
The
response
alternatives
described
and
evaluated
in
this
EE/
CA
would
comply
with
all
of
these
ARARs.
11
4.4.1
National
Ambient
Air
Quality
Standards
(
NAAQS)

The
NAAQS
under
the
Clean
Air
Act,
42
U.
S.
C.
§
7401
et.
seq.,
40
CFR
Part
250,
and
10
CSR
10­
6.010,
establish
ambient
air
quality
standards
for
emissions
of
lead
and
particulate
matter.
The
removal
action
will
involve
significant
amounts
of
regrading
and
movement
of
tailings,
which
could
cause
the
airborne
release
of
both
lead
and
particulate
matter.
Because
the
site
is
not
considered
a
"
major
source"
under
the
Clean
Air
Act,
the
NAAQS
are
not
applicable.
However,
they
are
relevant
and
appropriate
during
on­
site
construction
activities.

4.4.2
Fugitive
Particulate
Matter
Regulations
The
Fugitive
Particulate
Matter
Regulations,
10
CSR
10­
6.170,
provide
restrictions
on
releases
of
particulate
matter
to
ambient
air.
These
regulations
will
be
applicable
to
any
fugitive
emissions
of
particulate
matter
which
occur
as
a
result
of
on­
site
construction
activities.

4.4.3
Surface
Mining
Control
and
Reclamation
Act
(
SMCRA)

The
SMCRA
governs
activities
associated
with
coal
exploration
and
mining.
Because
the
standards
and
regulations
promulgated
under
SMCRA
are
intended
for
active
coal
mines,
they
are
not
applicable
to
actions
at
the
site.
However,
certain
surface
mining
standards
found
in
30
CFR
Part
816
are
relevant
and
appropriate
because
they
address
circumstances
that
are
similar
to
those
found
at
the
site.
The
requirements
will
be
complied
with
by
each
of
the
alternatives.

Sediment
Control
Measures
(
§
816.45)

The
SMCRA
requires
that
sediment
control
measures
be
designed,
constructed,
and
maintained
to
minimize
erosion
and
prevent
additional
sediment
from
entering
the
stream
flow
of
adjacent
watercourses.
The
removal
action
will
involve
runoff
diversion
designed
to
control
sedimentation.
Accordingly,
this
portion
of
the
SMCRA
regulations
will
be
complied
with:

Siltation
Structures
(
§
816.46)

The
SMCRA
requires
that
when
siltation
structures
such
as
sedimentation
ponds
are
used,
they
must
contain
spillways
and
be
designed
to
(
1)
provide
adequate
sediment
storage
volume;
(
2)
contain
or
treat
10­
year,
24­
hour
precipitation
events;
and
(
3)
provide
a
non­
clogging
dewatering
device
adequate
to
maintain
detention
time.
Any
erosion
control
basins
constructed
as
part
of
drainage
improvement
efforts
will
be
constructed
in
compliance
with
these
requirements.
12
Grading
Requirements
(
§
816.102)

The
SMCRA
requires
that
disturbed
mining
areas
be
graded
to
minimize
water
pollution
and
erosion,
eliminate
high
walls
and
depressions,
prevent
slides,
and
achieve
original
contour.
The
proposed
removal
actions
involve
significant
amounts
of
regrading,
which
will
be
done
in
compliance
with
these
performance
standards
to
the
extent
practicable.

Revegetation
(
§
816.111)

The
SMCRA
requires
that
on
regraded
areas
and
all
mining­
disturbed
areas,
a
vegetative
cover
must
be
established
which
is
comprised
of
native
species,
capable
of
stabilizing
surface
soil
from
erosion,
permanent,
and
capable
of
self­
regeneration.
A
vegetative
cover
will
be
established
at
the
site
which
satisfies
these
requirements.

4.4.4
Storm
Water
Requirements
(
10
CSR
20­
6.200)

The
state
of
Missouri
has
promulgated
regulations
that
are
applicable
to
storm
water
discharges
associated
with
areas
where
industrial
activity,
including
mining,
has
taken
place
in
the
past
and
significant
materials
remain
and
are
exposed
to
storm
water.
The
substantive
requirements
of
the
storm
water
program
must
be
complied
with
at
the
site
so
long
as
runoff
from
the
site
comes
into
contact
with
the
tailings.
Once
a
vegetative
cover
has
been
established
which
prevents
runoff
from
coming
into
contact
with
the
tailings,
these
requirements
will
have
been
met.

4.4.5
RCRA
Subtitle
D
Solid
Waste
Disposal
Regulations
The
Resource
Conservation
and
Recovery
Act
(
RCRA)
Subtitle
D
program
(
40
CFR
Part
257),
as
well
as
the
state
of
Missouri
Solid
Waste
Management
Law
and
Regulation,
regulates
the
management
of
nonhazardous
solid
waste.
40
CFR
Part
257
establishes
requirements
for
maintenance
of
a
facility
at
which
solid
wastes
are
disposed.
The
tailings
at
the
site
are
solid
wastes
and
thus
these
regulations
are
applicable
for
the
removal
action.
The
regulations
require
that
the
facility
be
maintained
to
prevent
a
wash­
out
of
solid
waste
and
that
the
public
not
be
allowed
uncontrolled
access
to
the
facility.
These
requirements
will
be
complied
with
by
the
removal
action
since
slope
stabilization,
long­
term
maintenance,
and
access
control
are
key
elements
of
all
of
the
proposed
alternatives.

4.4.6
Determination
of
Non­
ARARs
The
EPA
has
analyzed
a
number
of
other
state
and
federal
laws
and
determined
that
they
are
not
ARARs
with
respect
to
this
removal
action.
Following
is
a
brief
discussion
of
the
basis
for
EPA's
determination
that
certain
laws
are
not
ARARs.
13
4.4.7
RCRA
Subtitle
C
Hazardous
Waste
Regulations
The
tailings
at
the
site
are
the
result
of
mineral
extraction
and
benediction
activities,
and
are
therefore
excluded
from
regulation
as
hazardous
wastes
under
Subtitle
C
(
40
CFR
Part
260,
et.
seq.)
pursuant
to
RCRA
§
3001(
b)(
3)(
A)(
iii).
The
Subtitle
C
requirements
are
therefore
not
applicable
requirements.
In
addition,
the
RCRA
hazardous
waste
requirements,
including
closure
requirements,
are
not
relevant
and
appropriate
with
respect
to
this
removal
action.

4.4.8
Ground
Water
Requirements
Ground
water
cleanup
is
beyond
the
scope
of
this
removal
action,
and
thus
Maximum
Contaminant
Levels
under
the
Safe
Drinking
Water
Act
are
not
ARARs
for
this
removal
action.
Similarly,
ground
water
monitoring
is
not
part
of
the
removal
action
either.
State
requirements
for
well
drilling
and
well
construction
are
not
ARARs
for
this
action.

4.4.9
Other
Criteria
to
Be
Considered
Finally,
in
addition
to
applicable
or
relevant
and
appropriate
requirements,
EPA
and
the
state
may
identify
other
advisories,
criteria,
or
guidance
"
to
be
considered"
for
a
particular
release
or
response
action.
Following
are
the
"
to
be
considered"
criteria
and
guidance
for
this
removal
action.

State
of
Missouri
Metallic
Minerals
Act
This
law
only
regulates
closure
of
active
metallic
minerals
mining
operations.
Thus,
it
is
not
an
ARAR
for
closure
of
abandoned
mine
lands
such
as
the
site.
However,
the
closure
standards
and
criteria
under
the
Metallic
Minerals
Act
will
be
reviewed
and
considered
during
design
of
the
removal
action.

EPA/
OSWER
Interim
Guidance
on
Soil
Cleanup
Levels
The
EPA/
Office
of
Solid
Waste
and
Emergency
Response
(
OSWER)
Revised
Interim
Guidance
Concerning
Soil
Lead
Cleanup
Levels
at
Superfund
Sites,
OSWER
Directive
#
9355.4­
12,
provides
guidance
on
the
procedures
for
determining
appropriate
soil
cleanup
levels.
The
MDOH
has
also
established
guidance
on
"
Any
Use
Soil
Levels."
Since
the
issue
of
direct
soil
exposure
is
being
addressed
by
this
action,
the
removal
action
will
be
consistent
with
these
guidance
documents.

5.0
Identification
and
Initial
Screening
of
Removal
Action
Alternatives
This
EE/
CA
identifies
and
evaluates
removal
action
alternatives
to
mitigate
problems
14
associated
with
human
health
and
ecological
risks
from
mining
waste
piles
at
the
Site.
As
stated
previously,
this
removal
action
will
not
address
ground
water
which
may
be
contaminated
as
a
result
of
releases
from
the
site,
nor
contaminated
sediment
previously
deposited
in
the
local
streams.
These
releases
will
be
addressed,
if
necessary,
in
a
future
remedial
action.
Screening
alternatives
are
summarized
below.

5.1
Stabilization
and
Treatment
Several
technologies
exist
to
reduce
the
mobilization
and/
or
toxicity
of
the
metals
contamination
of
concern.
This
alternative
could
include
pozalonic
stabilization
with
cement
to
solidify
the
mining
waste
pile,
or
treatment
with
phosphate
to
reduce
the
metals
toxicity.
This
alternative
is
considered
to
be
significantly
more
costly
than
other
effective
alternatives
and
is
not
retained
for
further
consideration.

5.2
Capping
This
alternative
involves
covering
the
mining
wastes
in­
place
with
a
suitable
clay/
soil
cap.
The
mining
waste
piles
would
be
graded
to
improve
slope
stability
and
promote
proper
drainage.
The
piles
would
then
be
covered
with
12
to
18
inches
of
topsoil
to
establish
vegetation.
Capping
and
establishment
of
vegetative
growth
has
been
demonstrated
to
reduce
infiltration
and
migration
of
metals.
This
alternative
will
be
retained
for
father
consideration
and
development.

5.3
Excavation
and
Off­
site
Disposal
This
alternative
would
involve
excavation
of
the
mining
waste
piles
with
transportation
off
site
to
an
approved
disposal
facility.
A
significant
amount
of
the
wastes
would
likely
require
treatment
prior
to
disposal,
and
the
costs
associated
with
treatment
are
considered
high
given
the
amount
of
wastes
to
be
addressed.
Therefore,
this
alternative
will
not
be
retained
for
further
consideration
under
this
action.

5.4
Excavation
and
On­
site
Disposal
This
alternative
would
involve
excavation
of
the
mining
wastes
with
transport
to
a
central
on­
site
location
for
consolidation
and
disposal.
Actual
disposal
of
the
wastes
would
be
in
a
maintained
repository
structure.
For
purpose
of
this
action,
consolidation
into
the
highway
fill
is
considered
a
repository.
This
alternative
is
considered
highly
protective
and
permanent,
and
is
retained
for
further
consideration.

5.5
Revegetation
This
alternative
would
involve
regrading
the
mining
waste
piles
to
improve
slope
stability
and
promote
proper
drainage.
Then
biosolids,
such
as
composted
waste
water
treatment
plant
sludges
or
animal
wastes,
would
be
mixed
into
the
surface
of
the
waste
piles
to
promote
the
15
establishment
of
vegetation.
Establishment
of
vegetative
growth
has
been
shown
to
reduce
the
runoff
and
migration
of
metals
to
acceptable
levels.
However,
this
technology
has
not
been
proven
to
reduce
the
toxicity
of
metals
or
reduce
the
risk
of
direct
exposure.
Since
the
area
surrounding
the
highway
will
likely
be
developed,
this
alternative
is
not
retained
for
further
consideration.

6.0
Development
of
Removal
Action
Alternatives
Following
are
descriptions
of
the
removal
action
alternatives
carried
forward
for
consideration
for
cleanup
of
the
mining
wastes
in
the
area
of
the
proposed
highway
along
with
a
cost
estimate
for
each
alternative.

6.1
No
Action
Alternative
The
NCP,
40
C.
F.
R.
§
200.430(
e)(
6)
requires
that
the
No
Action
alternative
be
assessed
for
all
sites
when
selecting
a
cleanup
alternative.
The
mining
waste
have
been
documented
to
be
a
source
of
release
of
heavy
metals
which
are
causing
an
unacceptable
risk
to
human
health
and
the
environment.
The
No
Action
alternative
will
not
be
considered
further
because
EPA
has
determined
that
a
threat
to
human
health
and
the
environment
exists
at
the
Site
as
a
result
of
the
presence
of
the
mining
waste
piles.

6.2
Capping
Under
this
alternative,
approximately
140
acres
containing
approximately
588,000
cubic
yards
of
mining
wastes
would
be
re­
graded
to
reduce
the
slopes
and
promote
adequate
drainage
of
the
areas.
The
wastes
would
be
capped
with
one
foot
of
soil
cover
to
prevent
direct
exposure
to
the
wastes
and
establish
vegetative
cover.
Storm
water
runoff
controls
and
dust
suppression
would
be
required
during
grading
operations
to
ensure
metals
are
not
released
to
areas
surrounding
the
piles.
Approximately
1,613
cubic
yards
of
soil
would
be
require
to
cover
each
acre,
for
a
total
of
225,820
cubic
yards.
The
soil
would
be
obtained
from
the
area
surrounding
the
waste
piles,
and
would
contain
less
than
240
ppm
lead
and
25
ppm
cadmium.
Since
the
waste
would
be
left
in
place
and
subject
to
disturbance
during
future
development
that
will
likely
occur
in
the
area,
institutional
controls
would
be
required
to
regulate
development
of
the
area.
Total
cost
of
the
alternative
is
estimated
at
$
2,831,737
with
an
annual
operation
and
maintenance
cost
of
$
264,500
for
30
years.
Total
cost
estimated
for
this
alternative
is
$
2,726,880.
A
detailed
cost
estimate
is
provide
in
Table
1.

6.3
Excavation
and
On­
site
Disposal
Under
this
alternative,
the
same
140
acres
and
588,000
cubic
yards
of
wastes
addressed
under
the
capping
alternative
would
be
excavated
and
hauled
into
the
highway
corridor
and
used
as
fill
for
the
construction
of
the
roadway.
The
wastes
will
be
handled
and
placed
by
MDOT
in
areas
requiring
fill
and
compacted
to
construction
specifications.
Additionally,
approximately
one
16
foot
of
soil
underlying
the
mining
wastes
will
also
be
removed
along
with
the
wastes.
This
soil
will
be
used
to
aid
the
fill
compaction,
as
well
as,
remove
lead
contamination
exceeding
500
ppm
from
the
underlying
soil.
All
mining
wastes
exceeding
1,500
ppm
lead
exposed
in
the
side
slopes
of
the
highway
embankment
would
be
covered
with
one
foot
of
clean
soil.
MDOT
will
be
required
to
comply
all
with
storm
water
runoff
requirements
and
to
suppress
all
fugitive
dust.
The
total
cost
estimate
for
this
alternative
is
$
3,548,313.
Since
the
mining
wastes
will
be
removed
and
disposed
of
under
the
highway,
no
institutional
controls
or
annual
operation
and
maintenance
would
be
required.
A
detailed
cost
estimate
for
this
alternative
is
presented
in
Table
2.

7.0
Analysis
of
Proposed
Removal
Action
Alternatives
This
section
evaluates
and
compares
the
two
proposed
removal
action
alternatives
for
cleanup
of
the
mining
waste
piles
near
the
proposed
highway.
Both
proposed
alternatives
are
evaluated
for
their
effectiveness,
implementability,
and
the
costs
associated
with
implementation.
Each
alternative
is
compared
to
a
set
of
criteria
to
assess
the
appropriateness
of
the
alternative
and
determine
which
alternative
best
meets
the
criteria.

7.1
Effectiveness
The
effectiveness
of
an
alternative
refers
to
its
ability
to
meet
the
objectives
of
the
removal
action.
Specifically,
the
effectiveness
of
an
alternative
refers
to
it
its
ability
to
protect
human
health
and
the
environment
in
both
the
long
and
short
term.

7.1.1
Long­
term
Effectiveness
Both
the
alternatives
are
considered
to
have
long­
term
effectiveness.
The
excavation
and
disposal
alternative
is
more
effective
in
reducing
the
risk
of
long
term
exposure
since
the
capping
alternative
relies
on
institutional
control
to
ensure
the
piles
will
not
be
disturbed
in
the
future.
Under
the
excavation
and
disposal
alternative,
the
wastes
will
be
removed
and
placed
for
permanent
disposal
under
the
highway.

7.1.2
Short­
term
Effectiveness
Implementation
of
either
alternative
may
result
in
short­
term
risks
to
workers
and
local
residents
from
exposure
to
airborne
lead­
laden
particulates.
This
may
occur
during
excavation
or
grading
of
the
mining
wastes.
In
addition
to
posing
short­
term
health
risks,
fugitive
dust
from
removal
activities
could
also
have
adverse
effects
on
the
environment.
Engineering
controls,
such
as
application
of
water
for
dust
suppression
during
field
activities,
would
be
implemented
as
needed
to
prevent
a
threat
to
the
community
and
uncontaminated
areas
(
e.
g.,
nearby
vegetated
areas).
Storm
water
runoff
controls
will
be
utilized
to
protect
surrounding
soil
from
contaminated
sediment
migration
off
the
piles
and
protect
local
waterways
during
construction.
17
7.1.3
Compliance
with
ARARs
Pursuant
to
Section
300.415(
i)
of
the
NCP,
on­
site
removal
actions
conducted
under
CERCLA
are
required
to
comply
with
those
requirements
of
other
federal
and
state
environmental
and
siting
laws
that
are
ARARs
to
the
circumstances
found
at
the
Site,
to
the
extent
practicable
considering
the
exigencies
of
the
situation.
Applicable
requirements
are
those
public
and
environmental
health
and
welfare
requirements,
criteria,
and/
or
standards
that
address
specific
circumstances
or
scenarios
at
a
CERCLA
site.
Relevant
and
appropriate
requirements
are
those
public
and
environmental
health
and
welfare
requirements,
criteria,
and/
or
standards
promulgated
under
federal
or
state
law
that,
while
not
applicable
to
a
specific
site's
circumstances
or
scenarios,
address
problems
or
situations
sufficiently
similar
to
the
circumstances
of
the
release
or
response
action
and
are
well­
suited
to
the
site.
Both
alternatives
will
equally
achieve
compliance
with
all
identified
ARARs.

7.2
Implementability
The
implementability
criterion
addresses
the
technical
and
administrative
feasibility
of
implementing
the
alternatives
and
the
availability
of
various
services
and
materials
required
during
its
implementation.

7.2.1
Technical
Feasibility
Both
alternatives
are
considered
fully
technically
feasible.
The
proposed
alternatives
have
been
successfully
implemented
at
a
number
of
sites
that
exhibited
similar
conditions
as
the
Site.
No
construction
or
operational
problems
have
been
reported
or
noted.
Both
of
the
alternatives
face
difficulties
posed
by
climate
conditions.
During
winter,
achieving
soil
compaction
would
be
difficult
due
to
freezing
ambient
temperatures.
Successful
planting
or
seeding
would
also
likely
be
limited
to
periods
of
relatively
moderate
temperature
in
spring
and
fall.
Sudden
downpours
of
precipitation
may
also
affect
the
implementation
of
the
alternatives.
However,
storm
water
runoff
can
readily
be
accomplished.
It
is
anticipated
that
either
remedy
could
be
constructed
within
one
year.

7.2.2
Administrative
Feasibility
No
permits
or
easements
would
be
required
for
either
alternative.
MDOT
is
required
to
obtain
right­
of­
way
for
the
highway
construction
which
is
considered
highly
feasible.
However,
the
excavation
and
disposal
alternative
is
considered
to
be
more
administratively
feasible
since
the
capping
alternative
relies
on
institutional
controls.
This
area
of
the
Site
lies
in
an
unincorporated
area
of
Jasper
County.
Further,
Jasper
County
currently
does
not
have
county
planning
and
zoning
making
the
establishment
on
institutional
controls
difficult
at
best.
Without
the
controls
in
place
to
regulate
future
use
of
the
area,
the
capping
alternative
may
not
be
protective.
18
7.2.3
Availability
of
Services
and
Materials
Personnel
and
materials
to
construct
each
alternative
are
readily
available.
Standard
excavating
equipment
and
operators
would
be
used
to
construct
either
alternative.

7.2.4
State
Acceptance
The
MDNR
has
participated
in
the
review
of
the
draft
of
this
EE/
CA
and
is
in
agreement
with
the
concepts
proposed.
Additionally,
MDNR
has
attended
past
meeting
regarding
construction
of
the
highway,
and
has
previously
voiced
support
for
the
highway
project,
as
well
as,
utilizing
as
much
mining
wastes
as
possible
for
highway
construction
fill.
MDNR
prefers
the
excavation
and
disposal
alternative
over
the
capping
alternative.

7.2.5
Community
Acceptance
The
EPA,
MDNR,
and
MDOT
have
met
with
the
public
on
several
occasions
to
discuss
the
construction
of
the
proposed
highway
and
the
use
of
mining
wastes
for
fill
in
its
construction.
These
issues
have
been
discussed
at
several
meeting
held
by
two
citizen's
Task
Force
Committees
(
the
Jasper
and
Newton
County
Environmental
Task
Force,
and
the
Rangeline
Bi­
pass
Task
Force).
To
date
these
citizens
groups
have
voiced
strong
support
for
using
mining
wastes
as
fill
for
construction
of
the
highway
instead
of
using
clean
soil
fill.
The
Task
Forces
believe
that
use
of
the
mining
wastes
for
fill
would
significantly
speed
up
environmental
restoration
of
the
area,
and
create
a
more
permanent
remedy.

A
complete
evaluation
of
community
acceptance
of
the
proposed
alternative
will
be
evaluated
at
the
close
of
the
public
comment
period
on
this
EE/
CA.
A
responsiveness
summary
will
be
attached
to
the
Action
Memorandum
containing
EPA's
selected
removal
action.

7.3
Cost
The
estimated
costs
of
construction
of
the
principal
technology
associated
with
each
alternative
was
discussed
previously.
Reviewers
should
be
aware
that
costs
for
work
to
be
performed
under
a
specific
alternative
are
estimates
and
may
be
higher
than
standard
industry
cost
because
of
the
premium
labor
and
equipment
rates
associated
with
hazardous
waste
site
work
that
may
require
specialized
equipment
and
worker
health
and
safety
training.
Since
the
estimated
costs
for
both
alternatives
are
over
$
2,000,000,
a
consistency
waiver
will
be
required
to
conduct
this
action
as
a
non­
time
critical
removal.

8.0
Recommended
Removal
Action
Alternative
The
EPA's
recommended
alternative
is
excavation
of
the
mining
wastes
with
disposal
as
construction
fill
under
the
highway
during
construction.
This
alternative
is
slightly
more
costly
19
than
capping
but
better
meets
the
remediation
goals
than
the
capping
option.
The
disposal
of
the
wastes
under
the
highway
will
create
a
more
permanent
remedy
without
reliance
on
institutional
controls.
Further,
the
citizens
task
forces
have
voiced
a
preference
for
permanent
disposal
of
the
wastes
instead
of
capping
in
place
where
they
must
be
dealt
with
during
future
development
of
the
area.
Therefore,
the
following
alternative
is
proposed
for
the
removal
of
mining
wastes
in
the
vicinity
of
the
highway:

1.
Excavation
of
the
mining
waste
piles
with
transport
into
the
highway
corridor.
2.
Removal
of
the
top
12
inches
of
soil
beneath
the
excavated
waste
piles.
3.
Incorporation
of
the
mining
wastes
and
underlying
soil
into
the
highway
construction
fill.
4.
Implementation
of
storm
water
runoff
controls
during
excavation
and
disposal
activities.
5.
Dust
suppression
during
excavation
and
disposal
activities.
6.
Placement
of
12
inches
of
clean
soil
cover
on
all
mining
waste
exceeding
1,500
ppm
lead
in
the
highway
side
slopes.
7.
Revegetation
of
disturbed
areas.

9.0
Removal
Schedule
If
the
excavation
and
capping
alternative
proposed
in
this
EE/
CA
is
selected
as
the
removal
action,
based
on
public
comment,
construction
of
the
action
is
expected
to
begin
in
the
Summer
2001.
MDOT
anticipates
letting
the
contracts
for
bid
in
early
Spring,
awarding
the
contracts
for
construction
in
early
Summer,
and
initiating
the
action
by
mid
Summer
2001.
EPA
and
MDOT
anticipate
the
construction
will
be
completed
in
less
than
12
months.
20
Table
1
Cost
Estimate
for
Capping
Alternative
Item
Description
Unit
Cost
Quantity
Total
Cost
Capital
Costs
Grading
2,500
/
acre
140
acres
350,000
Soil
Cover
9.00
/
yard
225,820
yard
2,032,380
Storm
water
Control
and
Dust
Suppression
500
/
acre
140
acres
70,000
Institutional
Control
10,000
10,000
Subtotal
Direct
Capital
Costs
2,462,380
Indirect
Costs
Construction
Management
­
5%
of
direct
capital
costs
123,119
Engineering
Design
­
5%
of
direct
capital
costs
123,119
Contingency
­
5%
123,119
Subtotal
Indirect
Costs
369,357
Total
Estimated
Capital
Costs
2,831,737
Operation
&
Maintenance
Estimate
Annual
Monitoring
of
Caps
1,000
30
years
30,000
Annual
Repair
of
Caps
5,000
30
years
150,000
Administration
of
institutional
controls
5,000
10
yrs.
50,000
Subtotal
O&
M
Costs
230,000
Contingency
­
15%
(
c)
34,500
Total
Estimated
O&
M
Costs
264,500
Total
Cost
for
Capping
Alternative
2,726,880
Table
2
Cost
Estimate
for
Excavation
and
Disposal
Alternative
Item
Description
Total
Cost
Capital
Costs
Excavation
of
Mining
Wastes
and
Underlying
Soil
3,000,000
Transportation
and
Disposal
of
Wastes
and
Soil
475,000
Storm
water
Control
and
Dust
Suppression
42,863
Seeding
30,350
Total
Cost
for
Capping
Alternative
3,548,213
21
References
1.
Dames
&
Moore,
"
Final
Remedial
Investigation
Report,
Neck/
Alba,
Oronogo­
Duenweg,
Joplin,
Thoms,
Carl
Junction,
and
Waco
Designated
Areas,
Jasper
County
Site,
Jasper
County
Missouri,
"
October
31,
1995.

2.
Missouri
Department
of
Health,
"
Human
Health
Risk
Assessment
for
the
Oronogo­
Duenweg
Mining
Belt
Site,
Jasper
County,
Missouri".

3.
Black
&
Veatch
Special
Project
Corp.,
"
Baseline
Ecological
Risk
Assessment
(
ERA),
Jasper
County,
Missouri"
December
1997.

4.
U.
S.
EPA,
"
Record
of
Decision,
Residential
and
Mine
Waste
Yard
Soils,
Operable
Units
02
and
03,
Oronogo­
Duenweg
Mining
Belt
Site,
Jasper
County,
Missouri",
June
1996.

5.
U.
S.
Environmental
Protection
Agency,
"
Record
of
Decision,
Ground
Water
Operable
Unit
4,
Jasper
County
Superfund
Site,
Jasper
County,
Missouri",
July
1998.

6.
U.
S.
Environmental
Protection
Agency,
OSWER
Publication
,
"
Revised
Interim
Soil
Lead
Guidance
for
CERCLA
Sites
and
RCRA
Corrective
Action
Facilities",
July
14,
1994.

7.
Code
of
Federal
Regulations,
Protection
of
Environment
40,
Part
1
to
51,
July
1,
1987.

8.
U.
S.
Environmental
Protection
Agency
OWSER
Publication
9203.1­
03,
"
Guidance
on
Implementation
of
the
Superfund
Accelerated
Cleanup
Model
(
SACM)
under
CERCLA
and
the
NCP"
(
July
7,
1992),
PB93­
963252.

9.
U.
S.
Environmental
Protection
Agency,
OSWER
Publication
9360.0­
12FS,
"
Exemptions
from
the
Statutory
Limits
on
Removal
Actions"
(
November
1990),
PB91­
921304/
CCE.

10.
Comprehensive
Environmental
Response,
Compensation,
and
Liability
Act
of
1980,
as
amended
by
the
Superfund
Amendments
and
Reauthorization
Act
of
1986,
42
U.
S.
C.
§
§
9601­
9675
(
1992).
Engineering
Evaluation
/
Cost
Estimate
for
a
portion
of
the
Oronogo­
Duenweg
Mining
Belt
Site
Jasper
County,
Missouri
Prepared
by
the
U.
S.
Environmental
Protection
Agency
Region
VII
901
N.
5th
Street
Kansas
City,
Kansas
66101
August,
2000
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