Final Site Information Package for National Remedy Review Board ...

TABLE B9-2
Comparative Analysis of Remedy Protection Alternatives
Site Information Package for National Remedy Review Board
Feasibility Criterion Description of Criterion
Threshold Criteria
Overall Protection of Human Health
and the Environment
Compliance with Applicable or
Relevant and Appropriate
Requirements (ARARs)
Primary Balancing Criteria
Long-Term Effectiveness and
Permanence
Reduction of Toxicity, Mobility or
Volume through Treatment
Ability of alternative to achieve and maintain protection of
human health and the environment
Ability of alternative to meet location- and action-specific
ARARs
Ability of technology to be protective of human health and the
environment without upset over the long-term
Ability of alternative to reduce mobility, toxicity, or volume of
contaminants
Short-Term Effectiveness Ability of alternative to protect human health and the
environment during the short-term time frame.
Implementability Ability of alternative to meet technical, administrative, and
logistical challenges associated with implementation
ALTERNATIVE RP-1
No Further Action
(Post-Event Response)
Alternative RP-1 would be protective of human health and the environment because the existing
Selected Human Health Remedies are currently protective. The risk of exposure to
contaminated material for Alternative RP-1 could temporarily increase following a storm event
from the time the Selected Remedies were damaged until the post-event response was
completed.
Alternative RP-1 could potentially be implemented in compliance with location- and actionspecific
ARARs. Chemical-specific ARARs were not included as part of this evaluation because
the remedy protection alternatives only enhance the existing Selected Remedies.
Alternative RP-1 would provide relatively less long-term effectiveness and permanence. Based
on hydrologic and hydraulic models, there are areas of the existing Selected Remedies which
are at risk to recontamination due to flooding and uncontrolled surface water flow. Alternative
RP-1 would not address this issue of permanence of the existing Selected Remedies, but
instead would rely on post-event response to repair the Selected Remedies when damaged.
Alternative RP-1 would not reduce the toxicity, mobility, or volume of metals contamination
through treatment.
In general, Alternative RP-1 would be effective in the short term because the existing Selected
Remedies are currently protective of human health and the environment. Much of the existing
infrastructure within communities is under-capacity. Therefore, Alternative RP-1 would allow a
relatively higher risk of contaminant mobility within residential areas during and immediately
following storm events. Additionally, the risk of exposure could temporarily increase following a
storm event until the post-event response is completed.
Alternative RP-1 would not be expected to have any technical feasibility issues. There would be
administrative issues regarding the availability of federal funds to repair the Selected Remedies
following a storm event. Additionally, in some cases, the repair of the protective barriers could
be time-sensitive in order to maintain protectiveness and limit a resident's risk of exposure.
ALTERNATIVE RP-2
Modifications to Selected Remedies to Enhance Protectiveness
(Remedy Protection Projects)
Alternative RP-2 would be protective of human health and the environment because the
existing Selected Human Health Remedies are currently protective. Additionally, Alternative RP-
2 would be more protective of human health and the environment than Alternative RP-1
because it would enhance the long-term effectiveness and permanence of the Selected
Remedies by reducing the potential for floods or surface water flow to damage the existing
Selected Remedies.
Alternative RP-2 could potentially be implemented in compliance with location- and actionspecific
ARARs. Chemical-specific ARARs were not included as part of this evaluation
because the remedy protection alternatives only enhance the existing Selected Remedies.
Alternative RP-2 would enhance the long-term effectiveness and permanence of the Selected
Remedies. This alternative would be expected to provide protectiveness to the communities
from storm events smaller than the 50-year event.
Alternative RP-2 would not reduce the toxicity, mobility, or volume of metals contamination
through treatment.
Alternative RP-2 would be effective in the short term because the existing Selected Remedies
are currently protective of human health and the environment. Additionally, Alternative RP-2
reduces the risk of exposure to contaminated material by protecting the Selected Remedies up
to the 50-year storm event. This alternative would effectively convey stormwater and
floodwater for storm events smaller than the 50-year event and reduce the risk of exposure and
mobility of contaminants within residential areas.
Alternative RP-2 would not be expected to have any technical implementability issues. The list
of technologies and process options applied for Alternative RP-2 are standard engineering
practices. There could be administrative issues that arise in regard to determining which state
or local entity would be responsible for O&M of the Alternative RP-2 projects. Additionally,
there could be logistical challenges to implementing Alternative RP-2 on private properties,
where access and easement agreements would be needed prior to construction.
Cost Total Capital Cost for Upper Basin Communities a NA $13,700,000
O&M Cost (30-Year NPV) for Upper Basin Communities a NA $4,980,000
Total Cost (30-Year NPV) for Upper Basin Communities a $33,800,000 $18,800,000
Total Capital Cost for Side Gulches b NA $10,900,000
O&M Cost (30-Year NPV) for Side Gulches b NA $4,180,000
Total Cost (30-Year NPV) for Side Gulches b $16,300,000 $15,100,000
Total Cost (30-Year NPV) $50,100,000 $33,900,000
Notes:
NPV = net present value; ARARs = applicable or relevant and appropriate requirements; NA = nor applicable
a
The costs for Alternatives RP-1 and RP-2 in the eight Upper Basin communities include Pinehurst, Smelterville, Kellogg, Wardner, Osburn, Silverton, Wallace and Mullan
b
Side gulch costs for Alternatives RP-1 and RP-2 are approximate based on assumptions discussed in the FFS Report (see Appendix D, which is provided in File B14-1 on the Supplemental CD provided with this Site Information Package).
NOTE: The above costs are presented rounded to three significant figures
NOTE: The above cost opinion is a Feasibility Study-level estimate with a nominal accuracy of –30 percent to +50 percent (–30/+50%).
NOTE: The above cost opinion is in 2009 dollars and does not include future escalation. The order-of-magnitude cost opinion shown has been prepared for guidance in project evaluation from the information available at the time of preparation. The final costs of the project will depend on actual labor
and material costs, actual site conditions, productivity, competitive market conditions, the final project scope, the final project schedule, and other variable factors. As a result, the final project costs will vary from those presented above. Because of these factors, funding needs must be carefully
reviewed prior to making specific financial decisions or establishing final budgets.
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