United States
Environmental Protection
Agency
Off ice of
Emergency and
Remedial Response
EPA/ROD/R10-93/055
December 1992
SEPA Superfund
Record of Decision:
UmatillaArmy Depot (Lagoons)
-------
50272-101
REPORT DOCUMENTATION ". REPORT NO. 2. 3. Reclplent'e Acca.lon No.
PAGE EPA/ROD/R10-93/055
4. Title and Subtitle 5. Report Date
SUPERFUND RECORD OF DECISION 12/31/92
Umatilla Army Depot (Lagoons) (Operable Unit 1), OR 6.
Second Remedial Action
7. Author(l) 8. Performing Orgenlzatlon Rept. No.
9. Performing Org.nlzatlon Name and Addr... 10 Project Ta.klWork Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Add..... 13. Type 0' Report. Period Covef8d
U.S. Environmental Protection Agency
401 M Street, S.W. 800/800
.Washington, D.C. 20460 14.
15. Supplementary Note.
PB94-964609
16. Abstract (Limit: 200 words)
The 1.2-acre Umatilla Army Depot (Lagoons) (Operable Unit 1) site is located in the
southwestern portion of the 19,700-acre installation near Hermiston, in both Morrow and
Umatilla Counties, Oregon. Land use in the area is predominantly agricultural, with
approximately 1,000 residents in each of the bordering farm communities of Umatilla and
Irrigon. The Columbia River flows from east to west approximately 3 miles north of the
Umatilla Army Depot (UMDA) boundary, and the Umatilla River flows from south to north
approximately one to two miles to the east. Approximately 1,470 wells have been
identified within a 4-mile radius of the installation, the majority of which are used
for domestic and irrigation water. Three municipal water systems also draw from ground
water within that same radius. In 1941, UMDA was established as an Army ordinance
depot for the purpose of storing and handling munitions. The current and near future
mission of the installation is continued munitions storage, chemical weapons
detonation, and remediation. The former Deactivation Furnace and associated structures
covered approximately 1.2 acres of the site and could be technically described as an
Explosive Waste Incinerator (EWI). From the late 1950s until 1988, the furnace was
used to incinerate unserviceable or obsolete munitions of up to 50 caliber at the site.
In addition, the incineration process was designed to remove propellant, explosive,
.
(See Attached Page)
17. Document Analysis .. Duc:rlptora
Record of Decision - Umatilla Army Depot (Lagoons) (Operable Unit 1), OR
Second Remedial Action
Contaminated Media: soil, sediment, debris
Key Contaminants: organics, metals (arsenic, chromium, lead)
b. Identlflers/Opan-Ended Term.
c. COSATI Field/Group
18. Availability Statement 19. Sac:urlty CI... (ThIs Report) 21. No. 0' Pagas
None 60
20. Sac:urlty Cia.. (ThIs Page) 22. Price
None
(See ANSI-Z39.18)
S..lns'ructJons on Rev81'S6
OPTIONAL FORM 272 (4.77)
(Formerly NTI8-35)
-------
EPA/ROD/RI0-93/055
Umatilla Army Depot (Lagoons)
Second Remedial Action
(Operable Unit 1), OR
Abstract (Continued)
and/or pyrotechnic wastes from recoverable metals such as brass, lead, and steel, leaving
only a non-reactive ash residue. Beginning in 1978, based on studies conducted as part of .
the Department of Defense's Installation Restoration Program (IRP), it was determined that
past operations at the UMDA Deactivation Furnace have resulted in the contamination of
adjacent soil deposits, through the windblown deposition of furnace stack and
particulates, occasional spilling, and/or onsite dumping of residual furnace ash and
munitions incineration debris. In 1992, as part of a RCRA closure action, the furnace
within the buildings was decontaminated and removedoffsite for disposal or salvage, and
hazardous waste, including baghouse ash and rinse water that was collected during this
removal, was disposed of offsite at a RCRA hazardous waste treatment, storage and disposal
facility. Due to its large size, the number of sites, and the variety of potential
contaminants, the installation was divided into eight OUs for remediation. An earlier
1992 ROD addressed Explosive Washout Lagoons soil, as OU2. This ROD addresses the
contaminated soil, sediment, and debris in the Deactivation Furnace area, as OUI. Ground
water at UMDA is being addressed on an installation-wide basis and will be addressed in
future remedial actions. The primary contaminants of concern affecting the soil,
sediment, and debris are organics; and metals, including arsenic, chromium, and lead.
The selected remedial action for this site includes excavating approximately 4,640 yd3 of
soil surrounding. the furnace, with lead levels greater than 500 mg/kg, to a depth of 2 to
15 inches; screening/sieving the soil to remove debris, including large 'size fractions of
elemental lead; treating the soil onsite using cement-based solidification and
stabilization, with onsite disposal of the solidified mass in the UMDA active landfill;
decontaminating and demolishing onsite buildings, concrete pads, railroad ties, and rails,
with onsite disposal; and excavating and transporting offsite 5 yd3 of
organic-contaminated soil and sediment from the sump for treatment and disposal. The
estimated present worth cost for this remedial action is $957,600, which includes an
estimated annual O&M cost of $618,800 for one year. -
PERFORMANCE STANDARDS OR GOALS:
Soil excavation goals are based on concentrations of lead exceeding 500 mg/kg, and will
comply with RCRA LDRs. Stabilized soil will be tested prior to disposal to ensure that
-------
RECORD OF DECISION
UMATILLA. ARMY DEPOT ACTIVITY
DEACTIVATION FURNACE (SITE 1)
SOILS OPERABLE UNIT SITE
HERMISTON. OREGON
DECEMBER 1992
D
D
Prepared For:
. U.S. Army Depot Activity Umatilla
Herrrllston, Oregon 97838-9544
Prepared By:
rr:Pn
~
U.S. Army Corps of Engineers
Seattle District
P.O. Box 3755
-------
u.s. ARMY INSTALLATION
RESTORATION PROGRAM
RECORD OF DECISION
UMATILLA DEPOT. ACTIVITY
DEACI1V ATION FURNACE
sons OPERABLE UNIT
December 1992
In accordance with Army Regulation 200-2, this document is intended by the Army to comply with
-------
Sec:tion
1.
2.
TABLE OF CONTENTS
DECLARATION OF THE RECORD OF DECISION. . . . . . . . . . .
1.1 SITE NAME ANJ> LOCATION. . . . . . . . . . . . . . . . . . .
1.2 STATEMENT OF BASIS AND PURPOSE. . . . . . . . . . . .
1.3 ASSESSMENT OF THE SITE ....................
1.4 DESCRIPTION OF THE SELECTED REMEDY. . . . . . . . .
1.5 STATUTORY DETERMINATIONS. . . . . . . . . . . . . . . .
1.6 SIGNATURE AND SUPPORT AGENCY ACCEPTANCE
OF THE REMEDY. . . . . . . . . . . . . . . . . . . . . . . . . . .
DECISION SUMMARY. ". . . . . . . . . . . . . . . . . . . . . . . . . . .
2.1 SITE NAME, LOCATION, AND DESCRIPTION. . . . . . . .
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES "'"
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION. . . . . .
2.4 SCOPE AND ROLE OF OPERABLE UNIT . . . . . . . . . . . .
2.5 SITE CHARACTERISTICS. . . . . . . . . . . . . . . . . . . . . .
2.6 SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . . .
2.7 DESCRIPTION OF ALTERNATIVES. . . :": . . . . . . . . . .
2.8 SUMMARY OF COMPARATIVE ANALYSIS OF
AL TERNA TIVES ............................
2.9 SELECTED REMEDY. . . . . . . . . . . . . . . . . . . . .. . . .
2.10 STATUTORY DETERMINATIONS. . . . . . . . . . . . . . . . .
2.11 DOCUMENTATION OF SIGNIFICANT CHANGES. . . . . .
ii
Pal1e
1-1
1-1
1-1
1-1
1-1
1-2
1-2
2-1
2-1
2-5
2-8
2-9
2-9
2-14
2-22
2-30
2-35
2-36
-------
TABLE OF CONTENTS - Continued
Section
3.
RESPONSIVENESS SUMMARY. . . . . . . . . . . . . . . . . . . . . . .
APPENDIX A - State of Oregon's Letter of Concurrence
iii
. .
Paee
-------
Fimre
2
3
Table
1
2
3
4
5
6
7
TABLE OF CONTENTS - Continued
List or Figures
Facility Location Map .............................
Location of DeaCtivation Furnace Site. . . . . . . . . . . . . . . . . . . .
Extent of Lead Contaminated Soil with Concentrations
Greater than 500 mg/kg ............................
List or Tables
Range of Inorganic Concentrations Detected in Surface Soils to a
Depth of 2 Feet .................................
Noncarcinogenic Health Effects Criteria for
Contaminants of Concern. . . . . . . . . . . . . . . . . . . . . . . . . . .
Carcinogenic Health Effects Criteria for CoDwninants of Concern
Summary of Carcinogenic and Noncarcinogenic Risks From
Meta1sOtherlbanLead ............................
Summary of Environmental Toxicity to Four Wildlife Species. . . .
Summary of NCP Criteria Evaluation for Alternative 3 . . . . . . . . .
Effectiveness and Cost of Alternatives as a Function
of Cleanup Levels for Lead-Residential Scenario. . . . . . . . . . . . .
iv
Paee
2-2
2-3
2-13
Paee
2-11
2-15
2-16
2-19
2-21
2-26
-------
APE
ARAR
BRAC
CDC
CERCLA
DoD
EPA
ERA
EWI
FFA
FS
ACRONYMS AND ABBREVIATIONS
Army Peculiar Equipment
Applicable or Relevant and Appropriate Requirements
Base Realignment and Closure
Center for Disease Control
Comprehensive Environmental Response, Compensation, and Liability Act
Department of Defense
United States Environmental Protection Agency
Ecological Risk Assessment
. .
Explosive Waste Incineration
Federal Facility Agreement
Feasibility Study
IRP Installation Restoration Program
LDR Land Disposal Restrictions
NCP National Oil and Hazardous Substances Pollution Contingency Plan
ODEQ Oregon Department of Environmental Quality
O&M Operations and Maintenance
PNL Battelle - Pacific Northwest Laboratory
RCRA Resource Conservation and Recovery Act
RI Remedial Investigation
ROD Record of Decision
SARA Superfund Amendments and Reauthorization Act
TCLP Toxicity Characteristic Leaching Procedure
TNT Trinitrotoluene
TRC Technical Review Committee
TSD Treatment Storage and Disposal
UBK Uptake biotinetic
UMDA United States Army Depot Activity, Umatilla
USACE United States Army Corps of Engineers
-------
I. DECLARATION OF TIlE RECORD OF DECISION
1.1 SITE NAME AND LOCATION
U.S. Army Depot Activity, UmatiJIa
Deactivation Furnace, SoiJs Operable Unit
Henniston, Oregon 97838-9544
1.2 STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Deactivation Furnace Soils
Operable Unit at the U.S. Army Depot Activity, Umatilla (UMDA) in Hermiston, Oregon, which
was chosen in accordance with the Comprehensive Environmental Response, Compensation, and
LiabiJity Act (CERCLA), as amended by the Superfund Amendments and Reauthorization ACt
(SARA) of 1986 and, to the extent practicable, the National OiJ and Hazardous Substances Pollution
Contingency Plan (NCP). The decision was based on the administrative record for this site.
The remedy was selected by the United States Environmental Protection Agency (BPA) and the
United States Army (Army). The State of Oregon concurs with the selected remedy.
1.3 ASSESsMENT OF TIlE SITE
Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to public health and welfare, or the environment.
1.4 DESCRlPrION OF TIlE SELEcrEo REMEDy
The selected remedy addresses contaminated soils at the Deactivation Furnace Soils Operable Unit
and is the final remedial action planned for those soils. The function of the remedy is to reduce the
risks associated with exposure to surficial soiJs and thus address one of the principle threats at the
site. The major components of the selected remedy include the fOllowing:
-------
.
Excavation of soils surrounding the furnace having lead concentrations greater than 500
mgltg (initially estimated to be 4,640 cubic yards or 6,264 tons of soil);
.
Solidification and stabilization treatment of the excavated soils; and
. .
.
On-site disposal of the treated soils in the UMDA Active Landfill.
1.5 STATUfORY DETERMINATIONS
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 permanent solutions and alternative treatment technologies
to the maximum extent practicable, and satisfies the statutory preference for remedies that employ
treatment that reduces toxicity, mobility, or volume as a principal element.
Because this remedy will not result in hazardous substances remaining in on-site soils above
health-based levels, the 5-year review will not apply to this action.
1.6 SIGNATURE AND SUPPORT AGENCY ACCEPTANCE OF THE SELECTED REMEDY
Signature sheets for the ROD for the Deactivation Furnace Soils Operable Unit follow.
-------
LEAD AND SUProRT AGENCY ACCEPTANCE
OF THE RECORD OF DECISION
U.S. ARMY DEOOT ACTIYITY UMATILLA,
DEAC'fIVATlON E'URNACE. SOn.s OPERABLE IlNIT
SignatUre sheet for the foregoing Record of Decision for the Deactivation Furnace Soils Operable
Unit final action at the U.S. Army Depot Activity at Umatilla between the U.S. Army and the United
States Environmental Protection Agency, with concurrence by the State of Oregon Department of
Environmental Quality
~ tJL.J~
)2/21192-
Lewis D. Walker
Deputy Assistant Secretary of the Army
(Environment, Safety, and Occupational Health)
Date
-------
LEAD AND SUPPORT AGENCY ACCEPrANCE
OF TIlE RECORD OF DECISION
U.S. ARMY DEPOT ACTIVITY UMATILLA.
DEACTIVATION FURNACE. SOILS OPERABLE UNIT (CONT.)
. .
Signature sheet for the foregoing Record of DeciSion for the Deactivation Furnace Soils Operable
Unit final action at the U.S. Army Depot Activity at Umatilla between the U.S. Army and the United
States Environmental Protection Agency, with concurrence by the State of Oregon Department of
Environmental Quality
~~~
-------
0' ,
.' "," '.
"
, ,
',:,. .
LEAD AND SUPPORT AGENCY ACCEPTANCE
, OF'I1IE RECORD OF'DECISION
. . .
' ,
. U.S., ARMY DEPOT ACTlVITVoUMATlLLA.. :' ,
DEAC1TvATlON;FURNACE. '.SOILS' OP~LE,,~(C0N!'.)' ,
..
. ."..
Signature sheet for the foregoing Record of Decision for the Deactivation Furnace Soils Operable
Unit final action at the U.S. Army Depot Activity at Umatilla between the U.S. Army and the United
States Environmental Protection Agency. with concurrence by the State of Oregon Department of
Environmental Quality
~ '-. - ., "
~~-
('Lf-:s llCfL
Dana A. Rasmussen
Regional Administrator. Region 10
U.S. Environmental Protection Agency
Date
-------
LEAD AND SUPPORT AGENCY ACCEPTANCE
OF THE RECORD OF DECISION
U.S. ARMY DEPOT ACTIVITY UMATILLA.
DEACTIVATION FURNACE. SOILS OPERABLE UNIT (CONT.)
. .
Signature sheet for the foregoing Record of Decision for the Deactivation Furnace Soils Operable
Unit final action at the U.S. Army Depot Activity at Umatilla between the U.S. Army and the United
States Environmental Protection Agency, with concurrence by the State of Oregon Department of
Environmental Quality
~d7~-"'; ,;e
.Frederic]. Hansen
Director
~/~~UYr- . ~/1
9- ~ (J
I - Lj - 9 :;>
Date
Oregon Deparunent of Environmental Quality
Note: The State of Oregon's Letter of Concurrence is appended to this Record of Decision.
-------
2. DECISION SUMMARY
This Decision Summary provides an overview of the problems posed by the conditions at the
UMDA Deactivation Furnace, the remedial alternatives, and the analysis of those options. Following
that, it explains the rationale for the remedy selection and describes how the selected remedy satisfies
statutory requirements.
2.1 SITE NAME, LOCATION, AND DESCRIPTION
UMDA is located in northeastern Oregon in Morrow and Umatilla Counties, approximately 8
miles west of Hermiston, Oregon, as shown in Figure 1. The installation occupies approximately
19,700 acres of land. The UMDA Deactivation Furnace is located in the southwest corner of the
UMDA installation as shown in Figure 2.
The Deactivation Furnace buildings and gravel-surfaced hardstand cover approximately 1.2 acres.
In July 1992, the actual furnace within the buildings was decontaminated and removed ftom the site
and disposed or salvaged as nonhazardous solid waste during a Resource Conservation and Recovery
Act (RCRA) closure action. During the RCRA closure action, hUardous waste (e.g., baghouse ash
and rinse water) collected during cleanmg and removal of the furnace equipment was disposed of at
the RCRA-permitted bazardous waste treatment, storage, and disposal (TSD) facility in Arlington,
Oregon. The remaining buildings are approximately 2S feet by SO feet and 15 feet by 40 feet with
concrete floors. The larger building is roofless. A concrete slab totaling approximately 2,500 square
feet surrounds the buildings.
Surface water that collects on the concrete floor and perimeter slab is drained into an open
bottomed sump. The gravel hardstand and concrete slabs around the building encompass approxi-
mately 1.1 acres. Beyond the gravel hardstand, the terrain blends into a very subtle, east-west
trending hummock, with vegetation characterized by sagebrush, bluebrusb, wheatgrass, cbeatgrass,
-------
N
I
N
FIGURE 1
FACILITY LOCATION MAP
. I. J FRANKLIN COUNTY ( I
I -]" TOUCHET I
"1SUNN~IDE I (\) SNAK~ RIVER {RIVER ~
JlAKIMA RIVER I I L-----......
.., 'PASCO / ,-
-- - / RICHLAND-'" . ." I
I -,'" ~ WALLA W1~CA COUNTY
YAKIMA COUNTY \ I
I BENTON COUN=--J-' -- ( ~.ALLA WALLA I
--1 \ I ---
-------- . ~ - '/i~GTON
I . COLUMBIA RIVER ~-----lOREGON-T---
KLiCKITAT COUNTY ~.~..." UMATlLt: -- -.-/
RRIGO /:) WALLA WAL?LA I RIVER
.. - / . UMA TlLLA COUNTY
OARDMAN ... HERMISTON
-
,
~,-~
UMDA 511£
BOARDMAN
" MORROW COUNTY
i ~- -- ~UmR CREEK
I \~\(LLOW CREEK j!,
I \, ~ i)
;
w
LEGEND
----- RIVER
---
----
I
t:J
~
o
8
~
B
,-
u
COUNTY BOUNDARY
STATE BOUNDARY
5 10
SCAlE IN MILES
o
-------
FIGURE 2
LOCA TION OF DEACTIVATION FURNACE SITE
DEMll AVE.
N
I
~
BAGHOUSE
WAllED
STRUCTURE ;t.
~GRAVEL LOrJ
SECOND ST.
DEACTIVA TlON FURNACE SITE
~.
25'
APPROx. SCAI.l IN Fm
BLOCK 0
BLOCK C
BLOCK 8
UMDA
ACT! VE
LANDFILL
o
5000'
2500'
APPRO)( SCALE IN FEE:T
!
~
~
:>
/
8
. ~
j
-------
and bitterbrush. Two railroad lines, extending from north of the site, converge along the western
fringe of the gravel hardstand and continue to the south as one line.
UMDA was established as an Army ordnance depot in 1941 for the purpose of storing and
handling munitions. The current and near-furore mission of the installation is continued munitions
storage, chemical weapons destruction, and site remediation. Access currently is restricted to military
personnel and authorized contractors. After its chemical demilitarizatio~ ~s~ion is completed, the
installation may be scheduled for furore realignment under the Department of Defense (DoD) Base
Realignment and Closure (BRAC) program. Under this program, the Army may evenroally vacate
the site. Ownership could then be relinquished to another governmental agency or private interests.
Light industry is considered to be the most likely furore land use scenario; future residential and/or
agriculture use also is possible.
Northeastern Oregon, the setting for UMDA, is characterized by a semi-arid, cold desert climate,
an average annual precipitation of 8 to 9 inches, and a potential evapotranspiration rate of 32 inches.
The installation is located on a regional plateau of low relief that consists of relatively permeable
glaciofluvial sand and gravel overlying Columbia River Basalt.
Groundwater occurs primarily in two settings: an unconfined aquifer within the overlying
deposits and weathered basalts, and a vertical sequence of semiconfined and confined aquifers within
the basalt. Groundwater flows trend to the north and northwest. However, regional flow gradients
in the uppermost aquifer are influenced by irrigation, pumping, and leakage from irrigation canals.
The Columbia River flows from east to west approximately 3 miles to the north of the UMDA
boundary, and the Umatilla River flows from south to north approximately 1 to 2 miles to the east.
No natural streams occur within UMDA; the facility is characterized by areas of closed drainage.
Tbe region surrounding UMDA primarily is used for agriculmre. The population centers closest
to UMDA are Hermiston (population 10,075), approximately 8 miles east; Umatilla (population
3,032), approximately 6 miles northeast; and Irrigon (population 820), approximately 2 miles
northwest. The total populations of Umatilla and Morrow Counties are approximately 59,000 and
7,650, respectively.
Approximately 1,470 wells have been identified within a 4-mile radius of UMDA, the majority
of which are used for domestic and irrigation water. Three municipal water systems draw from
groundwater within a 4-mile radius of UMDA, including Hermiston, Umatilla, and Irrigon. Tbe
-------
Columbia River is a major source of potable and irrigation water, and also is used for recreation,
fishing, and the generation of hydroelectric power. The principal use of the UmatiJIa River is
irrigation.
2.2 SITE msroRY AND ENFORCEMENT ACI1VITIES
The Deactivation Furnace is technically described as an Explosive Waste Incinerator (EWI), and
. is designated as an Army Peculiar Equipment (APE) 1236 Deactivation Furnace in the inventory of
the U.S. Army Armament Munitions and Chemical Command. The furnace was used to incinerate
unserviceable or obsolete munitions up to 50 caliber (e.g., cartridges, mines, boosters, primers,
fuses, grenades, charges, and detonators). The incineration process was designed to remove
propellant, explosive, and/or pyrotechnic wastes from recoverable metals such as brass, lead, and
steel, leaving a non-reactive ash residue. The furnace was operated from the late 19508 until
November 1988.
During furnace operation, munitions were fed into the reton through a conveyor belt system.
Standard furnace operating temperatures ranged from highs of 1200°F to 1500"F and lows to 400'F
at tHe cool end of the reton. Exhaust gases were directed from the reton to a cyclone and baghouse
for ultimate collection and disposal of the ash paniculates. Established time and temperature
operating parameters were maintained to control the completeness of the deactivation process.
Discharged metal components were visually inspected for any obvious residues of the explosive
constituents and were tested periodically with Webster's reagent to determine the presence of
trinitrotoluene (TNT).
Standard operating procedures called for residual ash from the furnace bagbouse and cyclone to
be placed in disposal bags for temporary storage in Building 203. A fenced portion of the interior
of Building 203 was, and remains, the single RCRA-permitted hazardous waste storage facility on
UMDA. There is DO approved disposal area for hazardous waste on UMDA. The closest RCRA-
permitted hazardous waste disposal facility is in Arlington, Oregon, 50 miles west of UMDA.
The Deactivation Furnace operated for approximately 10 years prior to the addition of cyclone
and baghouse air pollution controls in the 19608. The initial air pollution equipment was replaced
by the present bagbouse system between 1975 and 1980.
Past operations at the UMDA Deactivation Furnace soils site have resulted in the contamination
of adjacent shallow soil deposits largely through the windblown deposition of furnace stack
paniculates and occasional spilling and/or dumping of residual furnace ash and munitions incineration
-------
debris (e.g., spent ammunition casings). During the remediaJ investigation (Rl), 12 metals in the top
2 feet of soil were determined to have at least one vaJue (in 62 or 63 samples) that exceeded a
background vaJue derived from a site at the UMDA border, upwind from the furnace site. The
metals detected above background concentrations were: antimony, arsenic, barium, beryllium,
cadmium, copper, lead, nickel, potassium, silver, thaJlium, and zinc. These metals generaJly exhibit
similar patterns of disttibution in the soil. Concentrations are typicaJly highest with close proximity
to the furnace structures and imm~iate gravel hardstand area. An increased occurrence in the
predominant northeast, downwind direction is evident. Contamination is highest in the upper few
inches of soil, and progressively decreases with depth at rates varying according to the specific metal.
The extent of the lateraJ migration and the magnitude of the concentrations present vary significantly,
however, between the 12 metals of concern. Lead and cadmium were found to be the most
widespread contaminants in the soils.
UMDA was inclqded in the Army's Installation Restoration Program (IRP) in October 1978. An
element of the IRP work at UMDA consisted of performing an environmental contamination survey
at severaJ sites suspected to be contaminant sources. The survey was conducted by the Battelle-Pacific
Northwest Laboratory (pNL) from January to November 1981, and involved a limited program of
soil and groundwater sampling and testing at each site.
A single sample of surface soil was recovered by PNL from the Deactivation Furnace soils site.
High concentrations of lead (J ,300 mgllcg), zinc (820 mgllcg), copper (500 mgllcg), and cadmium
(35 mgllcg) were detected. The specific sampling location is unknown. The PNL report concluded
that the presence of high metal concentrations in the soil was the result of atmospheric deposition of
furnace stack emissions. It is probable that these emissions occurred to a greater degree prior to the
installation of the baghouse.
A RCRA Facility Assessment was issued in 1987. Based on recommendations from EPA Region
10 following this assessment, an investigation under the Army's IRP was performed at severaJ
UMDA sites by Weston, Inc., from April through September 1988. Sampling at the Deactivation
Furnace soils site involved compositing surface soil (0- to 3-inch depth) from seven locations
downwind (northeast) of the furnace, and analyzing the single composite for the priority pollutant
metals and Extraction Procedure toxicity. A boring aJso was advanced downwind of the furnace,
with discrete soil samples retrieved at depths of 2.5, 5.0, 7.5, and 10.0 feet. Borehole samples were
analyzed for priority pollutant metals only.
-------
High buJlc metal concentrations were recorded in the composited surface soil for lead
(28,000 mglkg), copper (1,100 mglkg), antimony (210 mglkg), cadmium (32 mg/kg), and silver
(11.8 mglkg). Significant findings of the Weston 1988 repon are highlighted below.
. Based on chemical analyses of soil samples recovered from 2.5 to 10.0 feet in depth, the
Weston repon noted that heavy metals did not appear to be migrating downward through the
surface soil and threatening the alluvial aquifer.
. Only lead was found to exceed RCRA criteria for classification as a hazardous waste as
determined through the Extraction Procedure toxicity method.
On 31 October 1989, a Federal Facility Agreement (FFA) was entered into by EPA Region 10,
the Oregon Department of Environmental Quality (ODEQ), and the Department of the Army,
UMDA. The FFA identifies the Army as the Potentially Responsible Party for the installation. One
. - .
of the purposes of the FFA was to establish the legal framework to investigate environmental impacts
associated with past and present aCtivities at UMDA, and to develop, implement, and monitor
appropriate remedial aCtions in accordance with CERCLA, the NCP, Superfund guidance and pol icy,
RCRA, RCRA guidance and policy, and applicable state law. The Deactivation Furnace is listed as
one of several "operable units" covered by the FFA.
The UMDA Deactivation Furnace was functioning under interim status as a hazardous waste
treatment facility at the time of its final operation in November 1988. In compliance with 40 CFR
. " .
265.111 (Closure Performance Standard), a RCRA closure ;plan was developed by UMDA in
February 1990 and was approved in amended form by ODEQ in October 1990. This initial closure
plan was to include the dismantling and removal of the furnace and related structures as well as the
removal of all soil contaminated by the furnace emission particuJates. This plan was based on a very
limited amount of soil contamination data available at that time.
The closure plan specified that soils classified as RCRA hazardous waste would be excavated,
placed in drums, and stored at the RCRA-approved hazardous waste storage area in Building 203 for
eventual treatment and disposal through the CERCLA process as provided in the FFA. It was
estimated that 40 cubic yards (cu. yd.) of hazardous waste were present at the furnace site.
An RI and feasibility study (FS) of the entire UMDA installation, including the Deactivation
Furnace unit, was initiated in 1990 to determine the nature and extent of contamination and to identify
alternatives available to clean up the facility. Based on the results of the RI it became apparent in
May 1991 that soil contamination at the furnace site was probably much more extensive than initially
-------
envisioned. Laboratory data confirmed that widespread soil contamination existed at the site.
However, the completed RI sampling did not extend far enough from the furnace structure to
adequately define the limits of soil coDt;tmination above background for the region.
The United States Army Corps of Engineers (USACE), Seattle District conducted supplementary
field sampling work (phase 1 in June 1991 and Phase 2 in April 1992) to complete the definition of
soil contamination at the site. Regarding the RCRA closure plan, ODEQ agreed that a revised plan
would be required, and requested that the US ACE Seattle District prepare that document. Agreement
was reached between UMDA, EPA Region 10, and ODEQ that the closure plan would be limited
solely to actions related to the furnace equipment, and that the larger soil contamination issue would
be handled through an expedited CERCLA process, commencing with a site-specific FS. A revised
draft closure plan for the Deactivation Furnace was submitted by USACE Seattle District in May
1992.
The following documents outline the results of the site investigations and assessments of cleanup
actions for the Deactivation Furnace:
1. Remedial Investigation Reponfor the Umarilla Depot Activity, Hermiston, Oregon. Prepared by
Dames & Moore for the U.S. Army Toxic and Hazardous Materials Agency, 1992.
2. Hunum Health Baseline Risk Assessment for the Umarilla Depot Activity, Hermiston, Oregon.
Prepared by Dames & Moore, Inc. for the U.S. Army Toxic and Hazardous Materials Agency,
1992.
3. Ecological Assessment Report for the Umarilla ArmY Depot Activity, Hermiston, Oregon.
Prepared by Dames & Moore for the U.S. Army Toxic and Hazardous Materials Agency, 1992.
4. Feasibility Study for the Deaaivation Furnace Soils of Operable Unit, Umatilla Depot. Prepared
by the U.S. Army Corps of Engineers, Seattle District and Ecology and Environment, Inc. for
the U.S. Army Toxic and Hazardous Materials Agency, 1992.
2.3 IDGHLIGHTS OF COMMUNITY PARTICIPATION
In 1988, the UMDA commud assembled a Technical Review Committee (TRC) composed of
elected and appointed officials and other interested citizens from the surrounding communities.
Quarterly meetings provide an opportunity for UMDA to brief the TRC on installation environmental
restoration projects and to solicit input from the TRC. Two TRC meetings were held during
preparation of the supplemental investigation and FS for the Deactivation Furnace Soils Operable
Unit. In those meetings, the TRC was informed of the scope and methodology of the soils
investigation and remediation.
-------
The Feasibility Study and Proposed Plan for the Deactivation Furnace Soils Operable Unit were
released to the public on August 31, 1992. The public comment period started on that date and ended
on September 30, 1992. The documents constituting the administrative record were made available
to the public at the following locations: UMDA Building I, Hermiston, Oregon; the Hermiston
Public Library, Hermiston, Oregon; and the EPA offices in Portland, Oregon. The notice of
availabiJity of the Proposed Plan was published in the East Oregonian newspaper.
A public meeting was held at Armand Larive Junior High School, Hermiston, Oregon, on
September 15, 1992, to inform the public of the preferred alternative and to seek public comments.
Approximately eight persons from the community and media attended the meeting. At this meeting,
representatives from UMDA, the U.S. Army Toxic and Hazardous Materials Agency (USA THAMA),
EPA, ODEQ, and USACE, Seattle District, presented information about the site and remedial
alternatives under consideration. No comments were received at the public meeting or during the
public comment period, as indicated in the Responsiveness Summary (Section 3).
2.4 SCOPE AND ROLE OF OPERABLE UNIT
Operable units are discrete actions that constitute incremental steps toward the final overall
remedy. Operable units can be actions that completely address a geographic portion of a site or a
specific problem, or can be one of many actions that will be taken at the site.
The Deactivation Furnace Soils Operable Unit includes contaminated soil surrounding the
Deactivation Furnace structures. Contaminated soils surrounding the Decontamination Furnace
include the railroad track ballast. Associated debris in the operable unit includes the building
structures, concrete pads, aDd railroad ties and rails. GroundWater was not impacted by contaminants
associated with the Deactivation Furnace soils. The soils operable unit cleanup strategy presented
here is considered a final action only for the soil, building structures, concrete pads, and railroad
tracks.
UMDA groundwater is being addressed .on an installation-wide basis. The final remedial actions
for the groundwater and the remaining portions of the UMDA installation will be proposed following
completion of ongoing investigations.
2.5 SITE CHARACl'ERIsncs
The primary source of soil contamination at the UMDA Deactivation Furnace was furnace stack
particulate emissions. These particulates were contaminating the surrounding soils through
-------
windblown deposition. In addition, residual furnace asb and munitions incineration debris (e.g., spent
ammunition casings) were occasionally spiUed and/or dumped on the soils.
Several soil investigations bave been conducted at the Deactivation Furnace from 1981 to present.
Samples collected from the surface and from soil borings were used to detennine the vertical and
horizontal extent of soil contamination. The investigation results are summarized as follows:
. Lead is the primary contaminant with respect to concentration and both horizontal and
vertical extent. Other metals found at elevated levels included antimony, arsenic, barium,
beryllium, cadmium, copper, nickel, potassium, silver, thallium, and zinc. Physical and
chemical properties of the contaminants are summarized in Table 1. The extent of lead
contamination is such that cleanup of lead contaminated soil to 500 mglkg will concurrently
reduce the other metals to near their regional background levels. The lateral and vertical
extent of soil contamination at lead concentrations greater than 500 mglkg is illustrated in
Figure 3. Low concentrations of 2,4-DNT and nitrate/nitrite were detected in soil in the
sump area. Explosives or other organic constituents were not encountered within the soil
outside the sump.
. The maximum lead concentration found was 83,000 mgIkg as compared to a background
lead value of 8.37 mglkg. The total quantity of soil with concentrations above background
is estimated to be 29,868 cubic yards. Approximately 4,640 cubic yards of soil encompassing
approximately 4 acres were estimated to contain lead at concentrations greater than
500 mglkg.
. 1be maximum vertical extent of contamination above background concentrations is
estimated to be 30 inches. Lead at concentrations above 500 mglkg was found at depths no
greater than 15 inches. Groundwater exists locally at a depth of approximately 60 feet below
ground surface.
. Soil with higher Ie: :; concentrations dem
-------
N
I
-
-
Table I
RANGE OF INORGANIC CONCENTRATIONS DETECTED IN SURFACE SOILS TO A DEPTH OF 2 FEET(s)
(mg/kg)
Pereent
RaDle or Detected CODceotraUoD' Upper 95 PererDt Comparbon Criteria Pereent Exceeding
Cclnndrnce Pol/tlve Bacllground
Aoalyte Minimum Maximum Llmlt(b) Background Udedlon Limits Ddectloo,tc) Criteria(c)
Aluminum 2,970 6,900 4,832 8,604 DLNA 100 0
Antimony 7.04 1,400 78.1 3.8 3.8 - 3.8 46 46
Arsenic 0.863 11.8 2.'S '.24 DLNA 100 3
Barium 82.2 980 202 233 300 . 300 98 13
Beryllium 2.9 2.9 1 1.86 0.33 . 1.86 2 2
Cadmium 3.88 32 , 3.05 3.0' - 61 22 22
Calcium 3,'60 11,000 6,28' 29,006 DlNA 100 0
Chromium 17.2 17.2 6.81 32.7 12.7 - 12.7 2 0
Copper 90.7 210,000 8,925 58.6 '8.6 - 58.6 22 22
Iron 12,000 26,000 19,165 26,233 DlNA 100 0
Lead 3.97 30,ooo(d) 2,618 8.37 DlNA 100 84
Magnesium 2,990 5,920 4,'60 8,'8' DLNA 100 0
Manganese 280 574 481 874 DLNA 100 0
Nickel 21.2 32.1 8.17 12.6 12.6 - 12.6 5 5
POlassium 905 2,7'0 1,526 2,179 DLNA 100 3
Silver 0.03 1.94 0.222 0.038 0.02' 68 61
Sodium 229 570 400 978 ISO - ISO 98 0
-------
Table 1
RANGE OF INORGANIC CONCENTRATIONS DETECTED IN SURFACE SOILS TO A DEPTH OF 2 FEET(a)
(mglkg)
Pen:ent
RanRe or DfteI:ted Concentrations UPRtr 95 Pen:ent Comparooo Criteria Pen:eot Exceeding
Confidence PosltJ"e Background
Analyte Minimum Maximum Llmlt(b) BackRrouod Detectioo Limits Detectioos(c) Crlterla(c)
Vanadium 31.9 120 73.6 131 DLNA 100 0
Zinc 36.1 97,000 4,257 94 30.2 - 30.2 87 SI
DLNA . Detection limit could not be ascertained because the analyte was dectected in aU samples.
(a)
(b)
N (c)
I
-
N
(d)
Data reported includcs only that from the rcmedial invcstigation rcport. Supplemenlall8mpling data generaled by USACI! Scelile District not included.
Upper 95 percent confidcnce limit on the arithmetic mean. Calculated asuming one-half the detection level as the conccntration for those samplcs in which a given analyte
was not detected.
Total number of samples collected ranged from 62 to 63.
-------
FIGURE 3
ESTIMATED EXTENT OF LEAD CaNT AMINA TED SOIL
WITH CONCENTRATIONS GREATER THAN 500 mg/kg
"
DEACllV A 110N
FURNACE
N
I
-
\H
LEGEND
--..-
DEACTIVATION FURNACE
9UILDING!CONCRETE PAD ..
DEPTH OF SOIL WITH LEAD
CONTAMINATION EXCEEDING 500 mg/kg
15 INCHES ~
12 INCHES ~
9 INCHES ~
6 INCHES ~
3 INCHES ~:-:-j
2 INCHES E:J
RA I LROAD 1'111111
GRAVEL HARDSTAND
AND ACCESS ROAD
2nd AVE
o
200
100
300
SCAlE IN fEET
!
~
~
I
'"
lJ
SOURCE: FEASIBILITY STUDY, DEACTIVATION
FURNACE SOILS OPERABLE UNIT, 1992.
NOTE: LATERAL AND VERTICAL EXTENT OF LEAD
CONTAMINATION ESTIMATED FROM FIELD
-------
. Subsurface: Infiltration of precipitation provides a potential subsurface pathway for
migration. However, the rate of transport is expected to be low due to the high sorptive
nature of lead to soils, and the low precipitation and high evaporation rates in the region.
2.6 SUMMARY OF SITE RISKS
This section summarizes the human health risks and environmental impacts associated with
exposure to site contaminants and provides potential remedial action criteria.
2.6.1 Human Health Risks
A baseline risk assessment was conducted by Dames & Moore to estimate the risk posed to
human health by the Deactivation Furnace should it remain in its current state with no remediation.
The risk assessment consisted of an exposure assessment, toxicity assessment, and human health risk
characterization. The exposure assessment detailed the exposure pathways (such as dust inhalation)
that exist at the site for various receptors. The toxicity assessment documented the adverse effects
that can be caused in a receptor as a result of exposure to a site contaminant.
The health risk evaluation used both the exposure concentrations and the toxicity data to
determine a hazard index for potential noncarcinogenic effects and a cancer risk level for potential
carcinogenic contaminants. If the hazard index is below 1, then even the most sensitive population
is not likely to experience adverse health effects. If it is above 1, there might be a concern for
adverse health effects. The degree of concern typically correlates with the magnitude of the index
if it is above 1. The cancer risk level is the additional chance that an exposed individual will develop
cancer over the course of a lifetime. It is expressed as a probability such as 1 x 10-0 (i.e., one in
one million).
A risk assessment uses simplifying assumptions regarding health effects of compounds of concern
and the means by which persons or environmental receptors are exposed to these compounds.
Toxicity measures or healtb effects criteria are uncertain because they are often based on limited
laboratory studies on animal species and thus require factors to assure protection of human health.
For example, Table 2 summarizes human health. noncarcinogenic reference doses and shows
uncertainty factors used to provide additional protection by accounting for potential differences
between tested species and humans as well as variability among humans. Table 3 summarizes
carcinogenic slope factors, which are conservatively estimated upper bounds for these effects. Also,
in calculating exposure to chemicals of concern, higheSt plausible estimates are used to assure that
sensitive individuals or groups are addressed. For example, since it is possible that the site might
-------
N
I
-
VI
Table 2
NONCARCINOGENIC HEALTH EFFECTS CRITERIA FOR CONTAMINANTS OF CONCERN
DEACTIVATION FURNACE, UMDA
Inhalation
Oral RID Uncertainty , ROC Uncertainty Crlticallnhala-
Metal (mg/kg-day) Factor Conndence Crltlc8l Oul Route Effect (1II1/m 3) Factor Confidence lion Route Effect
Antimony 4.008-4 1,000 Low Longevity, blood glucose NO"
Arsenic 3.ooB-4 3 Medium Hyperpigmenlation, keratosis, NO/Review - - -
v8lcular complication I
Barium 1.008-02 3 Medium Hypertension 1.40e-04 1,000 Fetotoxicity
Beryllium 5.ooe-03 lOa Low NdAE!L, highest level tested NO
Cadmium 5.0E04 (water) 10 High Proteinurea NO/Review - - -
1.08-03 (diet)
Copper 3.10e.2 I Low Maximum Contamination I. 001!-02 -- Low u
Level (drinking water)
Lead(.) Inappropriate .. .- Neurotoxicity in children Inappro,)ri- n u u
ate
Nickel 2.0E.02 (solublo 300 Medium Ourealed body, liver and N D/Rcview u u n
saUs) Iplcen weight
Potaaslum Insufficient Data Insufficient
Oala
Silver S.OOE!-03 3 Low Skin discoloration InsufliciclIl u u u
Oala
Thallium 8.ooB.OS 3,000 Low NOA8L, highest level tested NO u u ..
Zinc 2.ooE!-01 100 .. Anemia NO -- u -.
NO = Not determined
Review.. Under review
NOABL =- No oblerved adverse efrut level
(a) - "callh e((uts criteria (or lead based on the probability o( lead levels in children's blood using the lead uplake biukinelie (UBK) model.
Sources:
lleallh cfrccls criteria shown arc thole valuel used in the remedial investigation which relied on the Integrated Risk Information System (IRIS), January 1991, and the
-------
t-)
I
-
0\
Table 3
CARCINOGENIC HEALTH EFFECTS CRITERIA FOR CO NT AMINANTS OF CONCERN
DEACTIVATION FURNACE, UMDA
lohalatlon Uolt
Weight or E,ldence Oral Slope Factor Risk
Metal Classlfieatloa(e) (malka-dayrt Type or Caocer (pg/m3rl Type or Caocer Source
Arsenic A 1.75E+00 Skin tumon 1.4E+01 - HEAST
Beryllium B2 4.30+00 Oross lumon, all 8.4IHoo .. IRISIIIEAST
slles
Cadmium BI NO - 6.31!+OO Lung cancer, IRISIHI!AST
Iracheal and
bronchiallumors
Lead B2 NO Renal tumors ND Digeslive Iracl, IRIS
respirator system,
peritoneum
Nickel (soluble A NO - 8.4e.OJ Lung and nasal
salts) 1.71!+OO tumors (higher
value, for nickel
subsulfate, was used.
(a) . According to EPA weight of Evidence Classification, an A carcinogen is a human carciongenj B carcinogens are probahle human carcinogens, with BI having limilcd human
dala available and B2 having sufficient evidence In animals and inadequate or no evidence in humans.
Sources: llealth effccts crileria shown arc Ihose values used in the remedial invesligallon which relied on Ihe InlcgrnlcJ Risk Information Syslem (IRIS), January 1991, al1<1lhe
-------
be used in the future for residences, exposures to the contaminants (especially lead) were calculated
for the most sensitive POpulation, children from the ages 0 to 7 years old, although children may
never occupy the site. Other possibly significant sources of uncertainty in the risk assessments are:
airborne dust models that could over- (or under-) state exposure to human receptors, crop and game
consumption as a means of exposure to chemicals of concern, exposure frequencies and durations for
humans and environmental receptors, and the assumption that cancer risk and noncancer hazards from
different chemicals are additive.
Contaminants of concern in the UMDA Deactivation Furnace Soils Operable Unit were identified
as those metals detected in soil samples that exceeded UMDA background concentrations in at least
one sample.
They were:
. Antimony
. Arsenic
. Barium
. Beryllium
. Cadmium
. Copper
. Lead
. Nickel
. Potassium
. Silver
. Thallium
. Zinc
The risk of exposure to the population of these metals was identified by considering both current
and future use scenarios. Currently, public access to the UMDA facility is restricted, and there is
little incentive or oPPOrtunity for trespassers to approach the furnace area, so public exposure is
unlikely. There are no operations being conducted in the furnace area other than remediation, so
unplanned exposure of military .personnel also is unlikely. Therefore, the potential for current
exposure was judged to be low and risks associated with current exposure scenarios were not
evaluated.
Future site use may vary from its current state. Although the ordnance storage mission at
UMDA has been transferred to another installation, the base is to remain open until its chemical
demilitarization mission is completed. After this period, UMDA may be scheduled for future
realignment under the Department of Defense (DaD) Base Realignment and Closure (BRAC)
program. Under this program, the Army may eventually vacate the site. Ownership could then be
relinquished to another government agency or private interest. Light industrial land use is considered
a potential scenario for future use of UMDA based on site toPOgraphy and the availability of utilities
and resources; however, future residential use also is possible. Because it is more conservative,
residential use was evaluated in the risk assessment. The exposed population in this scenario would
consist of site residents, including both adults and children.
-------
The exposure pathways for each of these future use scenarios were identified. Those pathways
with the probability of providing significant exposures include the following:
. Incidental ingestion of soil,
. Dust inhalation, and
. Crop ingestion.
For purposes of calculating exposure, soil concentrations of the metals of concern were assumed
to be the 95 percent upper confidence limit on the arithmetic mean of sampling data. Using these
concentrations and exposure factors obtained from EPA's Risk Assessme1ll Guidance/or Superfund,
chronic daily intake factors for each chemical within each exposure pathway for a given population
at risk were calculated.
The risks estimated were of three kinds: 1) carcinogenic, 2) noncarcinogenic hazard estimates
for all metals except lead, and 3) an uptake model for children ages 0 to 7 years which predicts the
concentration of lead in blood.
The basic toxicity information and health effects criteria used to calculate risk and the models
from which the risk values were derived are provided in Tables 2 and 3. All metals are potentially
toxic. In addition, arsenic, beryllium, cadmium, lead, and nickel are classified as potential human
carcinogens. Using this toxicity assessment and the calculated chronic daily intake factors, excess
cancer risks and noncancerous hazard indices were calculated for each of these pathways and under
the residential scenario, assuming that no remediation of soils takes place. The results are
summarized in Table 4. Cumulative risks are shown for each of the exposure pathways evaluated.
The cumulative risks do not include those from lead or potassium. There is insufficient toxicity data
to calculate risks from potassium. Risks due to lead were evaluated independently and are discussed
below.
The NCP states that the acceptable risk range for carcinogens "is 1 x 10-4 to 1 x 10-6, and for
noncarcinogens a hazard index of less than 1. The noncarcinogenic hazard index acceptable value
is exceeded under the residential use scenarios. Therefore, actual or threatened releases of bazardous
substances from the site, if not addressed by implementing the response action selected in this ROD,
may present an imminent and substantial endangerment to public health, welfare, or the environment.
In the case of human exposure to lead, children are more at risk than adults. Excessive amounts
of lead in the human system bave been linked to impaired neuro-behavioral development, kidney
damage, anemia, and hypertension in children. Adverse health impacts to children are closely related
-------
Table 4
SUMMARY OF CARCINOGENIC AND NONCARCINOGENIC RISKS
FROM METALS OTHER THAN LEAD
(ASSUMING. NO REMEDIATION OCCURS)
ResideuDaI Use
Pathway CaDCel' Nooc.aDCel'
RwJaA Rdksb
Incidental Ingestion of Soil IE-OS 3.0
Inhalation of Dust 9E-09 0.0006
. .
Consumption of Crops I E-OS 40.0
Combined Pathways Total Risk: 2E-OS 3.0
a- Excess lifdimc cancer risk to an individual.
b- Noncancer risk hazanI index values (a hazard index of 1.0 or lower indicalea that no
adverse cffc:cu would be cxpcctcd).
to the levels of blood lead that is found. 'f!1e r~ks from lead exposure to sensitive populations of
children assumed to potentially live at the Deactivation Furnace site in the future are compared to the
advisory standards established by the Center for Disease Conttol (CDC). CDC considers blood lead
levels of less than 10 micrograms per deciliter (JLg/dL) to be below any level of concern; and iflevels
are between 10 I&g/dL and IS l&g/dL, some children may warrant further medical evaluation.
EP A has developed a lead uptake biokinetic (UBK) model that provides a method for predicting
blood lead levels in populations of children (real and hypothetical) exposed to lead in air, food,
drinking water, soil, indoor dust, and paint. The UBK model, version S, was used to predict blood
lead levels associated with the current soil lead levels analyzed at the Deactivation Furnace. Under
a residential use scenario, children living at the site exposed to current soil concenttations would be
at risk from health effects due to lead. The model predicted that 99.04 percent of children
hypothetically exposed to existing soil lead levels at the Deactivation Furnace site would have blood
lead levels exceeding 101&g/dL. An estimated 88.63 percent of exposed children would have blood
-------
lead levels exceeding 15 J£g/dL. In addition, the model predicts that the geometric mean of blood
lead is 23.95 J£g/dL. Accordingly, the child at average risk at the site in a future residential condition
would require medical attention.
2.6.2 Environmental Evaluation
An ecological risk assessment (ERA) that includes the Deactivation Furnace was completed as part
of the installation-wide RIIFS. The ERA report discusses the risks presented to representative animal
species under the current site conditions. Table 5 summarizes risk values of potential toxicity to four
wildlife species at the UMDA Deactivation Furnace site. Only metals with chronic hazard quotients
greater than 1 are shown. Representative species analyzed for the site included the field mouse, the
pronghorn antelope, the badger, and Swaioson's hawk.
Chronic hazard quotients for potential toxicity to the field mouse were available for II metals.
Lead dominated the ri~k .with a hazard quotient of 266. Antimony and zinc also had chronic hazard
quotients greater than 1.0. None of the metals had acute hazard quotients above 1.0. The ERA
concludes that there is a significant chance for burrowing rodents to show effects of lead, antimony,
and zinc at the site.
For the pronghorn antelope, chronic toxicity data only were available for lead and zinc, of which
only lead data exceed chronic hazard quotient unity with a value of 1.1. Again, no acute hazard
quotients were exceeded. The ERA concludes that there is a random chance that a pronghorn might
receive an acute dose from eating large quantities Oarger than used in the calculation) of soil, but
chronic impacts to the animals are unlikely because of the small area of contamination compared to
the ranging area for individuals.
For the badger, copper and lead were identified as chemicals of concern. Chronic hazard
quotients for copper and lead were determined to be 17.1 and 24.6, respectively. No acute hazard
quotients were exceeded. Despite the exceedance of chronic hazard quotient unity, the ERA
concludes that there is small risk to the animal given the animal's ranging habits, which would carry
it far beyond the furnace site.
For Swainson's hawk, metals toxicity information was only available for arsenic, cadmium, and
lead. Only lead exceeded the chronic hazard quotient of 1.0, with a value of 120. There was no.
exceedance of acute hazard quotient unities, although the ERA indicates that there is increased
potential for Swainson's hawk to receive an acute exposure to lead due to the possibility that
structures and powerpoles in the vicinity of the furnace could be used as a hunting perch. However,
-------
N
~
-
Table 5
SUMMARY OF ENVIRONMENTAL TOXICITY TO FOUR WILDLIFE SPECIES
(ASSUMING NO REMEDIATION OCCURS)
No Ad,ene ,rrects SO% Lethll Dose
Indicator Species Ind Eltlmlted Expolure Le,el Cbronlc llizard (LDSO)
Met8b (m&lkg-dIY) (mg/kg-dIY) Quotient (IIQ) \ (mg/kg) Acute IIQ
.
Field Mouse
Antimony 3.51!-OI 3.S01!-01" 1.001!+00 5.4SI!+02 6.391!-04
Lead 8.5IE+00 3.20E-02. 2.66E+02 7.0JE+01 1.21E-01
Zino 1.91 +01 9.60IHOO t.99E+OO 1.68E+02 t.l41!-01
Pronghorn Antelope
Lead 2.S71!+00 2.601!+00 1.1 OIH 00 2.161!+02 1.331!-O2
Dldger
Copper 5.65E+OO 3.301!-01 1.711HOI .- --
Lead 1.6SE+OO 6.70B-02 2.46E+01 -- ..
Swalnsnn'. IIRWk
-------
the repon also DOtes that the proximity (within about 1/2 mile) of higher quality hunting habitat and
the relatively small area of contamination relative to the hawk's home range greatly reduces the
potential for chronic ingestion to present a risk to the hawk.
2.6.3 Remedial Action Criteria
Applicable or relevant and appropriate requirements (ARARs) for the site include the Oregon
Environmental Cleanup Rules (OAR 340-122), the RCRA Land Disposal Restrictions (LDRs) (40
CFR Part 268), the Oregon Solid Waste Management requirements (OAR 340-61), and the RCRA
Solid Waste Disposal Facility Criteria (40 CFR Pan 257 and 258). The Oregon Environmental
Cleanup Rules require that if hazardous substances are released, the environment must be restored
to background conditions, if feasible. If attainment of background conditions is not feasible, then the
environment must be restored to the lowest concentration level that is both equally protective and
feasible. The RCRA LDRs require RCRA characteristic hazardous waste to be treated prior to land
disposal and require that the treatment meet specified standards. Nonhazardous solid wastes are
disposed under the Oregon Solid Waste Management requirements and the federal Solid Waste
Disposal Facility Criteria.
Other federal and state guidance documents "to be considered" (mC) in establishing cleanup
levels include the EPA's "Interim Guidance on Establishing Soil Lead Cleanup Levels at Superfund
Sites" and adopted amendments to the Oregon Environmental Cleanup Rules OAR-340-122-045.
EPA's guidance indicates 500 or 1,000 mglkg lead in soils is an acceptable cleanup range for
Superfund sites. This cleanup range is considered protective for direct soil contact in residential
settings. The Oregon Environmental Cleanup Rules OAR-340-122 state that a soil cleanup level of
200 mglkg is protective for residential areas, but a higher residual concentration also may be
acceptable, based upon site-specific factors.
2.7 DESCRIPI10N OF ALTERNATIVES
After screening numerous potential remedial responses, five remedial alternatives (including DO
action) were developed for the Deactivation Furnace soils. A description of each is provided in the
following sections. With the exception of Alternative 1, each alternative considered three plausible
options for the volume of soil to be treated. Those options included:
-------
. Excavation of all soil with lead concentrations exceeding those equal to UMDA background.
UMDA lead background concentrations were demonstrated to be approximately 8.37 mg/kg.
The equivalent volume would be approximately 29,868 cubic yards.
. Excavation of 9,052 cubic yards of soil with lead concentrations exceeding 200 mg/kg.
. Excavation of 4,460 cubic yards of soil with lead concentrations exceeding 500 mg/kg.
2.7.1 Alternative 1: No Action
Evaluation of the no action alternative is required under CERCLA, serving as a common reference
point against which other alternatives can be evaluated.
In Alternative 1, no containment, removal, or treatment of the soil at the Deactivation Furnace
would occur, and no new controls would be implemented to prevent human exposure. However,
existing security provisions that limit public access will continue until such time as the Army vacates
the UMDA facility.
This alternative does not meet the Oregon requirement for cleanup to background, or the lowest
levels that are protective, feasible, and cost-effective, nor does it achieve protection of human health .
and the environment within the guidelines of the NCP.
Alternative 1 requires no time to implement, and involves no capital or operations and
maintenance (O&M) costs.
2.7.2 Alternative 3: Solidification/Stabilization of both RCIiA Hazardous and Nonhazardous
Wastes. and Disposal of All Solidified Wastes in UMDA Active Landfill
This alternative involves excavation of soil contaminated with lead in excess of the 500 mg/kg
cleanup level and treatment by solidification/stabilization. The treatment process would take place
on-site and involve the use of additives such as cement to bind the lead (and other metals), thus
preventing their transport by water or air. Air monitoring would be conducted during soil excavation
and treatment, and dust would be controlled using water sprays and/or plastic covers. Once the waste
was treated, it would be tested to make sure that the lead in the stabilized waste would not leach.
The solidified waste would then be transponed via truck to the UMDA Active Landfill for disposal.
Any wastewater generated during the solidification/stabilization process or though dust suppression
would be treated in accordance with local, state, and federal regulations before disposal.
Prior to solidification/stabilization, the soil would be pretreated to separate oversized material
including large-size-fraction elemental lead, munition fragments, rocks, and miscellaneous debris
-------
through screening. Once separated, the oversized material would undergo recycling or further
pretreatment. Pretreatment would remove or reduce the size of any large-fraction lead such that it
would not cause the solidified material to fail TCLP testing. The soil would then be solidified and
stabilized. Railroad ballast would be included in the treatment. The ballast may be pretreated along
with other soil or solidified and stabilized directly.
A number of solidification/stabilization applicable techniques are available; however, it is assumed
that a cement-based process would be used. In cement-based solidification, reagents (proprietary or
not) may be added to improve the physical characteristics and/or chemical stability of the solidified
product. Soll1ble silicates are added to "flash set" cement and reduce the interference of metal ions
with setting.
The solidified material would be transported to the on-site UMDA Active Landfill. The UMDA
Active Landfill is not lined. As part of the eventual UMDA Active Landf1l1 closure, the landfill
would be capped as required by Oregon's solid waste disposal regulations (OAR 340-61) and federal
solid waste disposal requirements (40 CFR Part 257 and 258). Disposal in the on-site landfill will
provide additional containment. Barring physical disturbances of the solidified material, proper on-
site disposal of the solidified material will provide long-term effective controls for inhalation exposure
and direct contact/ingestion exposure at the site.
Alternative 3 would also include demolition and removal of the Deactivation Furnace buildings
and concrete pads, removal of railroad ties and metal rails, and removal of approximately 5 cubic
yards of soil and sediment at the base of the furnace collection sump. This soil and sediment may
be contaminated with organic compounds. The cOntaminated soil and sediment would be transported,
then treated and disposed at an off-site RCRA-permitted facility. The demolition debris, including
the buildings, concrete pads, and railroad ties and rails, would be steam cleaned and disposed or
recycled. The debris will be tested prior to its disposal or recycling as a nonhazardous waste to
ensure adequate decontamination. Any debris which is shown to be hazardous will be disposed as
such in an off-site RCRA-permitted facility.
The following costs for Alternative 3 at the three cleanup level options are as follows:
. Capital
- Background:
- 200 mglkg
- 500 mgltg
$1,886,000
$612,500
$338,800
-------
. O&M
- Background:
- 200 mglkg
- 500 mglkg
$3,931,400
$1,201,400
$618,800
. Total Costs
- Background:
- 200 mg/kg
- 500 ppm
$5,817,400
$1,813,900
. $957,600
The total costs as shown are equivalent to a present worth value since the remediation would be
completed in less than a year.
A summary of the NCP criteria for evaluation of Alternative 3 is presented in Table 6. The
following major ARARs are cited for the alternative.
. This alternative is consistent with the process described in the Oregon Environmental Cleanup
Rules. Cleanup to background is evaluated to determine whether it is technically feasible.
Because cleanup to background is not feasible administratively or economically, optimal
cleanup levels that are feasible and that are protective and cost effective are also evaluated.
. This alternative will meet relevant and appropriate state and federal solid waste regulations
for the disposal of the solidified, nonhazardous waste as described in OAR 340-61 and 40
CPR Parts 257 and 258, respeCtively.
. This alternative is consistent with all state ambient air quality standards for excavation and
treatment processes.
. This alternative is consistent with all relevant and~'appropriate requirements of the RCRA for
identification, treatment, storage, and disposal of hazardous waste.
Under Alternative 5, soils with contamin:ttion exceeding the action level would be excavated and
separated into RCRA hazardous and nonhazardous wastes. RCRA hazardous wastes require specific
treatment such as solidification and/or disposal in a RCRA-permitted landfill specially designed to
handle such wastes. Soils contaminated with lead at conceutrations greater than approximately
900 mglkg were shown in the FS to possess RCRA hazardous waste characteristics. In accordance
with LDRs. those soils shown to be RCRA hazardous waste must first be treated to ensure the TCLP
treatment standard of 5 mglL is achieved. By separating soil containing greater than approximately
-------
N
~
0\
Table 6
SUMMARY OF NCP CRITERIA EVALUATION FOR ALTERNATIVE J
SOLIDIFICATION/STABILIZATION OF RCRA AND NON-RCRA WASTES, AND
DISPOSAL OF SOLIDIFIED WASTES IN THE UMDA LANDFILL
Overall Protection or ! Reduction or
Compliance with lIuman Health and Long-Term and Short-Term Toxicity, 'Mobility,
ARARs the Environment Effectiveness and Permanence or Volume I mplementability Cost
In accordance with Risks from nonhaZlrd- Reliability of S/S Is.high. Haz- Reduction in mob iii- Excavation easily im- Background: $5,817,400
Oregon Environmental ous and hazardous soils ardous contaminants not de- ty but not toxicity; plemented. S/S rc- 200 ppm: $1,813,900
Cleanup Rules, an significantly reduced by stroyed, but risks reduced. S/S hazardous waste quires readily available 500 ppm: S 957,600
optimal cleanup level S/S and on-site dispos- soils require proper disposal. would be rendered specialist. On-site
that is protective, a!. Reliability of disposal at UMDA nonhazardous waste disposal and transporta-
feasible, and eost Active Landfill depends on fol- by treatment; total tion easily implement-
effective is achieved. Slight risk remains by lowing proper closure. Increase waste volume in- ed.
disposing of S/S mater- in dust production during excava- creased due to add i-
Recommended LDR ials in unlined landfill. tion, S/S, and transportation to tion of stabilizing
treatment method on-site landfill materials.
utilized along with
testing to ensure treat-
ment standard is met
UMDA Active Landfill
must be capped and
closed to comply with
slate and federal solid
waste regulations.
SIS - Solidification/Stabilization
LDR - Land Disposal Restrictions
-------
900 mglkg lead from those excavated soils, only those soils requiring treatment under RCRA would
be solidified. Such separation and limited treatment reduces the cost of the alternative.
Extensive soil sampling would occur to confirm accurate separation. The RCRA hazardous
wastes would be pretreated and solidified/stabilized as described for Alternative 3. Tbe solidified soil
would then be tested to make sure the lead was not leaching from the soil, and transported to the
UMDA Active Landfill for disposal. The nonhazardous wastes would not be treated; they would be
loaded into trucks and transported to the UMDA Active LandfiU for disposal. Associated debris,
including building structures, concrete pads, and railroad ties and rails will be decontaminated and
disposed or recycled as described in Alternative 3. Air monitoring and dust control would be
implemented.
The costs for Alternative 5 at the three cleanup level options are as follows:
. Capital
- Background:
- 200 mg/kg
- 500 mg/kg
. O&M
- Background:
- 200 mglkg
- 500 mglkg
. Total Costs
- Background:
- 200 mg/kg
- 500 mglkg
$1-;752,300
$646,400
$405,800
$389,400
$389,400
$389,400
$2,141,700
$1,035,800 .
$795,200
The following major ARARs are cited for Alternative 5.
. This alternative is consistent with the process described in the Oregon Environmental Cleanup
Rules. Cleanup to background is evaluated to determine whether it is technically feasible.
Because cleanup to background is not feasible administratively or economically, optimal
cleanup levels that are feasible aDd that are protective aDd cost effective also are evaluated.
. This alternative will meet relevant and appropriate state solid waste regulations for the
disposal of the solidified, nonhazardous waste as described in OAR 340-61 and 40 CPR Parts
257 and 258, respectively.
. This alternative is consistent with all state ambient air quality standards for excavation and
treatment processes.
-------
. This alternative is consistent with all relevant and appropriate requirements of RCRA for
identification, treatment, storage, and disposal of hazardous waste.
2.7.4 Alternative 6: Solidification/Stabilization or both RCRA IIA7J1rdous and Nonhazardous
W8Ste$. and Disoosal or All Solidified Wastes in Orr-site Solid Waste Landfill
This alternative involves excavation and treatment by solidification/stabilization of all soil
contaminated with lead at concentrations exceeding the cleanup levels as discussed for Alternative 3.
Air monitoring and dust control measures would be implemented and the treated waste would be
tested. Alternative 6 differs from Alternative 3 in that the solidified waste would be transported off-
site to a lined solid waste disposal facility, as opposed to the unlined on-site UMDA Active Landfill.
Since the off-site solid waste facility is lined, the degree of long-term effectiveness is increased.
The costs for Alternative 6 at the three cleanup level options are as follows:
. Capital
- Background:
- 200 mg/kg
- 500 mg/kg
. O&M
- Background:
- 200 mg/kg
- 500 mglkg
. Total Costs
- Background:
- 200 mglkg
- 500 mglkg
$4,937,800
$1,537,400
$814,800
$3,931,400
$1,201,400
$618,800
$8,869,200
$2,738,800
$1,433,600
The following major ARARs are cited for Alternative 6.
. This alternative is consistent with the process described in the Oregon Environmental Cleanup
Rules. Cleanup to background is evaluated to determine whether it is technically feasible.
Because cleanup to background is Dot feasible administratively or economically, optimal
cleanup levels that are feasible and that are protective and cost effective also are evaluated.
. This alternative will meet relevant and appropriate state solid waste regulations for the
disposal of the solidified, nonhazardous waste as described in OAR 340-61 and 40 CPR Parts
257 and 258, respectively.
. This alternative is consistent with all state ambient air quality standards for excavation and
treatment processes.
-------
. This 31ternative is consistent with 311 relevant and appropriate requirements of the RCRA for
identification, treatment, stOrage, and dispos31 of hazardous waste.
Under this 31ternative, 311 soil with lead concentrations exceeding the cleanup standard would be
excavated. Air monitoring and dust controls would be employed during excavation. The soils with
greater than 900 mg/kg lead would then be separated from the excavated soil in order to isolate those
soils classified as RCRA hazardous waste. Intensive sampling and analyses would be included in
order to accurately separate the soils. Associated debris would be decontaminated and disposed or
recycled as described in Alternative 3.
Following separation, the soils identified as RCRA hazardous waste will be transponed to an off-
site RCRA-permitted TSD facility. The hazardous waste would be solidified/stabilized by a
proprietary method so that they no longer exhibit hazardous characteristics. The waste would then
be disposed of at the TSD facility.
The nonhazardous soils with lead concentrations less than 900 mg/kg would be disposed of at an
off-site solid waste landfill.
The costs for Alternative 10 at the three cleanup level options are as follows:
. TotaJ Costs
- Background:
- 200 mglkg
- SOO mglkg
$5,376,100
$2,829,300
$2,283,000
There are no O&M costs since the 31ternative is a turnkey operation involving no on-site
processing equipment.
The following major ARARs are cited for Alternative 10.
. This 31ternative is consistent with the Process described in the Oregon Environmental Cleanup
Rules. Cleanup to background is ev31uated to determine whether it is technicaJ~ feasible.
Because cleanup to background is not feasible administratively or economicaJly, optimal
cleanup levels that are feasible and that are protective and cost effective 31so are ev31uated.
. This 31ternative wiJI meet relevant and appropriate state solid waste regulations for the
disposal of the solidified, nonhazardous waste as described in OAR 340-61 and 40 CFR Parts
257 and 258, respectively.
-------
. This alternative is consistent with all state ambient air quality standards for excavation and
treatment processes.
. This alternative is consistent with all relevant and appropriate requirements of the
RCRA for identification, treattnent, storage, and disposal hazardous waste.
2.8 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
2.8.1 Threshold Criteria
Overall Protection of Human Health and the Environment. All alternatives except Alternative
1: No Action are protective of human health and the environment. With the exception of Alternative
1. all alternatives would protect approximately 9S percent of children exposed to site soil from
exceeding blood lead levels of 10Ilg/dL. A 9S percent protection level also can be expressed as a
5 percent risk level as shown in Table 7 at the 500 mg/kg cleanup level. At the 200 mg/kg and
background cleanup level. approximately 99.9 percent of the children are protected. By removing
soil contaminated with lead at even the highest cleanup level of 500 mg/kg, the concentration of all
other metals would be reduced to either that of background or to a level such that hazard quotient for
noncarcinogenic effects would be reduced below 1.0. None of the metals whose concentration would
not be reduced to background at the 500 mglkg cleanup level are listed as carcinogens.
Alternatives 3 and 6 provide the highest levels of overall protection since all soil above the
cleanup level would be stabilized/solidified before being disposed. Under Alternative 3, all treated
waste would be disposed of at the UMDA Active Landfill, which is unlined. The overall pro-
tectiveness of Alternative 6 is similar to Alternative 3 except that the stabilized/solidified waste would
be disposed of off-site at a lined solid waste landfill. Alternative 6 would, therefore. provide added
groundwater protection. However, because all the wastes would be treated and both landfills would
be covered, the probability that the lead would leach is low, and the added protectiveness of the liner
would not be necessary. Alternatives 10 and S are less protective because they would treat only the
RCRA hazardous waste. However, Alternative 10 disposes all waste off-site at lined landfills,
thereby providing the added groundwater protection. Alternative 5 disposes all waste in the unlined
UMDA Active Landfill.
Potential ecological effects also were evaluated at these three cleanup levels for all metals,
including lead. Again, lead was most important with regards to adverse impacts. At lead
concentrations above background, potential adverse impacts to wildlife were predicted to be primarily
limited to burrowing rodents. Raptorial birds, such as hawks. which feed within areas containing
-------
t-)
~
-
Tohle 7
EFFECTIVENESS AND COST OF ALTERNATIVES AS A FUNCTION
OF CLEANUP LEVELS FOR LEAD-RESIDENTIAL SCENARIO
Risk Leyels Ip SoU Risk Leyels Ia SOU
Alleroldye Clrrled RemllalDl It the Site, RemllDlDl It the Site, Man or Coot8mluated
Forwlrd for DeuUed Cleeoup Level Based OD 10 Pi'L Bised OD 15 1I./dL SOU by Alleroadye Tot81 Cost or Eacb
Aullysls (ppm laid) Blood Lead . Blood Lead . (loa.) Aberoadye
All I: No Aclion 2,618 .. 99.04,,1 88.63" 0 SO
All 3: excavalion, ..
Component Separalion wilh ~OO S.S2" 0.31" 6,264 . S957,600
Lead Rc:c:ycUng, SIS of AU 200 0.06" 0.00% 12,220 SI,813,9oo
Wastes, On-Site Disposal of 10 0.01 % <0.01" 40,322 S5,817,4oo
Solidified Malerial
All 5: excavation,
Component Separation with ~OO ~.S2" 0.31" 6,264 $795,200
Lead Rc:c:ycling, SIS or 200 0.06" 0.00% 12,220 S 1,035 ,800
Hazardous Wasle and On- 10 <0.01" <0.01" 40,322 S2,141,7oo
Site Disposal, On-Site
Disposal of Nonhazardous
Solid Waste
Alt 6: Excavation,
Component Separation with 500 5.52% 0.31" 6,264 SI,433,6oo
Lead Rc:c:ycling, 5/5 of 200 0.06" 0.00% 12,220 S2,738,8oo
All Wasles, Off-Sile 10 0.00" 0.00" 40,322 $8,869,200
Disposal of Solidified
Material
All 10: excavation, Off-
Site Disposal of Hazardous ~OO ~.S2" 0.31" 6.264 $2,283,000
Waste to RCRA Subtitle C 200 0.06% 0.00" 12,220 $2,829,300
TSD facility, Off-Site 10 <0.01" <0.01" 40,322 SS,376,I00
Disposal of Nonhazardous
Solid Wasto
Risk II blled on direct contact by a child 0 to 7 years of age Wllh soil: IngestIon, Inhalallon, and dlmnal contact.
The values arc the percentage or the population or children that arc eSlimated to have grealer than 10 or 15 118 of lead per dL of blood.
See text for explanation of thelo levell.
.. The value of 2,618 ppm is the 9S" upper confidence limit on the mean soUleed value for the site (Phase I data only).
S/S - Solidificalion/Stabilization .
LDR . Land Disposal Restriclions
-------
soil-lead concentrations greater than 200 mg/kg, also may be impacted although the extent of such
areas in comparison to the birds' natural range is expected to be quite small. Other representative
wildlife in the area such as badgers, coyotes, and pronghorn antelope were not predicted to be
adversely impacted by the site at any of the three cleanup levels.
Residual risks associ~ed with children's blood levels exceeding advisory blood lead levels for
each alternative at the three cleanup levels are compared to related costs in Table 7.
Excavation to such an extent that the lead soil concentration is reduced to no greater than
500 mglkg provides the best balance of net risk reduction and cost effectiveness. The level of
protectiveness provided by the 500 mglkg cleanup for lead is consistent with EP A guidance.
A
-------
and permanence at the site would be gained under Alternatives 3 and 6, because they both stabi-
lize/solidify all the contaminated soil at the site and dispose of the treated waste at the UMDA Active
Landfill and off-site solid waste landfill, respectively. The Active LandfiJl is not lined; however,
given that the groundwater occurs at approximately 59 feet below the base of the landfiJl, rainfall is
low in the area, and the landfiJl would be covered in accordance with federal and Oregon regulations,
future leaching of treated waste to groundwater is not anticipated. In the unlikely event that treated
waste started to leach, the off-site Jined JandfiJI would be more effective. AJternative 10 provides the
next highest level of long-term effectiveness. Alternative 10 only treats the RCRA hazardous waste;
however, all waste is disposed of at off-site lined landfiJls. AJternative 5 is less effective since,
similar to AJternative 10, only the RCRA hazardous waste would be treated, and all waste would be
disposed of at the unlined UMDA Active Landfill.
Reduction or Toxicity, Mobility, or Volume or the Contaminants Through Treatment.
Alternative 1 does not reduce thetoxici.ty, mobility, or volume of contaminants. Alternatives 3 and
6 use solidification/stabilization to greatly reduce the mobility of lead and other metals in all conta-
minated soils at the site. Under Alternative 3, the solidified material would be disposed of in the
UMDA Active Landfi.IJ. The landfiJI would further reduce mobility since a permanent low permea-
bility cover would be placed over the treated waste to prevent infiltration of any precipitation. The
placement of the cover would take place after the solidified waste is disposed under the landfi.IJ' s
planned closure and not as a pan of Alternative 3. Under Alternative 6, the solidified material would
be disposed off-site at a lined solid waste landfiJl. In addition to the liner, the landfJJI would be
covered, which would provide additional reduction in mobility. AJternatives 5 and 10 reduce the
mobility of metals only in that portion of the soils to be classified as RCRA hazardous waste, through
solidification/stabilization and disposal of the treated waste. The treated soil and remaining
nonhazardous soil would be buried in the on-site UMDA Active Landfill (AJternative 5) or an off-site
lined solid Waste landfill (Alternative 10), thus reducing the mobility of the metals. The landfilJs used
for Alternative 10 provide additional mobility reduction since they are Jined.
Short-Term Effectiveness. Potential shon-term impacts of soil excavation and handling under
AJternatives 3, 5, 6, and 10 would be the generation of dust. Alternatives 3 and 6 would generate
the greatest amount of dust on-site since all wastes would be excavated and treated entirely on the
instaiJation. Under Alternative 5, all of the waste would be excavated but only the RCRA bazardous
waste would be treated on-site. Under Alternative 10, alJ waste would be excavated but treatment
of the RCRA hazardous waste occurs off-site. Use of water sprinklers to control dust and plastic
-------
sheeting to cover soil piles would minimize risk to on-site workers and the spread of dust in the envi-
ronment.
ImplementabiHty. All of the alternatives are implementable. However, Alternatives 5 and 10
are harder to implement, because they would involve separation of the soils into RCRA hazardous
and nonhazardous waste components. This would require sampling and analysis of the wastes to
assure that accurate separation ~rred. Alternatives 3 and 6 would not require waste separation.
Alternative 3, 5, and 6 include on-site treatment which would involve procurement, mobilization, and
demobilization of a mobile treatment facility. A number of vendors are available for implementation
of the on-site solidification and stabilization treatment. Alternative 10 would be easier to implement
in this regard, since treatment and disposaJ of wastes would occur at an existing off-site facility.
Cost. The estimated capital, O&M, and total costs for each remedial alternative at the 500 mg/kg
cleanup level are presented below. The total costs are equivalent to present worth costs in each case
since each alternative would be implemented within a I-year period.
." ".
. Alternative 1
- Capital:
- O&M:
- Total Cost:
. Alternative 3
- Capital:
- O&M:
- Total Cost:
. Alternative 5
- Capital:
- O&M:
- Total Cost:
. Alternative 6
- Capital:
- O&M:
- Total Cost:
. Alternative 10
- Capital:
- O&M:
- Total Cost:
$0
$0
$0
$338,800
$618,800
$957,600
$4OS,800
$389,400
$795,200
$814,800
$618,800
$1,433,600
$2,283,000
SO
$2,283,000
-------
2.8.3 Modirvin~ Criteria
State Acceptance. The State of Oregon concurs with the Army and EPA in the selection of
AJtemative 3 and the cleanup level of 500 mglkg of lead. In addition, the state is satisfied that the
state's remedial action process was followed in evaluating remedial action for the Deactivation
Furnace.
Public Acceptance. Based on the absence of any negative comments, it is assumed the public
supports the selection of Alternative 3.
2.9 SELEcTED REMEDY
The selected remedy to clean up the soil contamination associated with the UMDA Deactivation
Furnace is Alternative 3:
. Alternative 3 - Solidification and stabilization of all soil with lead concentrations
eXceeding the cleanup level of 500 mg/kg and disposal of the solidified soil in the
UMDA Active landfill.
This alternative was selected because it is protective, feasible, and cost-effective. The primary
selected technology is solidification and stabilization. It is a proven technology for treatment of soil
contaminated with metals with a number of process options available. The specific process option
will be identified by sit~pecific.treatabiIity studies. Approximately 11 months will be required for
". . - " .
the development ef performance specifications and to complete the necessary procurement actions.
The actual treatment and disposal period is estimated at between an additional 2 to 6 months. The
estimated present worth cost of AJternatives 3 is $957,600. The estimated volume of soil to be
removed and treated is 4,640 cubic yards.
The major COmponents of the selected remedy include the following:
. Demolition and decontamination of building structures. concrete pads, and railroad
ties and rails; .
. Excavation of approximately 5 cubic yards of sump soils and sediment contaminated
with organic compounds. The sump soils and sediments identified as a hazardous
waste wiJI be transponed to a RCRA-penn.itted TSD facility for treatment and
disposal;
. Excavation of soils with lead concentrations exceeding 500 mglkg;
. Mobilization of the treatment facilities;
-------
. Screening/sieving of the soil to remove oversized debris, including large-size fraction
elemental lead.
. Solidification and stabilization of the soil through a cement-based process.
. Material testing and laboratory analysis to ensure adequate stabilization; and
. Transportation of the solidified and stabilized soil to the UMDA Active Landfill for
disposal. . - . .
Alternative 3 will attain the following remediation goals:
. Soils will be excavated to the cleanup level of 500 mglkg lead. This level of cleanup
will attain the recommended goal of protecting 95% of children exposed to soil from
exceeding blood lead levels of 10 JLg/dL.
. Excavated soils will be treated in such a manner as to immobilized the lead and other
metals present through solidification and stabilization. At a minimum, the degree of
immobilization will be such that no treated soil will produce a TCLP extract
containing greater than 5 mglL of lead.
. The treated soil will be disposed of in the UMDA Active Landfill, eliminating all
potential for direct contact and further reducing contaminant mobility.
2.10 STATIrrORY DEI'ERMlNATIONS
The selected remedy satisfies the requirements under Section 121 of CERCLA to:
. Protect human health and the environment;
. Comply with ARARs;
. Be cost-effective;
. Utilize permanent solutions and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable; and
. Satisfy the preference for treatment as a principal element.
2.10.1 Protection of Human Health and the Environment
In summary, Alternative 3 would achieve substantial risk reduction by first excavating all soil
contaminated above the cleanup action level of 500 mglkg of lead. The 4,640 cubic yards of
excavated soil will then be treated to reduce contaminant mobility. The cleanup would focus on the
upper 2 to 15 inches of soil, where the highest concentrations exist. No soil with lead concentrations
-------
greater than 500 mg/kg has been found at depths greater than 15 inches. Long-term management is
not required because contamination will be removed. Alternative 3 achieves this risk reduction using
an established treatment technology, solidification, where all soils contaminated above the cleanup
level are incorporated into a cement/soil matrix, reducing contaminant mobility. In addition,
contaminant mobility would be further reduced by placing the treated soils in the UMDA Active
LandfiU.
Human health risks associated with direct exposure of children to lead in the soil will be reduced
such that the blood lead levels of 95 % of the children exposed to site soils under a residential
scenario will not exceed 10 p.g/dL. Environmental protection is achieved by reducing lead and other
metal concentrations such that excessive adverse impacts to wildlife are not anticipated.
No unacceptable shon-term risks or cross-media impacts will be caused by implementation of
Alternative 3. During remediation, adequate protection will be provided to the community by
controlling dust generated during material handling operations and transpon. In addition, workers
will be provided with personal protective equipment and air monitoring during all phases of
remediation.
2.10.2 Comoliance with ARARs
The discussion below addresses compliance of the selected remedy with chemical-specific,
locatlon-specific, and action-specific ARARs.
ChemicaJ-Spedfic ARARs. The Oregon Environmental Cleanup Rules (OAR 340-122), which
specify generic cleanup standards, are ARARs for the UMDA Deactivation Furnace. In summary,
the regulations state that in the event of a release of hazardous substances, cleanup shall be to
background or. if that is not feasible. to the lowest level that is protective, feasible, and cost-
effective.
Recently adopted amendments to the state environmental cleanup rules (OAR 340-122-04S) state
that a soil cleanup level for lead of 200 mglkg is protective for residential.areas. but a higher residual
concentration also may be acceptable, based upon site-specific factors. The 200 mg/kg level cited
in the amendment is not considered an ARAR, but is to be considered. Other guidance to be
considered includes that of EPA which indicates that 500 to 1,000 mg/kg of lead is an acceptable
cleanup range for Superfund sites.
In order to identify the lowest level that is protective, feasible, and cost-effective, cleanup levels
to background. 200 mglkg, and 500 mglkg lead were evaluated. As shown in Table 7, Alternative
-------
3 costS for cleanup to background and 200 mg/kg lead were 6.1 and 1.9 times greater, respectively,
than the costS for cleanup to 500 mg/kg lead. Since the 500 mglkg cleanup level provides adequate
protection, the background and 200 mglkg cleanup levels were determined not to be cost effective.
Under RCRA (40 CFR 261), soils producing a TCLP extract containing lead at concentrations
greater than 5 mg/L are EPA D008 hazardous wastes based upon toxicity characteristics. Soil from
the Deactivation Furnace containing greater than 900 mg/kg lead typically will exhibit such
characteristics. RCRA regulations are, therefore,robSidered applicable.
Alternative 3 provides for solidification and stabilization of all soil containing lead at
concentrations greater than 500 mg/kg. In doing so, the soil will be treated such that it no longer
exhibitS toxic characteristics, and therefore, will not be considered an EP A D008 hazardous waste.
Location-Speclfic ARARs. No location-specific ARARs are identified for this Alternative.
Although areas of the UMDA installation provide critical habitat for threatened or endangered
species, no activities at the Deactivation Furnace are expected to impact those habitatS.
Action-Spedfic ARARs. The treatment and disposal of solidified and stabilized soil at the
UMDA Active Landfill will comply with the relevant and appropriate sections of the RCRA LDRs
(40 CFR 268), the Oregon Solid Waste Management Regulation (OAR 340-61), and the RCRA Solid
Waste Disposal Facility Criteria (40 CFR 257 and 258). The RCRA LDRs establish treatment
standards for lead contaminated soils, allowing subsequent land disposal as a nonhazardous solid
waste. Tbe Oregon Solid Waste Regulations govern the transpon, storage, and disposal of
nonhazardous solid wastes, including general rules pertaining to specified wastes. The RCRA Solid
Waste Disposal Criteria sets fonb the minimum federal criteria for solid waste landfills, including
facility design and operating criteria and closure and post-closure care requirementS. In addition, all
activities under Alternative 3 will comply with the Oregon Ambient Air Quality Standards. These
standards include those for lead and particulate emissions.
2.10.3 Cost-Effectiveness
The selected remedy provides overall effectiveness proportionate to its costs. Alternative 3 costs
are substantially less than those of Alternatives 6 and 10 while providing equal overall protection of
human health and the environment. Alternative 3 cost is greater than Alternative 5. However, all
wastes are solidified in Alternative 3 as opposed to only those soils classified as RCRA hazardous
waste. Such complete treatment will greatly reduce the mobility of the contaminant as a whole.
-------
2.10.4 Utilization ofPennanent Solutions and Alternative Treatment Technololries or Resource
Recovery Technolcmes to the Maximum Extent Pradicable
The selected remedy provides a high level of long-term effectiveness and permanence.
Solidification and stabilization constitutes the best demonstrated available technology for treatment
of D008 waste. Stabilization and solidification produces a matrix of interlocked particles and
chemicaJly transforms' contaminants into less soluble forms, thereby increasing the strength and
decreasing the permeability and leachability of the treated soil. In addition to treatment, the soil will
be disposed in the UMDA Active Landfill. The landfill will be capped, significantly reducing
infiltration of precipitation and thus potential leaching of contaminants.
2.10.5 Preference for Treatment as a Principal Element
The statutory preference for treatment is satisfied by using solidification and stabilization as the
primary means for remediating the contamination. Solidification converts the soil into a solid by
forming a matrix of interlocked particles. Stabilization reduces the solubility and chemical reactivity
of the contaminants in the soil by changing the chemical state or through physical entrapment. These
treatment processes combine to form the principal element in the selected -remedy.
2.11 DOCUMENTATION OF SIGNIFlCANT CHANGES
Tbe selected remedy was the preferred alternative presented in the Proposed Plan. Since the
issuance and approval of the Proposed Plan, no significant changes bave been made. The only
change in the selected remedy as presented in the Proposed Plan is in the time period required for
the development of performance specifications. The Proposed Plan indicated 6 months would be
required as opposed to II months as stated above.
-------
3. RESPONSIVENFSS SUMMARY
The final component of the ROD is the Responsiveness Summary, which serves two purposes.
First, it provides the agency decision makers with information about community preferences
regarding the remedial alternatives and general concerns about the site. Second, it demonstrates to
members of the public how'their comments were taken into account as it part of the decision-making
process.
Historically, community interest in the UMDA installation has centered on the impacts of
installation operations on the local economy. Interest in the environmental impacts of UMDA
activitieS bas typically been low. Only the proposed chemical demilitarization program, which is
separate from facility remediation programs, has drawn substantial comment and concern.
As part of the installation's community relations program, in 1988 the UMDA command
assembled a TRC composed of elected and appointed officials and other interested citizens from the
surrounding communities. QUarterly meetings provide an opportunity for UMDA to brief the TRC
on installation environmental restoration projects and to solicit input from the TRC. Two TRC
meetings were held during preparation of the supplemental investigation and FS for the Deactivation
Furnace Soils Operable Unit: one on February 19, 1992, and the other on August 12, 1992. In
those meetings, the TRC was briefed on the scope and results of the supplemental investigation and
the methodology of and remedial alternatives considered in the FS. The response received from the
TRC was positive; the members showed particular interest in and support for the solidification and
stabilization alternative.
Notice of the public comment period, public meeting. and availability of the Proposed Plan was
published in the East Oregonian newspaper. The Feasibility Study and Proposed Plan for the
Deactivation Furnace Soils Operable Unit were released to the public on August 31, 1992. The
public comment period started on that date and ended on September 30, 1992.
-------
A public meeting was held at Armand Larive Junior High School, Hermiston, Oregon, on
September 15, 1992, to inform the public of the preferred alternative and to seek public comments.
At this meeting, representatives from UMDA, USATHAMA, EPA, ODEQ, and USACE. Seattle
District presented the proposed remedy. Approximately eight persons including media representatives
attended the meeting. There were no questions asked during the informal question-and-answer period
and no formal comments or statements were received during the public meeting. No other comments,
either verbal or written, were received by UMDA, EPA, or ODEQ during the public comment
period.
-------
Appendix A
-------
OCTOBER 20, 1992
Gregor
Ms. Dana Rassmussen
Regional Administrator
U. S. Environmental Protection Agency
'200 Sixth Avenue
Seanle, WA 98101
DEPARTMENT Of
ENVIRONMENT A I
QUALITY
Re:
Umatilla Depot Activity
Furnace Soils Operable Unit
Record of Decision
Dear Ms. Rassmussen:
The Oregon Department of Environmental Quality (DEQ) has reviewed the draft Record
01 Decision, for the Deactivation Furnace Soils Operable Unit at the U.S. Army's
Umatilla Depot Activity. I am pleased to advise you that DEQ concurs with the
remedy recommended by EPA and the Army (i.e., sOl,idification of the contaminated
soils and disposal in the Active Landfill at the Depot). I find that this alternative is
protective, and to the maximum extent practicable is cost effective, uses permanent
solutions and alternative technologies, is effective and implementable. Accordingly,
it satisfies the requirements of ORS 465.315, and OAR 340-122-040 and 090.
It is understood that placement of treated soils from this operable unit into the Active
Landfill is subject to the requirements of a closure permit for the landfill to be issued
by this Department. Although a detailed ciosure plan has not yet been received, and
a closure permit not yet issued, DEQ approves of this proposal in concf!pt. I have rio
reason to believe at this time that DEQ's final approval would be withheld.
If you have any questions concerning this maner, please contact Bill Dana of DEO's
Environmental Cleanup Division at (503) 229-6530 or Ed Liggen of DEO's EaStern
Region Office at (503) 276-4063.
Sincerely,
~~~~
WD:m
SITE\SM35\SM4741
cc: Lewis, D. Walker, DaD
l TC. William McCune, UMDA
Harry Craig, EPA-OOO
Bill Dana, SRS, DEQ
ED liggen, ERa, DEQ
Fred Hansen
Director
.
811 sw Sixth A\'cnu\'
PClrtland. OR ~7!o.J-D'!
(503) 2:!9-~"'~
TDD (5('3) ~q-nQ9~
DEQ-I
------- |