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