United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R08-921067
September 1992
PB93-964408
&EPA
Superfund
Record of Decision:
Ogden Defense Depot (Oper-
able Unit 3), UT
EPA Report Collection
Information Resource Center
US EPA Region 3
Philadelphia. PA 19107
u. S. Environmental Protection Agency
Region III Hazardous Waste
Technical Information Center
84 1 Chestnut Street, 9th Floor
Philadelphia I PA 19107
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NOTICE
The appendices IIstecl in the index that are not found in this document have been removed at the request of
the issuing agency. They contain material which supplement, but adds no further appIicabJe information to
the content of rite document. All suppIementaJ material is, however. contained in the administrative record
for this site.
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REPORT DOCUMENTATION \" REPORT NO. I ~ 3. Recipient'a Acceaalon No.
PAGE EPA/ROD/R08-92/067
4. ntle and SUbtlUe 5. Report Date
SUPERFUND RECORD OF DECISION 09/28/92
Ogden Defense Depot (Operable Unit 3), UT
6.
Fourth Remedial Action - Final
7. Author(a) 8. Perfonning Organization Rapt. No.
9. Perfonning Orgeinization Nome end Addre.. 10. ProjeetlTeeklWork Uni1 No.
11. Contract(C) or Grent(G) No.
(C)
(G)
12. Sponsoring Orgenlz81lon Nome and Addre.. 13. Type 01 Report & Period Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. Supplementery NOlee
PB93-964408
16. Abetrec1 (Urnlt: 200 worde)
The 1,100-acre Ogden Defense Depot (Operable Unit 3) site is a key installation in the
Department of Defense (DOD) supply system in ogden, Weber County, Utah. Land use in
the area is predominantly rural and residential. The site overlies both a shallow and
a deep aquifer, which appear to be hydraulically connected. Since 1941, oily liquid
materials and combustible solvents have been burned in pits, and solid materials have
been buried onsite, burned, or removed for offsite disposal. Several waste disposal
areas have been identified on property previously or currently controlled by the
Defense Distribution Depot Ogden, Utah (DDOU). The main onsite waste disposal areas
include (1) the WWII Mustard Agent Storage Facility; (2) the Burial Site 3-A
(consisting of four subareas: Chemical Warfare Agent (CWA) Identification Kit, Riot
Control and Smoke Grenade, Miscellaneous Items, and Compressed Gas Cylinder Reburial
Areas); and (3) the Water Purification Tablet Burial Area. From 1942 to 1946, over
1 million pounds of mustard agent were stored at the WW II Mustard Storage Facility.
In 1946, the containers were moved to Dugway Proving Ground, Utah, and subsequent
onsite sampling indicated no current contamination in this area. From the 1950's to
1960's, items also were buried intermittently at Burial Site 3-A. During a 1988 Army
(See Attached Page)
17. Document Anelyeia .. Deecriplore
Record of Decision - Ogden Defense Depot (Operable Unit 3), UT
Fourth Remedial Action - Final
Contaminated Media: soil, debris
Key Contaminants: organics (pesticides), metals (arsenic), inorganics
b. Identifiere/Open.Ended Terma
c. COSA T1 Field/Group
18. Aveilebillty Ste1emenl 19. Security Cia.. (Thie Report) 21. No. 01 Pegea
None 62
20. Security Cle.. (Thia Pege) 22. Price
None
OP 272 (4-77)
50272.101
1500 ANSI Z39.18)
See Instructions on Reverse
(Formet1y NT1~)
Deperbnenl 01 Conunerce
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EPA/ROD/R08-92/067
Ogden Defense Depot (Operable Unit 3), UT
Fourth Remedial Action - Final
Abstract (Continued)
site investigation, chemical warfare agents, VOCs, including TCE, and heavy metals were
detected in the onsite soil samples from the CWA Identification Kit Burial Area.
Pressurized gas cylinders with unknown contents were found in the Compressed Gas Cylinder
Reburial Area, and bottles containing halzone water purification tablets were found in
the Water Purification Tablet Burial Area. In 1991, investigations confirmed that ground
water underlying the site was also contaminated by VOCs. The.site has been divided into
four operable units for remediation. A 1992 ROD addressed the reduction of the principal
threat posed by contaminated soil and shallow ground water, as OU4. This ROD addresses
the potential threats to future onsite residents and Depot workers posed by contaminated
soil and debris, as OU3. Another 1992 ROD will address the contaminated ground water
underlying the site, as OU1. The primary contaminants of concern affecting the soil and
debris are organics, including pesticides: metals, including arsenic: and other
inorganics.
The selected remedial action for this site includes excavating, handsorting, and
mechanically sieving 530 cubic yards of contaminated soil and debris from the Chemical
Warfare Agent Identification Kit and the Riot Control and Smoke Grenade burial areas:
incinerating offsite any debris or soil contaminated by chemical warfare agent~ or
grenade fragments at a DOD facility; excavating soil and debris from the Miscellaneous
Items Burial Area, and treating soil and debris that does not meet TCLP treatment
standards using solidification, or another appropriate technology prior to disposal in an
offsite RCRA landfill along with the untreated debris; returning excavated soil that
meets criteria to the excavated areas; excavating and disposing of offsite compressed gas
cylinders and the water purification tablet bottles from the Compressed Gas Cylinder and
Water Purification Tablet Burial Areas. The total cost for this remedial action is
5393,000. There are no O&M costs associated with this remedial action.
PERFORMANCE STANDARD$ OR GOALS:
Chemical-specific soil clean-up goals are based on a future residential exposure
scenario, which was calculated under a residential ingestion scenario where a person was
assumed to be exposed as a 15 kg child ingesting 200 mg of soil per day for 6 years, and
also a 70 kg adult ingesting 100 mg of soil per day for 24 years. These include arsenic
35 mg/kg and mercury 2 mg/kg.
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-~~
Defense Dis"tribution Depot
Ogden, Utah
--------"---- u
Final
Record of Decision and
Responsiveness Summary
for Operable Unit 3
August 21, 1992
.... James M tv10ntgarery
.
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FINAL RECORD OF DECISION
AND
RESPONSIVENESS SUMMARY
FOR OPERABLE UNIT 3
DEFENSE DISI'RIBUTIONDEPOT OGDEN, UTAH
This is a primary document of the DDOU RIlFS.. It will be available in the Administrative.
Record, which is maintSmed at the:
Weber County Library
2464 Jefferson Avenue
Ogden, Utah
Hours:
10 am - 9 pm (Monday-Thursday)
10 am - 6 pm (Friday and Saturday)
August 21, 1992
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Defense Distribution Depot
Ogden, Utah Operable Unit 3
Declaration for the Record of Decision
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DDOU OPERABLE UNIT 3
DECLARATION
FOR THE
RECORD OF DECISION
Site Name and Location
Defense Distribution Depot Ogden, Utah
. Ogden, Weber County, Utah
Operable Unit 3 . Burial Site 3-1\, the Water Purification Tablet Burial Area, and
the World War II Mustard Storage Facility
gbIa.-t of Basis andPurpoae
This decision document presents the remedial action for Defense Distribution Depot
Ogden, Utah (DDOU) Operable Unit 3 (OU 3) selected in accordance with the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act .of 1986
(SARA) and, to the extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP). This decision is based on the Administrative Record
for DDOU OU 3.
The State of Utah Department of Environmental Quality (UDEQ) and the U.S.
Environmental Protection Agency (EPA) concur on the selected remedy presented in this
Record of Decision (ROD).
Ast~nt of'the Site
Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action selected in this ROD, may present an imminent and
substantial endangerment to public health, welfare, and the environment.
Description of the Se1ected Remedy
Operable Unit 3 is composed of Burial Site 3-1\, the Water Purification Tablet Burial Area,
and the World War (WW II) Mustard Storage Facility. The remedy for OU 3 addresses
the principal threats posed by contaminated soil and debris in these burial areas. The
remedy will remove these principal threats by excavating and disposing of contaminated
soil and debris.
Because of the variable nature of the materials buried at OU 3, two alternatives have been
combined for the soil cleanup. These alternatives apply to different areas of the site. The
selected remeqy for DOOU OU 3 consists of the following:
.
Soil and debris from the Chemical Warfare Agent Identification Kit and the
Riot Control and Smoke Grenade burial areas will be excavated, hand sorted,
and mechanically sieved. All debris and contaminated soil will be
transported off site and placed in a permitted Resource Conservation and
Recovery Act (RCRA) hazardous waste (Subtitle C) landfill. Any debris or soil
contaminated by chemical warfare agents or grenade fragments will be
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destroyed by incineration at a Department of Defense facility. All soil meeting
remediation criteria will be replaced in the excavation.
.
Soil and debris from the Miscellaneous Items Burial Area will be excavated
and transported off site for disposal in a permitted RCRA hazardous waste
(Subtitle C) landfill. Soil that does not meet treatment standards will be treated
before placement in the landfill.
.
The compressed gas cylinders from the Comp-essed Gas Cylinder Reburial
Area will be excavated and disposed of by a commercial operator.
.
The water purification tablet bottles from the Water Purification Tablet Burial
Area will be excavated and transported off site for disposal in a permitted
RCRA industrial waste (Subtitle D) landfill.
The selected alternative "will eliminate potential future exposure and risks associated with
contaminated soil and debris at OU 3. "
Statutmy DetermiDations
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
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. However, because treatment of all the principal threats of the site was
not found to be practicable, the element of the selected alternative that involves disposal of
soil and debris in a RCRA hazardous waste landfill does not satisfy the statutory
preference for treatment. Technical infeasibility and no identified hot spots preclude a
remedy in which contaminants could be treated. No soil will remain on-site with
contaminant concentrations above health-based levels, and therefore no five-year review
will be required.
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By:
UNITED STATES ENVIRONMENTAL
PROTECTION AGENCY
Jack W. McGraw
AC I G REGIONAL ADMINISTRATOR
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Date:
cr/L.-~/ 7~
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By:
Kenneth L. Alkema
EXECUTIVE DIRECTOR,
UTAH DEPARTMENT OF
ENVIRONMENTAL QUALITY
<"
. -,
Date: .
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Sff T -2-9, I C; 7 v
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DEFENSE DISTRmUTION DEPOT OGDEN, UTAH
By:
~~
M.D.Cuny,C .,USN
COMMANDING FlCER
Date: ~q2-.
..
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Defense Distribution Depot
Ogden, Utah Operable Unit 3
Decision Summary for the
Record of Decision
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TABLE OF CONTENTS
1.0 SITE NAME, LOCATION, AND DESCRIPrION
2.0 SITE HISTORY AND ENFORCEMENT ACTMTIES
2.1 Site History
2.2 Enforcement Activities
2.3 Investigation History
2.4 Community Relations History .
2.5 Scope and Role of Operable Unit 3
3.0 SITE CHARACTERIZATION
3.1 Nature and Extent of Soil Contamination
3.1.1. Chemical Warfare Agent Identification Kit Burial Area
3.1.2. Riot Control and Smoke Grenade Burial Area
3.1.3. Miscellaneous Items Burial Area
3.1.4. Compressed Gas Cylinder Reburial Area
3.1.5. Water Purification Tablet Burial Area
3.2 Public Health and Environmental Impacts
3.2.1. Contaminant Identification
3.2.2. Exposure Assessment
3.2.3. Toxicity Assessment
3.2.4. Risk Characterization
3.2.5. Uncertainties
3.2.6. Summary of Site Risks
4.0 ALTERNATIVES EVALUATION
4.1 Development of Preliminary Alternatives
4.2 Initial Screening of Preliminary Alternatives
4.3 Description of Alternatives
4.3.1. Alternative 1 - No Action
4.3.2. Alternative 2 - Institutional Controls
4.3.3. Alternative 3a - On-Site Mechanical Sieving of Soil
and Off-Site Disposal at a RCRA Permitted Landfill
4.3.4. Alternative 3b - On-Site Mechanical Sieving of Soil and
Off-Site Disposal by Incineration
4.3.5. Alternative 4a - Off-Site Disposal at a RCRA Permitted
Lan dfi II
4.3.6. Alternative 4b - Off-Site Disposal by Incineration
4.4 Comparative Analysis of Remediation Alternatives
4.4.1. Overall Protection of Human Health and the Environment
4.4.2. Compliance with ARARs
4;4.3. Long-Term Effectiveness and Permanence
4;4.4. Reduction in Mobility, Toxicity, and Volume
4.4.5. Short-Term Effectiveness
4.4.6. Implementability
4.4.7. Cost
PAGE
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Table of Contents
4.4.8. State Acceptance
4.4.9. Community Acceptance
5.0 SELECTED REMEDY
5: 1 Description of the Selected Remedy
5.1.1. Remediation Goals
5.1.2. Costs
5.2 Statutory Determinations
5.2.1. Protection of Human Health and the Environment
5.2.2. Compliance with Applicable or Relevant and Appropriate
Requirements
5.2.3. Chemical-Specific Requirements
. 5.2.4. Location-Specific Requirements
5.2.5. Action-Specific Requirements
5.2.6. To be Considered Requirements
5.3 Cost Effectiveness
5.4 Utilization of Permanent Solutions
5.5 Preference for Treatment as a Principle Element
5.6 Documentation of No Significant Changes
APPENDIX A - SOIL REMEDIATION CRITERIA
APPENDIX B - PERFORMANCE AND COMPLIANCE MONITORING PLAN
APPENDIX C - FEDERAL AND STATE CHEMICAL, LOCATION, AND
ACTION -SPECIFIC ARARs
ii
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24
24
25
26
26
26
26
Zl
Zl
Zl
28
28.
28
29
29
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Table of Contents
LIST OF TABLES
TABLE
NO.
TITLE
PAGE
1
2
3
Screening Summary for OU 3 Soil Remediation Alternatives
Comparison of Alternatives Performance at Individual Burial Areas in OU 3
Cleanup Levels and Areas of Attainment for OU 3 Burial Sites
J2
13
18
LIST OF FIGURES
FIGURE
NO.
TITLE
FOU.OWlNG
PAGE NO.
1
2
DDOU and Operable Unit 3 Location Map
Operable Unit 3 Burial Site Areas Location Map
1
2 -
iii
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DDOU OPERABLE UNIT 3
DECISION SUMMARy
FOR THE
RECORD OF DECISION
1.0 SITE NAME, LOCATION, AND DESCRIPTION
The Defense Distribution Depot Ogden, Utah (DDOU) is located at 1200 South Street and 500
West in the northwest part of the City of Ogden, Weber County, Utah as depicted in Figure 1.
The DDOU facility has been a key installation in the Department of Defense (DOD) supply
system since September 15, 1941.
DDOU covers approximately 1,100 acres in the Great Salt Lake Valley and is situated in a
semi-rural setting with the small communities of Harrisville (population 2,500) located 1.5
miles to the north, Farr West (population 1,750) three miles to the northwest, and numerous
small ranches and a few small businesses located to the west, east, and south. Walquist
Junior High School is approximately 1.5 miles to the northwest. The nearest off-Depot
residences are located about one-quarter mile to the west of Operable Unit 3 (OU 3), and the
nearest residential community is about one mile to the east.
Mill and Four-Mile creeks flow from east to west and drain the topographically flat areas of
the installation. Branches of Mill Creek flow around OU 3 and drain the southern portion
oHhe Depot. There are no wetlands within OU 3. The Depot is underlain by unconsolidated.
lacustrine and alluvial deposits of Quaternary and Recent Age.
An unused shallow water table aquifer, ranging in thickness from approximately 20 to 30
feet, underlies DDOU (including OU 3) and is classified by the State of Utah as a Class II
Aquifer, a potential future source of drinking water. Ground-water flow in the shallow
aquifer underlying OU 3 is toward the northwest. A deeper, confined aquifer has been
encountered at a depth of approximately 110 to 125 feet below the ground surface in the
northern part of DDOU. Where encountered, this aquifer exhibits strong artesian flow with
water levels in the deep wells rising above the ground surface. Regional studies indicate
that there may be some hydraulic connection between the shallow and deep aquifers. The
strong upward gradient that currently exists could potentially change in the future as a
result of excessive pumping of ground water from the deeper aquifers.
In the .past, both liquid and solid materials were disposed of at DDOU. Oily liquid
materials and combustible solvents were burned in pits, and solid materials were buried,
burned, or taken off site for disposal. Several waste disposal areas have been identified on
property. currently or formerly controlled by DDOU, and divided into four operable units.
Two of these contaminated sites (OU 1 and OU 3) are depicted in Figure 1. Under the
National Oil and Hazardous Substance Pollution Contingency Plan (NCP), "an operable
unit is a discrete part of a remedial action that can function independently as a unit and
contributes to preventing 01' minimizing a release 01' threat of a release."
Located in the southwest part ofDDOU (Figure 1), Operable Unit 3 is composed of Burial Site
3-A, the Water Purification Tablet Burial Area (formerly Burial Site 3-C), and the WW II
Mustard Storage Facility. Four distinct burial areas containing diverse types of materials
are located within Burial Site 3-A. These areas are: the Chemical Warfare Agent (CWA)
Identification Kit Burial Area, the Riot Control and Smoke Grenade Burial Area, the
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PROJECT NO.
1587.0753
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WATER PURIFICATION
TABLET BURIAL AREA
(1urt8I - SoC)
!
E8 Operable Unit 1
. Operable Unit 3
Source: UGMS Great Salt Lake and Vicinity, Utah, 1974
DDOU AND OPERABLE UNIT 3
LOCATION MAP
FIGURE 1
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Miscellaneous Items Burial Area, and the Compressed Gas Cylinder Reburial Area.
Figure 2 depicts the burial areas "in and surrounding Burial Site 3-A.
Soil sampling activities have revealed the presence of various chemical compounds and
buried debris at OU 3. Chemical warfare agents, semi-volatile compounds, and heavy
metals were detected in soil samples collected from the CW A Identification Kit Burial
Area. The volatile organic compounds 1,1,2,2-tetrachloroethane and trichloroethene were
detected in soil samples from the Miscellaneous Items Burial Area. Chloroacetophenone
and N-nitrosodiphylamine were detected in soil sampled in the Riot Control and Smoke
Grenade Burial Area. Pressurized gas cylinders were located in the Compressed Gas
Cylinder Reburial Area, and bottles containing water purification tablets were found in the
Water Purification Tablet Burial Area. No contaminants were detected in the WW II
Mustard Storage Facility.
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.1 SITE HISTORY
Burial Site 3-A. Burial Site 3-A occupies approximately one acre in the northwestern
corner of the igloo storage area (Figure 1). The site is enclosed by a 6-foot high chainlink
fence topped with strands of barbed wire. Items were buried in Burial Site 3-A
intermittently from the early 1950s through the mid 1960s. Materials found during site
investigations of Burial Site 3-A include: small glass CW A vials that were found empty,
broken, arid in some cases intact in buried trenches; riot control and smoke grenades and .
grenade fragments; compressed gas cylinders, steel cylinders, and an empty 55-gallon
stainless steel drum.
Water Purification Tablet Burial Area. While not originally part of OU 3, the Water
Purification Tablet Burial Area. formerly referred to as Burial Site 3-C, was transferred to
OU 3 from OU 1 as a result of its discovery during the 1990 OU 3 site investigation. Bottles of
. water purification tablets were buried in a single trench oriented northwest to southeast as
depicted in Figure 2.
World War n Mustard Storage Facility. Over one million pounds of mustard agent were
stored at this facility in one-ton containers from 1942 to 1946. The containers were moved to
Dugway Proving Ground, Utah, in 1946. Samples collected from the former location of the
Mustard Storage Facility confirm reports that "no problems" were ever reported with the
mustard containers.
2.2 ENFORCEMENT ACTIVITIES
A records search in 1979 by the U.S. Army Toxic and Hazardous Materials Agency
identified locations on DDOU where hazardous materials might have been used, stored,
treated, or disposed. These locations were recommended for further study.
Defense Distribution Depot Ogden, Utah was proposed for inclusion on the National
Priorities List (NPL) in 1984 and the decision was finalized in July of 1987. As a result, the
Defense Logistics Agency (DLA) conducted a study to determine the location of any past
disposal sites and the potential for ground-water contamination resulting from those sites.
. On June 30, 1986, DDOU entered into a Memorandum of Agreement with the State of Utah
Department of Health (which is now the Utah Department of Environmental Quality) and
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PROJECT NO.
1587.0753
EXPLANATION
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Burial Area
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Water Purification
Tablet Burial Area
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Scale In Feet
Miscellaneous Items
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BURIAL SITE
. 3-A
x
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Chemical Warfare Agent
Identification Kit
Burial Area
x
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xx
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xx-xx
All James M. Montgomery
OPERABLE UNIT 3
BURIAL AREAS LOCATION MAP
FIGURE 2
. DDOU OU 3 RIIFS
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the U.S. Environmental Protection Agency (EPA) to undertake a remedial
investigation/feasibility study (RIfFS) under DOD's Installation Restoration Program.
In November of 1989, DDOU entered into a Federal Facility Agreement (FFA) between
DDOU, EPA, and UDOH. The purpose of the agreement was to establish a procedural
framework and schedule for developing, implementing, and monitoring appropriate
response actions at DDOU in accordance with existing regulations. In response to the FFA,
DDOU was divided into four operable units. The FFA requires the submittal of several
primary and secondary documents for each of the operable units at DDOU. This ROD
concludes all of the RIfFS requirements for OU 3.
2.3 INVESTIGATION HISTORY
From 1981 through 1991, shallow monitoring wells were installed at or near OU 3 to
investigate the quality of shallow ground water underlying OUs 1 and 3. Ground water
sampled from these wells indicates the presence of volatile organic compounds (VOCs), but
chemical warfare agents and thiodiglycol, the primary breakdown product of mustard,
have never been detected in the shallow ground water underlying OU 3.
In 1985, a survey of aerial photographs was conducted to delineate waste disposal areas. at
OU 3. Ground disturbances were identified from photographs dated 1952, 1958, and 1965,
primarily in the Burial Site 3-A area. A geophysical survey using magnetics was
conducted to confirm the presence of burial areas observed on the aerial photographs.
Twenty-four test pits were excavated in Burial Site 3-A by the U.S. Army Technical Escort
Unit (TEU) from mid May to June of 1988 to investigate areas considered suspect based on
geophysical investigations, evaluations of aerial photographs, and visual inspections. All
CW As discovered during the investigation were removed, labeled, and shipped by the TEU
to the Tooele Army Depot for disposal. A preliminary baseline health evaluation and
environmental assessment recommended that additional sampling and analysis of air,
ground water, surface water, and soil be conducted in the Burial Site 3-A vicinity.
In November of 1989, another geophysical survey was conducted using magnetics, ground
penetrating radar, and electromagnetic induction to delineate buried trenches in the Burial
Site 3-A area. Results indicated the presence of several possible trenches in and
surrounding Btirial Site 3-A. .
Additional site characterization activities were conducted in July and August of 1990,
including installation of additional shallow ground-water monitoring wells
down gradient of the WW II Mustard Storage Facility and Burial Site 3-A. Although VOCs
were detected in ground-water samples from the shallow aquifer underlying OU 3, no
thiodiglycol or mustard was detected.
Between November 1990 and January 1991, 36 test pits were excavated and sampled at Burial
Site 3.A. Soil samples were analyzed for CWAs, VOCs, semi-volatile organics (SVOCs).
pesticides, PCBs, metals, and pH. Although soil sample results indicated no CW A
contamination, VOCs. SVOCs, pesticides, and metals were present in distinct burial areas
within Burial Site 3-A. Six burial areas were identified containing a wide variety of
debris. During the same investigation, 14 soil borings were drilled and 20 soil samples
were collected for mustard and lewisite analysis in the WW II Mustard Storage Facility.
No soil contamination was detected. Air monitoring for CWAs during the test pit
excavations in Burial Site 3-A indicated no CWAs were present in the atmosphere during
the 1990 investigation. .
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In June of 1991, one monitoring wen was installed and sampled in the Miscellaneous Items
Burial Area.. A ground-water sample collected from the monitoring well confirmed the
presence ofVOCs in the ground water beneath OU 3. .
2.4 COMMUNITY RELATIONS HISTORY
The RI/FS Report and the Proposed Plan for DDOU OU 3 were released to the public on
December 6, 1991 and March 4, 1992, respectively. These documents were made a'-!lilable to
the public in both the Administrative Record and an information repository maintained at
DDOU and the Weber County Library. The notice of availability for these two documents
was published in the Salt Lake Tribune, the Deseret News, and the Ogden Standard
Examiner on March 4, 5, and 6, 1992.
A public comment period was held from March 14, 1992 through April 13, 1992 and a public
meeting was held on March 26, 1992. At the public meeting, representatives from DDOU,
EPA, and UDEQ presented the prefeTred alternative and answered questions. A court
reporter prepared a transcript of the meeting. A copy of the transcript and all written
comments received during the comment period have been placed in the Administrative
Record. In addition, copies of the transcript were sent to interested meeting attendees. A
response to the comments received during the public comment period is included in the
Responsiveness Summary, which is in the final section of this ROD. This decision
document presents the selected remedial action for DDOU OU 3, chosen in aCC
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3.1.1. Chemical Warfare Agent Identification Kit Burial Area
During the 1988 site investigation, vials of CW As used for training were recovered and
removed from this burial area. Although one sample contained the CWAs adamsite at
134 milligrams per kilogram (mg/kg) and mustard at 5,000 mg/kg, this contamination
was caused by the release of CW As from vials that were accidentally broken during the
site investigation. Since CW As are unstable in the environment, they are not normally
expected to be present in the soil. Semi-volatile organic compounds (hexachoroethane
at 0.55 mg/kg, chloroacetophenone ranging from 2.5 to 2.9 mg/kg, and
N-nitrosodiphenylamine at 0.75 mg/kg), and pesticides (delta-BHC at 0.0078 mg/kg and
4,4-DDE ranging from 0.015 to 0.130 mg/kg) were detected in soils during the 1988 and 1990
investigations. Elevated levels of metals including arsenic (559 mg/kg), lead (44.4
mg/kg), mercury (9.8 mg/kg), and barium (ranging from 153 to 248 mg/kg) were also
detected. The estimated volume of soil and debris -in this burial area is approximately 100
cubic yards, based on a disturbed area of approximately 40 by 22 feet, and a depth of 3 feet.
However, it is estimated that only about one percent of this mixture contains debris. The
semi-volatile organic compounds are not expected to be mobile, and chloracetophenone
should degrade via hydrolysis. While many variables affect the mobility of the metals,
arsenic is likely to be mobile, while the other metals are likely to migrate slowly.
3.1.2. Riot Control and Smoke Grenade Burial Area
. Numerous unfused grenades and grenade fragments have been found in this burial area.
Chloroacetophenone, a tear gas \1sed in riot control grenades, was detected in one soil -
sample at a concentration of 170,000 mg/kg. Only one semi-volatile organic compound
(N-nitrosodiphenylamine at 0.75 mg/kg) and one pesticide (4,4-DDE at 0.13 mg/kg) were
detected. The metals barium (153 to 225 mg/kg), lead (17.1 mg/kg), nickel (19.5 mg/kg),
and zinc' (55.0 mg/kg) were also detected but at levels near background concentrations,
indicating that no metals contamination exists in this burial area. The estimated quantity
of soil and debris in this burial area is approximately 90 cubic yards, based on a disturbed
area of approximately 33 by 24 feet, and a depth of 3 feet. However, it is estimated that only
about one percent of this area contains debris. The contaminants found in this area are
relatively immobile, and chloroacetophenone is subject to degradation via hydrolysis.
3.1.3. Miscellaneous Items Burial Area
Numerous CWA detection kits containing no CWAs, World War II gas mask canisters,
two one-gallon containers of paint, broken glass, wooden boxes, and pieces of iron were
encountered in this area. The VOCs 1,1,2,2-tetrachloroethane (ranging from 0.008 to 0.13
mg/kg) and trichloroethene (0.21 mg/kg) and the metals cadmium (0.63 mg/kg) and zinc
(74.5 mg/kg) were detected in soil samples from this burial area. The estimated volume of
soil and debris in this burial area is 230 cubic ,yards, based on a disturbed area of
approximately 83 feet by 19 feet, and a depth of 4 feet. It is estimated that approximately 25
percent of this material is debris. Although the VOCs have migrated to the shallow ground
water, the metals are much less mobile..
3.1.4. Compressed Gas Cylinder Reburial Area
This area was used to rebury compressed gas cylinders excavated from other burial areas
during the 1988 site investigation activities. These items were buried in a 2-foot wide by 15-
foot long trench approximately 2 feet below the ground surface. The Compressed Gas
Cylinder Reburial Area contains two compressed gas cylinders and four smaller steel
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tanks removed from the CW A Identification Kit and Riot Control and Smoke Grenade
burial areas. The contents of the cylinders and steel tanks are unknown.
3.1.5. Water Purification Tablet Burial Area
Although a large number of bottles containing halazone water purification tablets were
found in this burial area, no contamination was found in the soil surrounding and beneath
the bottles. The burial trench is appro?rimately 3 feet wide, 6 feet deep, and 175 feet long. . The
volume of soil and deb~s in this burial area is estimated at 110 cubic yards.
3.2 PUBLIC HEALTH AND ENVIRONMENTAL IMPACTS
A baseline risk assessment was conducted for au 3 following completion of the site
characterization activities. The purpose of this assessment was to determine the most
significant contaminants present at OU 3, the different ways by which people, plants, and
animals could potentially come into contact with the contaminants, and the probability of
any harmful effects occurring as a result of that contact. The medium of concern for au 3
was the soil and debris in the Burial Site 3-A and the Water Purification Tablet burial
areas. Because ground water affected by the burial areas has similar contaminants to and
is within the contaminant plume of OU 1, the contaminants, the potential exposure, and the
potential health risks are addressed as part of the remedy for au 1.
Results of the health risk assessment for au 3 indicate that currently there are no complete
and significant exposure pathways within OU 3. However, arsenic in the soil in the CWA -
Identification Kit Burial Area could pose a future chronic risk to human health. In
addition, there are three potential sources of acute risks: intact vials of CW A still buried
within the CW A Identification Kit Burial Area that could cause an acutely toxic dermal or
inhalation exposure; buried halazone water purification tablets could cause adverse health
effects if they were ingested in sufficient quantity; and buried gas cylinders could be a
physical hazard if punctured, assuming that one or more are still pressurized. No current
or future environmental effects are expected to occur as a result of contaminants present at
OU3.
3.2.1. Conta1n;l"ISll"It Identification
The initial step of .the risk assessment was the selection of contaminants of potential
concern. These consisted of all compounds present above background concentrations with
a reasonable potential to cause adverse health affects. Compounds at background
concentrations included several metals present at levels expected to be found in
uncontaminated soils in the vicinity of DD.oU, and the pesticides DDE and delta-BHC,
which were present at levels corresponding to an anthropogenic background in agricultural
. areas. Chemical compounds selected as contaminants of potential concern and their
maximum detected concentrations were: arsenic (559 mg/kg), barium (248 mg/kg) , lead
(44 mg/kg) , mercury (9.8 mglkg), zinc (75 mglkg), N-nitrosodiphenylamine (0.75 mg/kg),
1,1,2,2-tetrachloroethane (0.13 mglkg), and trichloroethene (0.21 mglkg), the CWAs
adamsite (134 mglkg), chloroacetophenone (2.9 mglkg) , and mustard (5,000 mg/kg), and
the mustard degradation product thiodiglycol (120 mglkg). Also included as contaminants
. of potential concern were chloropicrin, lewisite, and phosgene. Although these CWAs were
not detected in soil, they were found in intact vials that were removed during the 1988
investigation.
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3.2.2. Exposure Assessment
No current exposure pathways were considered complete. However, a significant potential
future exposure to contaminated soil or dust may exist for dust inhalation or soil ingestion
by construction 'workers, or future residents. in additiori, construction workers or residents
could be exposed to three acute hazards: dermal or inhalation exposure to a broken vial of
CW A the physical hazard associated with a punctured compressed gas cylinder; or
ingestion of halazone tablets.
3.2.3. Toxicity Assessment
Cancer slope factors have been developed for estimating excess lifetime cancer risks
associated with exposure to potentially carcinogenic chemicals. Reference doses have
been developed for indicating the potential for adverse health effects from exposure to
chemicals exhibiting non carcinogenic effects. All conventional carcinogenic
compounds had slope factors except for N-nitrosodiphenylamine, which did not have an
inhalation slope factor for use in evaluating the risk to construction workers from
inhalation of contaminated dust. No reference doses were available for lead,
N-nitrosodiphenylamine, or 1,1,2,2-tetrachloroethene; no inhalation reference doses were
available for arsenic, trichloroethene, or zinc. Because the remedy for au 3 was not based
on the risk assessment, the values of the reference doses and slope factors and their sources
are not presented here.
The toxicity of the CWAs were evaluated qualitatively, with an emphasis on the potential
acute affects of each agent. The dose necessary to cause adverse acute health effects was
evaluated for halazone tablets by examining both animal and human data in the
toxicology literature. Reference doses and slope factors are not applicable to the gas
cylinders because the primary concern is a physical hazard. Without knowledge of the
contents of the cylinders, the nature of any additional toxic hazard could not be evaluated.
3.2.4. Risk Characterization
Excess lifetime cancer risks are determined by multiplying the intake by the cancer slope
factor. These risks are probabilities that are generally expressed in scientific notation
(e.g., 1 x 10-6). An excess lifetime cancer risk of 1 x 10-6 indicates that, as a plausible
upper bound, an individual has a one in one million chance of developing cancer as a
result of chronic site-related exposure to carcinogens over a 70-year lifetime under the
specific exposure conditions at the site. The target risk level for a site is 1 x 10-6, although a
value in the range of 1 x 10-4 to 1 x 10-6 may be acceptable.
Potential concern for non carcinogenic effects of a single contaminant in a single
medium is expressed as the hazard quotient. By adding the hazard quotients for all
contaminants within a medium and across all media to which a given population may
reasonably be exposed, a hazard index can be generated. A hazard index greater than 1
indicates that there may be a concern for potential health effects, while a hazard index less
than 1 indicates that the concern for potential health effects is quite low.
The potential carcinogenic risk to future construction workers who are exposed to
conventional contaminants in soils within au 3 (i.e., not CWAs) is on the order of 2 x 10-4,
while the hazard index was e!)timated to equal 1. The total hazard index for future adults
in a residential soil ingestion scenario was estimated to equal 3, while the carcinogenic
risk was estimated to equal 6 x 10-4. The estimated future carcinogenic risk to children for
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this scenario was estimated to equal 1 x 10-3, and the total hazard index was estimated to
equal 10. These are significant risks. They result from the presence of arsenic, which
was detected above background levels in the CW A Identification Kit Burial Area, and is
believed to be associated with the degradation of adamsite. If arsenic were not present, the
potential cancer risks and hazard indices would have been estimated to be less than 1 x 10-6
and 1, respectively, for all scenarios.
For the CW As, the most severe effects could result from encountering phosgene or
mustard. Inhalation of the contents of a single vial of phosgene could cause death, while
dermal exposure to a vial of mustard could cause severe, irreversible effects. For the other
agents (as specified in Section 3.2.1.), exposure to a single vial would be expected to cause
only ~mporary symptoms such as eye irritation or nausea.
The health effects caused by the ingestion of a bottle of halazone tablets by a small child are
uncertain, but could include nausea and vomiting. There is a possibility that the dose
would be fatal if a sufficient number of tablets were consumed. It should be noted that the
dose of one bottle of tablets is arbitrary. With lower doses (such as a single tablet) the
probability of any effects occurring is reduced, as would be the severity of any affects that
did occur. Conversely, the likelihood of adverse affects occurring would increase if more
than one bottle of tablets were consumed.
Although observations indicate that most of the buried gas cYlinders are no longer intact, at
least one large cYlinder may still contain an unidentified compressed gas. This cYlinder
may pose a significant physical hazard. The nature of any risk from the toxicity of the
contents is unknown.
Based on the following conclusions, no significant environmental threats appear to be
associated with OU 3. First, contaminated soil and debris are buried, limiting any
potential effects these materials may have on burrowing animals and long-rooted plants.
Because CW As are not expected to accumulate through the food chain, the potential for these
compounds to have a significant ecological impact is reduced. Second, the affected area at
OU 3 is small, which limits the potential for the site to have an observable impact on the
overall ecosystem. Third, there are no receptors for which the potential loss of either a
small area of land or a small number of individuals would be considered a significant
loss to the overall ecosystem as the area does not serve as critical habi~t for plants or
animals, endangered species visit the area only occasionally, and those species that
inhabit OU3 are generally not native to the area. Fourth, because CWAs are designed to
degrade rapidly in the environment and because conventional contaminants have been
detected above background only a small percentage of the time, the average exposure would
be much lower than indicated by the maximutn concentrations of the contaminants.
3.2.5. Uncertainties
The risk estimates for conventional contaminants were based on the maximum detected
contaminant concentrations obtained from a biased sampling design, implying that the
risks were overestimated. The total cancer risk and hazard index are primarily derived
from arsenic, which was detected at high concentrations only in the CW A Identification
Kit Burial Area. While the risks calculated may be representative of this area, they are
unlikely to be representative of au 3 as a whole, or a reasonable area of exposure.
Contaminants such as trichloroethene and 1,l,2,2-tetrachloroethane may be present at
higher than assumed concentrations, because they were detected in samples where the
holding times were exceeded. However, these VOCs were not detected in samples collected
at a depth 2 feet below where these compounds were originally detected. Therefore, the
-8-
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extent of contamination is small, and the average VOC concentration over a reasonable
area of exposure would not be expected to be higher than the VOC concentrations used for
estimating the potential risk.
Risk characterization of CW As was based on the assumption that buried intact vials are
still present. However, it is unlikely that large quantities of intact vials are still present
because Burial Site 3-A has been intensively sampled and all observed CW A vials were
removed in 1988. High concentrations of undetected residuals from previously broken
vials are unlikely to be present because agents are generally not persistent in the
environment. However, the potential to encounter an individual unbroken vial cannot be
ruled out.
3.2.6. Sl1nnnSlpY of Site Risks
Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action selected in this ROD, may present an imminent and
substantial danger to public health, welfare, or the environment. There are no current
significant risks to human health and the environment from exposure to soil at OU 3, nor
are significant risks likely to develop in the future as long as the Depot remains in
existence. However, there could be a significant potential for both carcinogenic and non
carcinogenic health effects to occur should construction workers conduct excavations
within the CWA Identification Kit Burial Area, or should adults or children ingest soil
from this area. Significant risks may also be associated with exposure to intact vials of
CWAs, intact compressed gas cylinders, and bottles of water purification tablets.
4.0 ALTERNATIVES EVALUATION
The selected remedial action must be protective of human health and the environment, be
cost effective, and attain Federal and State applicable or relevant and appropriate
requirements (ARARs), under Section 121 of SARA.. The selected alternative must also use
permanent solutions and alternative treatment or resource recovery technologies to the
maximum extent practicable. Remedies that employ treatment that permanently and
significantly reduces the mobility, toxicity, or volume of hazardous substances is a
statutory preference. This section summarizes how alternatives for remediation of soils at
au 3 were developed, screened, and finally selected.
4.1 DEVELOPMENT OF PRELIMINARy ALTERNATIVES
Preliminary alternatives that represent the range of available remediation options were
developed starting with the no-action alternative. Subsequent alternatives represented an
increasing degree of technical complexity. Each alternative contains different processes
and extent of remediation for soil at au 3.
The main features of the five preliminary soil alternatives are:
1.
No Action - No remedial action would be taken to reduce the levels of
contamination in the soil at OU 3.
2.
Institutional Controls - Legal and administrative actions would be taken to
limit potential exposure under both current and future use scenarios.
Compressed gas cylinders would be excavated, tested, and removed from
DDOU.
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3.
Containment - The potential for human exposure and/or contamipation of
ground water due to soil contamination would be reduced by covering each
burial site with a clay cap and controlling run-on and run-off.
Containment of potential sources by a slurry cut-off wall intercepting the
silty clay layer underlying the burial sites would also reduce the potential
for the soil to act as a continuing source of ground-water contamination.
Compressed gas cylinders would be excavated, tested, and removed from
DDOU.
4.
On-Site Mechanical Sieving of Soil and Off-8ite Disposal- Contaminated
soil and debris within each burial site would be excavated and sieved to
remove debris. The excavated soil would then be analyzed and if levels of
contaminants comply with cleanup standards, the soil would be returned to
the excavation. Soil that does not meet cleanup .standards and all debris
would be removed from DDOU and disposed of at an off-site RCRA
hazardous waste (Subtitle C) landfill facility or incinerated at a RCRA
permitted facility. The water purification tablets would be disposed of at a
RCRA industrial (Subtitle D) landfill. Compressed gas cylinders would be
excavate.d, tested, and removed from DDOU.
5.
Off-Site Disposal - With the exception of the water purification tablets,
contaminated soil and debris within each burial site would be excavated and
transported off site to a RCRA hazardous waste (Subtitle C) landfill or
incinerated at an RCM permitted facility. The water purification tablets
would be disposed of at a RCRA industrial (Subtitle D) landfill. Compressed
gas cylinders would be excavated, tested, and removed from DDOU.
Burial areas containing CW A, volatile organic compounds, halazone tablets, and
pressurized gas cylinders are the principal threats at OU 3. Therefore, removal of soil and
debris containing these materials and contaminants is the primary concern fOT
remediation at OU 3.
Chemical Warfare Agent Contingency Plan. Due to the possibility that CWAs may be
encountered during the OU 3 cleanup, several precautionary measures would be taken to
minimize the potential for on-site worker and public exposure to these. chemicals.
Personnel from the U.S. Army Technical Escort Unit (TEU) who are trained in the
identification and handling of CW As would be present during all excavation activities at
OU 3, including the Miscellaneous Items Burial Area, the Compressed Gas Cylinder
Reburial Area, and the Water Purification Tablet Burial Area. In the event that CWA
materials are encountered, all civilian personnel would leave the excavation area and
TEU personnel would assume control of the site. If agent-contaminated soils are detected,
TEU personnel would hand-dig and containerize the affected soil and transport it, along
with any CWA material, to a Department of Defense chemical munitions disposal facility
for destruction by incineration in accordance with Department of Defense regulations. The
DOD chemical munitions disposal facility is designed for the destruction of the entire
ordnance item and will be permitted for the destruction of lewisite and other CW As that
contain arsenic as a principle constituent. TEU would ensure that the excavation is free of
CWAs and decontaminate all affected equipment before work would be allowed to resume.
Monitoring of air quality and dust suppression would be carried out at all times to protect the
public and control dust emissions during site cleanup.
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4.2 INITIAL SCREENING OF PRELIMINARY ALTERNATIVES
Preliminary alternatives were screened using three broad criteria: effectiveness,
implementability, and cost. The purpose of this screening was to reduce the number of
alternatives requiring a detailed analysis. Comparisons were made among those
alternatives that offered similar functions or extent of remediation. Table 1 indicates how
each alternative compared with the three major criteria.
The end result of the screening process was a shortened list of alternatives for remediation
of soil at au 3 that were recommended for detailed analysis. The initial screening
retained those alternatives that appeared more effective, easier to implement, and less
costly than other alternatives offering a similar level of protection or extent of remediation.
The selected proposed remediation alternatives for au 3 are as follows:
Alternative 1 ~ No Action
Alternative 2 - Institutional Controls
Alternative 4 - On-Site Mechanical Sieving of Soil and Off-Site Disposal
Alternative 5 - Off-Site Disposal
Alternative 3 was eliminated because compliance with Department of Defense ARARs
regarding CWA and clean closure could not be achieved, future land use would be limited,
and long-term effectiveness could not be assured.
4.3 DESCRIPTION OF ALTERNATIVES
To aid in tracking the selected alternatives through the detailed analysis, Alternatives 4
and 5 were renumbered as Alternatives 3 and 4. In addition, the renumbered Alternatives
3 and 4 have options for off-site disposal at a RCRA permitted landfill or at an off-site
RCRA permitted incinerator. For this reason, Alternatives 3 and 4 have been further
divided into Alternatives 3a and 3b and 4a and 4b, respectively. The alternatives are listed
below:
Alternative
No Action
Institutional Controls
On-Site Mechanical Sieving of Soil and Off-Site Disposal at a RCRA
Permitted Landfill
:b On-Site Mechanical Sieving of Soil and Off-Site Disposal by
. Incineration
4a Off-Site Disposal at a RCRA Permitted Landfill
4b Off-Site Disposal by Incineration
Alternative 1
Alternative 2
Alternative 3a
Alternative
Alternative
4.3.1. Alternative 1 . No-Action
No remedial action would be taken to reduce the levels of contamination detected in soil
within au 3. Therefore, Alternative 1 does not reduce the risk to human health and the
environment. A no-action alternative is not required to comply with ARARs. The
indirect, capital, operating, and maintenance costs associated with this alternative are
presented in Table 2, as are estimates of net present worth costs based on a statutory review
every five years.
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TABLE 1
SCREENING SUMMARY FOR OU 3 SOIL REMEDIATION ALTERNATIVES
Implement-
Alternative Effectiveness abUity Cost Selected Comments
1. No Action Pcxr Excellent Excellent . Yes Represents baseline case for
comparison.
Does not prevent continued
contamination of ground water.
2. Institutional Controls Pcxr Excellent Good Yes Affords non-invasive exposure
control.
Potentially applicable to some
burial areas.
Does not prevent continued
contamination of ground water.
.
~ 3. Containment (Slurry Fair Good Poor No May not provide 8n effective long-
I
Wall and Cap) term solution.
Clean closure is not achieved.
4. On-Site Mechanical Good Good Fair Yes Eliminates the potential80UI'OO
Sieving of SOU and Off. areas.
Site Disposal Is cost effective and would allow
clean closure.
5. Off-Site Disposal Good Good PoĞr Yes Eliminates the potential80UI'OO
areas.
Would allow clean closure.
Bold indicates a selected alternative.
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TABLE 2
COMPARISON OF ALTERNATIVES
PERFORMANCE AT INDMDUAL BURIAL AREAS IN OU 3
Alternative 3D Alternative 3b
On-Blte Mechanical On-Site Alternative 4a
Sieving 0' SOU and Off. Mechanical Off-Slte DIspoeal Alternative 4b
Alternative 2 Site Dispc8d at a Sieving 0' Soil and ataRCRA ()ft'.Si te
Evaluation Alternative 1 Inatitutional RCRA Permitted Off-Slte DIsposal Permitted Disposal by
Criteria No Action Contl"ols Landfill by incineration LandnU Incineration
TIlRESHOLD CRITERIA
1. Overall Protection 0' Human Health and the Environment
Chemicill Warfllre Agent Identification Kits A 0 . . . 8
Riot Control and Smoke Grenades . . . 8 8 .
Miscellaneous Items A A . 8 8 .
Water Purification Tablets A 0 . 8 . .
, Compressed Gas Cylinders A . 8 . 8 .
....
Cf
2. Compliance with AltARs
Chemlcill Warfare Agent Identification Kits Not Required A 8 . . .
Riot Control and Smoke Grenades Not Required 8 . . . 8
Miscellaneous Items Not Required A 8 . 8 .
Water Purification Tablets Not Required . . . . .
Compressed Gas Cylinders Not Required . . . . 8
BAi..ANCING CRITERIA
3. Loq.Term Eflectiven- and Permanence
Chemical Warfare Agent Identification Kits A 0 . . . .
Riot Control and Smoke Grenades A 0 . . . .
Miscellnneous Items A A 0 0 8 8
. Meets criterion.
o Pnrtially meets criterion.
A Does not meet criterion.
NA Not Applicable
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TABLE 2
COMPARISON OF ALTERNATIVES
PERFORMANCE AT INDIVIDUAL BURIAL AREAS IN OU 3
(CONTINUED)
AltErnative 3a Alternadve 3b
On-Blte Mechanical On-Bite Alternative .fa
Slevinc of SOU and Off. Mechanical Off-Blte DIspoeaI AltErnative 4b
Aitemative 2 Site DI&pc.Il at a Slevinc of SOU and at a RCRA Off.SUe
Evaluation Alternative I institutional RCRA P..-mItted Off-Blte DIspoeaI P..-mItted DIspoeaI by
Criteria No Adion Conlnlle Landfill bY Incineration LandfiU incineration
Water Purification Tablet. fj. 0 . . . .
Compressed Gas Cylinden fj. . . . . .
4. Reduction In Mobility, To:dcilty, and Volume
Chemical Warfare Agent Identification Kits fj. fj. 0 0 0 0
Riot Control and Smoke Grenades fj. fj. 0 . 0 .
I Miscellaneous Items fj. fj. 0 . 0 .
......
~
, Water Purification Tablets fj. fj.
. . . .
Compre88ed Gas Cylinden fj. . . . . .
6. Short.Term Effectlven-
Chemical Warfare Agent Identification Kits . . . . . .
Riot Control and Smoke Grenades . . . . . .
Miscellaneous Items . . . . . .
Water Purification Tablets . . . . . .
Compressed Gas Cylinden . . . . . .
88. ImplementabWty ('i'echnlcal)
Chemical Warfare Agent Identification Kits . . . . . .
Riot Control and Smoke Grenades . . . . . .
. Meets criterion.
o Partially meets criterion.
fj. Docs not meet criterion.
NA Not Applicable
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TABLE 2
COMPAIUSON OF ALTERNATIVES
PERFORMANCE AT INDMDUAL BURIAL AREAS IN OU 3
(CONTINUED>
AltErnative 3a Alternative 3b
. On-Slte Mechanical On-Slte Alternative 4a
Sieving 01 SOU and Off. Mechanical otr-Slte DisposaJ AltErnative 4b
Altemative 2 Site DIspoea1 at a Sieving or Soil and a&a RCRA Off.Slte
Evaluation Alternative I Inadtutional RCRA Permitted Off-Slte DIspoea1 Permltted Dispoea1 by
Criteria No Action Contl'ols Landfill by incineration Landran incineration
Miscellancous Items . . . . . .
Water Purification Tablets . . . . . .
Compressed Gas Cylinders . . 0 0 0 0
8b. Implementability (Adml.nlstratlve)
Chemical Warfare Agcnt Identification Kits . . 0 0 0 0
Riot Control and Smoke Grenadcs . . 0 0 0 0
,
~
C11 Miscellancous Items
, . . . . . .
Water Purificalion Tablets . . . . . .
Compressed Gas Cylinders . . . . . .
7. Cost
Current Present Worth $) $160,000 $362,000 $570,000 $410,000 $1,792,000
f).Year Prcsent Worth $3,920 $165,000 NA NA NA NA
IO-Year Present Worth $6,990 $184,000 NA NA NA NA
20-Year Present Worth $11,300 $201,000 NA NA NA NA
8. State Aooeptahce /:} 0 . . . .
9. Community Aooeptanoo /:} 0 . . . .
. Meets critcrion.
o Partially mceta criterion.
/:} DOC8 not meet criterion.
NA Not Applicable
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4.3.2. Alternative 2 - Institutional Controls
Modi :ations in the property deeds and facilities drawings would be made to provide
information regarding the presence of hazardous materials in the soils at Burial Site 3-A.
Perimeter fencing would be periodically inspected, and site access woula continue to be
restricted. Compressed gas cylinders would be excavated and disposed of off site and no
other materials or debris would be removed from the site.
This altePJlative does not comply with the State of Utah regulation R450-101 because
contaminants detected in the Miscellaneous Items Burial Area are a source of
contamination at OU 3. The regulation requires that any corrective action at a RCRA,
CERCLA, or UST site begin with elimination of the source(s) of contamination through
removal or control. Also, since the CW A Identification Kit and Miscellaneous Items
burial areas may contribute to cross-media contamination, the State of Utah Ground-
Water Protection Statute (R448-6) would be violated. In the event of the sale ofland at OU 3
in the future, the requirements of CERCLA section 12O(h) would have to be complied with.
The indirect, capital, operating and maintenance costs associated with this alternative are
presented in Table 2, as are estimates of present net worth costs based on a 20-year
monitoring period and a statutory review every five years.
4.3.3. Alternative 3a - On-Site Mechanical Sieving of Soil and Off.Site Disposal at a
RCRA Permitted Landfill
Each burial area within OU 3 would be excavated individually, and the buried debris
would be removed from the soil by hand sorting and/or mechanical sieving. Debris is
considered to be any buried material other than soil, rock, or vegetation. Excavation would
proceed in each burial area until the following criteria are achieved in the soils forming
the perimeter of the excavation:
.
Removal of all debris encountered during excavation.
.
Removal of all visually contaminated soil.
.
Removal of soil and debris with contaJDinants that pose a cancer risk under a
residential ingestion scenario greater than one in ten thousand, with a target
risk of one in one million, wherever practicable. Contaminant concentrations
associated with a cancer risk of one in ten thousand are specified in
Appendix A.
.
Removal of soil and debris with contaminants at concentrations corresponding
to a hazard index greater than one under a residential ingestion scenario.
Contaminant concentrations required to meet this criterion are specified in
Appendix A
.
Removal of soil and debris with detectable CW A contamination in accordance
. with the CWA Contingency Plan. . .
.
Removal of all water purification tablet bottles.
Excavated soil that has been separated from the debris would be stockpiled and tested for
compliance with the cleanup standards specified above and toxicity characteristic
leaching proce -:ure (TCLP) criteria for tc~:ic characteristics. To ensure compliance with
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the RCRA land disposal restrictions (LDRs), the soil from each burial area excavation
would be subjected to tests that relate to the contaminants found in that particular burial
area. Soil that passes the cleanup criteria would be replaced in the excavations.
Soil that fails the cleanup criteria defined above, or contains RCRA listed or characteristic
hazardous wastes, would be transported off site, treated if necessary using stabilization!
fixation or some other method that complies with LDRs, and disposed of in a RCRA
hazardous waste (Subtitle C) landfill. Screened debris would also be tested for hazardous
characteristics using TCLP to ensure correct waste classification, and transported, along
with soil that fails the cleanup criteria, to the RCRA landfill disposal facility. Water
purification tablet bottles would be disposed of at a RCRA industrial (Subtitle D) landfill
because they are neither a listed hazardous nor characteristic waste. Compressed gas
cylinders would be excavated and disposed of off site.
Any CWAs encountered in soil or debris during implementation of Alternative 3a would
be excavated, transported, and disposed of by certified DOD personnel according to the
CWA Contingency Plan described in Section 4.1. Materials contaminated by CWAs
would be transported to a DOD disposal facility for deactivation by incineration. This
action would be implemented only if CWAs are encountered. No CWA contaminated
materials would be transported to or disposed of at a non-military commercial facility.
Because the sources. of contamination would be removed from OU 3 by implementation of
Alternative 3a, ARARs regarding source control would be met at each burial area. These
ARARs include Utah Administrative Code (UAC) R450-101, which requires removal or
control of sources involved in corrective actions under CERCLA., and R448-6, which would
impose discharge and ground-water monitoring requirements in the absence of source
control. Land disposal restrictions would be met by testing soil using TCLP, and treating
soil that does not pass this test at the landfill facility. Permit requirements for VOC
emissions of 1.5 tons per year under the Utah Air Conservation Rules would not be
applicable as there are less than 1.5 tons of VOCs buried within OU 3. The congressional
mandate regarding the disposal of CW As and CW A-contaminated materials by
incineration is met by the CW A Contingency Plan. All other ARARs listed in Appendix C
would also be met. .
The costs associated with Alternative 3a are listed in Table 2. The area of attainment for
each burial area and cleanup levels are listed in Table 3. The estimated remediation time
frame for this alternative is less than one year.
4.3.4. Alternative 3b - On-Site Mechanical Sieving of Soil and Off-Site Disposal by
Incineration .
Alternative 3b is identical to Alternative 3a except that all separated debris and
contaminated soil would be transported off site for incineration at a permitted RCRA
incinerator instead of to a RCRA landfill. Water purification tablet bottles would be
disposed of at a RCRA industrial (Subtitle D) landfill because they are neither a listed
hazardous nor characteristic waste. Compressed gas cylinders would be excavated and
disposed of off site.
Any CWAs encountered in soil or debris during implementation of Alternative 3b would
be excavated, transported, and disposed of by certified DOD personnel according to the
CW A Contingency Plan described in Section 4.1. Contaminated materials would be
transported to a DOD disposal facility for deactivation by incineration. This action would
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TABLE 3
CLEANUP LEVELS AND AREAS OF ATTAINMENT FOR OU 3 BURIAL SITES
Type of Cleanup Area of
Burial Area Nature of Buried Items ContAmin"nts Level Attainment
Chemical Warfare Agent Vials of chemical warfare agents, CWAs Non Detection 100 cubic yards
Identification Kit Burial Area broken glass BNAEs Health Based(a)
Metals Health Based(a)
Riot Control and Smoke Decomposing grenades and wire BNAEs Health Based(a) 90 cubic yards
Grenade Burial Area bundles Metals Health Based(a)
Miscellaneous Items Burial Lead foil covered test kits, air VOCs Health Based(a) 230 cubic yards
. Area purification canisters, containers Metals Health Based(a)
~
00 of VOCs and unknown organic
.
compounds, and other items
Water Purification Tablet Thousands of small glass jars None Removal 110 cubic yards
Burial Area containing halazone ta~lets
Compressed Gas Cylinder Several cylinders of compressed Unknown Removal NE
Reburial Area gas
530 cubic yards
NE
CWAs
VOCs
BNAEs
Not estimated
Chemical Warfare Agents
Volatile Organic Compounds
Base, Neutral, or Acid Extractables (semi-volatile organic compounds)
(a) Health Based - Reduce potential cancer risks due to exposure to contaminants by ingestion by future residents to less
than. one in ten thousand with a target of one in one million, and reduce the hazard index under this
exposure scenario to less than one (see Table A-I for cleanup levels).
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be implemented only if CWAs are encountered. No CWA contaminated materials would
be transported to or disposed of at a non-military commercial facility.
ARARs of concern are the same as those described under Alternative 3a, except that LDRs
would not apply. The costs associated with Alternative 3b are listed in Table 2. The area of
attainment for each burial area and cleanup levels are listed in Table 3. The estimated
remediation time frame for Alternative 3b would be less than one year.
4.3.5. Alternative 4a . Off-Site Disposal at a RCRA P'!nDitted. Landfill
Alternative 4a differs from Alternative 3a in that under Alternative 3a all debris and only
soil that fails cleanup criteria would be transported off site for disposal and clean soil
would be returned to the excavation. Under Alternative 4a, all soil and debris excavated
from the burial areas within OU 3 would be excavated and transported off site for disposal.
Determination of the extent of excavation in each burial area. would be made using the
methodology outlined for Alternative 3a in Section 4.3.3.
Under Alternative 4a, all soil and debris excavated from OU 3 burial areas would be
transported to an off-site RCRA permitted landfill for treatment, if necessary, and
disposal. Most of the soil and debris, including all soil from the CW A Identification Kit
Burial Area that does not contain CW As, would be placed in a RCRA hazardous waste
(Subtitle C) landfill. Laboratory analyses of soil samples, including TCLP testing, would
be performed to determine if treatment is necessary prior to disposal. Because the water
purifiCation tablet bottles are not a listed hazardous' or characteristic waste, they would be
disposed of in a RCRA industrial (Subtitle D) landfill. Compressed gas cYlinders would be
excavated and disposed of off site by a commercial operator.
Any CW A-contaminated soil or debris encountered would be excavated, transported, and
disposed of by certified DOD personnel as described in the CW A Contingency Plan
(Section 4.1).
The ARARs of concern under Alternative 4a are the same as those described for
Alternative 3a. The costs associated with Alternative 4a are listed in Table 2. The area of
attainment for each burial area and the cleanup levels are listed in Table 3. The estimated
remediation time frame would be less than one year for Alternative 4a.
4.3.6. Alternative 4b . Off.Site Disposal by Incineration
Alternative 4b is identical to Alternative 4a except that the soil and debris would be
transported off site for incineration at a permitted RCRA incinerator instead of to a RCRA
permitted landfill. Because the water purification tablet bottles are not a listed hazardous
or characteristic waste, they would be disposed of in a RCRA industrial (Subtitle D)
landfill. The compressed gas cylinders would be excavated and disposed of off-site by a
commercial operator.
AAy CW A-contaminated soil or debris encountered would be excavated, transported, and
disposed of by certified DOD personnel as described in the CW A Contingency Plan
(Section 4.1).
The ARARs of concern under Alternative 4b are the same as those described for
Alternative 3a, except that the LDRs would not apply. The costs associated with Alternative
4b are listed in Table 2. The area of attainment for each burial area and the cleanup levels
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are listed in Table 3. The estimated remediation time frame would be less than one year
for Alternative 4b.
4.4 COMPARATIVE ANALYSIS OF REMEDIATION ALTERNATIVES
During the detailed analysis of remediation alternatives for OU 3, each alternative was
assessed using the nine evaluation criteria defined under the NCP. These criteria were
developed to address the technical and policy considerations that have proven important for
selecting among remedial alternatives and serve as the basis for the detailed analysis,
assessment, and the final selection of an appropriate remedial action. To be an
appropriate remedial action, an alternative must meet criteria 1 and 2, which are the
threshold criteria. Those alternatives satisfying the threshold criteria are compared
using the five balancing criteria. The final two modifying criteria can change the
preferred alternative .selected as a result of applying the balancing criteria. The
evaluation criteria are described below.
Thresho1d Criteria
Threshold criteria used in the comparative analysis include overall protection of human
health and the environment and compliance with ARARs. These threshold criteria must
be met by an alternative before it can be evaluated under the five balancing criteria.
1.
Overall Protection of Human Health and .the Environment - The
assessment against this criterion describes how the alternative, as a whole,
achieves and maintains protection of human health and the environment.
2.
Compliance with ARABs - The assessment against this criterion describes
how the alternative complies with ARARs or, if a waiver is required, how it
is justified. The assessment also addresses other information from
advisories, criteria, and the guidance that the parties have agreed is "to be
considered. "
RA1S1ncm~ Critetia
The five balancing criteria form the basis of the comparative analysis because they allow
tradeoffs among the alternatives involving different degrees of performance.
3.
Long-term Effectiveness and Permanence - The assessment of
alternatives against this criterion evaluates the long-term effectiveness of
each alternative in protecting human health and the environment after the
response objectives have been met.
4.
Reduction of Mobility, Toxicity, and Volume Through Treatment - The
assessment against this criterion evaluates the anticipated performance of
the specific treatment technologies an alternative may employ.
5.
Short-term Effectiveness - The assessment against this criterion examines
the effectiveness of alternatives in protecting human health and the
environment during the construction and implementation of a remedy
until the response objectives have been met.
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6.
Implementability - The assessment against this criterion evaluates the
technical and administrative feasibility of the alternatives and the
availability of the goods and services needed to implement them.
7,
Cost - The assessment against this criterion evaluates the capital, indirect,
and operation and maintenance costs of each alternative. Cost can only be
a deciding factor for alternatives equally protective of human health and
the environment.
Mndifvin~ Criteria
8.
State Acceptance - This criterion reflects the State's preferences among or
concerns about alternatives.
9.
Community Acceptance. This criterion reflects the community's
preferences among or concerns about alternatives. .
The results of the analysis of alternatives using the nine criteria are summarized in
. Table 2. This summary is used to compare the alternatives and identify the key tradeoffs
among them. The comparative analysis of the alternatives was then conducted to evaluate
the alternatives with respect to their relative performance according to the threshold and
balancing criteri,a. The results of this comparison are presented below.
4.4.1. Ovenill Protection ofBuman Health and the Environment
Because there are cunently no exposure pathways to contaminated soil at OU 3, all the
remedial alternatives are equally protective of human health and the environment if
present land use at DDOU remains unchanged. Therefore, the cunent risks to human
health are acceptable under present land use conditions for all of the alternatives.
Under Alternative 1 (no action), there would be a potential for future exposure to
unacceptable concentrations of CW As in the CW A Identification Kit Burial Area and to the
contents of bottles in the Water Purification Tablet Burial Area. Because the
Miscellaneous Items Burial Area is a source of ground-water contamination, the no action
alternative would not be protective of ground water. In addition, a physical risk from
buried compressed gas cylinders would remairi. Therefore, Alternative 1 is not acceptable
for use as a site-wide remedy for au 3. However, it could be an acceptable remedy at the
Riot Control and Smoke Grenade Burial Area because future health risks at this disposal
site are considered acceptable.
While the risk of exposure to contaminated soil is acceptable under Alternative 2, the
potential for the soil in the Miscellaneous Items Burial Area to act as a continuing source of
ground-water contamination is not considered acceptable. Thus, Alternative 2 meets or
partially meets the criterion at all burial areas except the Miscellaneous Items Burial
Area. Alternatives 3a, 3b, 4a, and 4b would comply with this criterion at all burial areas.
4.4.2. Compliance with ARABs
The institutional controls alternative (Alternative 2) would fail to meet ARARs for control
or removal of contamination sources in soil at the Miscellaneous Items Burial Area, as
required under Utah Administrative Code Rule 450-101. Alternatives 3a and 4a would
comply with ARARs relating to contaminant source removal, transportation, and disposal
if the soil and debris meet the treatment standards and are handled according to RCRA
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classifications and LDRs. If soil does not meet treatment standards, treatment by
fixation/stabilization or some other. method (Alternatives 3a and 4a), or incineration
(Alternatives 3b and 4b) would allow LDRs to be met. Alternative 1 (no action) is not
required to comply with ARARs.
4.4.3. Long-Term Effectiveness and Permanence
The no-action alternative (Alternative 1) would provide the least compliance with this
criterion, faiiing at all burial areas. The institutional controls alternative (Alternative 2)
also rates lower than the alternatives that remove contaminated debris and soil from the
site (Alternatives 3a, 3b, 4a, and 4b). However, the restriction of site access under
Alternative 2 gives it a higher rating thGll the no action alternative. The permanence of
fixation/stabilization and landfilling contaminated debris and soils under Alternatives
3a and 4a rates these alternatives higher than Alternatives 1 and 2. However, in the
Miscellaneous Items Burial Area, the relatively high analytical detection limits of
contaminants in soil implies that soil reburied under Alternative 3a could still-act as a
source of ground-water contamination. While Alternative 3b rates higher than
Alternative 3a in the Miscellaneous Items Burial Area due to the complete destruction
afforded by incineration, it rates lower than Alternative 4a due to the potential for
continuing ground-water contamination. Alternative 4b carries the highest rating in this
area because all soil and debris would be incinerated. In the CW A Identification Kit
Burial Area, arsenic is the contaminant of greatest concern, except for CW As, which
- require incineration at a DOD facility. Because incineration of arsenic would not result
in .destruction, small amounts of uncontrolled arsenic emissions may escape through the
stack; thus, Alternatives 3a and 4a rate slightly higher than Alternatives 3b and 4b in this
area. Alternatives 3b and 4b rate slightly higher than Alternatives 3a and 4a for the Riot
Control and Smoke Grenade Burial Area because the alternatives requiring incineration
are more effective and permanent if significant contamination is present. However, no
contamination has been identified that would pose an unacceptable health threat in this
area. Alternatives 380 3b, 480 and 4b address the compressed gas cylinders and the water
purification tablets identically.
4A.4.. Reduction in Mobility, Toxicity, and Volume
Alternatives 1 and 2 rate lowest against this criterion because-no action or limited action
would be taken to remediate contamination sources. -Alternatives 3a and 4a partially meet
this criterion because the mobility of contaminants would be reduced by removing them
- from all burial areas in OU 3 and placing them in a RCRA permitted landfill and in the
case of Alternative 3a. volume would be reduced by separating contaminated soil from
uncontaminated soil. However toxicity would not be reduced without additional treatment.
Treatment by incineration under Alternatives 3b and 4b would reduce toxicity, mobility,
and volume in the Miscellaneous Items Burial Area. These alternatives would also
reduce toxicity, mobility, and volume in the Riot Control and Smoke Grenade Burial Area
if there is undetected contamination in this area. However, these alternatives will not
reduce the toxicity of arsenic in the CWA Identification Kit Burial Area, and may slightly
increase its mobility and volume through losses in the incinerator stack.
4.4.5. Short-Term Effectiveness
Both the no-action and the institutional controls alternatives achieve a high rating under
this-criterion because with no excavation, or Hmited excavation, there is little or no risk to
on-site workers or the community. The other alternatives compare equally with a high
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rating at all burial areas under this criterion if the CWA Contingency Plan describecrin
Section 4.1 is implemented during the remediation activities.
- .
4.4.6. Implementability
Although all of the alternatives are both technically and administratively implementable,
some have more technical or administrative requirements than others. The no-action
alternative is the easiest to implement technically and has been given the highest rat!l.ng
(Table 2). Alternatives 2, 3a, 3b, 4a, and 4b include recovering, sampling, and disposing of
the compressed gas cylinders, which is more difficult to implement technically, but is a
technology that is commercially available. Alternative 2 has also been given a high
rating because in addition to removing the compressed gas cylinders, it would initi8Ily
require only an inspection and reporting program. Alternatives 3a, 3b, 4a, and 4b would
require coordination with the U.S. Army Technical Escort Unit for handling and disposal
of CWAs, a construction contractor, and coordination with a commercial disposal facility.
In addition, because the U.S. Army is currently in the process of revising policies and"
procedures for the removal, handling, and disposal of CW As and CW A-contamin3ted
soil, until the procedural issues are resolved, remediation of sites contaminated with
CWAs cannot proceed. However, assuming the Army finalizes the procedural issues;
none of Alternatives 3a, 3b, 4a, or 4b, present prohibitively difficult problems with regard to
technical, administrative, or equipment-related implementability. For this reason, tliese
alternatives have been given a moderate rating. ;- :
4.4.7. Cost
Costs for each of the remedial alternatives have been tabulated in Table 2. The no-action
alternative (Alternative 1) has a total present worth cost of $11,300 to prepare four five-year
site review reports at the end of the 5th, 10th, 15th. and 20th years. Of the other alternatives,
Alternative 2 (institutional controls), with a present worth of $201,000 for the first 20 y~ar:s
of controls, has the lowest costs. Alternative 3a (on-site treatment and off-site disposal) has
a total one-year cost of $362,000. Alternative 3b, which includes incineration, has a tiotal
one-year cost of $570,000. Alternative 4a (off-site disposal) has a one-year cost estimated at
$450.000, and Alternative 4b, which includes incineration, has the highest cost with a one-
year cost estimated at $1,792,000. ~ ".
4.4.8. Stai2 Acceptance
~ ..:
The State has been involved in each step of the RllFS process and the presentation of die
preferred alternative in the Proposed Plan for au 3. Therefore, this criterion has been
addressed in the development of the remedy for au 3. The State is supportive of the seleCted
remedy.
4.4.9. Community Acceptance
Community acceptance is implicitly analyzed for the selected remedy in ,.the
Responsiveness Summary at the end of this document. All comments received during. the
public comment period have been addressed and the alternatives altered if necessary.
Therefore, public concerns regarding the selection of a remedy for aU3 have been
addressed. . "
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5.0 SELECl'ED REMEDY
Because the nature of the items and chemical contaminants present in the OU 3 burial
areas varies greatly, it was determined that no single remedial action alternative was
suitable for all burial areas. The selected remedy consists of the two alternatives presented
here that provide the best balance of trade-offs with respect to the nine evaluation criteria
listed in Section 4.4. The selected remedy for Operable Unit 3 is a combination of
Alternative 3a, on-site mechanical sieving of soil and debris and off-site disposal at a
RCRA permitted landfill for the CWA Identification Kit and Riot Control and Smoke
Grenade burial areas, and Alternative 4&, off-site disposal of soil and debris at a RCRA
permitted landfill for the Miscellaneous Items, Water Purification Tablet, and the
Compressed Gas Cylinder burial areas. Under both alternatives, any soil or debris
containing CWAs will be taken off site to a licensed DOD chemical munitions disposal
facility for destruction by incineration in accordance with DOD regulations. The only
difference between Alternative 3a and Alternative 4a is that under Alternative 48, soil and
debris will not be sorted, and no soil would be returned to the excavations. This remedy
was presented as the preferred alternative in the Proposed Plan for OU 3 and has the
support of the State and EPA Because the State has been intimately involved in the RIlFS
process at OU 3, State acceptance of the selected remedy has been achieved through
incorporation of State comments on primary documents prepared in support of this ROD,
and included in the Administrative Record. Community acceptance of the selected
remedy has been achieved through the Community Relations Program, public meetings,
and the public comment period. A detailed description of the selected alternative,
including the remediation goals, cleanup levels, and the costs associated with each
component of the remedy is presented in the following discussion.
5.1 DESCRIPl'ION OF THE SELECTED REMEDY
Alternative 3a will be implemented at the CWA IdentificatIon Kit and Riot Control and
Smoke Grenade burial areas. Alternative 4a will be implemented in the Miscellaneous
Items, the Water Purification Tablet, and the Compressed Gas Cylinder burial areas.
Each burial site will be excavated using a track-mounted backhoe operated by specially
trained personnel. The extent of excavation will be determined using the following
cleanup criteria:
.
Removal of all debris encountered during excavation.
.
.' Removal of all visually contaminated soils.
Remova1 of soil and, debris with contaminants that pose a cancer risk under a
residential ingestion scenario greater than on in ten thousand, with a target
risk of one in one million, wherever practicable. Contaminant concentrations
associated with a cancer risk of one in ten thousand are specified in
Appendix A.
.
Removal of soil and debris with contaminants at concentrations corresponding
to a hazard index greater than one under a residential ingestion scenario.
Contaminant concentrations required to meet this criterion are specified in
Appendix A
.24-
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.
Removal of soil and debris with detectable CWA contamination in accordance
with the CW A Contingency Plan.
.
Removal of all water purification tablet bottles.
Excavation will proceed in each burial area until the cleanup criteria listed above are
achieved in the soils forming the perimeter of the excavation. Debris will be separated
from the soil in the CW A Identification Kit and Riot Control and Smoke Grenade Burial
Areas by a combination of hand and 'ribratory sorting using a mechanical soil shaker
screen. Any containers of CWAs, riot control or smoke grenade fragments, and CWA.
contaminated soil or debris encountered will be transported off site and disposed of by
incineration at a Department of Defense facility, as described in the CWA Contingency
Plan (Section 4.1). Chemical warfare agent or grenade contaminated material will not be
transported to, or disposed of at a non-military facility. The total area of attainment
calculated by summation of the individual burial areas is 530 cubic yards (Table 3).
Soil that is not contaminated by CWAs .will be tested for compliance with the Toxicity
Characteristics Leaching Procedure (TCLP) criteria for toxic characteristics to determine
if they are hazardous. The soil in the CWA Identification Kit and Riot Control and Smoke
Grenade Burial Areas will also be tested for semi-volatile organic and metals
contamination to determine compliance with cleanup. criteria.
If the screened soil exceeds the cleanup criteria listed in Appendix A, or is a RCRA listed or
characteristic waste, the soil will be transported to an off-site RCRA hazardous waste
(Subtit:e C) landfill for disposal. Soil and debris that contain listed hazardous wastes
above RCRA treatment standards or exhibit hazardous characteristics using TCLP
criteria win be treated prior to disposal by the RCRA facility. The water purification
tablets will be disposed of in a RCRA (Subtitle D) industrial landfill.
Soil that meets the cleanup criteria WIn be replaced in the excavation in .;.1e CW A
Identification Kit and Riot Cc ::-01 and Smoke Grenade Burial A.:. ;as. Determination of
whether the material complie" with the cleanup criteria will be based on a statistical
analysis performed on a representative number of samples of the stockpiled material.
Compliance monitoring is discussed in detail in Appendix B of this document.
The Compressed Gas Cylinder Reburial Area will be excavated, the compressed gas
cylinders recovered, sampled, and the gas contents disposed of by a civilian contractor.
Empty cylinders will be disposed of by recycling.
5.1.1. Remediation Goals
The point of compliance for soil will be removal of all soil and debris from the CW A
Identification Kit, Riot Control and Smoke Grenade, Miscellaneous Items, Water
Purification Tablet, and Compressed Gas Cylinder burial areas. The extent or volume of
soil to be removed will be determined by the c:~anup criteria listed in Section 5.1.
During the excavation process, excavated soil and debris will be tested using the Toxicity
. Characteristics Leaching Procedure
-------
frequency of TCLP testing will be no less than three samples for every burial area. This
test will ensure proper characterization of the material so that the landfill receiving the
material can determine if treatment will be necessary before landfill disposal.
5.1.2. Costs
Total project costs should be approximately $393,000 using a combination of costs from
Alternatives 3a and 4a for remediation of the five burial areas. Indirect costs for
administration, engineering, and design services were estimated to be approximately
one-third of the total project costs. There are no annual operation and maintenance costs
because the remediation of au 3 should take less than one year.' ,
5.2 STATUTORY DETERMINATIONS
With the exception of the Miscellaneous Items Burial Area, the selected remedy for au 3
meets the statutory requirements of Section 121 ofCERCLA as amended by SARA. These
statutory re'quirements include protection of human health and the environment,
compliance with ARARs, cost effectiveness, utilization of permanent solutions and
alternative treatment technologies to the maximum extent practicable, and preference for
treatment as a principal element. The manner in which the selected remedy for au 3
meets (or the reason for not meeting) each of the statutory requirements is presented in the '
;-,"llowing discussion.
5.2..1. Protection of Human Health and the Environment
The s,,1ected remedy for au 3 protects human health and the environment through the
followl::g engineering controls:
.
Excavation of all contaminated soil and debris from the various burial areas at
au 3 and removal of all soil and debris necessary to comply with the cleanup
criteria defined in Section 5.1.
.
Excavation and removal 0' 3 n soil and debris in areas where there is an
obvious threat to ~~U1l~"-''''~'''
Removal of the soil and debri .,' .:1 the various burial areas of au 3 will eliminate potential
sources of ground-wateT ':',: ..~mination and remove the potential for exposure to the
contaminants found I!'!' "~':;e selected remedies for S9il at au 3 will not pose an
unacceptable shor. ',' "- ''li:' " 2,ve the effect of minimizing cross-media impacts.
5.2.2. CompliID:.:,r..'
'"
,~~';;e or Relevant and Appropriate Requirements
Section 121(d)(1 : ,:' CERCLA, as amended by SARA, requires that remedial actions must
attain a degree::: -Cleanup that assures protection of human health and the environment. In
addition, remedial actions that leave any hazardous substances, p.ollutants, or
contaminants on site must, upon completion, meet a level or standard that at least attains
legally applicable or relevant and appropriate standards, requirements,limitations, or
criteria that are "applicable or relevant and appropriate requirements" (ARARs) under the
circumstances of the release. ARARs include Federal standards, requirements, criteria,
and limitations and any promulgated standards, requirements, criteria, or limitations
under State environmental or facility siting regulations that are more stringent than
Federal standards.
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The remedial action proposed, the hazardous substances (including possible CWA) present
at the site, the physical characteristics of the site, and the potential receptor population, were
all considered when determining which requirements are applicable or relevant and
appropriate to the selected remedy for OU 3. The only State regulations identified that
required more stringent requirements than equivalent Federal regulations were the
source control requirements of Utah Administrative Code (UAC) Rule 450-101.
Through careful review of all applicable or relevant and appropriate public health .and
environmental requirements of Federal or State laws, it has been determined that the
remedy selected for OU 3 will meet these ARARs. Therefore, no SARA Section 121(d)(4)
waiver will be necessary. A brief discussion of how the selected remedy for OU 3 satisfies
the principal ARARs associated with the site is presented below.
5.2.3. Chemical-Specific Requirements
Chemical-specific ARARs set health- or risk-based concentration limits in various
environmental media. The Utah COT'T'ective Action Cleanup Standards Policy is
applicable to the site, and will be complied with by removing the source of ground-water
contamination. The contingency for incinerating all CW As and CW A-contaminated
materials will comply with the congressional mandate under which incineration is the
only approved method of chemical agent disposal. The land disposal restrictions under
RCRA will be complied with by treating all soil and debris that fails TCLP tests. Other
applicable or relevant and appropriate requirements include the Department of Defense
regulations for handling, transportation, and disposal of CWAs, the Occupational Safety
and Health Administration (OSHA) regulations, and the Department of Transportation
(DOT) hazardous material transportation regulations. Federal and State chemical-
specific ARARs are presented in Tables C-l and C-2 of Appendix C.
5.2.4. Location-Specific Requirements
Location-specific ARARs set restrictions on remediation activities, depending on the
location of a site or its immediate environs. The only location-specific ARA.R associated
with the selected remedy for OU 3 is the EPA ground-water protection strategy that
establishes a ground-water classification system for protecting ground water based on its
value to society, use,. and vulnerability. This ARA.R requires removal of the source of
ground-water contamination in the Miscellaneous Items Burial Area. Because Operable
Unit 3 is not located in a wetlands area or flood plain, is not a historic place, and the
remedy will not affect any historic place, endangered species or habitat, regulations
pertaining to these concerns are not ARARs. The Federal location specific AMRs for OU
3 are presented in Table C-3.
5.2.5. Action-Specific Requirements
Performance, design, or other action-specific requirements set controls or restrictions on
certain kinds of remedial activities related to management of hazardous substances,
pollutants, and contaminants. The Utah Air Conservation Rules are applicable in that
they require a permit to emit over 1.5 tons ofVOCs per year. However, becaus.e less than 1.5
. tons of VOCs are buried within OU 3, the selected remedy will comply with this ARAR. The
remedy will comply with the Utah COT'T'ective Action Cleanup Standards Policy and the
Utah Groundwater Quality Protection Standards by removing the source of ground-water
contamination. RCRA. Land Disposal Restrictions will be complied with by treating all
soil that fails a TCLP test. The Source Separation of Materials Recovery Guidelines will
be complied with by recycling the compressed gas and/or cylinders if possible. Other
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Federal action-specific ARARs that are relevant to the remediation activities at OU 3
include RCRA Closure Regulations, RCRA Standards for Generators and Transporters of
Hazardous Waste, DOT Hazardous Material Transportation Regulations, and OSHA.
Potential Federal and State action-specific ARARs are presented in Tables C-4 and C-5 of
Appendix C.
5.2.6. To Be Considered Requirements
In implementing the selected remedy for OU 3, DDOU has agreed to consider requirements
that are not legaUy binding. No "to be considered" requirements were identified for the
selected remedy at OU 3.
5.3 COST EFFECTIVENESS
Overall cost-effectiveness can be defined as the reduction in threat to human health and the
environment per dollars expended on a remedy. The selected remedy for OU 3 is the most
cost-effective alternative because it provides the maximum effectiveness proportional to
cost of any of the alternatives analyzed. For aU of the burial areas except the
MisceUaneous Items Burial Area, the selected alternative is the least expensive
alternative meeting the threshold alternative, while being nearly equal to any other
alternative in terms of long-term effectiveness and' permanence, reduction of toxicity,
mobility, and volume through treatment, and short-term effectiveness. While Alternative
4b would have been more permanent and achieved reduction in toxicity, mobility, and
volume through treatment in the Miscellaneous Items Burial Area, the, cost of
implementing Alternative 4b in that area would have been six to seven times that of
Alternative 4a. Because the major threat associated with contaminants in the
MisceUaneous Items Burial Area is cross-media contamination rather than a direct
health hazard, the additional cost associated with Alte,rnative 4b was not justifiable.
5.4 UTILIZATION OF PERMANENT SOLUTIONS
This section briefly explains how the selected remedy for OU 3 provides the best balance of
tradeoffs among all the alternatives using the five balancing criteria described in Section
4.4. '
In the long term, incineration (Alternatives 3b and 4b) would be more effective and
permanent in protecting human health and the environment in the MisceUaneous Items
Burial Area than disposing of soil and debris in a RCRA permitted landfill (Alternatives
3a and 4a) because the contaminants would be completely destroyed in the incineration
process. However, incineration of all of the material in this area would be six to seven
times more costly than landfill disposal. All four alternatives are considered to be equaUy
effective and permanent in the Riot Control and Smoke Grenade Burial Area, where
contaminants are not known to pose a chronic health threat above health-based criteria.
Alternatives 3a and 4a would be more effective and permanent in the CW A Identification
Kit Burial Area because incineration would not destroy the arsenic in the soil and may
lead to uncontrolled releases to the atmosphere because incineration by a commercial
facility does not destroy arsenic. '
In the short term, there is little risk of exposure to contaminants at OU 3 under the no action
and institutional control alternatives. The other alternatives that involve excavation and
off-site disposal (Alternatives 3a, 3b, 4a, and 4b) compare equaUy because specially trained
personnel will conduct the cleanup activities.
-28-
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Alternatives 3b and 4b, which involve incineration of contaminants, rate highest with
regard'to reduction of mobility, toxicity, and volume in the Miscellaneous Items Burial
Area. However, Alternatives 3a and 4a rate highest in the CWA Identification Kit Burial
Area where arsenic is the major contaminant of concern. Under Alternatives 3a and 4a,
volume would be reduced (although not to the extent achieved by incineration) by
separating contaminated soil from uncontaminated soil. Alternatives 3a and 4a are
equivalent to Alternatives 3b and 4b if CWAs are encountered during excavation because
contaminants would be removed and destroyed by incineration according to the CW A
Contingency Plan. At the Riot Control and Smoke Grenade Burial Area, only a small
reduction of toxicity and volume would be achieved by incineration because there is
estimated to be less than one cubic yard of contaminated soil in this area, and the
contaminants detected are not known to be present above health-based levels. All of the
alternatives are both technically and administratively implementable.
In summary, Alternatives 3a, 3b, 4a, and 4b, which involve excavation and off-site
disposal of soil and debris from the au 3 burial sites, provide the most permanent solutions
for remediation of the contaminants found at au 3, when compared with alternatives that
involve no removal actions (Alternatives 1 and 2). Alternative 3a offers the most
permanent solution for the CWA Identification Kit Burial Area and is also the least
expensive method of remediating this area. Alternatives 3a. 3b, 4a. and 4b are comparable
in terms of the balancing criteria for the Riot Control and Smoke Grenade Burial Area, as
there is no known threat above health-based levels in this area. Alternative 3a is the least
expensive remedial alternative among the four permanent treatment alternatives for this
area, and was therefore selected. In the Miscellaneous Items Burial Area, only
Alternatives 4a and 4b provided guaranteed long-term effectiveness in terms of prevention
of future ground-water contamination. While Alternative 4b is more protective,
Alternative 4a was selected because the soil in the Miscellaneous Items Burial Area causes
no direct threat to human health or the environment. In addition, Alternative 4a is less
expensive that Alternative 4b by a factor of six to seven while still providing long-term
protection to human health and the enVironment, limited short-term risks, a reduction in
mobility, toxicity, and volume, and can be relatively easily implemented. Alternatives
3a, 3b, 4a, and 4b are identical with respect to the Compressed Gas Cylinder Reburial Area
and the Water Purification Tablet Burial Area.
5.5 PREFERENCE FOR TREATMENT AS A PRINCIPLE ELEMENT
With the exception of the Miscellaneous Items Burial Area. the selected remedy for au 3
utilizes permanent solutions and treatment technologies to the maximum extent
practicable. Treatment of soil before disposal in an off-site RCRA (Subtitle C) landfill will
be undertaken only if necessary to comply with RCRA Land Disposal Restrictions. If
CW As are detected during the excavation activities, the materials will be destroyed by
incineration following guideli~es outlined in the CW A Contingency Plan (Section 4.1).
5.6 DOCUMENTATION OF NO SIGNIFICANT CHANGES
The Proposed Plan for au 3 was released for public comment in March 1992 and identified
the preferred alternative as a combination of Alternatives 3a and 4a for remediation of the
burial sites at au 3. All written and verbal, comments submitted during the public
comment period were reviewed. The conclusion of this review was that no significant
changes to the preferred alternative were necessary prior to it becoming the selected
remedy.
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APPENDtt A
. ~
SOIL REMEDIATION CRITERIA
II
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APPENDIX A
son. REMEDIATION CRITERIA
This appendix describes the remediation criteria for soil at Operable Unit 3
-------
TABLE A-1
SOIL REMEDIATION CRITERIA
BASED ON A FUTURE RE;IDENTIAL EXPOSURE SCENARIO
Concentration Clean.Up
in Level Clean.Up
Chemical mglkglBasis Base RisklHQ (mg/kg) Risk/HQ
N -nitrosodiphenylamine 0.75/Max 6 x 1O-9/__(a) 1,250 1 x 1O-5/__(a)
1,1,2,2- Tetrachloroethane 0.13/Max 4 x 10-8/0.00006 3) 1 x 10-5/0.01
Trichloroethene 0.21/Max . 4 x 1O-9/__(a) 490 1 x 1O-5/__(a)
Arsenic 559/Max 2 x 1O-3n 35 1 x 10-4/0.5
Mercury 9.B/Max NC/O.4 2 NC/0.1
(a)
No reference dose or slope factor available to calculate the hazard quotient or cancer
risk
H Q Hazard quotient
NC Noncarcinogen
Max Maximum concentration detected
A-2
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APPENDIX B
PERFORMANCE AND COMPLIANCE
MONITORING PLAN
-------
APPENDJXB
PERFORMANCE AND COMPLIANCE MONITORING PLAN
PERFORMANCE AND COMPLIANCE MONITORING FOR REMOVAL OF SOIL AND
DEBRIS FROM OU 3 BURIAL SITES
Remediation Goals
Remediation goals for soil are defined in Section 5.1. of the ROD.
Area of Aiftl1ft~t
The area of attainment for remediation goals is the soil and debris in the various burial
areas depicted in Figur.e 2 of the ROD. The volume of soil and debris requiring
remediation is approximately 530 cubic yards.
Restoration Time Frame
The restoration time frame for this action is estimated to be approximately six months after
commencement of work on site, and will be completed within 15 to 21 months after the ROD
is signed. .
Ped'o.nnance Standards
Specific performance standards used to ensure attainment of the remediation goals for soil
are:
.
Reduce contaminant concentrations in soils within the area of attainment to
comply with the remediation goals specified in Section 5.1. of the ROD
.
Meet all ARARs identified in the ROD
.
Separate out all soil and debris consisting ~f or contaminated by chemical
warfare agents for incineration at a.DOD facility
.
The soil will be remediated in a timely manner in compliance with the selected
remedy presented in the ROD to achieve remediation goals as soon as
practicable. .
Completion of~tion
Remediation will be considered complete after the soil remediation goals have been
attained in all samples taken from the perimeter of the excavation. Samples to be used for
compliance monitoring will be specified during Remedial Design (RD) in the
Performance and Compliance Monitoring Sampling Program. Sample locations will be
approved by EPA and UDEQ during the RD. The number and location of samples to be
taken may be modified during remediation to ensure compliance with remediation goals.
Any statistical methods to average soil concentrations areally or vertically shall be
specified during the RD. The guidance entitled "Methods for Evaluating the Attainment of
'Cleanup Standards-Volume 1: Soils and Solid Media" (EPA 230/02-89-042) will be
consulted when establishing the Performance and Compliance Sampling Program.
B-1
-------
Performance and Compliance Sampling Program
A Performance and Compliance Sampling Program (PCSP) will be implemented during
the remedial action to monitor performance and compliance with remediation goals. This
program will be developed during the RD and will include locations of performance
monitoring points within OU 3, sampling methods, analytical methods, and statistical
methods for evaluating data.
Role ofDt::pu: t..ucDt ofDefeDse m the RE-~'sat:ion Process
A task force was recently established under the U.S. Army Chemical.Materiel Destruction
Agency (USACMDA) to manage non-stockpile chemical materiel (NSCM). The NSCM
mission is as follows:
Provide centralized management and direction to the DOD program for the
reclamation, recovery, and disposal of non-stockpile chemical materiel to
include contaminated structures or facilities in a safe and environ-
mentally sound and cost-etfel!tive manner.
As part of the au 3 remedial action, USACMDA will coordinate with TEU to ensure that all
necessary resources are made available to facilitate cleanup of the site.
B-2
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APPENDIX C
FEDERAL AND STATE CHEMICAL,
LOCATION, AND
ACTION-SPECIFIC ARARs
-------
APPENDIX C
FEDERAL AND STATE CHEMICAL, LOCATION,
AND ACTION-SPECIFIC ARABs
The following tables present the chemical-specific, location-specific, and action-specific
applicable or relevant and appropriate requirements (ARARs) for Defense Distribution
Depot Ogden, Utah Operable Unit 3.
C-l
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TABLE C-l
IDENTIFICATION OF FEDERAL CHEMICA{;SPECIFIC ARARs
Standard, Requirement,
Criterion, or Limitation
DOD Requirements for
Handling, Transport, and
Disposal 01 CSMs and CWAs
U.S. Army
()
I
t'-'
Citation
(AR) 50-6
(AR) 50-6-1
U.S. Army Material (AMC-R) 385-131
Command (AMC)
U.S. Army
Technical Manuals
(TMs) and Field
Manuals (FMs)
Description
Outlines requirements for
certification to work with or
transport chemical agents.
Also defines types and
amounts of agents which fall
into the chemical surety
program.
Defines procedures for
safeguarding chemical
surety materials
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TABLE C-)
IDENfIFICATION OF FEDERAL CHEMICAL-SPECIFIC ARABs
(CONTINUED)
Applicable!
Relevant
Standard. Requirement, and
Criterion, or Limitation Citation Description Appropriate Comment
TM 8-285 Treatment of Chemical Yes/--- In the event of an exposure to CSMs or
Agent Casualties and CW As this TM would be applicable.
Conventional Military
Chemical Injuries.
TM 10-227 Protective Clothing for Yes/--- Protective clothing specified by this
(') Chemical Operations. TM would be required of all DOD
c., personnel.
FM 3-5 NBC Decontamination. Yes/--- Chemical Decontamination
requirements would be applicable.
AMC-R 385-100 AMC Safety Manual. Yes/---
(AR) 700-107 Preparation of Standard Yes/--- Preparation of SOPs for handling,
Operating Procedures. transport, and disposal of CSMs are
applicable.
Congressional Mandate Public Law 91-121 Prohibits open air testing Yes/--- Applicable to any agents or agent-
and transportation of contaminated soils recovered at OU 3.
chemical agents within the
United States.
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TABLE C-t
IDENfIFICATION OF FEDERAL CHEMICAL-SPECIFIC ARARs
(CONTINUED)
Applicable'
Relevant
Standard. Requiremen4 and
Criterion, or Limitation Citation Description Appropriate Co~ent
Public Law 91-441 Prohibits disposal of Yes/--- Incineration is the only disposal
chemical agents without method authorized for chemical agent
congressional approval. disposal.
Solid Waste Disposal Act 42 USC Sec. 6901-6987
(') Identification and 40 CFR Part 261 Defines those solid wastes No/Yes Identifies wastes that are subject to
J.. Listing of Hazardous which are subject to land disposal restrictions under 40
Waste regulation as hazardous CFR 268.
wastes under 40 CFR Parts
262-265 and Parts 270, 271,
124.
Clean Air Act 42 USC Sec. 7401-7642
National Primary and 40 CFR Part 50 Establishes standards for N olY e s Relevant and appropriate to any
Secondary Ambient Air ambient air quality to protect activity.which might result in air
Quality Standards public health and welfare emissions during remedial actions at
(including standards for OU3.
particulate matter and lead).
National Emission 40 CFR Part 61 Sets emission standards for N o/Y e s Relevant and appropriate to release
S~ndards for Hazardous designated hazardous from compressed gas cylinders.
Pollutants pollutants.
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TABLE C-t
IDENfIFICATlON OF FEDERAL CHEMICAL.SPECIFIC ARARs
(CONTINUED)
Standanl, Requirement,
Criterion, or Limitation
Citation
Description
Applicable to any activity carried out
under the selected remedy.
Occupational Safety and
Health Act
20 USC Sec. 651-678
Regulates worker health and
safety.
D.O.T. Hazardous Material 49 CFR Parls107, May regulate transportation
Transportation Regulations 173.329-173.331,173.333 of CWAs, CSMs, and
hazardous materials.
o
I
C11
Resource Conservation and
Recovery Act
Section 3004(ni)
Waives prohibition of land
disposal of a particular
hazardous waste if levels or
methods of treatment
substantial1y reduce toxicity
or likelihood of migration of
hazardous constituents to
minimize short and long-
tenn threats to human health
and the environment.
Applicable!
Relevant
and
Appropriate
Yes/---
Yes/u-.
NolYes
Comment
Applicable to remedial actions
involving off-Depot movement of
CWAs, CSMs, and hazardous
materials during remediation.
Relevant and appropriate for remedial
alternatives involving landfiHing of
contaminated debris and soi1.
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TABLE C-2
IDENTIFICATION OF STATE CHEMICAL-SPECIFIC ARARS
Standard, Requirement,
Criteria, or Limitation
Citation
Description
Applicable!
Relevant
and
Appropriate
Comment
Division of Solid and
Hazardous Waste,
Department of
Environmental Quality
(')
bI
Utah Administrative
. Code (U,AC,) R450-101
Corrective action clean-up
standards policy - RCRA,
UST, and CERCLA sites.
Yes/---
Lists general criteria to be
considered in establishing
clean-up standards., Refer to
Safe Drinking Water Act and
Clean Air Act.
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TABLE C-3
IDENTIFICATION OF FEDERAL LOCATION.SPECIFIC ARABs
Standard, Requirement.
Criteria, or Limitation
Citation
Description
Comment
EPA Ground-Water
Protection Strategy
EPA Guidance
Establishes a ground-water
classification system for
protection of ground water
based on its value to society I
use, and vulnerability.
o
I
-:J
Applicable!
Relevant
and
Appaupa-iate
N o/Y e s
Contributes to the National
Primary Drinking Water
Standards (MCLs) being
remedial action objectives.
To be considered should source
removal be required.
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TABLE C-4
IDENTIFICATION OF FEDERAL ACTION-SPECIFIC ARARs
Applicable!
Relevant
Standard, Requirement, and
Criteria, or Limitation Citation Description Appropriate Comment
Solid Waste Disposal Act 42 USC Sec. 6901-6987
Guidelines for the Land 40 CFR Parl241 Establishes requirements Yes/--- Applicable to landfill storage or reburial
Disposal of Solid Wastes and procedures for land of contaminated soils.
disposal of solid wastes.
() Source Separation of 40 CFR Parl246 Establishes requirements No/Yes Recycling of compressed gas and/or
. Materials Recovery and recommended cylinders and lead foil may be possible.
OD
Guidelines procedures for source
separation by Federal
agencies of residential,
commercial, and
institutional solid wastes.
Criteria for 40 CFR Parl257 Establishes criteria for use Yes/m Applicable to remedial alternatives
Classification of Solid in determining which solid involving landfil1ing of contaminated
Waste Disposal waste disposal facilities and debris and soils.
Facilities and Practices practices pose a reasonable
probability of adverse effects
on health or the
environment.
Standards Applicable to 40 CFR Parl262 Establishes standards for Yes/-- Applicable to landfilling of
Generators of Hazardous generators of hazardous contaminated debris and soils.
Wasle waste.
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TABLE C-4
IDENTIFICATION OF FEDERAL ACTION. SPECIFIC ARARs
(CONTINUED)
ApplicableJ
Relevant
Standard, Requirement, and
Criteria. or Limitation Citation Description AwtUlğiate Comment
Standards Applicable to 40 CFR Part 263 Establishes standards which Yes/--- Applicable to transport of hazardous
Transporters of apply to persons transporting materials off-site.
Hazardous Waste hazardous waste within the
U.S. if the transportation
requjres a manjfest under 40 .
CFR Part 262.
0
cD Land Disposal 40 CFR Part 268 Identifies hazardous wastes Yes/--- Applicable to off-site land disposal of soil
Restrictions that are restricted from land containing listed or characteristic
disposal. hazardous waste. Relevant and
appropriate for on-site disposal
activities.
Occupational Safety and 20 USC Sec. 651-678 Regulates worker health and Yes/--- Applicable to all remedial actions
Health Act safety. carried out under the selected remedy.
D.O.T. Hazardou8 Material 49 CFR Parts 107, 171 Regulates transportation of Yes/--- Applicable to off-site disposal of wastes.
TransponationRe~tion8 -177 hazardous ma.terials.
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TABLE C-5
IDENTIFICATION OF STATE ACTION-SPECIFIC ARARs
Applicable!
Department, Division Relevant and
or Commission Statute Suliect ApJropriate Remarks
State Engineer, V.A.C. Rule R625-4 We)) drilling standards Yes/--- Includes such requirements as
Deportment ofNaturaI -standards for drilling performan!:e standards for
Resources and abandonment of casing joints, requirements for
wells. abandoning a well, etc.
Industrial Commission V.A.C. Rule R500 Utah Occupational Safety Yes/--- These rules are identical to
and Health Standards. Federal OSHA regulations.
o Division of Solid and Title 19, Chapter 6, Utah Solid Waste. Not yet N o/Y es These rules govern solid waste
I
.....
o Hazardous Waste, Code Annotated codified; copy available. landfills.
Department~ from the Bureau of Solid and
Environmental Quality Hazardous Waste.
V.A.C. Rule R450 Solid and Hazardous Y es/---
Waste.
R450-0, regarding spill reporting
requirements, has no
corresponding Federal
provisions.
U.A.C. Rule R450-101
Corrective Action Clean-
up Standards Policy -
RCRA, VST, and
CERCLA sites.
Yes/---
Lists general criteria to be
considered in establishing clean-
up standards including
compliance with MCLs in Safe
Drinking Water Act and Clean
Air Act.
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TABLE C-5
IDENTIFICATION OF STAn: ACTION-SPECIFIC ARARs
(CONTINUED)
Department, Division
or Commission
SCatuIe
SuItject
Applicable!
Relevant and
Appropriate
Remarks
Division of Water Quality,
Department of
Environmental Quality
o
I-'
I-'
Division of Air Quality,
Department of
Environmental Quality
U.A.C. RuJe 448-6
Groundwater QuaJity
Protection.
Yes/---
ApplicabJe if ground-water
contamination sourceS in OU 3
soiJs are not removed.
AppJicable for fugitive dust and
VOC emissions.
U.AC. RuJe R446
Utah Air Conservation
Rules.
Yes/---
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