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TABLE B9-1a<br />

Comparative Analysis of the No Action Alternative and Alternatives 3+(a) through 3+(e)<br />

<strong>Site</strong> <strong>In<strong>for</strong>mation</strong> <strong>Package</strong> <strong>for</strong> <strong>National</strong> <strong>Remedy</strong> <strong>Review</strong> <strong>Board</strong><br />

Criteria No Action<br />

Compliance with ARARs<br />

Chemical-specific ARARs Would not comply with chemicalspecific<br />

ARARs (AWQC) <strong>for</strong><br />

surface water until natural decay<br />

processes reduced loading to<br />

below AWQC levels (see ARARs<br />

summary above).<br />

Location- and action-specific<br />

ARARs<br />

Long-Term Effectiveness and Permanence<br />

Magnitude of residual risk Magnitude of existing ecological<br />

risk may decrease slightly or<br />

remain essentially unchanged <strong>for</strong><br />

several decades or centuries.<br />

Adequacy and reliability of<br />

controls<br />

OU 2 Alternative (a)<br />

Minimal Stream Lining<br />

OU 3 Component<br />

Alternative 3+: More Extensive Removal, Disposal, and Treatment<br />

OU 2 Component<br />

OU 2 Alternative (b)<br />

OU 2 Alternative (c)<br />

OU 2 Alternative (d)<br />

Stream Lining/French Drain<br />

Extensive Stream Lining<br />

French Drains<br />

Combination<br />

OU 2 Alternative (e)<br />

Extensive Stream Lining/French<br />

Drain Combination<br />

Combined Upper Basin Alternative<br />

Alternative 3+(a) Alternative 3+(b) Alternative 3+(c) Alternative 3+(d) Alternative 3+(e)<br />

Would significantly reduce metals<br />

concentrations in surface water, but<br />

would not meet surface water ARARs<br />

following remediation (see ARARs<br />

summary above).<br />

Not applicable Would comply with all action-specific and<br />

location-specific ARARs, including<br />

substantive requirements of CWA<br />

Section 404, Rivers and Harbors Act<br />

Section 10, and Endangered Species<br />

Act.<br />

Potential <strong>for</strong> ecosystem recovery is<br />

limited by contaminants.<br />

Potentially significant residual risks<br />

to humans.<br />

No controls would be implemented<br />

to control residual risks.<br />

Moderate reduction in expected postremediation<br />

mass loadings (estimated<br />

42% reduction). Some smaller loading<br />

sources would receive no action or<br />

limited containment. Low potential <strong>for</strong><br />

mobilization (through erosion) of<br />

contaminated alluvium left in place.<br />

Natural source depletion processes<br />

would further reduce residual risks.<br />

Low residual risk to humans.<br />

Decontamination of structures and<br />

access restrictions would be effective.<br />

<strong>Remedy</strong> could effectively be maintained<br />

through monitoring, maintenance, and<br />

institutional controls. Moderate<br />

maintenance requirements <strong>for</strong> caps,<br />

stream and riparian improvements,<br />

sediment traps, French drains, and<br />

stream liners. High maintenance<br />

requirements <strong>for</strong> passive and active<br />

treatment.<br />

Would significantly reduce metals<br />

concentrations in surface water, but<br />

would not meet surface water ARARs<br />

following remediation (see ARARs<br />

summary above).<br />

Would significantly reduce metals<br />

concentrations in surface water, but<br />

would not meet surface water ARARs<br />

following remediation (see ARARs<br />

summary above).<br />

Would significantly reduce metals<br />

concentrations in surface water, but<br />

would not meet surface water ARARs<br />

following remediation (see ARARs<br />

summary above).<br />

Would significantly reduce metals<br />

concentrations in surface water, but<br />

would not meet surface water ARARs<br />

following remediation (see ARARs<br />

summary above).<br />

See Alternative 3+(a). See Alternative 3+(a). See Alternative 3+(a). See Alternative 3+(a).<br />

See Alternative 3+(a). Additional Large reduction in expected post-<br />

benefits would be achieved through remediation mass loadings (estimated<br />

this alternative by significantly 60% reduction). Some smaller loading<br />

improving water quality in several OU 2 sources would receive no action or<br />

tributaries (Government, Magnet, and limited containment. Low potential <strong>for</strong><br />

Deadwood Creeks).<br />

mobilization (through erosion) of<br />

contaminated alluvium left in place.<br />

Natural source depletion processes<br />

would further reduce residual risks.<br />

Low residual risk to humans.<br />

Decontamination of structures and<br />

access restrictions would be effective.<br />

Low residual risk to humans.<br />

Decontamination of structures and<br />

access restrictions would be effective.<br />

See Alternative 3+(a). See Alternative 3+(a). More linear feet of<br />

French drain are included in this<br />

alternative, although less stream lining.<br />

Page 2 of 6<br />

Large reduction in expected postremediation<br />

mass loadings (estimated<br />

62% reduction). Load reduction<br />

estimates provided are <strong>for</strong> the SFCDR.<br />

Additional benefits would be achieved<br />

through this alternative by significantly<br />

improving water quality in Government<br />

Creek. Some smaller loading sources<br />

would receive no action or limited<br />

containment. Low potential <strong>for</strong><br />

mobilization (through erosion) of<br />

contaminated alluvium left in place.<br />

Natural source depletion processes<br />

would further reduce residual risks.<br />

Low residual risk to humans.<br />

Decontamination of structures and<br />

access restrictions would be effective.<br />

See Alternative 3+(a). More linear feet<br />

of French drain and slightly less stream<br />

lining would be included in this<br />

alternative.<br />

Large reduction in expected postremediation<br />

mass loadings (estimated<br />

66% reduction). Additional benefits<br />

would be achieved through this<br />

alternative by significantly improving<br />

water quality in many OU 2 tributaries.<br />

Some smaller loading sources would<br />

receive no action or limited containment.<br />

Low potential <strong>for</strong> mobilization (through<br />

erosion) of contaminated alluvium left in<br />

place. Natural source depletion<br />

processes would further reduce residual<br />

risks.<br />

Low residual risk to humans.<br />

Decontamination of structures and<br />

access restrictions would be effective.<br />

See Alternative 3+(a). Significantly<br />

more stream lining and French drains<br />

would be included in the alternative, as<br />

well as slurry walls and groundwater<br />

extraction wells.

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