PB94-964419
EPA/ROD/R08-94/086
January 1995
EPA Superfund
Record of Decision:
Tooele Army Depot-North Area,
Operable Units 5,6,7 and 10, UT
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Tooele Army Depot-North Area
.
Record of Decision
for
Operable Units 5, 6, 7, and 10
September 1994
..
...
. U.S. Army Environmental Center
Aberdeen Proving Ground, Maryland 21010-5401
Under Contract No. DAAAI5-90-D-0007
In accordance with Army Regulation 200-2, this document is intended by the Army to comply
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Contents
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Section 1: Background Infoimation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1-1
1.0 In~oduction .............................................. 1-2
1.1 Purpose................................................ 1-2
1.2 Record of Decision Organization. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1-Q .
1.3 General Background.. . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . .. 1-6
1.3.1 Physical Setting. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1-6
1.3.1.1 Surface Features. . . . . . . . . . . . . . . . . . . . . . . . . . .. 1-6
1. 3.1. 2 Meteorology............................... 1-6
1.3.1.3 Geology.................................. 1-7
1.3.1.4 Soils.................................... 1-7
1.3.1.5 Hydrogeology.............................. 1-7
1. 3.1. 6 Surface Water. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1-7
1.3. 1'.7 Land Use. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1-8
1.3.1.8 Vegetation................................. 1-8
1.3.1.9 Wildlife Species. . . . . . . . . : . . . . . . . . . . . . . . . . . . .. 1-8
1. 3 .1.10 Threatened and Endangered Species. . . . . . . . . . . . . . .. 1-8
1.3.2 History and Enforcement Activities. . . . . . . . . . . . . . . . . . . . . . .. 1-9
1.3.3 Highlights of Community Participation. . . . . . . . . . . . . . . . . . . . . . 1-10
1.3.4 Responsive Summary. . . . . . ... . . . . . . . . . . . . . . . . . . . . . . . . . 1-11 .
Section 2: Record of Decision for Operable Unit 5 ........................ 2-1
2.0 Decision Summary for Operable Unit 5 . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2-7
2:1 Scope and Role of Operable Unit 5 ............................ 2-7
2.1.1 Description. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2-7
2.1.2 Characteristics. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2-7
2.1.3 Summary of Risks. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2-9
2.1.3.1 Human Health. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2-9
2.1.3.1.1 Noncarcinogenic Risk. . . . . . . . . . . . . . . . . . . 2-10
2.1.3.1.2 Carcinogenic Risks. . . . . . . . . . . . . . . . . . . . . 2-10
2.1.3.2 Ecological Risk. . . . . . . . . . . . . . . . . . . . . . . '.' . . . . . 2-10
2.1.4 Description of the No-Action Alternative. . . . . . . . . . . . . . . . . . . . 2-11
Section 3: Record of Decision for Operable Unit 6 ........................ 3-1.
3.0 Decision Summary for Operable Unit 6 . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 3-7
3.1 Scope and Role of Operable Unit 6 ............................ 3-7
3.1.1 Description. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 3-7
3.1.2 Characteristics. . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . . " 3- 7
3.1.3 Summary of Risks. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 3-9
3.1.4 Description of the No-Action Alternative. . . . . . . . . . . . . . . . . . .. 3-9
ROD/August S. 1994
ii
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. Contents (continued)
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: 1>
Section 4: Record of Decision for Operable Unit 7 ........................ 4-1
4.0 Decision Summary for Operable Unit 7 . . . . . . . . . . . . . . . . . . . . . . . . . . . ., 4-8
4.1 Scope and Role of Operable Unit 7 ............................ 4-8 '
4.1.1 Description. . . . . . . . . . . . ~ . . . . . . . . . . . . . . . . . . . . . . . . .. 4-8
4.1.2 Characteristics. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 4-8
4.1.3 Summary of Risks . . . . . . . . . . . . . . . . . .. . '. . . . . . . . . . . . . . .4-10
4.1.3.1 Human Health. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-10
4.1.3.1.1 Noncarcinogenic Risk. . . . . . . . . . . . . . . . . . . 4-11
4.1.3.1.2 Carcinogenic Risk. . . . . . . . . . . . . . . . . . ',' .4-11
4.1.3.2 Ecological Risk. . . . . . . . . . . .. . . . . . . . . . . . . . . . . . 4-11
,4.1.4 Description of Alternatives. . . . . . . . . . . . . . . . . ~ . . . . . . . . . . . 4-12
4.1.5 Summary of the Comparative Analysis of Alternatives. . . . . . . . . .' '. . 4-12 '
4.1.6 Selected Remedy. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-16
4.1.7 Statutory Determinations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-17
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Section 5: ,Record of Decision for Operable Unit 10 ....................... 5-1
5.0 Decision Summary for Operable Unit 10 ................... . . . . . . . .: 5-8
5.1 Scope and Role of Operable Unit 10 ........................... 5-8
5.1.1. Description. . . . . . . . " . . . . . . . . . . . . . .. . . . . . . . . . . . . . . .. 5-8
5.1.2 Characteristics. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .'. 5-8
5.1.3 Summary of Risks. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-10
5.1.3.1 Human Health. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-10
. .5.1.3.1.1 Noncarcinogenic Risk. . . . . . . . . . . . . . . . . . . 5-11
5.1.3.1.2 Carcinogenic Risk .....................5-11
5.1.3.2 Ecological Risk. . . . . . . . . . . . . . . . . . . . . . . . . . : . . . 5-11
5.1.4 Description of Alternatives. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-12
5.1.5 Summary of the Comparative Analysis of Alternatives. . . . . . . . . . . . 5-13
5.1.6 Selected Remedy. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .'5-13
5.1; 7 Statutory Determinations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-18
--
, Appendix
Appendix
A
Transcript of Tooele Army Depot Public Meeting. . . . . . . . . . . . A-I
..
RODiSeptcmba: 1994
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Figure
Table
ROC/Septemb
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4
ARAR
BRAC
CAP
CERCLA
CERFA
DEQ
DOT
EP
EPA
FFA
ill
HQ
mg/day
NCP
NPL
NRC
OSHA
au
PCBs
PCDDs
PCDFs
ppm
RCRA
ROD
SARA
SmfUs
TCLP
TEAD
TEAD-N
TEAD-S
TSCA
p.g/g
..
..
Acronyms and Abbreviations
applicable or relevant and appropriate requirement
Base Realignment and Closure
Corrective Action Permit. .
Comprehensiv~ Environmental Response, -Compensation, and Liability Act
Community Environmental Response Facilitation Act .
State of Utah Department of Environmental Quality
Department of Transportation
extraction p~ocedure
U.S. Environmental Protection Agency
Federal Facility Agreement
hazard index
hazard quotient
milligrams per day .
National Oil and Hazardous Substances Pollution Contingency Plan
National Priorities List . .
Nuclear Regulatory Commission
Occupational Safety and Health Adminis~ation
operable unit
. polychlorinated biphenyls
polychlorinated dibenzodioxins
polychlorinated dibenzofurans
parts per million
Resource Conservation and Recovery Act
Record of Decision
Superfund Amendments and Reauthorization Act
solid waste management units
toxicity characteristic leaching procedure
Tooele Army Depot .
. Tooele Army Depot-North Area
Tooele Army Depot-South Area
Toxic Substances Control Act
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,
.
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Section 1
Background Information
ROD/August S, 1994
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1.0 INTRODUCTION
1.1 PURPOSE
Tooele Army Depot-North Area (TEAD-N) is a National Priorities List (NPL) site under the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of
1986, as amended by the Superfund Amendments and Reauthorization Act (SARA). TEAD-N
occupies approximately 24,732 acres of the Tooele Valley, in Tooele County, Utah. The .
facility is located just west of the city of Tooele, Utah, approximately 35 miles southwest of
Salt Lake City (Figure 1-1). There are7 Operable Units (OUs) containing 17 solid waSte
management units (SWMUs) under the Superfund program at TEAD-N (Figure 1-2). Of
these, it has been determined that sufficient infonnation is available to proceed to a decision on
four OUs, which include six SWMUs. The remaining 11 SWMUs are undergoing additional
field investigations prior to reacmng a decision.
»
. Assembled herein is the Record of Decision (ROD) for four OUs containing the six SWMUs
for which sufficient infonnation exists to establish appropriate response actions (Figure 1-3).
These OUs and associated SWMUs are shown in Table 1-1.
Table 1-1. Operable Units and SWMUs at TEAD-N Covered by This Record of Decision
Operable Unit.
SWMU No.
SWMU Name
5
17
33
Fonner Transfonner Storage Area
PCB Storage Building 659
6
. 9
18
Drummed Radioactive Waste Area
Radioactive Waste Storage Building
7
5
Pole Transfonner PCB Spill
10
41
Box Elder Wash Drum Site
This ROD has been developed to comply with CERCLA and with the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP) in accordance with a Federal Facility
Agreement (FFA) between U.S. Environmental Protection Agency (USEPA) Region VIll,
State of Utah Department of Environmental Quality (DEQ), and Tooele Army Depot (TEAD).
{
ROD/August S, 1994
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RODlAugust S, 1994
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Location Map of Operable Units and SWMUs at Tooele Army Depot-North Area Covered by This Record of
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1.2 RECORD OF DECISION ORGANIZATION
In accordance with EP A guidance, the ROD follows this general outline:
1. The Declaration-An abstract for key information in the ROD, which provides a brief
description of the selected remedy for each site and a statement that the remedy complies.
with CERCLA and is consistent, to the extent practicable, with the NCP. It is signed by
designated officials of all involved parties.
.
2. The Decision Summary for each OU-An overview of potential problems posed by the
conditions at a site, possible remedies to any problems, a rationale for remedy selection,
and an analysis of the selected remedy's satisfaction of statutory requirements.
3. The Responsiveness Summary-A summary of significant comments received from the
public during the public comment period and TEAD responses to these comments.
1.3 GENERAL BACKGROUND
1.3.1 Physical Setting
1.3.1.1 Surface Features
TEAD-N is located in the southern portion of the Tooele Valley in Tooele County, Utah. The
north-trending Oquirrh and Stansbury Mountains rise from the valley floor at elevations
ranging from 5,000 to over 10,000 feet. TEAD-N is situated on the floor of the valley shaped
by coalescing alluvial fans formed by erosional debris washed from the Oquirrh and Stansbury
mountains. The valley floor in the vicinity of TEAD-N: slopes toward the north. The average
topographic gradient in the northern portion of the site is approximately 70 feet per mile,
increasing to about 150 feet per mile at the southern boundary.
1.3.1.2 Meteorology
The climate of the Tooele Valley ranges from arid to semiarid at the salt flats near the Great
Salt Lake to moderate in the mountains surrounding the valley. Rainfall is minimal in the
valley, and the average annual precipitation between 1897 and 1985 was approximately 16.95
inches in Tooele, although in Grantsville the average annual precipitation was 11 inches
between 1957 and 1977. The greatest precipitation occurs in the mountains surrounding the
valley, where the average amount is more than 40 inches per year. Air temperatures at Tooele
from 1941 to 1970 averaged 51°F (10.6 °C).
I
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ROD/August S, 1994
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1.3.1.3 Geology
A
The Tooele Valley is typical of basin and range physiography in which fault-block mountains
rise above flat intermountain valleys. Bedrock in the mountain ranges bordering the valley has
been extensively folded and faulted. The Tooele Valley is filled with a thick sequence of
unconsolidated alluvial sediments of Tertiary and Quaternary age. The valley was formed as
sand grains, gravels, and cobbles composed of quartzite, sandstone, and limestone, eroded
primarily from the Oquirrh Mountains east of TEAD-N. Because alluvial deposits at TEAD-N
generally are coarse grained, they form a productive aquifer system when saturated.
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1.3.1.4 Soils
Eight primary soil types have been identified in the vicinity of the TEAD-N facility: the (1)
Abela, (2) Berent, (3) Hiko Peak, (4) Birdow, (5) Medbum, (6) Taylorsflat, (7) Doyce, and
(8) Manessa. Additionally, two miscellaneous types (manmade) were identified, Borrow Pits
and Disturbed Area. These soils, which developed in alluvial deposits or lacustrine sediments,
consist primarily of gravelly loam, loam, or fme sand. Hydraulic conductivities of the soil in
the TEAD-N area range from 1 x 10-2 to 1 X 10-4 centimeters per second. Table
2-1 of the FiTZLll Remedial Investigation Report for Operable Units 4-10 presents general
characteristics of surface soil at TEAD-N.
1.3.1.5 Hydrogeology
Groundwater in Tooele Valley is found in the alluvial valley fIll deposits and, to a less extent,
in underlying bedrock. . Groundwater flow direction at TEAD-N is from the southeast to the
. northwest, but is altered somewhat in the northeastern area of the facility where the alluvial
aquifer encounters a fault-block bedrock ridge. The potentiometric surface is relatively flat
with a hydraulic gradient of approximately 0.007 foot per foot across the installation. The.
depth to the regional groundwater aquifer under the facility is generally over 200 feet.
Numerous, localized moist zones may exist on the installation. It is believed that groundwater
perched along these zones will eventually reach the regional alluvial aquifer. For a more in-
depth discussion of the hydrogeology at TEAD-N, see Section 2.6 of the FiTZLlI Remedial
Inv.estigation Report for Operable Units 4-10. .
1.3.1.6 Surface Water
During rare periods of heavy rain or rapid melting of mountain snowpacks, surface water may
occur at TEAD-N in Box Elder Wash ~d South Willow Creek, both of which cross TEAD-N
near its western boundaries.
ROD/August S, 1994
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1.3.1.7 Land Use
Except for the city of Tooele, properties immediately adjacent to TEAD-N boundaries are
undeveloped. Properties to the north are used for pasture or cultivation; properties to the west
and south are used for rangeland grazing. Properties east of TEAD-N consist of Tooele and
undeveloped rangeland along the lower western slopes of the Oquirrh Mountains. Scattered
gravel pits are also located southeast of TEAD-N along SR 36. Except for the southeastern
portion (bounded by SR 36), TEAD-N is bounded on the east by the Union Pacific Railroad
right-of-way. Residential development abuts the northern boundary of this portion of TEAD-
N. Tooele Municipal Airport and scattered residential homes are located along the eastern
boundary north to SR 112, which forms the northeastern boundary of TEAD-N. The area
northeast of SR 112 is undeveloped except for a construction company and Tooele LandfIll.
There is on-base housing for both civilians and military families in the administrative area.
For a complete discussion of current and future land use, see Sections 3.5.2.1.1 and 3.5.2.1.2,
respectively, of the Final Remedial Investigation Reportfor Operable Units 4-10.
1.3.1.8 llegetGUion
The Tooele Valley region is dominated by sagebrush and saltbrush plant species. A total of
seven range site types have been identified within the TEAD-N facility area: (1) Semidesert .
Sand (Utah}uniper), (2) Semidesert Gravelly Loam (Wyoming Big Sagebrush), (3) Semidesert
Loam (Wyoming Big Sagebrush), (4) Semidesert Alkali Loam (Black Greasewood), (5)
Upland Stony Loam (pinyon-Utah Juniper), (6) Loamy Bottom (Basin Wildrye), and (7)
Upland Loam (Mountain Big Sagebrush). Characterization of these types is discussed in detail
in Section 2.8 of the Final Remedial Investigation Report for Operable Units 4-10.
1.3.1.9 Wildlife Species
Approximately 127 species have been identified in the near vicinity of the TEAD-N facility
area. Of these, 58 species were mammals and 63 were birds. Additionally, six reptiles were
also identified. No fish or amphibians were identified. Wildlife species noted either have
been observed during field investigations or considered as likely habitants based upon
extensive previous studies conducted at TEAD-N.
1.3.1.10 Threatened and Endangered Species
~
There are 15 endangered, candidate, or sensitive mammalian and avian wildlife species either'
known to occur or potentially occur on the TEAD-N facility, 11 of which are protected by the
Endangered Species Act of 1973, Section 668-668d. Of these 15, 9 are endangered,
candidate, or sensitive bird species that have been either identified in the region or observed on
the TEAD-N facility area; 2 are federal candidate mammalian species that may also occur on
the site; and 4 are Utah State sensitive species that occur or may occur on the site either as
ROD/August S. 1994
-------
permanent or seasonal residents. Table 2-7 of the Final Remedial Investigation Report for
Operable Units 4-10 presents a list of mammals, birds, and reptiles at TEAD- N. .
4
An endangered species survey for flora has been conducted on the TEAD-N site, but no
observations of endangered or sensitive species have been recorded. However, because of the
types of vegetation communities present on the site or because of sightings in adjacent areas,
the following federally listed species could possibly occur on the site: clay phacelia (Phacelia
argillacea), cryptantha (Crypantha compacta), desert milkvetch (Astragalus desereticus),
Pohl's milkvetch (Astragalus lentiginous ssp. pohliz), Ute lady's tresses (Spiranthes diluvialis),
deep creek stickseed (Hackelia ibapensis), and basin fishhook cactus (Sclerocactus
pubispinus). Only the clay phacelia is listed as endangered; all of the other species are listed
as Category II species.
1.3.2 History and Enforcement Activities
TEAD-N was established as the Tooele Ordnance Depot on April 7, 1942, by the U.S. Army
Ordnance Department. It was redesignated as TEAD-N in August of 1962. At that ~e, a
second facility, Tooele Army Depot-South Area (TEAD-S; formerly the Deseret Chemical
Warfare Depot) became part of the Tooele Army Depot, although the two facilities are located
approximately 17 miles apart. .
During World War II, TEAD was a back-up depot for the Stockton Ordnance Depot and
Benicia Arsenal, both located in California. It stored vehicles, small arms, and other
equipment for export.
The current missions of TEAD-N include the maintenance, renovation, and storage of wheeled
vehicles, and the reception, storage, issuance, maintenance, aIid disposal of munitions.
Developed features at TEAD-N include igloos, magazmes, administrative buildings, an
industrial maintenance area, military and civilian housing, roads, hardstands for vehicle.
storage, and other allied infrastructure.
Currently, TEAD is one of the major ammunition storage and equipment maintenance
installations in the U.S., supporting other Army installations throughout the western U.S.
However, portions of the installation are slated for closure under Base Realignment and
Closure (BRAC) actions.. BRAC legislation passed in September 1993 specifies that the
Army's maintenance and related missions must cease at TEAD-N by September 1999. Current
closure plans envision that the maintenance area (Figure 1-3) will be utilized for industrial
purposes by private firms or other government entities. A total of about 1,700 acres would be
transferred from TEAD-N by this. action.
As a result of continuous operations since 1942, a variety of known and potential waste and
spill sites have been identified at TEAD-N. A variety of enviromriental investigations have
been conducted at TEAD-N from 1979 to the present. In 1987, a Final Interim Resource
Conservation and Recovery Act (RCRA) Facility Assessment for TEAD-N was published,
RODfAugust S. 1994
-------
identifying 28 SWMUs. These SWMUs were suspected or known to have released
contaminants into the environment. Subsequent investigations resulted in the identification of
an additional 26 SWMUs, which resulted in a total of 54 potential hazardous waste sites at
TEAD-N. .
.
On October 2, 1984, the EPA proposed TEAD-N for inclusion on the NPL. The facility was
listed on the NPL on October 1, 1990. As a result, the EPA, State of Utah, and TEAD .
entered into an FFA on September 16, 1991. In this agreement, 17 of the 46 SWMUs
identified at the time were redesignated asCERCLA action areas contained witJiin 7 OUs.
The remaining 29 SWMUs are covered under a RCRA Corrective Action Permit (CAP),
which was issued to TEAD by the State of Utah on January 7, 1991. Under the CAP, the
SWMUs were divided into 9 known releases SWMUs and 20 suspected releases SWMUs. . As .
a result of the FF A and CAP, work plans were prepared and field investigation activities were
undertaken. Since that time, 8 additional SWMUs have been identified for investigation,
bringing the total to .54 SWMUs identified on TEAD- N.
Guidelines for the remediation of hazardous constituents released from federal facilities. are
provided in Section 120 of CERCLA. Essentially, all guidelines, rules, regulations, and
criteria carned out under CERCLA apply to federal facilities. In.that context, environmental
studies and remediation activities to be conducted at TEAD- N are governed by CERCLA
under the review and approval of the EP A Region vm and the State of Utah (the Division of
Environmental Response and Remediation). The FF A specifies the responsibilities of each
agency for the study and cleanup of waste sites at TEAD-N. The.FFA also includes a
schedule for the completion of each major phase of the CERCLA process.
1.3.3 Highlights of Community Participation
A Community Relations Plan for TEAD remedial action was completed on February 1, 1992.
The plan development began in 1988 and included interviews with 24 individuals. from the
TEAD labor force and the local community. The Community Relations Plan is currently
undergoing revision. Additional community interviews will be conducted to update the
database. Technical Review Committee meetings, which are open to the public, have been
held locally every 3 months since February 1988 to discuss specific characterization progress
and planned clean-up ~ctivities involving TEAD Installation Restoration work. Specific
. presentations and site tours have been readily available upon request by public interest groups.
The Final Remedial Investigation Reportfor Operable Units 4-10 was released to the public on
July 1993. The Final Feasibility $tudy Reportfor Operable Units 5, 6, 7, and 10 was released
to the public on December 1993. The Proposed Plan for Operable Units 5, 6, 7, and 10 was
released to the public on May 2, 1994. These documents were made available in the
Administrative Record and in information repositories maintained in the Public Affairs Office
at.TEAD, the Tooele Public Library, the Grantsville Public Library, and the Marnott Library
at the University of Utah. Information in these repositories is regularly updated. The notice
of availability of these documents was published in the Deseret News on May 2, 1994, and the
RODiSeptemb<:r 1994
-------
..
Transcript Bulletin on May 3, 1994. A public comment period on the Proposed Plan was held
from May 9, 1994, through June 8, 1994. In addition, a public meeting was held on June 2, .
1994, at the Tooele County Courthouse. At this meeting, representatives from TEAD, the
EPA, and the DEQ answered questions about the site and remedial alternatives considered for
the site. A response to the comments received during this period is included in the
Responsiveness Summary, which is part of this ROD. A complete transcript of the meeting is
provided as Appendix A to this ROD. This decision document presents the selected remedial
action for OUs 5, 6, 7, and 10 at TEAD-N in accordance with CERCLA, as amended by
SARA and, to the extent practicable, the NCP. The decision for these OUs is based on the
Administrative Record.
1.3.4 Responsive Summary
As outlined in Section 1.3.3, the Feasibility Study and the Proposed Plan were made available
to the public in the administrative recordf1le located in the Public Affairs Office at TEAD-N
and in information repositories located in the Tooele Public Library , the Grantsville Public
Library, and the Marriott Library at the University of Utah.
The public comment period on the Proposed Plan was from May 9, 1994 through June 8,
1994. In addition, a public meeting was held at the Tooele County Courthouse on June 2,
1994. At this meeting, representatives of the U.S. Army and its contractor, the USEPA, and
the State of Utah discussed with the public the preferred alternatives for the four operable units
containing the six SWMUs under consideration at this time.
Written comments were not received during the public comment period. This Responsiveness
Summary addresses comments received during the public meeting. The comments are
summarized and responses provided as applicable.
Public Comment Nci. 1
Who would be performing the actual field cleanup?
Res,ponse to Public Comment No.1
After formal Record of Decision approval, the Army Corps of Engineers will assume
responsibility for remedial design and implementation of cleanup. Contractors will be chosen
by the Corps of Engineers for this work. Groundwater cleanup is currently underway at
TEAD-N.
~
Public Comment No.2
Who is the contractor for the groundwater cleanup?
RODlSepu:mbcr 1994
-------
Response to Comment No.2
Metcalf and Eddy.
Public Comment No.3
..
The Proposed Plan states that SWMU 33, the PCB Storage Building, is permitted under
TSCA. This is not correct as 'no permits are required by the Toxic Substances Control Act
(TSCA) for operation of this facility. The storage facility was operated under TSCA
regulations, but did riot require a permit.
Re~onse to Public Comment No.3
Although the comment is correct, the clarification of TSCA permitting does not affect the
preferred alternative analysis for SWMU 33.
RODlSeptember1994
-------
Section 2
Record of Decision for Operable Unit 5
~
-
ROD/August S. 1994
-------
DECLARATION OF THE RECORD OF DECISION FOR OPERABLE UNIT 5
Operable Unit Name and Location
au 5 has been or continues to be used to store electrical transformers or other switch gear,
which may contain polychlorinated biphenyls (PCBs). It is located in the Maintenance Area of
TEAD-N, Tooele, Utah. The SWMUs in this au are SWMU 17, Former Transformer.
Storage Area, and SWMU 33, PCB Storage Building 659.
Statement of Basis and Purpose
This decision document records the selected remedy for au 5 at TEAD-N. The actions were
chosen in accordance with CERCLA, as amended by SARA, and to the extent practicable, the .
NCP. The decision on the selected remedy is based upon information contained in the
Administrative Record for this au.
The USEP A and the State of Utah concur with the selected remedy.
Description of the Selected Remedy: No Action
The selected remedy for au 5 is No Action because current conditions at SWMU 17 do not
present unacceptable risks to human health and the environment. Further, no action is
designated for SWMU 33, the PCB Storage Building 659, because EPA is deferring authority .
on this SWMU to existing RCRA and TSCA regulating jurisdiction and to closure under
BRAC requirements, which will require compliance with CERCLA.
Declaration Statement
No remedial action is necessary at au 5 to ensure continued protection of human health and
the environment. Conditions at SWMU 17 are protective of human health and the .
environment. SWMU 33 is currently active, is operated under TSCA regulations, and is also
regulated under the TEAD-N RCRA Post Closure Permit as specified in Section 5 of the
TEAD-N FFA. There have been no known PCB releases to the environment from activities
inside Building 659. Any future closure of the facility would be conducted under the
appropriate TSCA, RCRA, and BRAC closure requirements.
RODiSeptember 1994
-------
.
.
~
Signature and Support Agency Acceptance of the Remedy
Date
RODlAllgllS! S. 1994
Jesse L. Brokenburr
COL,OD
Commanding
Tooele Army Depot
-------
SEP-29-19'34 13:53 FROM
SAILE-ESOH
TO
913032947559
P.B2
Sj~~ and SUDport ~~ A~CI~ of the p~
~cS ,/,)l~.
. Lewis D. Wa1ker
Deputy Assiztant ~ of tbe Army.
~ Safety, and Oa:upuioml Health)
1/2'7/91
. D=
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-------
. .Signature and Support Agencv Acceptance of the Remedy
9/,z~/91
Date
William P. Yellowtail
Regional Administrator;
Region VIll,. USEP A
. .
~
2-5
-------
U:11 ~Vl Oil
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:Signature :md Support Afen~ ~cceptance of the Remedy
Tooele Anmy Depot - North Area. Record of Decision
For Operable Unit 5
~.
j-marmeR .Niels~n, Ph.D.
. E."{ecutlve D1I'eCtor
'Utah Department of Environmental Quality.
"'3J~;- 7¥
Date
AODt-S-5, tPIU
-------
.. 2.0 DECISION SUMMARY FOR OPERABLE UNIT 5
2.1 SCOPE AND ROLE OF OPERABLE UNIT 5
Operable Unit 5, which consists of SWMU 17 and SWMU 33,.is located in the Maintenance
. Area of TEAD-N (Figure 2-1). These areas are both associated with past or present storage of
PCB-containing electrical transformers. Action on this au will be to continue to protect the
public health and the environment from possible risks due to current or future exposure to
contaminated soils or groundwater. .
2.1.1 Description
SWMU 17, the Former Transformer Storage Area, is known as Open Storage Lot No. 675B.
The lot is unpaved, but graveled, and covers an area of approximately 5 acres (350 by 600
feet). Lot 675B is currently used for storage of vehicle-related equipment. SWMU 33, PCB
Storage Building 659, is a TSCA-regulated facility currently used to store transformers on
open pallets and in wooden crates within the building. The 180 feet by 250 feet PCB storage
area has a sealed cement floor and an 8-inch-high perimeter berm and diversion structures at
each entrance for the containment of oil spills. Much of the surface around the outside of the
building is paved. Operation of the site is conducted under TSCA regulations. AIly future'
closure of SWMU 33 would also be conducted under TSCA regulations and BRAC
. requirements, which specify compliance with CERCLA, and will satisfy RCRA Corrective
Action obligations as specified in the TEAD-N FFA.
2.1.2 Characteristics
One of the responsibilities of TEAD-N has been the receiving, storage, maintenance, and
shipment of oil-containing electrical transformers and capacitors. Based upon TEAD-N
records, prior to 1979 thousands of transformers and capacitors were stored at SWMU 17.
Many of these transformers contained PCB-contaminated oil. In 1979, all transformers were
removed from SWMU 17, which is currently used for the storage of vehicle-related
equipment. Transformers awaiting re-use are now stored in the enclosed building, SWMU 33.
Potential contaminants of concern to public health and the environment at Operable Unit 5 are
PCBs. PCBs are generally considered chemically and environmentally stable, exhibiting low
volatilization rates. PCBs, however, may enter the annosphere through adsorption to particles
that become airborne. The most likely exposure pathways for PCBs at au 5 are via dermal
contact, incidental soil ingestion, . and inhalation of fugitive dust.
Although PCBs are not appreciably taken up by plants, they do bioconcentrate in fatty tissue in
animals because of their stability, high lipid solubility and/or binding, and low water
solubility. In addition to the low bioavailability of PCBs in soils, the current physical nature
of au 5 (graveled storage lot or enclosed building) minimizes the likelihood of possible PCB
ROD/August 5,1994
-------
"~,
'~
"~
"~
"
o
1,600
SCAlf IN FID
(AI'!'ROX. J
3.200
LEGEND
SOURCE: CFFICE OF T}£ fACILITIES .
ENGI~ TEAD-N SITE
MAP "EXiSTING COM>ITIONS"
iiARCH, 1989: PAIS I FINAL '
DRAFT REPOOT. EA. 1988
~
INlERPRETIVE GROlNIWATER
FLOW DIRECTI(loj
1 682I-f'07 .[)QI
..
. .
',.. _/
Figure 2-1. Location Map of Operable Unit 5, the Former Transformer Storage Area
(SWMU 17) and PCB Storage Building 659 (SWMU 33)
RODlAugustS, 1994
2-8
-------
bioaccumulation. au 5 is part of a large industrial complex at TEAD-N and, as such, is not
available for locally grazed cattle or homegrown produce; therefore, these pathways are not
considered complete for current land use conditions, but may be considered complete for a
future residential scenario. BRAC plans envision that au 5 will be transferred to non-Army
industrial use, further minimizing the possibility of potential future human habitation.
Contaminant fate and transport are discussed in Section 5.1.5 of the Final Remedial
Investigation Report for Operable Units 4-10. Because of the relative immobility of PCBs in
soil, the low concentration of PCBs detected in the soil, the great depth to groundwater
(approximately 280 "feet) at au 5, and results of vadose zone contaminant fate and transport
modeling, groundwater cont;:!mination by PCBs from au 5 was not considered likely. .
2.1.3 Summary of Risks
2.1.3.1 Human Health
Potential human health effects associated with the non-remediated site were evaluated to
provide a baseline risk to determine if remediation was necessary according to EPA guidelines.
The evaluation began with identification of chemicals present at the site that pose a potential
risk to human health based on their prevalence and concentr~tion in the environment and their .
inherent toxicity. For au 5, risks were assessed for SWMU 17 based upon reported PCB
concentrations. A similar risk assessment was not made for SWMU 33 because there is no
evidence that PCBs have been released to the environment from activities inside the building.
Next, a toxicity assessment was conducted to estimate the relationship between the extent of
exposure to a contaminant and the increased likelihood and/or severity of adverse effects. The
next step in the risk assessment was to perform an exposure ass.essment to evaluate pathways
by which humans could possibly contact contaminants. The fmal step consisted of determining
the magnitude and probability of current and future human health risks associated with the
identified contaminant of concern. Both carcinogenic and noncarcinogenic risks were
evaluated.
,
In conducting an assessment as described, the health effects tl;1at could result from all
applicable exposures are evaluated. For personnel who may be working on SWMU 17 within
au 5, effects that could result from direct exposUre to the contaminants asa result of the soil
coming into direct contact with the skin, from inadvertent direct ingestion of the soil, or from
iIihalation of dust particles were evaluated. Exposure to the contaminants for others not
directly working on SWMU 17 was restricted to the inhalation pathway.
For comparison purposes, a hypothetical future case was calculated to show what might
happen if SWMU 17 were released for public use and a residence was constructed on the site.
For this case, additional health effects were evaluated, including consumption of beef,
vegetables, and fruit grown on site.
RODiSept_1994
-------
2.1.3.1.1 Noncarcinogenic Risk. Noncarcinogenic risks are calculated as follows: The
potential for noncarcinogenic health effects is estimated by comparing a daily intake of a
compound through a specific exposure route to a reference dose for that compound. The ratio
of the.. intake to reference dose for an individual chemical is termed the hazard quotient (HQ).
A HQ greater than 1 indicates the potential for adverse health effects, since the intake exceeds
the reference dose. A hazard index (HI) is calculated by adding all the HQs for a specific
pathway. A residual III of 1 or less means that, even without cleanup, insufficient
cont;tmin~tion exists to cause adverse noncancer health effects during a normal human lifetime.
For PCB concentrations in soils at SWMU 17, calculated cumulative noncarcinogenic hazard
levels for all current 'and future cases are less than 1.
2.1.3.1.2 Carcinogenic Risks. The excess lifetime cancer risk is the incremental increase in
the likelihood of getting cancer if exposed to site contaminants as compared to the probability
of that with no exposure to site cont~minants. These cancer risks are stated as probabilities.
A risk of 1E-6 for example, represents the probability that one person in one million exposed
to a carcinogen over a lifetime of 70 years will develop cancer. The EPA has set. a 1E-4 to .
1E-6 risk range as the "point of departure" for taking action at a Superfund site.
All SWMU 17 carcinogenic risks fall below or within the risk range of 1E-4 to 1E-6.
Carcinogenic risks for two of the potential receptors-the current on-site worker and the future
on-site resident-are calculated to be within the acceptable range. Carcinogenic risks for all
other potential receptors are below the acceptable range. The on-site worker risk is calculated
to be just within the acceptable range. The assumptions used in this calculation are
conservative (e.g., assumes a worker will be on SWMU 17 for 250 days per year for 25
years). .
For the future on-site resident scenario, the assumptions used in these calculations are again
conservative. For example, this scenario assumes an incidental soil ingestion rate of 200
milligrams per day (mg/day) for a child and 100 mg/day for an adult. with all of the ingested
soil emanating from SWMU 17. In addition, it is assumed that 75 percent of all beef
. consumed by a future SWMU 17 resident comes from cattle that have grazed on SWMU 17.
Further, EP A Guidance on Remedial Actions for Superfund Sites with PCB. Contamination
recommends that remedial action be considered when PCB levels exceed 1 part per million
(ppm) for residential land use and 10 to 25 ppm for industrial land use. All available data for
au 5 indicate that soil contamination is below the most stringent of these levels.
2.1.3.2 Ecological Risk
au 5 was also evaluated qualitatively and semi-quantitatively for ecological risks. There is no
indication that this area is a critical habitat for any endangered or threatened species. The
contamimmt of concern is PCB Aroelor 1260. This compound is toxic and bioaccumulates.
However, the levels of PCB were found to be too low to cause any direct toxic effects on
RODiSeptember1994
-------
wildlife.. A model was used to evaluate the effects of bioaccumulation on raptors by ingestion
of small animals and birds. The PCB levels at .OU 5 were found to belower than levels that
could cause effects in raptors or other wildlife. .
2.1.4 Description of the No-Action Alternative
.
.
As a result of this extensive review and analysis, it is determined that no remedial action is
necessary at OU 5 to ensure continued protection of human health and the environment. In the .
process of arriving at this conclusion, several alternatives were examined for SWMU 17 as
outlined in the Final Feasibility Study Reportfor Operable Units 5, 6, 7, and 10 (Sections
3.1.6 to 3.1.14). In addition to No Action, institutional controls such as fences, emplacement
of a soil cover oyer the lot, cement stabilization of the storage lot soil, removal of storage lot
soil to an approved landfill, and incineration of the storage lot soil were all evaluated.
Because no unacceptable risks to human health and the environment were identified for
SWMU 17, the No Action alternative has been selected.
The designation of No Action for SWMU 33 is protective of human health and the
environment and is cost-effective. Building 659 will continue to operate as a storage facility
for an indeterminate length of time. Continued operation of the facility will be conducted
according to TSCA regulation. Any future closure would be conducted under TSCA and
BRAC requirements and satisfy RCRA Corrective Action obligations as specified in the
TEAD-N FFA. The statutory preference for remedies that employ treatment that reduces
toxicity, mobility, or volume as a principal element will be addressed, as appropriate, by any
later remedy. Review of this site and storage activities will be ongoing as the Army continues
to develop final plans for TEAD-N. The FFA specifies that TEPill-N properties will be
subject to a rigorous process to ensure compliance with all appropriate regulations prior to
transfer to non-Army use. This process is designed to comply with CERCLA regulations; that
is, the final disposition of SWMU 33 will protect-human health and the environment.
. .
RODJScptcmber 1994
-------
Section 3
Record of Decision for Operable Unit 6
RODIAugllst 5,1994
-------
DECLARATION OF THE RECORD OF DECISION FOR OPERABLE UNIT 6
Operable Unit Name and Location
au 6 is located in the Maintenance Area of TEAD-N, Tooele, Utah. The SWMUs in this
au are SWMU 9; the Drummed Radioactive Waste Storage Area, and SWMU 18, the
Radioactive Waste Storage Building. .
SWMU 9 consists of a concrete pad and nearby field area that were reportedly used for
temporary storage of drummed low-level radioactive waste. SWMU 18 consists of a secured
room in Building 659 and is an active facility for storing low-level radioactive materials.
Statement of Basis and Purpose.
This decision document records the selected remedy for au 6 at TEAD-N. The action was
chosen in accordance with CERCLA, as amended by SARA, and to the extent practicable, the
NCP. The decision is based upon the Administrative Record for this au.
The EP A and the State of Utah concur with the selected remedy.
Description of the Selected Remedy: No Action
The selected remedy for au 6 is No Action. Current conditions at SWMU 9 do not present
unacceptable risks to human health and the environment so no action is appropriate. SWMU
18, the Radioactive Waste Storage Building, is designated as No Action because the USEPA is
deferring authority to existing Nuclear Regulatory Commission (NRC) jurisdiction and to
closure under BRAC requirements, which will meet CERLCA requirements and satisfy RCRA
Corrective Action obligations specified in the TEAD-N FFA.
Declaration Statement
No remedial action is necessary at au 6 to ensure continued protection of human health and
the environment. SWMU 18 is currently active, is a permitted NRC facility, and is also
subject to the TEAD-N RCRA Post Closure Permit as specified in Section 5 of the TEAD-N
FF A. The facility would be investigated under NRC, RCRA, and BRAC regulations if it is
closed or the function changed at any future time. Conditions at SWMU 9 are protective of
human health and the environment.
ROD/September 1994
-------
SIgnature and Support Agency Acceptance of the Remedy
Date
RODIAugust5.1994
Jesse L. Brokenburr
COL,OD
Commanding
Tooele Army Depot
-------
SEP-29-1994 13:53 FROM
SA I LE-ESOH
TO
9130.:~7S53
P.03
.'
f~-;.~ure ~nrl St~ A~ A~ of the Remmx
~b.~
Lewis D. WaIkc',
DepU1J Ass~~t ~et3i:y of the AmrJ
~ Safet1t and Oca1patioual Health)
,
1CCMr....... S. 8M
3-4
9/1. r /'71
Date .
I
I
-------
. Signature and Support Agency Acceptance of the Remedv
.
ROCfAllgust S. 1994
William P. Yellowtail
Regional Administrator,
Region VIII, USEP A
Jlk-
7J
c;/:l~ /17
Date
-------
"'CI "'..,v, ..,"'v
Signature and Support Agency Acceptance of the Remedy
T.ooele Army Depot - North Area, Record of Dec.is~6n:'
For Operable Unit 6
~:£d./
Dianne R. Ni~n, Ph.D.
Executive Director
Utah Department" of Environmental Quality
3P~71
Date
3-6
-------
.3.0 DECISION SUMMARY FOR OPERABLE UNIT 6
3.1 SCOPE AND ROLE OF OPERABLE UNIT 6
Operable.Unit 6, which consists of SWMU 9, the Drummed Radioactive Waste Storage Area
and SWMU 18, the Radioactive Waste Storage Facility, is located in the Maintenance Area of
TEAD-N (Figure 3-1). These areas are both associated with past or present storage of
radioactive matenals. Action on this au will be to continue to protect the public health and
the environment from possible risks due to current or future exposure to CODtarniTlated soils or
groundwater.
3.1.1 Description
SWMU 9, the Drummed Radioactive Waste Storage Area, is located in the Maintenance Area
of TEAD-N and consists of a concrete pad and a nearby field that were reportedly used for the
temporary storage of drummed low-level radioactive waste. .
SWMU 18, the Radioactive Waste Storage Facility in Building 659, is located in the
Maintenance Area of TEAD- N. . It is a walled-off and locked section approximately 20 feet by
20 feet in size, in the northeastern comer of the building. It is a facility used currently to store
NRC-licensed radioactive materials in Department of Transportation (DOT)-approved
containers within the building.
3.1.2 Characteristics
SWMU 9 consists of TEAD-N areas that were used for temporary storage of drummed low-
level radioactive wastes. Because of concerns that radioactive materials may have
CODtarniTlated TEAD-N, containers suspected of containing radioactive wastes were removed in
1978 for off.:.site disposal by the TEAD-N Radiation Protection Office. There are no records
that identify the exact storage locations of the containerized waste and no indication that any.
radioactive spills occurred at SWMU 9. SWMU 9 is in a sparsely vegetated industrial area.
Radiological surveys were conducted in the areas suspected to have been locations for the
storage of radioactive waste containers, and only background levels of radiation were detected.
The two areas surveyed that were thought to have been used for radiological container storage
~e a concrete pad which now holds a small wooden shed and a field that was being used to
store 4-wheel-drive pickup trucks at the time of the RI.
SWMU 18, the Radioactive Waste S~orage facility in Building 659, began operating in 1975.
Wastes stored within the facility include radiation-detection meters, compasses, sights, range
fmders, and radioactive luminous compounds. Because of the small amount of material
stored, waste removal occurs only once every 5 years. NRC regulations control the conditions
for storing and monitoring the radioactive waste. There is no evidence that any uncontrolled
release to environmental pathways has occurred as a result of operations of this facility.
RODlSeptembcr 1994
-------
TM7/
" "
/" fIll II ,/'
" ,/
" , ' I
" /'" I
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o
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Legend
I~~I BUILDING OR STRUCTURE
x-x-x- FENCELINE
~ INTERPRETIVE GROUNDWATER
~ FLOW DIRECTION
. RAILROAD TRACKS
!
~
1', ~,
II ", '~
1 "-
(~~ . """'",/,SUSPECTED RUN
. " / ~7 STORAGE AREA
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" 1
, 1
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SUSPECTED
DRUM
STORAGE
AREA
(SWMU 9)
RADIOACTIVE WASTE
STORAGE BUILDING S-659
(SWMU 18)
o 200 4QO
SCALE IN FEET
(APPROX, )
2470HC23.DGN
Figure 3-1.
Location Map of Operable Unit 6 and SWMUs 9 and 18 at Tooele Anny Depot-
North Area
ROD/August S, 1994
-------
Because the facility is operated in complete compliance with a NRC permit and there is no.
evidence or data to indicate that cont.aminated wastes have been released to the environment from
operations of the Building 659 facility, no sampling or analytical investigations were conducted
at SWMU 18. .
3.1.3 Summary of Risks
Radiological surveys were conducted in the suspected drum storage areas of SWMU 9 as
described in Section 6.1.2 of the Final Remedial Investigation Report for Operable Units 4-10.
The north survey area was gridded and a walking survey was conducted over the entire area,
using a hand-held probe with a 3-foot extension. Because of the presence of 4-wheel-drive
vehicles in the survey area, it is estimated that approximately 90-percent coverage was achieved
(Le., only the soil directly under vehicle tires was not surveyed).
It was determined that an alpha radiation survey was not necessary because no elevated
beta/ gamma readings were reported and the beta/gamma radiation meter used was sensitive to all
potential alpha emissio"ns. Because there are no identified contaminants of concern for SWMU
9, a risk assessment was not performed.
Radiation surveys are conducted periodically at SWMU 18, as required by the NRC regUlations.
These surveys indicate that no uncontrolled releases have occurred and. that the storage area is
being properly controlled and maintained: Because there are no identified contaminants of
concern for SWMU 18, a risk assessment was not performed.
3.1.4 Description of the No-Action Alternative
Because there are no indications of contamination at au 6, No Action is the only remedial action
that was evaluated and thus is the recommended alternative.
For SWMU 18, continued operation of the facility will be regulated by the NRC. Any future
closure would be completed under NRC and the BRAC program, and satisfy RCRA Corrective
Action obligations as specified in the TEAD-N FFA. The statutory preference for remedies that
employ treatment that reduces toxicity; mobility, or volume as a principal element will be
addressed, as appropriate, by any later remedy. Review of this site and storage activities will be
ongoing as the Army ~ontinues to develop final plans for TEAD-N. In October 1992, the
Community Environmental Response Facilitation Act (CERFA) (Public Law 102-426) amended
Section 120 (b) of CERCLA, establishing new' requirements for cont;!mination assessment,
cleanup, and regulatory agency notification and concurrence for Federal facility closures.
CERF A requires the Federal government, before termination of Federal activities on real
property owned, to identify property where no hazardous substances are stored, released, or
disposed. CERF A designations must be concurred with by the EP A. These requirements are
being implemented at TEAD-N. This process is designed to comply with CERCLA regulations;
that is, the final disposition of SWMU 18 will protect human health and the environment.
RODiSeptomber 1994
-------
~
comply with CERCLA regulations; that is, the fmal disposition of SWMU 18 will protect
human health and the environment as directed by CERCLA.
RODIAugust S, 1994
-------
Section 4
Record of Decision for Operable Unit 7
ROD/August S, 1994
-------
DECLARATION OF THE RECORD OF DECISION FOR OPERABLE UNIT 7
Operable Unit Name and Location
OU 7 contains SWMU 5,. the Pole Transformer PCB Spill Site, which is located in the south-
central portion of TEAD-N, Tooele, Utah.
Statement of Basis and Purpose
This decision document records the selected remedy for OU 7 at TEAD-N. The action was
chosen in accordance with CERCLA, as. amended by SARA, and to the extent practicable, the
NCP. . The decision is based upon the Administrative Record for this OU.
The EP A and the State of Utah concur with the selected remedy.
Assessment of the SWMU
Actual or threatened releases of hazardous substances from this SWMU, if not addressed by
implementing the action selected in this ROD, may present an endangerment to public health
or the environment. . .
Description of the Selected Remedy
The function of the remedy selected for Operable Unit 7 is to ensure protection of public
health and the environment from exposure to cont~mination by PCB, dioxins, and
dibenzofurans at SWMU 5, the Pole Transformer PCB Spill Site.
The components of the remedy are:
.
Fill the excavated hole
Cover the site with 10 inches of clean soil
Cover the soil with gravel
.
.
In addition to protecting human health, this remedy will provide additional protection to cattle
and wildlife by physically covering the contaminated soil. .
Declaration Statement
. - The selected remedy is protective of human health and the environment, complies with Federal
and State requirements that are legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. This remedy utilizes perm~ent solutions and alternative
RODiSeplember 1994
-------
treatment technologies to the maximum extent practicable for the SWMU. However, because
treatment of the principal threat of the SWMU was not found to be practicable, this remedy
does not satisfy the statutory preference for treatment as a principal element of the remedy.
The size of the spill area and the fact that there are no on-site contamimmt levels that represent
risks outside of EP A targets preclude a remedy in which contaminants could be excavated and
treated effectively.
ROD/August S, 1994
-------
,. ""'--"
Signature and Support Agency Acceptance of the Remedy
Date
ROC/Allgust S, 1994
Jesse L. Brokenburr
COL,OD
Commanding
Tooele Army Depot
-------
SEP-29-1994
13:54 FROM
SAlLE :SOH
TO
913a..~4','::59
S"~~ and SU'PJ?01't ~<:y A~nc!!. t# 'th~ "Q~
P.84
9 1z-7/'11./
~~<~
Lewis D. Walker
. Deputy Assistant Sectem1 of the Army
(Em- ~o(J~ Safety, and Occupational ~Jtl\)
Date
.'
4-S
1OOI""~19H
, .
-------
Signature and Support Agencv Acceptance of the Remedv
7/29/91
Date
William P. Yellowtail
Regional Admini~trator,
Region VITI, USEPA
4-6
-------
- - - ----
Signature and Support Agency Acceptance of the RemedJ'
Tooele Army Depot - North Area, Record of Decision
For Operable Unit 7
~
. Dianne R. N"u:: on, Ph.D.
Executive Director
. Utah Department of Enviromnemal Quality
~~4-r'19'
Date
4-7
-------
. 4.0 DECISION SUMMARY FOR OPERABLE UNIT 7
4.1 SCOPE AND ROLE OF OPERABLE UNIT 7
Operable Unit 7, which contains SWMU 5 in the southeastern area of TEAD-N, is the location
of a 1976 transformer fIre, which spilled PCB-containing oils,. dioxins, and dibenzofurans on
the ground near the utility pole on which the transformer had been mounted (Figure 4-1). .
Action on this OU will be to protect the public health and the environment from possible risks
due to current or future exposure to contaminated soils or groundwater.
4.1.1 Description
OU 7 resulted when, in 1976, a fIre occurred in a pole-mounted electrical transformer.'
During the fITe, the transformer leaked PCB-containing oil to the surrounding soils. The oil-
containing soils were excavated in an area adjacent to and north of the pole. The excavation
measured approximately 5 feet by 5 feet wide and 3 feet deep. Eleven 55-gallon drums of soil
w~re collected from the excavation. Subsequently, the drums were properly disposed of off
site. The area of the excavation was not backfilled.
4.1.2 Characteristics
An earlier investigation at OU 7 included the collection of a composite sample from soil
removed after the fITe which was analyzed for PCBs. This sample contained 3.45 micrograms
per gram (;.Lg/g) of PCB 1260. Recent sampling and analysis characterized the surface and
subsurface soils within and immediately surrounding the former excavation to determine if
residual CODt~min3tion is present. Some CODtaminants remained after the cleanup of soils in
1976. Residual cont~mination consists of the PCB Aroclor 1260, which is present in low but
detectable concentrations in three of four surface-soil samples and in one of the subsurface-soil
samples collected in the excavation. PCBs were not detected in subsurface samples collected
at depths of up to 5 feet around the perimeter of the excavation. Detectable concentrations of
polychlorinated dibenzodioxins (PCDDs) and polychlorinated dibenzofurans (PCDFs) were
also present in most of the samples collected. These contaminants are presumably the result of
combustion of PCBs. These contaminants were detected in the parts per trillion range.
PCBs are generally considered chemically and environmentally stable, exhibiting low
volatilization rates. PCBs, however, may enter the atmosphere through adsorption to particles
which become airborne. The fate and transport of PCDDs and PCDFs are similar to the fate
and transport of PCBs. They are chemically and environmentally stable, relatively insoluble in
water, highly persistent, and have long environmental half-lives.
The most likely exposure pathways at OU 7 are via dermal contact, incidental soil ingestion,
inhalation of fugitive dust, and ingestion of beef derived from cattle potentially exposed to
ROD/August S, 1994
-------
. . --.-.,.. -:-',
i '---~----'-~ '.
N~T LO
-------
cantaminatian while grazing at TEAD-N. Hawever, . fugitive dust emissians fram au 7 are
minimal because af the small size af the area.
Althaugh PCBs, PCDDs, and PCDFs are nat appreciably taken up by plants, they do.
biacancentrate in fatty tissue in animals because af their stability, high lipid salubility andlar
binding, and law water salubility. In additian to. the law biaavailability af PCBs, PCDDs, and
PCDFs in sails, the small size af au 7 minimizes the likelihaad af passible biaaccumulatian.
Currently, au 7 is available to. grazing cattle an TEAD-N but is nat available far hamegrawn
praduce; therefare, ha~egrawn praduce consumptian is nat considered a camplete pathway
far current land use canditians, but is far a future residential scenario..
. .
Because the graundwater is appraximately 300 feet belaw the surface at au 7 and the relative
immability af PCBs, PCDDs, and PCDFs in sail, the passibility af graundwater cantaminatian .
. fram au 7 sails is nat cansidered likely. The results af vadase zane cantaminant fate and
transpart madeling canfIrm this. In additian, PCB sail cleanup levels based an direct cantact
assumptians will generally pravide sufficient pratectian af graundwater. .
4.1.3 Summary of Risks
4.1.3.1 Human Health
Patential human health effects assaciated with the nan-remediated site were evaluated to.
pravide a baseline risk to. determine if remediatian was necessary accarding to. EP A guidelines.
The evaluatian began with identifIcatian af chemicals present at the site that pase a patential
risk to. human health based an their prevalence and cancentratian in the enviranment and their
inherent taxicity. Far au 7, risks were assessed using PCB cancentratians faund during the
RI (see Sectian 7.1.3 af the Final Remedial Investigation Report for Operable Units 4-10).
Next, a taxicity assessment was canducted to. estimate the relatianship betWeen the ext~nt af .
expasure to. a cantaminant and the increased likelihaad andlar severity af adverse effects. The
next step in the risk assessment was to. perfarm an expasure assessment to. evaluate pathways
by which humans cauld passibly cantact cantaminants. The fInal step cansisted af determining
the magnitude and prabability af current and future human health risks assaciated with the
identifIed cant~minants af cancern.
In canducting an assessment as described, the health effects, bath carcinagenic and nan-
carcinagenic, that cauld result fram all applicable expasures were evaluated. Far persannel
who. may be warking an au 7, effects that cauld result from direct expasure to. the
cantaminants as a result af the sail caming into. direct cantact with the skin, fram inadvertent
direct ingestian af the sail, ar fram inhaiatian af dust particles were evaluated. Expasure to.
the cant~minants far athers nat directly warking an au 7 was evaluated in tWo. ways: by
inhalatian af dust particles ariginating fram au 7 and by cansumptian af beef fram caws that
may have grazed an the site.
RODiS
-------
For comparison purposes, a hypothetical future case was calculated to show what might
happen if au 7 were released for public use and a residence was constructed next to the site.
For this case, additional health effects were evaluated, including consumption of vegetables
and fruit grown on site. . .
4.1.3.1.1 Noncarcinogenic Risk. Noncarcinogenic risks are calculated as follows: The
potential for noncarcinogenic health effects is estimated by comparing a daily intake of a
compound through a specific exposure route to a reference dose for that compound. The ratio
of the intake to reference dose for an individual chemical is termed tbe hazard quotient (HQ).
A HQ greater than 1 indicates the potential for adverse health effects, since the intake exceeds
the reference dose. A hazard index (HI) is calculated by adding all the HQs for a specific
pathway. A residual In of 1 or less means that, even without cleanup, insufficient
contamination exists to cause adverse noncancer health effects during a normal human lifetime. ,
Using the Rl-derived concentrations for PCBs in the soils on au 7, calculated cumulative
noncarcinogenic hazard levels for all current and future cases are less than 1. This means that,
even without cleanup, insufficient contamination exists to cause adverse non-cancer health
effects during a normal human lifetime.
4.1.3.1.2 Carcinogenic Risk. The excess lifetime cancer risk is the incremental increase in
the likelihood of getting cancer if exposed to site contaminants as compared to the probability
of that with no exposure to site contaminants. These cancer risks are stated as probabilities.
A risk of 1E-6 for example, represents the probability that one person in one million exposed
to a carcinogen over a lifetime of 70 years will develop cancer. The EPA has set a 1E-4 to
1E-6 risk range as the "point of departure" for taking action at a Superfund site.
Residual concentrations of PCBs, PCDDs, and PCDFs were found to be present at au 7.
However, because of the low contaminant concentrations detected and the extremely small area
of au 7, the threat to public health and the environment is small. Carcinogenic risk factors
for au 7 are within or below the risk range of lE-4 to 1E-6. Further, EPA Guidance on
Remedial Actions for Superfund Sites with PCB Contamination recommends that remedial
action be considered when PCB levels exceed 1 ppm for residential land use and 10 to 25 ppm
for industrial land use. An available data for au 7 indicate that soil contamination is below
the most stringent of these levels.
4.1.3.2 Ecological Risk
There is no indication that this area is a critical habitat for any endangered or threatened
species. The contaminants of concern-PCBs, dioxins, and furans-are toxic and tend to
bioaccumulate to varying degrees; however, the levels found were too low to cause any direct
toxic effects on wildlife. A model was used to evaluate the effects of bioaccumulation on
raptors by ingestion of smaJl mammals and birds. The contaminant 'levels at au 7 were found
to be lower than levels that would cause adverse effects in raptors or other wildlife.
RODiSept_1994
-------
4.1.4 Description of Alternatives
Six remedial alternatives were considered for this au. Applicable or relevant and appropriate
requirements (ARARs) for these alternatives are tabulated in Table 4-1. Also, refer to Section
5.1.8 of the Final Feasibility Study for Operable Units 5, 6, 7, and 10.
Alternative 1: No Action. Site soils would remain in place.
Alternative 2: Insti~utional Controls. This alternative does not involve active remediation;
site soils would be left in place. However, this alternative wo~d limit the potential for human
and fauna exposure to site contaminants by placing controls on access to the site. These
controls would include fences or other barriers, warning signs, and regular" surveillance. Deed
restrictions would be developed for future protection in the event the property were released to
the public. "
Alternative 3: Soil Cover. This alternative involves filling the excavation hole and placing a
10-inch-thick clean soil and 2-inch-thick gravel cover over the au. A 1O-"foot-by-10-footarea
was chosen for remediation. This conservatively covers the known areas of contamination.
This alternative does not involve active remediation; site soils would be left in place beneath
the cover. However, this alternative would reduce the potential for human and fauna exposure
to site cont~minants and possible stumbling hazards by placing a soil cover over the area. It
would also comply with current TSCA standards for back-filling excavated spill areas with .
clean soil. . "
Alternative 4: Stabilization. This alternative involves mixing the contaminated soil with a
solidifying agent such as. cement. Hardening of the solidifying agent binds and reduces the
mobility of the soil contaminants. Stabilization can either be done in situ or in an external
mixing vessel. There would be an overall volume increase. The soils would be left in place,
but relatively immobilized.
Alternative 5: Landrill Disposal. This alternative involves excavation of contaminated soil
and hauling it to a TSCA-approved disposal site. Clean soil from TEAD-N would be used to
backfill the excavation. For au 7, a volume of 20 cubic yards (10 feet by 10 feet by 6 feet
deep minus the volume of the existing excavation) was used for remediation estimate purposes.
Alternative 6: Incineration. This alternative involves excavation of 20 cubic yards of
potentially cont~minated soil and hauling it to a TSCA-approved site for incineration. Clean
soil from TEAD-N would be used to backfill the excavation.
4.1.5 Summary of the Comparative Analysis of Alternatives
Table 4-2 provides a comparative analysis of Alternatives 1 through 6 for au 7. Each
alternative is discussed in more detail in Section 5.1.9 of the Feasibility Study for Operable
Units 5, 6, 7, and 10.
ROD/Scptc:mber 1994
-------
:oJ
0
i Table 4-1. Compliance of Alternatives with ARARs for OU 7
Alternative 1: No Alternative 2: Alternative 3: Soil Alternative 4: Alternative 5: TSCA Alternative 6: ARAR
:;; Action Institutional Controls Cover Stabilization Approved LandnI Incineration Category
'"
... Disposal
Statute Meets Does Not Meets Does Not Meets Does Not Meets Does Not Meets Does Not Meets Does Not
Slds. Meel Slds. Slds. Meet Stds. Stds. Meet Slds. Stds. Meet Stds. Slds. Meet Stds. Stds. Meet Stds.
TSCA-Soils X X X X X X Chemical
Specific
EPA PCD Guidance- X. X. X.. X. X. X. Chemical
Soils Specific
OSHA NA X X X X X Action
. Specific
Utah Air Conservation NA NA X.. X" X.. X.. Action
Act Specific
Utah Solid & NA NA NA NA X X Action
Hazardous Waste Act Specific
~
I Utah Solid Waste NA NA NA NA X X Chemical
.......
w Mgmt.Act Specific
Safe Drinking Water X X X X X X Chemical
Act (MCLs) Specific
40 CFR Part 268 NA NA NA NA NA X Action
Landfill Disposal Specific
Utah .Groundwater X X X X X X Chemical
Protection Rule Specific
Utah Safe Drinking X X X X X X Chemical
Waler Act (MCLs) Specific
Hazardous Materials NA NA. NA . NA X X Action
Transport Act Specific
.=10 be considered (TDC)
.**=action-specilic. would apply during cleanup
-------
~ Table 4-2. Comparative Analysis of Remedial Alternatives for OU 7
~
i Criterion Alternative 1: No Action Alternative 2: Institutional Alternative 3: SOU Cover Alternative 4: Stabilization Alternative 5: Landfill Alternative 6:
~ Controls Disposal Incineration
:0
'f
Overall Protection Meets the remedial-action Meets the remedial-action Meets the remedial-action Meets the remedial-action Meets the remedial-action Meets the remedial-action
objectives of protecting objectives of protecting objectives of protecting objectives of protecting objectives of protecting objectives of protecting
human health and the human health and the human health and the human health and the human health and the human health and the
environment. environment. environment. environment. environment. environment.
Compliance with Meets TSCA(b) and EPA Meets TSCA(b) and EPA Meets TSCA and EPA Meets TSCA(b) and EPA 'Meets TSCA and EPA Meets TSCA and EP A
ARARs(') standards for clean residual standards for clean residual standards for a clean soil of standards for clean residual standards for a clean soil standards for a clean soil
soils of less than 1 mg/kg' soils of less than 1 mg/kg l~ss than 1 mg/kg PCBs. soils of less than 1 mg/kg of less than 1 mg/kg of less than 1 mg/kg
PCBs. However does not PCBs. However does not Would comply with TSCA PCBs. However does not PCBs. Would meet PCBs. Would meet
meet TSCA requirements for meet TSCA requirements for requirement to fill excavated meet TSCA requirements for OSHA requirements for OSHA requirements for
clean soil fill material. clean soil fill material. spill area with clean soil. clean soil fill material. worker health and safety worker health and safety
Meets $DW A MCLs. Would meet OSHNe) Would meet OSHA Would meet OSHA during implementation. during implementation.
requirements for worker requirements for worker requirements for worker Also meets State and Also meets State and
health and safety during healtl.t and safety during health and safety during Federal Land Disposal Federal Land Disposal
implementation. Meets implementation. Meets implementation. Meets and Hazard Waste and Hazardous Waste
SDW A MCLs. SDW A MCLs. SDW A MCLs. Handling regulations. Handling regulations.
Meets SDW A MCLs. Meets SDW A MCLs.
~ Long-Term Would meet the remediation Would meet the remediation Would meet the remediation Wonld meet the remediation Would meet the Would meet the
I Effectiveness goals of limiting the. goals.of limiting the goals of limiting the goals of limiting the remediation goals of remediation goals of
-
~ cumulative excess cancer cumulative excess cancer cumulative excess cancer cumulative excess cancer limiting the cumulative limiting the cumulative
risk to human receptors to risk to human receptors to risk to human receptors to risk to human receptors to excess cancer risk to excess cancer risk to
levels within or below the levels within or below the levels within or below the levels within or below the human receptors to levels hnman receptors to levels
EPA target range for EPA target range for EPA target range for EPA target range for within or below the EPA within or below the EPA
residual risk of 1 E.4 to 1 E-6 residual risk of I E-4 to I E-6 residual risk of I E-4 to 1 E-6 residual risk of lE.4 to lE-6 target range for residual target range for residual
and limiting the cumulative and limiting the cumulative and limiting the cumulative and limiting the cumulative risk of I E-4 to lE-6 and risk of I E-4 to I E-6 and
noncancer hazard index to noncancer hazard index to noncancer hazard index to noncancer hazard index to limiting the cumulative limiting the cumulative
levels of 1- or less. The levels of I or less. The levels of I or less. The levels of I or less. The noncancer hazard index to noncancer hazard index to
qualit;lIive risk to ecological qualitative risk to ecological qualitative risk to ecological qualitative risk to ecological levels of I or less. TIte levels of 1 or less. The
receptors would be low. receptors would be low. receptors would be low. receptors would be low. qualitative risk to qualitative risk to
ecological receptors ecological receptors
would be low. would be low.
Reduction of There is no reduction of the There' is no reduction of the There is no reduction of the TIlere is no reduction of There is no reduction of Toxicity and mobility of
Toxicity, toxicity. mobility, or volume toxicity, mobility, or volume toxicity. mobility. or volume toxicity with this treatment. the toxicity, mobility, or contamination are
Mobility, and of soil contaminants through of soil contaminants through of soil contaminants through Mobility of contaminants is volume of soil permanently removed by
Volume treatment under this treatment under this treatment under this significantly reduced. There contaminants through this alternative. Waste
alternative. alternative. alternative. is an overall increase in treatment under this volume is unchanged.
volume due to the addition alternative.
-------
~
~
i
~
i
Criterion
Alternative 1: No Action
Table 4-2. Comparative Analysis of Remedial Alternatives for OU 7 (continued)
Alternative 4: Stabilization
Short- Tenn
, Effectiveness
There are no short-tenn
hazards to human health or
the environment associated
with this allernative.
Implementability
lllere are no
implementability concerns.
No cost.
Cost
State Acceptance NNQ
t'
t-O
VI Community NA
Acceptance
Alternative 2: Institutional
Controls
Health concerns are the
construction hazards
associated with installation
of a fence or other barrier.
No disruption of wildlife is
expected.
Readily
implementable.
Capital: $3,800
O&M/yrd): $400
PW(') @ 5%: $6,200
Total: $10,000
NA
NA
'ARARs=Applicable or Relevant and Appropriate Requirements.
"TSCA=Toxic Substances Control Act.
'QSHA=Occupational Safety and Health Act.
dO&M/yr=operation and maintenance/year.
'PW=present worth.
'NA=not applicable.
Alternative 3: SOU Cover
Health concerns are the
construction hazards
associated with installation
of the soil cover.
Temporary disruption of
wildlife may occur during
construction.
Readily
implementable.
Capital: $850
O&M/yr: 0
PW@ 5%: 0
Total: $850
The State of Utah 'concurs
with the selection of
Allernative 3.
As outlined in the
Responsiveness Summary,
public comments have been
addressed and, where
appropriate, incorporated
into the selected remedy.
Health con~erns are the
construction hazards
associated with the
stabilization process.
Temporary disruption of
wildlife may occur during
stabilization.
Readily
implementable.
Capital: $2,700
O&M/yr: 0
PW@5%: 0
Total: $2,700
NA
NA
Alternative 5: LandfiU
Disposal
Health concerns are the
construction hazards
associated with the soil
removal, haulage, and
backfill. Temporary ,
disruption of wildlife may
occur during
construction.
Readily implementable.
Capital: $2,600
O&M/yr: 0
PW@5%: 0
Total: $2,600
NA
NA
Alternative 6:
Incineration
Health concerns are the
construction hazards
associated with the soil
removal; haulage, and
backfill. Temporary
disruption of wildlife may
occur during
construction.
Readily implementable.
Capital: $41,000
O&M/yr: 0
PW@5%: 0
Total: $41,000
NA
-------
4.1.6 Selected Remedy
The selected remedy for OU 7 SWMU 5 is Alternative 3: Soil Cover. Based upon current
information, this alternative provides the best balance of trade-offs when evaluated against the
nine EP A criteria as follows:
Overall protection of human health and the environment. This alternative meets the
remedial-action objectives.
Compliance with ARARs. This alternative meets the EPA guidance and the TSCA standard
for clean soil of less than 1 mg/kg PCBs and current TSCA standards for back-filling
excavated spill areas with clean soil. This alternative would also comply with Occupational
Safety and Health Administration (OSHA) requirements for worker health and safety dunng
the installation of the soil cover. The Utah Air Conservation Act would be the action-specific
ARAR to regulate fugitive dust and particulates. Federal and Utah drinking water maximum
contaminant levels (MCLs) are met by this alternative.
Long-term effectiveness and permanence. The baseline risk assessment indicates that the
residual risk for this alternative would meet the remediation goals of limiting the cumulative
excess cancer risk to human receptors to levels within or below the EP A target range for
residual risk of 1E-4 to 1E-6 and limiting the cumulative noncancer hazard index to levels of 1
or less. By placing a clean soil cover on the site, this alternative could exceed the remediation
goals by further reducing the residual excess cancer risk to on-site workers, current on-site
residents, and current off-site residents. The qualitative ecological risk assessment also
indicates that the potential risk to ecological receptors would be low. The installation of a soil
cover is not expected to negatively impact the environment.
Reduction of toxicity, mobility, or volume through treatment. There is no reduction of the
toxicity or volume of soil contaminants through treatment under this alternative~ Mobility of
windblown soil that may contain adsorbed PCBs would be reduced by this alterative.
Short-term effectiveness. Human health concern associated with the implementation of this
alternative are limited to the construction hazards to personnel involved with the installation of
the soil cover at the site. The implementation time would be sufficiently short (less than r
week), so that the health risk due to potential exposure to site contaminants would be
negligible. Wildlife may be temporarily disturbed by the construction activities.
Implementability. The placement of a soil cover over the site involves simple construction
activities. Contractors are readily available, so this alternative is readily implementable.
Cost. Costs for the selected remedy are summarized in Table 4-3.
RODlSeptembcr 1994
-------
Table 4-3. Total Capital Costs
Remedial Component
1. Haul and Place Soil
Units Unit Cost
6.5 CY 21
65 CY 2
5CY 9
1 400
Cost
. $135
13
2. Compact
3. Haul and Place Gravel
4. Sample and PCB Analysis
5. Indirects at 10 percent
6. Contingencies at 30 percent
Total Costs
Note.-There are no annua,l operatipg or maintenance costs for this alternative.
45
400
59
198
$850
4.1.7 Statutory Determinations
. .
The selected remedy, fill and cover the spill site with clean soil, meets the statutory
requirements of CERCLA Section 121 as follows:
Be protective of human health and the environment. Covering the spill area with clean soil
will result in human health risks within or below EPA guidelines. The remedy will also result
in acceptable ecological/wildlife risks.
Comply with ARARs. The selected remedy will comply with all state and federal ARARs .
and to-be-considered issues as follows:
.
Toxic Substances Control Act
-40 CFR 761
EP A PCB Guidance-Soils
-EPN$40/0-90 007
Occupational Health and Safety Act
-29 CFR 1910.120 Hazardous Waste Operations
Utah Air Conservation Act 19-2-101
Safe Drinking Water Act
Utah Groundwater Protection Rule
Utah Safe Drinking Water Act
.
.
.
.
.
.
Cost Effectiveness. The selected remedy is the least costly alternative other than No Action,
which does nothing to reduce risks to human health and the environment. .
Utilization of Permanent Solutions and Alternative Treatment to the Maximum Extent
Possible. Covering the site is a practically permanent solution. The small size of the spill
ROD/August 5,1994
-------
area and very low contaminant concentration levels do not make alternative treatments
practical. .
The selected remedy represents the best trade-off of evaluation criteria as shown in Table 4-2.
The remedy is permanently effective ~d reduces mobility of the contaminants. Health and
environmental concern over the short term are negligible because the implementation time is
very short. Labor and equipment are immediately available to implement the remedy. The
public health! environment cost benefit ratio is determined to be the lowest of the evaluated
alternatives.
State and local community review of the information, which has gone into preparation of the
Administrative Record for au 7, has all been favorable toward the selected remedy.
.. .
RODIAugusl 5,1994
-------
Section 5
Record of Decision for Operable Unit 10 .
ROCfAugusl S, 1994
-------
DECLARATION OF THE RECORD OF DECISION FOR OPERABLE UNIT 10
Operable Unit Name .and Location
OU 10 consists of the Box Elder Wash Drum Site (SWMU 41) located in the north-central
section of TEAD-N, Tooele, Utah.
Statement of Basis and Purpose
This decision document records the selected remedy for OU 10 at TEAD-N. The action was
chosen in accordance with CERCLA as amended by SARA, and to the extent practicable, the
NCP. The decision is based upon the Administrative Record for this OU.
The EP A and the State of Utah concur with the selected remedy.
Assessment of the SWMU
Actual or potential releases of hazardous substances from the drums on this. site, if not
addressed by implementing the response selected in this ROD, may present a threat to public
health, welfare, or the environment. .
Description of the Selected Remedy
The functi~n of the remedy selected for this OU is to remove the source of possible soil,
surface water, and groundwater contamination that may occur because of the presence of 21
drums previously dumped into Box Elder Wash. The remedy.addresses the removal of these
drums and cleanup of areas where the contents of the drums have spilled onto the. ground.
The components of the remedy are:
.
Prepare and remove drums
Remove small areas of stained soil
Characterize waste materials
Incinerate drummed materials
.
.
.
Declaration Statement
The selected remedy is 'protective of human health and the environment, complies with federal
and state requirements that are legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. The remedy utilizes permanent solutions and alternative
ROD/Scptember1994
-------
treatment technologies to the maximum extent practicable for this site. Because this remedy
will not result in hazardous substances remaining on site above health-based levels, a 5-year
review will not be required for this site.
ROD/August S,1994
-------
Signature and Support Agency Acceptance of the Remedy
RODIAugust S, 1994
Date
Jesse L. Brokenburr
COL,OD
Commanding
Tooele Army Depot
-------
SEP-29-1994
13:S4FROM
5141 L£-t::iUH
IU
"::I.1~'.:;1<'I'(:>:>::I
r-.~
SiaJl~ :md SU1)port ~C1 A~p{~~ of the Rmned-v .'
- ~, lv~
q !2-r{1j
Lewis D. W31k£r
Deputy Assistmtt ~~wiy of the Army
~, Safety, and. Qecnpa!iomd Health)
Dm
,
accr-.-So.,,"
s-s
-------
Signature and Support Agencv Acceptance of the Remedv .
.' '
7/.2 9/91
Date
William P. Yellowtail
Regional Administrator,
Region vm, USEP A
5-6
-------
_wr, "",VI" wr-.
---~. ---..
~ --..., --v
Signature and Support Afen~ Acrf'.Pt~nce of the Remedy
Tooele Army Depot - North Area, Record of Decision
. For Operab1 e Unit IO
.
.
~S?k
. DiamleR. Ni~n, Ph.D.
Executive Director
Utah Department .of Environmental Quality
3o.~HY
Date
5-7
-------
. .5.0 DECISION SUMMARY FOR OPERABLE UNIT 10
5.1 SCOPE AND ROLE OF OPERABLE UNIT 10
Operable Unit 10, which consists solely of SWMU 41, is an area containing 21 drums dumped
in the bottom of Box Elder Wash. Action on this OU will be to protect human health and the
environment from possible risks due to current or future exposure to contaminants.
5.1.1 Description
SWMU 41, the Box Elder Wash Drum Site, is located southeast of row J of the Igloo Storage
Area in the north-central section of TEAD-N (Figure 5-1). The site consists of 21 drums
located in the wash, which carries intermittent runoff from the southwestern comer of TEAD-
N, north through the facility, and across the north-central TEAD-N boundary.
5.1.2 Characteristics
Operable Unit 10 (SWMU 41) was created when 21 drums were dumped off the eastern edge
of Box Elder Wash into the lower bank and bottom of the wash. The drums are present in an
approximately 200-foot-Iong stretch of the wash. Most of the drums are at least partially
obscured by soil and/or vegetation. The soil cover appears to have resulted from.
sedimentation during periods of surface-water flow and from caving of the steep wash bank.
The drums are in various stages of deterioration and have no obvious markings. The drums
contain a substance that resembles roofmg tar. There are small areas of stained soil and one
area of a surface tar spill above the wash channel.
In April 1989, TEAD Environmental Management Office personnel collected samples from
four of the open drums at the site. The samples were analyzed for certain organic compounds
and for the characteristic of extraction procedure (EP) toxicity for selected.metals. In addition
to indicating the presence of several complex organic compounds, the analyses indicated that
mercury was present in one sample at the minimum regulatory level for designation as a
hazardous waste.
The scope of the Remedial Investigation included locating all of the drums, sampling of eight
representative drums, sampling soils surrounding and downstream from the drums, and taking
a biased sample at a tar spill above the wash. Analyses of the drums showed that they
contained varying amounts of volatile organics, explosives, metals, and anions. However,
toxicity characteristic leaching procedure (TCLP) analyses for metals of samples from the
drums did not show any levels of leachable metals characteristic of hazardous waste. Soil
samples indicated little, if any, contamination. One sample downstream of the drums showed
a low concentration of pyrene. The biased sample collected from a small tar spill above the
wash showed a concentration of nickel that exceeded background concentrations.
RODIAugllstS,1994
-------
. '.
.
!
~
~
-,-"""'--......_--
/'~
/'
"
-'"'
Legend
~ INTERPRETIVE GROUNDWATER
~ FLOW DIRECTION
~-'~ ~6~~~m~i~TREAM
RAILROAD TRACKS
- - 4620- - TOPOGRAPHIC CONTOURS
IN FEET (MSU
o
400
SCAI..E IN FEET
IAPPROX. )
800
1682HP40 . DGN
Figure 5-1. Location Map of au 10, Box Elder Wash Drum Site (SWMU 41)
ROD/August S, 1994
5-9
.~
~
-------
The drums are believed to be the only source of contamination at the site. An analysis has
indicated that mercury was present in the drummed material at levels designated by the EP A as
hazardous. All available analyses show that the drums contain a complex mixture of organic
and inorganic compounds. The removal of these drums and any visibly contaminated soils will
prevent any further spread of these contaminants to soils and water media.
For soils in Box Elder Wash, pyrene is a potential contaminant of concern, although it has
been detected only in 1 of 13 samples at a low level. PYrene strongly adsorbs to soil and is
resistant to leaching. Pyrene exhibits low volatility, although it may enter the atmosPhere
through adsorption to airborne particles. Leaching of pyrene to groundwater at au 10 is
highly unlikely because the depth to groundwater is approximately 180 feet, the concentration
of the contaminant is low, and pyrene has a strong adherence to soils. For soils that have been
contaminated by material spilled from the drums, nickel could be a potential contaminant of
concern if the soils were not removed. Nickel was detected in the sample taken from a tar
spill above the wash. The elevated nickel in this sample reflects the nickel concentrations
found in the drummed material. Nickel is not present above the method reporting limits in any
of the soil samples collected from soils in the wash. ..
The most likely exposure pathways at au 10 are via dermal contact, incidental soil ingestion,
inhalation of fugitive dust, and ingestion of beef derived from cattle potentially exposed to
cont;!mination while grazing at TEAD-N. However, fugitive dust emissions from au 10 are
mii1imal because vegetative cover at this site limits potential dust emissions and au 10 is
located in a wash below ground surface. .
Although pyrene is not appreciably taken up by plants, it does bioconcentrate in tissue because
of its stability; high lipid solubility andlor binding, and low water solubility. The overall
potential for pyrene to bioaccumulate at au 10 is minimal because of the low concentration
detected and the infrequency of detection.
Currently, au 10 is available to grazing cattle on TEAD-N but is not available for
homegrown produce; therefore, homegrown produce consumption was not considered a
complete pathway for current land use conditions but was for a future residential scenario.
5.1.3 Summary of Risks
5.1.3.1 Human Health
Potential human health effects associated with the non-remediated site were evaluated in order
to provide a baseline risk to determine if remediation was necessary according to EP A
guidelInes. The evaluation began with identification of chemicals present at the site that pose a
potential risk to human health based on their prevalence and concentration ~ the environment
and their inherent toxicity. Risks for au 10 were assessed based upon reported pyrene in soil
concentrations, assuming that the drums will be removed.
ROC/August S, 1994
-------
Next, a toxicity assessment was conducted to estimate the relationship between the extent of
exposure to a contaminant and the increased likelihood and/or severity of adverse effects.
.
The next step in the risk assessment was to perform an exposure assessment to evaluate
pathways by which humans could possibly contact contaminants. The fInal step consisted of
determining the m,agnitude and probability of current and future human health risks associated
with the identifIed contaminants of concern. Both carcinogenic and noncarcinogenic risks
were evaluated.
The baseline risk assessment for au 10 was designed to estimate the human health and
environmental problems that could result if the drums were removed but soil contamination
were not cleaned up. For personnel who may be working on the SWMU, effects that could
result from direct exposure to the contaminants as a result of the soil coming into direct contact
with the skin, from inadvertent direct ingestion of the soil, or from inhalation of dust particles
were evaluated. Exposure to the contaminants for others not directly working on au 10 was
evaluated in two ways: by inhalation of dust particles originating from au 10 and by
consumption of beef from cows that may have grazed on the site.
For comparison purposes, a hypothetical future case was calculated to show what might
happen if au 10 were released for public use and a residence was constructed on the site. For,
this case, additional health effects were evaluated, including consumption of vegetables and
fruit grown on site. '
5.1.3.1.1 Noncarcinogenic Risk. Noncarcinogenic risks are calculated as follows: The
potential for noncarcinogenic health effects is estimated by comparing a daily intake of a
compound through a specifIc exposure route to a reference dose for that compound. The ratio
of the intake to reference dose for an individual chemical is termed the hazard quotient (HQ).
A HQ greater than 1 indicates the potential for adverse health effects, since the intake exceeds
the reference dose. A hazard index (HI) is calculated by adding all the HQs for a specifIc
pathway. A residual m of 1 or-less means that, ,even without cleanup, insufficient
contamination 'exists ,to cause adverse noncancer health effects during a normal human lifetime.
For all current and future use cases evaluated for post drum removal, calculated non-cancer
hazard levels are less than 1. This means that, even without cleanup other than drum removal,
insufficient contamination exists to cause adverse noncancer he~lth effects during a normal
human lifetime.
5.1.3.1.2 Carcinogenic Risk. The excess lifetime cancer risk is the incremental increase in
the likelihood of getting cancer if exposed to site contaminants as compared to th~ probability
of that with no exposure to site contaminants. These cancer risks are stated as probabilities.
A risk of lE-6 for example, represents the probability that , one person in one million exposed
to a carcinogen over a lifetime of 70 years will develop cancer. The EPA has set a lE-4 to
lE-6 risk range as the "point of departure" for taking action at a Superfund site. Evaluation of
RO~I_1994
-------
risks attributable.to OU 10 after removal of the drums shows that all cancer risks calculated for
current use c~nditions as well as the hypothetical futUre.case fall below the risk range.
5.1.3.2 Ecological Risk
OU 10 (SWMU 41) was also evaluated qualitatively for ecological risks. The primary
contaminant of concern at this site is pyrene. While pyrene has a potentially high biological
hazard because of its toxicity and propensity to bioaccumulate, the overall risk at OU 10 is
considered low because pyrene was detected at a low level in only one sample.
..
.Several chemicals of concern were identified for the material in the drums at this site. These
chemicals could be of concern to wildlife if they come into contact with these contaminants.
Small mammals frequently burrow, nest, or otherwise utilize habitat formed by natUral rock
cairns, felled trees, or shrubs-,-.as well as manmade form,ations such as piles of trash, lumber,
etc. In this case, sman mammals may utilize habitat created by the drums, thereby being
exposed to these contaminants. Six of the contaminants identified within the drums are metals:
barium, cadmium, chromium, lead, mercury, and silver. These contaminants are known to
bioaccumulate to some degree, although there is evidence that they are eventUally eliIninated
or transformed to other metabolites. Additionally, these inorganic contaminants are known to
be toxic. Many of the other contaminants identified are also toxic and may bioaccumulate as.
well. Thus~ it is advisable that these drums and the associated contaminants be removed as
quickly as practicable in order to eliminate this source of environmental degradation.
ActUal or threatened releases of hazardous substances from the drums on this site, if not
addressed by implementing the response action selected in this ROD, may present a threat to
public health or the environment. .
5.1.4 Description of Alternatives
The drums.at OU 10 could pose a threat to human health and the environment. Once the
drums and stained soils are removed, the current condition of remaining soils would meet the
remediation goals. Fcmr remedial alternatives have been considered for this site.
Alternative 1: No Action. Site soils and the drums would remain in place.
Alternative 2: Institutional Controls. This alternative does not involve active remediation;
site soils and the drums would be left in place. However, this alternative would limit the
potential for human and fauna exposUre to site contaminants by placing controls on access to.
the site. These controls would include fences or other barriers, warning signs, and regular
surveillance. Deed restrictions would be developed for future protection in the event the
property were released to the public.
ROD/Septealbc:r 1994
-------
Alternative 3: Removal and Off-Site Incineration of Drums and StaiDed Soil. This
alternative includes the removal and off-site disposal of 21 drums and approximately 35 cubic
feet of visibly stained soil from OU 10. The material would be properly handled and
incinerated in'a permitted hazardous waste incinerator. The drums would be transported by
licensed hazardous waste handlers, utilizing manifests to track the shipment and the'receipt of
the waste by a licensed hazardous waste treatment, storage, and disposal facility. The
materials may require treatment as part of, or prior to, disposal. .
Alternative 4: Removal and Off-Site Landfill Disposal of Drums and Stained Soils. This '
alternative includes 'the removal and off-site disposal of 21 drums and approximately 35 cubic
feet of visibly stained soil from OU 10. The material would be properly handled and placed in
a permitted hazardous waste landf1ll. The material would be transported by licensed hazardous
waste handlers utilizing manifests to track the shipment and to track the receipt of the waste at
a licensed hazardous waste treatment, storage, and disposal facility. The materials may
require treatment as part of, or prior to, disposal.
Table 5-1 lists compliance of the four alternatives with ARARs. See also Section 6.1. 7 of the
Feasibility Study for Operable Units 5, 6, 7, and 10.
5.1.5 Summary of the Comparative Analysis of Alternatives
Table 5-2 provides a comparative analysis of Alternatives 1 through 4 for OU 10. Each
alternative is discussed in more detail in Section 6.1.8 of the Feasibility StUdy for Operable
Units 5, 6, 7,. and 10.
5.1.6 Selected Remedy
The preferred alternative for Operable Unit 10, SWMU 41, is Alternative 3: Removal and
Off-Site Incineration of Drums and Stained Soil. Based upon current information, this
alternative would provide the best balance of trade-offs when evaluated against the nine EP A
criteria as follows:
Overall protection of human health and the environment. This alternative meets the .
remedial action objectives for the drum contents and the stained soil and protects human health
and the environment.
Compliance with ARARs. This alternative would comply with federal and state ARARs for
removal, transportation, and disposal of the drums and stained soil at a hazardous waste
incinerator. The owner and operator of the h~dous waste disposal facility would take
responsibility for compliance with treatment, storage, and disposal requirements.
Long-term effectiveness and permanence. The baseline risk assessment indicates that the
residual risk for this alternative would meet the remediation goals of limiting human health
RODiScptembcr1994
-------
13 Table 5-1. Compliance of Alternatives. with ARARs for OU 10
~
1 Alternative 1: No Action Alternative 2: Institutional Alternative 3: Alternative 4: RCRA ARAR
~ Controls Incineration of Soil and Approved Landfill Category
:0
'" Drums Disposal
.
Statute Meets Stds. Does Not Meets Stds. Does Not Meets Stds. Does Not Meets Does Not
Meet Stds. . Meet Stds. Meet Stds. Meet
Stds. Stds.
OSHA NA X X X Action
Specific
Utah Air Conservation Act NA NA x* x* Action
Specific
. Utah Corrective Aciion Clean- X X X X Action
Up Standards Policy (UAC-R- Specific
315-101)
U1 Utah Transporter and Landfill NA NA X x** Action
I Disposal Standards (R315-1 Specific
......
.J:>. through -10)
Safe Drinking Water Act X X X X Chemical
(MCLs) Specific
40 CFR Part 268 Landfill NA NA X X** Action
Disposal Specific
40 CFR Part 264 TSD Stds. NA NA X X Action
Specific
Utah Groundwater Protection X X X X Chemical
Rule Specific
Utah Safe Drinking Water Act X X X X Chemical
(MCLs) Specific
Hazardous Material Transport NA NA X X Action
Act Specific'
NA=not applicable.
*=action-specific, would apply during cleanup.
-------
13
~
1
,!A
:g
..
Criterion
Alternative 1: No Action
Table 5-2. Comparative Analysis of Remedial Alternatives for Soils and Drums at au 10
Alternative 2: Institutional
Controls
Alternative 3: Removal
and Off-Site Incineration
of Drums and Stained
Soil
Alternative 4: Removal
and Off-Site Disposal of
Drums and Stained Soil
Overall Protection
Compliance with
ARARs(l)
VI
I
-
VI
Long-Term
Effectiveness
Does not meet the remedial-action
objectives of protecting human
health and the environment because
the drums would remain on site.
Does not comply with land disposal
restrictions because the drums
contain potentbilly hazardous
waste.
Would meet the remediation goals
for soil of limiting the cumulative
excess cancer risk to hum.,n
receptors to levels within or below
the EP A target range for residual
risk of lE-4 to lE-6 and limiting
the cumulative noncancer hazard
index to levels of 1 or less. TIle
drum contents pose a threat to
potential ecological receptors.
Does not meet the remedial-action
objectives of protecting human
health and the environment
because the dnuns would remain
on site.
Does not comply with land
disposal restrictions because the
drums contain potentially
hazardous waste. Complies with
OSHA (b) requirements for worker
health and safety during
- implementation.
. Would meet the remediation goals
. for soil of limiting the cumulative
excess cancer risk to human
receptors to levels within or
below the EP A target range for
residual risk of lE-4 to lE-6 and
limiting the cumulative noncancer
hazard index to levels of 1 or less.
The drum contents pose a threat
to pOlential ecological receptors.
Meets the remedial-action
objectives of protecting
human health and the .
environment.
Complies with ARARs for
transport of the drums to
an off-site hazardous waste
(Jisposal facility. Complies
with OSHA requirements
for worker health and
safety during
implementation.
Would meet the -
remediation goals for soil
of limiting the cumulative
excess cancer risk to
human receptors to levels
below t1le EP A target
range for residual risk of
lE-4 to 1 E-6 and limiting
t1le cumulative noncancer
hazard index to levels of 1
or less. Would protect the
environment and eliminate
the need for long-term
management of the site
through the removal and
proper off-site disposal of
the 21 drums and stained
soil.
Meets me remedial-action
objectives of protecting'
human health and the -
environment.
Complies Wit11 ARARs
for transport of the drums
.to an off-site hazardous
waste disposal facility.
Complies with OSHA
requirements for worker
health and safety during
implementation.
Would meet the
remediation goals for soil
of limiting the cumulative
excess cancer risk to
human receptors to levels
below the EP A target
range for residual risk of
lE-4 to lE-6 and limiting.
the cumulative noncancer
hazard index to levels of 1
or less. Would protect.
the environment and
eliminate the need for
long-term management of
the site through the .
removal and proper off-
site disposal of the 21
drums and stained soil.
-------
Table 5-2. Comparative Analysis of Remedial Alternatives for Soils and Drums at OU 10 (continued)
:r>
0
~ Criterion Alternative 1: No Action Alternative 2: Institutional Alternative 3: Removal Alternative 4: Removal
i Controls and Off-Site Incineration and Off-Site Disposal of
~ of Drums and Stained Drums and Stained Soil
~
... Soil
Reduction of Toxicity, 111ere is no reduction of the There is no reduction of the Eliminates toxicity and There is no reduction of
Mobility, and Volume toxicity, mobility, or volume of toxicity, mobility, or volume of mobility of contaminants the toxicity, mobility, or .
contaminants in the soil or in the contaminants in the soil or in the through removal and off- volume of contaminants in
drum contents through treatment drum contents through treatment site disposal by the soil or in the drum
under. this alternative. under this alternative. incineration. There is no contents through treatment
reduction of waste volume under this alternative.
under this alternative.
Short-Term There are no short-term hazards to Health concerns are the Health concerns are the Health concerns are the
Effectiveness human health or the environment. construction hazards associated physical hazards associated physical hazards
associated with this alternative. with installation of a fence or with the removal and off- associated with the
other barrier. Wildlife may be site transport of the drums removal and off-site
temporarily disturbed by the and soil. Wildlife may be transport of the drums and
VI construction activities. temporarily disturbed soil. Wildlife may be
I during removal and temporarily disturbed
,....
0\ shipment of the drums. during removal and
shipment of the soil.
Implementability No implementability concerns. Readily implementable. Readily implementable. Readily implementable.
Cost No cost. Capital: $19,500 Capital: $222,000 Capital: $193,000
O&M(C)/yr: $500 O&M/yr: 0 O&M/yr: 0
PW(d) @ 5%: $7,700 Total: $222,000 Total: $193,000
Total: $27,200
State Acceptance NA(c) NA The State of Utah concurs NA
with the selection of
-------
Alternative 1: No Action
Table 5-2. Comparative Analysis of Remedial Alternatives for Soils and Drums at OU 10 (continued)
Criterion
Alternative 2: Institutional -
Controls
Alternative 3: Removal
and Off-Site Incineration
of Drums and Stained
Soil
Alternative 4: Removal
and Off-Site Disposal of
Drums and Stained Soil
Community Acceptance
NA
NA
NA
"ARARs=Applicable or Relevant and Appropriate Requirements.
bOSHA=Occupational Safety and Health Act.
'O&M/yr=operation and maintenance per year.
dPW=present worth.
eNA=not applicable.
VI
I
.....
--..1
As outlinr.d in the
Responsiveness Summary
for au to, public
comments have been
addressed and, where
appropriate, incorporated
-------
risks to c1.lrrent human receptors to below EPA target levels. The qualitative ecological risk
assessment also indicates that potential risk to ecological receptors would be low. By
removing the 21 drums and stained soil, this alternative eliminates the need for long-term
management of the site.
Reduction of toxicity, 'mobility or volume through treatment. This alternative provides
permanent reductions in the toxicity, mobility, and volume of the drum contents and stained
, soil through incineration.
Short-term effectiveness. Human health concerns associated with the implementation of this
alternative are limited to personnel subject to physical hazards involved with the removal and '
off-site transport of the drums. The implementation time would be very short, so that the
health risk due to potential exposure to site contaminants would be negligible. Personal
protective equipment would be utilized in packaging the drums for disposal.
Implementability. Hazardous waste removal and disposal services for the 21 drums and 5
drums of contaminated soil are readily available in the Tooele area.
Cost. Costs for the selected remedy are summarized in Table 5-3.
Table 5-3. Total Capital Costs
Remedial Component
Units
Unit Cost
Cost
1. Prepare and remove drums
2. Haul to LandfIll
3. Characterize wastes
4. Incinerate drums
5. Indirects @ 10%
6. Contingencies @ 30 %
26*
Lump Sum
2
26
$5,000
1,000
550
1,000
$130,000
1,000
1,100
26,000
, 16,000
48,000
Total Costs
Note.- There are no annual operating or maintenance costs for this alternative. , '
*The 21 drums in the wash plus 5 drums of stained soil.
$222,000 '
5.1.7 Statutory Determinations
The selected remedy, removal and off-site disposal of drums and stained soil, meets the
statutory requirements of CERCLA Section 121 as follows:
Be protective of human health and the environment. Removal of the 21 drums and 5
drums of stained soil will result in human health risks below EPA guidelines.
RODlSeptembcr 1994
-------
Short-term risks.from implementation of this remedy would be negligible because of the very
short time frame required for drum removal and because appropriate prrsonal protective
equipment would be used during drum handling.
Comply with ARARs. The selected remedy will comply with all state and federal ARARs as
follows:
.
Utah Solid and Hazardous Waste Act 19-6-101 et seq.
- Citation R315-101
Sets standards for cleanups
Utah Solid Waste Management Act 19-6-501 et seq.
- Citation R315-30l
Sets standards for disposal and incineration facility
siting and operation
Citation R315-101.
Sets standards for cleanups
Occupational Health and Safety Act
- 29 CFR 1910.120 Hazardous Waste Operations
Utah Air Conservation Act 19-2-101
Resource Conservation and Recovery Act
- 40 CFR 264 Standards for Owners and Operators of
Hazardous Waste Treatment, Storage, and Disposal
Facilities
40 CFR 268.50 Prohibitions on Storage of Restricted
Wastes
Safe Drinking Water Act
Utah Safe Drinking Water Act
Utah Ground Water Protection Rule
.
.
.
.
.
.
.
Cost-Effectiveness. The selected remedy, removal and off-site disposal of drums and stained
soil, appears to be the most cost-effective alternative evaluated for au 10. Alternatives 1 and
2, while less costly, do nothing to remove risks to human health and the environment.
Utilization of Permanent Solutions and Alternative Treatment to the Maximum Extent
Possible. The selected remedy to remove the drums and stained soils from Box Elder Wash.
and appropriately dispose of them permanently eliminates contamination that may result from
these materials ~d utilizes treatment to the maximum extent.
. .
The seleCted remedy represents the best trade-off of evaluation criteria as shown in Table 5-1
above.. The remedy is permanently effective and utilizes treatment technologies. The remedy
effectively eliminates toxicity, mobility, and volume of the contamination. Health and
environmental concerns over the short term are negligible because the implementation time for
the remedy is very short. Contractors are readily available in the Tooele area to implement the
selected remedy. The public health/environment cost benefit ratio is determined to be the
lowest of the evaluated alternatives.
ROD/Scp_1994
-------
The fact that hazardous waste disposal facilities exist near Tooele is the primary consideration
in choosing the drum and stained soil disposal remedy.
State and local community review of the information, which has gone into preparation of the
administrative record for au 10, has all been favorable toward the selected remedy.
ROClScpt- 1994
-------
.'
APPENDIX A
TRANSCRIPT OF TOOELE ARMY DEPOT PUBLIC MEETING
-------
Errata
Certain errors were made in the transcription of the public meeting. The following are
corrections for those errors.
Page
For
Read
2, line 11 Environmental and Emphasis Environment and Infrastructure
Structure
3, line 2 Hal Hunting Hal Dunning
5, line 20 calls called
9, line 8 formate format
10, line 3 compassitors capacitors
12, line 5 bums berms
12, line 11 . known none
17, line 24 TOSCA TSCA
18, lihe 1 (2 TOSCA TSCA
places)
-------
DISCUSSION:
DATE:
TIME:
, .
PLACE:
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MEUNDAJ.ANDERSEN
CSR No. 281
.TOOELE ARMY DEPOT
PUBLIC MEETING
Tooele Army Depot-North Area
CERCLA proposed plan for
Federal Facility Agreement
Operable units 5, 6, 7 and 10
June 2, 1994
7:00 p.m.
Toole County Courthouse
47 South Main Street
Tooele, Utah 84074
CERTIFIED COpy
INDEPENDENT REPORTING
SERVICE
1710 Beneficial Life Tower
36 Sou1h State Street.
Salt Lake City, Utah 84111
(801) 538-2333
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June 2, 1994
7:10 p.m.
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PRO C E E DIN G S
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MR. FISHER:
Good evening.
My name is Larry
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Fisher.
Ilm from the Tooele Army Depot Environmental
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Office.
I would like to welcome you tonight to the public
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meeting in which we will be discussing Tooele Army Depot's
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post plan for operable units 5, 6, 7 and 10.
The proposed
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plan actually presents the clean up options for six of the
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17 superfund sites out at Tooele Army Depot.
Tonight we have Mr. Bob Sanders from the RUST
Environmental and Emphasis Structure.
He will summarize
the results of our studies and present the chosen clean up
.options for the six sites at the depot.
Before we begin with the presentation I would
like to introduce some other people who are here with us
tonight and have been working for us at the depot on this
project.
We have Ms. Mary Ellen Maly.
She is from the
Army Environment in Aberdeen Proving Grounds~ which is an
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organiza~ion that helps the depots all across the country
with these studies and working on those projects.
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Basically the studies and the clean up of the superfund
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projects.
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I would also like to present the representatives
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from the Utah Department of Environmental Quality.
We have
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Mr. Terry Hawkins and we have Ms. Diane Simmons.
Also we
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have representatives from our regional EPA offices in
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Denver, Mr. Floyd Nichols and Mr. Hal Hunting.
They've
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been with us on this project also.
They watch us very
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closely as we go about our studies and our clean up and
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processes.
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If you haven't already signed our attendance
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roster, please do so.
It's right over there on the table.
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If you'll do that on the way out we would appreciate it.
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And also if you would like your name to be placed on the
mailing list there is a signup sheet over there also and
you'll be sent copies and documents and various things that
go along with our studies out at Tooele Army Depot.
And also please feel free to ask any questions
during the presentation tonight, or if you have any
comments or any discussion please feel free to interrupt at
any time.
Bob won't mind.
Please feel free to do that.
If there are no questions at this time what I
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would like to do is turn the time over to Mr. Bob Sanders.
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MR. SANDERS:
Good evening.
Tonight I will be
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discussing the process that we are following to .investigate
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several locations at the Tooele Army Depot.
In the past
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these locations have been associated with the use of some
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kind of hazardous materials.
Because of this use of
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hazardous materials the locations have been placed under
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the federal environmental regulations associated with
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superfund.
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The superfund process requires that a series of
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steps be performed in a very' vigorous manner to insure
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protection of the public health and the environment.
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My presentation this evening explains this
overall process and presents the results of the Army's
investigation of six of the 17 locations.
Now associated with this work there are a lot of
acronyms.
So what I'll do is on this overhead is a listing
of most of the acronyms that I'll be using tonight and also
their definitions.
Now like I mentioned, there are a lot
. of acronyms, so if you get confused you can refer back here
. when I mention OU, FSi NFL or that kind of thing.
The outline for the presentation tonight.
To
give you a little bit of the background we'll discuss the
remedial investigation/feasibility study process under
CERCLA or superfund, and then. we'll also get into the
specific actions that we're going to take which were
addressed in the proposed plan.
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Tooele Army Depot'was listed on the NFL, the
national priorities list, which is a list associated with
superfund of s.ites across the united States that are
considered to be contaminated with hazardous chemicals.
The listing followed a series of preliminary
investigations designed to determine the hazards associated
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with the installation out at Tooele.
A series of
calculations were performed and the installation was given
a hazard ranking score.
This hazard ranking score was
above the EPA minimum, and therefore Tooele Army Depot was
listed on the NFL.
Part of the superfund regulations require that
all federal facilities that are listed on the national
priorities list enter into what is known as a federal
facility agreement, or FFA, with the EPA, the environmental
protection agency, and also the state the facility is
located in.
In the case of Tooele this agreement was
entered into between EPA Region 8 and the state of utah' and
this was signed in September of 191.
The federal facility agreement outlines exactly
what each one of the respective parties have responsibility
for during this process.
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This federal facility agreement included 17
locations that were suspected of having hazardous
materials.
These 17 locations were grouped into seven
common areas calls operable units.
All seven operable
units were investigated by drilling monitoring wells,
taking soil samples, sediment samples, surface water
samples.
And then those samples were sent to a chemical
laboratory for analysis.
They were analyzed for. the
presence or absence of hazardous materials.
The
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iItEormation that was reca1veQ troll the 1nve&'t.lga.t.lon \ ~\:f
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~1yzed and'48ve1oped into a report called a remedial
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idvestigation report.
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Based on tha RI r8port it was decided that three
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011 the operable uni1:s, 4, 8 and 9, required more
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J4v~-t:1.qaticm before we. could carry 'them. fo~4 in 'thiA '
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Fcu:r of the operable un1 1;5 , 5, 6 I 7 and '10, are
PJlCcess.
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1Htinq carried on to t:he feasibility study, proposed plan
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,~ record of decision.
Part: of the .uper~lD1d ~rocesS'.
TJte record of dec1s'1on, wh1c11 1sn1t up here, i. Go leqal
dctcument thA~ is sioned between all parties, of the federal.
f(cili'ty agreement that has t:he final remedy for clea\'\-up
ot a siote i1 it 'is required.
Also based on the resu1ts of the RI report 1 t
'q1l ciecid.ec! ~t aore inv8.t:ivaUon ftCll8d.d ~o be performed.
ot't at '1'0081. north area to determine if any plants and
ati1d.ls vue at. risk.. ~ order to do this th~e is 901~g
t. be a site-wiet. quantitative ecolagicU risk ass8S&tGQn't
~opie4.
'MIls is a UP of 'the 'J!ooale Army Depot north
~ea 1:0 kind of orient yoU into where we're at here.
In
1:118 vicinity of this north ar~~ is ~era Ifooele, Ut:a1' is '
lbcated, and over here north of otJ 9 .1.. where GrantSv 1.11.8
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nut areas that 'I'. 901D9 to be talkiD9 about
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The ones that I mentioned
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that are going to be carried on for further investigation
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are the ones that are outlined in the yellow.
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The overall remedial investigation and
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feasibility process under superfund can really be broken
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down into three major steps.
The first step is a
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preliminary study of a location.
This involves record
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searches, discussions with employees that might be at the
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site, site walk overs and those types of things.
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The results of this study determine whether or
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not a site is listed on the superfund NPL.
That's really
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in these two blocks right here.
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If it's warranted in the first step, which is
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this part of the diagram, a more detailed study' is
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undertaken to determine the presence or absence of
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During this step actual monitoring
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. wells are drilled.
Once again samples of water, air and
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detailed series of reports.
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The outcome of this study results in detailed
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recommendations about the need for the clean up of any
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location.
The study also provides the basis for the
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completion of the third step, which is this one down here.
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The third step of the process is what we are really
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discussing tonight.
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This is the point in this whole process where a
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decision has been made as to the need of a location to be
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cleaned up.
And this step also evolves through remedial
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design and remedial action the implementation of the actual
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clean up through detailed engineering and public
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participation.
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To give everyone that's working in this area,
the EPA has developed some criteria that can be used or
that have to be used, I guess should say, in order for us
to determine if a clean up alternative is acceptable or
. not.
These nine criterias are listed on the overhead.
The first one, the clean up alternative that's
developed must be protective of human health and the
environment before it is acceptable.
The alternative must
also comply with all federal, state and local regulations.
This is referred to as applicable or relevant and
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appropriate requirements, ARARs.
The alternative must also
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provide for long-term effectiveness and also a permanent
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solution.
The alternative must reduce the toxicity,
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mobility and volume of the hazardous chemical.
The
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alternative must be effective in the short term as well as
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long term.
The alternative must be readily able to be
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implemented from both a cost and technical standpoint.
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alternative must be cost effective.
The alternative must
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have overall state and EPA acceptance.
And lastly, the
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alternative must also be accepted by the community.
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Really the item that we're discussing tonight is
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the proposed plan.
The detailed or the clean up
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alternatives that are developed during the detailed
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engineering phase of this process are placed into a report
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formate. called a proposed plan.
This p~oposed plan was
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developed to help the public participate in selecting the
remedy.
There are three main areas that the proposed
plan is involved with that identifies the preferred
. alternative from the FS.
It describes other alternatives
that were ~valuated during the feasibility study.
It
solicits public review and comment.
And the record of
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decision, which is the legal document that I mentioned
earlier, is based on the proposed plan and any comments
that are received from the public on the proposed plan.
with that little bit of background what I would
like to do now is get into the specific sites that we're
talking about that were included in the proposed plan.
The first site is the former transformer storage
area,
or location 1.7.
This was an open storage lot that is
gravel and covers approximately five acres.
This lot has
the size of about 350 by 600 feet.
One of the
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Tooele Army Depot north in" the past has
storage, maintenance and shipment of
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oil containing electrical transformers and compassitors.
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Prior to 1979 long-term storage of those
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compassitors and transformers happened at this site.
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Many
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of these transformers contain PCB contaminated oil.
In
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1979 all the transformers were removed from this location
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and either properly disposed of or transferred to the PCB
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storage area, building 659, which is the next site that
I'll talk about.
The potential of a PCB spill that might
have occurred in this area is the reason that this site was
listed as one of the locations under the federal facility
. agreement.
with that in mind the proposed plan that has
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been developed for this site is as follows:
The chemicals
that we expected to find, or as I'll say on all of these
overheads from this point forward, the contaminants of
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concern, were PCBs of this location.
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What was found is that the maximum concentration
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of PCBs at this location was a half a part per million.
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Now to put that into perspective, a part per million is
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like taking a teaspoon of water out of your swimming pool
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is what that's about equivalent to.
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The second thing is a risk assessment.
The EPA
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requires that a risk assessment be performed as part of thE
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entire process.
The outcome of the risk assessment is a
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determination of whether or not the location presents a
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hazard to human health or the environment.
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The EPA has come up actual values called the EPA
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target range.
In this case we were either within or below
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the EPA target range for the risk associated with this
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site.
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The next step that we followed was to evaluate
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the clean up alternatives.
There were six of them in this
case.
There was no action, which means we do nothing.
Institutional controls, which is you put a fence up around
the property or you restrict access.
We looked at a soil
cover, taking say a four inch protective soil cover over
the whole site.
We looked at stabilization.
That could be
as similar to mixing and pouring cement with the soil and
then stabilization will be accomplished.
The other two
that we looked at is disposal of the material in a
permitted off-site landfill and also disposal in a
permitted off-site incinerator.
When it was allover and done with, and the
alternatives were evaluated, it was determined that no
action in this case is the preferred alternative.
And in
fact this does meet the EPA criteria that I discussed
earlier.
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The next location is the PCB storage building
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659, location 33.
This building is currently being used to
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store transformers inside.
This facility was opened in
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1979 as I mentioned earlier and received the items that
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were removed from the storage lot.
The building is
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-equipped with burns inside and a sealed concrete floor to
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prevent any spills from being released in the environment.
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There was a concern that there may have been a .
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spill in the past, therefore this building was included as
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one of the locations under the .federal facili~y agreement.
The proposed plan for this location,
contaminants o! concern again were PCBs, but known were
found.
A risk assessment in this case because we didn't
find any PCBs was not performed.
And the only other
alternative that we evaluated was no action.
And because
of these two items this does meet the EPA criteria.
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The next area is the drummed radioactive waste
storage area, location 9.
This is a picture of location 9,
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this concrete building.
This building had one 55 gallon
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drum of material that contained gages and dials that had
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been painted with radium paint.
Now this type of material
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can be considered a low level radioactive waste, therefore
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the concern that maybe there was potential for
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contamination within this area caused it to be listed
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under the federal facility agreement.
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The proposed plan that's been developed for thi~
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location, a scan for radioactive materials was performed
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a~d we didn't find any.
Because of that no risk assessment
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was performed and the only alternative that we looked at in
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this case was no action.
And it does meet the EPA
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criteria.
The next location is the radioactive waste
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storage area, which is located ina small room inside
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building 659.
This room has been used in the past, and is
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also currently being used, to store radiation detection
meters, compasses, range finders and radioactive luminous
compounds.
These items can contain radioactive materials.
And the potential for a release to the environment at this
location caused this area to be listed under the federal
facility agreement.
The proposed plan for location 18, the
contaminants of concern were radioactive'materials.
A scan
was performed and none were found~
So here again, the risk
assessment, no evidence of contamination and,the
alternatives evaluated were no action.
And this does meet
the EPA criteria.
This is kind of an interesting site, the pole
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transformer PCB spill site.
Back in 1976 lighting struck,
this utility pole, started the pole on fire and caused the
transformer that was on the pole to spill on the soil
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below.
Unfortunately the oil in the transformer contained
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The installation immediately cleaned up this oil and
PCBs.
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disposed of the soil iIT an appropriate manner.
However,
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there is an approximately five foot by five foot by three
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foot deep whole that's still left around the utility pole
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and there was a concern that that may still contain some
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PCBs.
So it was included under the federal facility
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agreement.
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The contaminants of concern at this site were
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PCBs. as I mentioned because of the transformer spill.
Soil
samples were taken and we found maximum concentration of
.33 ppm.
A risk assessment was performed with this value
and it was determined that that is within or below the EPA
.target range.
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We evaluated more alternatives in this case. We
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evaluated the no action alternative, institutional
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controls, soil cover, stabilization, off-site landfill
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disposal and off-site incineration.
Through the detailed
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engineering the soil cover is the preferred alternative, .
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just cover up the hole, grade it and that type of thing.
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Th~s does meet the EPA criteria.
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The next site that we'll be talking about is the
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Box Elder Wash. site, location 41.
This is a little
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difficult to see.
But what this is, this is a picture at
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the bottom of this wash where 21 drums were dumped over the
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edge.
The drums are located in a 100 to 200 foot long
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stretch of the dry wash.
~~d as you can see -- well, it's
a little difficult -- most of the drums are covered with
soil or vegetation in most cases.
The drums contain a substance that resembles
roofing tar.
These drums could have been left over from
the construction of the igloos that were constructed out at
Tooele.
During construction of the igloos tar was actually
painted over the top of the concrete structures before they
were covered with soil.
The unknown nature of the contents
of the drums and stained soil that exists around the drums
caused these to be listed under the federal facility
agreement .-
The proposed plan for this location 41 -- as I
mentioned, we expected to find chemicals associated with
roofing tar, and that is what we found, chemicals expected
in roofing tar.
We found low levels of explosives in two
of the 21 drums.
We also found chemicals similar to the
roofing tar chemicals found in the drums and around each
one of the drums.
A risk assessment was performed at this
location.
And in this case if the drums and stained soil
are left in place they will represent a risk that is out of
the EPA target range.
So we evaluated four alternatives in
this case, no action again, institutional controls,
off-site incineration of both the drums and the stained
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soil, and then also removal to an off-site landfill of the
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drums and the stained soil.
In this case the preferred
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alternative balanced against all the EPA nine criterias
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turns out to be no. 3 or off-site incineration of the" drums
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and stained soil.
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This completes my presentation.
Larry already
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indicated to you about the signup sheets.
Also located in
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the back are copies of the presentation that I just gave,
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copies of the proposed plan, and we also have some copies
of the detailed engineering reports that I mentioned during
my presentation.
Are there any questions, comments or discussions
. that anybody would like to ask?
MR. KLINGER:
My name is Jeff Klinger.
I'm here
with Salt Lake community college.
I'm going through an
environmental hazardous training program.
I came to see
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the public hearing.
I was wondering who is doing the clean
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MR. SANDERS:
I'll defer that to Mary" Ellen.
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MS. MALY:
The clean up. will actually be
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performed by the Armed Corp of Engineers under contract.
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Since we're just in the proposed plan stage and still have
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to go through the formal record of decision, which is the
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legal document, we're proposing that that will probably be
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signed off by the Army regulatory agencies in October.
At I
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which point the corp of engineers will go ahead and start
the design and .actual implementation.
They will have to go
out and bid through a contractor.
So we don't know right
now.
There is currently is a clean up ongoing at the
depot at another site.
It's some ground water
contamination.
There is a pump and treating facility.
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think about 5,000 gallons of water per minute are being
extracted and treated then reinjected back into the ground
water.
Who is your contractor for that?
MR. FISHER:
Metcalf and Eddie out of
California.
MS. MALY:
There is currently several other
investigations that are ongoing at the depot both in the
north area and in the south area, and there are three other
contractors that are involved in those studies, Science
Applications International Corporation, Montgom~ry Watson
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and Insearch as well as RUST.
Quite a bit going on out
there.
MR. SANDERS:
Any other questions?
MR. FISHER:
I have a comment on my own
document.
In the proposed plan it mentions in 33, the PCB
storage building, that that was a TOSCA permitted facility.
That is not correct.
There are no permits required under
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TOSCA and I just wanted to make that clear.
It was a TOSCA
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regulated facility a "long time back when we had those
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transformers stored there and we are inspected under TOSCA
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regulations.
But as far as the no action site goes, yes,
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it was a no action site under CERCLA.
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MR. SANDERS:
Okay.
Thank you.
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(The public hearin9 concluded at 7:40 p.m.)
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1.
C E R T I F I CAT E
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STATE OF UTAH
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COUNTY OF SALT LAKE)
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I, Melinda J. Andersen certified Shorthand Reporter
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and Notary Public within and for the County of Salt Lake
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and State of utah, do hereby certify:
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'That the foregoing proceedings were taken before me
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at the time and place herein set forth, and were taken down
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by me in s~orthand and thereafter transcribed into
typewriting under my direction and supervision:
That the foregoing 1.8 pages contain a true and
correct'transcription of my shorthand notes so taken.
WITNESS MY HAND and official seal at Salt Lake City,
utah this 1.3th day of June, 1.994.
My commission expires:
December 9, 1.995 '
(L{ r:1u7{)~
J. An rsen, C.S.R.
()
NOTARY PUBUC
STATE OF UTAH
.. ~ .w... Es;iIII
0ICInIbIr8, 11111S
IIE1JI)A ... ANDERSEN
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T-'e, UIII 8A074
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