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Comments and Conclusions

The Remedial Investigation is biased both  toward treating the site as a rural area and overemphasizing the cost of removing slag from the site. Accordingly, the selected remedy places a large grass covered slag mound in the middle of an expanding urban center. The selected remedy, while not unsafe, is inappropriate for this site. 

The following specific conclusions can be drawn:

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EPA's selection for residential standards of cleanup is reasonable and appropriate, regardless of the final commercial usage of the site.  

 

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Groundwater is presently affected, but discharges have been more of a problem in the past. There is cause for concern over discharges during cleanup. Flow in the area is probably high enough to support natural attenuation if all sources are removed.  

 

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Meyer's Cove is affected by the site. There is insufficient information to determine any adverse effects on the local ecology.  

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Radiation threats from slag may be overstated, possibly to make removal appear untenable. Radiation is a threat in the former ponds area.  

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The main health threat is from arsenic, and the threat is site-wide.  

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The borders of the areas requiring in situ stabilization under option 5(b) can not be confirmed using the data provided, likely this will need to be expanded prior to the Remedial Design being approved.  

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It is doubtful if pond 42 can be remediated by excavation without discharging to the Anclote. In Situ stabilization may make more sense for this site. This will be of principle concern in the Remedial Design.  

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The selected Alternative, 5(b), is generally effective regarding long-term safety. However, the plan is inappropriate to this urban area. A similar site in an urban area could not be located. Also, a similar site on similar geology and with similar climate could not be located. The long-term stability regarding storm damage and sinkholes cannot be predicted using the information provided.  

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Past effect on flora and fauna is greatly underestimated. No studies on bioaccumulation were available. Since this can effect the pace of the cleanup it should be studied.  

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Windborne dust is not currently a threat, but is a major concern for the Remedial Design safety plan.  

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A pathway currently does not occur between the slag area and Gulfside Elementary school. However, more testing is necessary to define the northern boundary of the slag storage area since toxic runoff can occur at this site.  

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The area dimensions for the final slag mound are not defined. The base dimensions should be expanded to reduce the overall height and improve long-term stability.  

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Studies suggest a tide induced reversal in groundwater flow up to 300 feet up slope from the rivers edge. The western edge of the Remedial Design treatment should be located to well beyond this effect.  

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Removal should be revisited using slag removal by rail car to reduce the volume of the material left on site. There is precedence for this action at other sites.  

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It does not appear that any treatment of the buried phosphorus will occur, other that covering with a slag layer.

 

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