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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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