PB94-964417
EP A/ROD/R08-94/084
September 1994
EP A Superfund
Record of Decision:
Hill Air Force Base,
Operable Unit 4, UT,
6/14/1994
o
Hazardous Waste Collection
Information Resourc.e Center
US EPA Region 3
PhllodelphkJ, PA 19101
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Hill Air Force Base
Final
Record of Decision and
Responsiveness Summary
forOperab'e Unit 4
(IRP Sites LF11, LF12, OT20, OT41, OT42}
April 1994
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FINAL RECORD OF DECISION
FOR OPERABLE UNIT 4
HILL AIR FORCE BASE, UTAH
This is a primary document for Operable Unit 4 at Hill Air Force Base. It will be
available in the Administrative Record, which is maintained at the following locations:
.
Davis County Library
Central Branch
155 N. Wasatch Drive
Layton, Utah 84041
Hours:
Mon - Thurs: 11 :00 am - 9:00 pm
Fri - Sat: 11:00 am - 6:00 pm
.
Environmental Management Directorate
OO-ALC/EMR
Building 5
7274 Wardleigh Road
Hill AFB, Utah 84056-5137
Contact: Gwen Brewer
(801) 777-8790
Submittal Date:
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TABLE OF CONTENTS
PAGE
DECLARATION FOR THE RECORD OF DECISION
DECISION SUMMARY FOR THE RECORD OF DECISION
1.0 SITE NAME, LOCATION, AND DESCRIPTION
1-1
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
2-1
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 4 Within Site Strategy
2-1
2-2
2-2
2-2
2-3
3.0 SUMMARY OF SITE CHARACTERISTICS
3-1
3.1 Nature and Extent of Contamination
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. Summary of Site Risks
3-1
3-2
3-2
3-2
3-6
3-6
3-9
4.0 DESCRIPTION OF ALTERNATIVES
4-1
4.1 Development of Alternatives
4.2 Detailed ~alysis of Alternatives
4.2.1. Ground-Water Alternatives
4.2.2. Surface-Water AJternatives
4.2.3. Landfill Contents Alternatives
4.2.4. Air Alternatives
4.3 Comparative Analysis of Alternatives
4.3.1. Ground Water
4.3.2. Surface Water
4.3.3. Landfill Contents
4.3.4. Air
4-1
4-6
4-6
4-8
4-10
4-12
4-13
4-14
4-15
4-16
4-16
5.0 SELECTED-REMEDY
5-1
5.1 Description of the Selected Remedy
5.1.1. Remediation Goals and Performance Standards
5.1.2. Restoration Time Frame
5.1.3. Costs
5-1
5-2
5-4
5-4
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Table of Contents
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. Cost Effectiveness
5.2.4. Utilization of Pennanent Solutions.
5.2.5. Preference for Treatment as a Principal Element
5.3 Documentation of Significant Changes
RESPONSIVENESS SUMMARY
REFERENCES
APPENDIX A - APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS
APPENDIX B - PUBLIC MEETING TRANSCRIPT
APPENDIX C - WRITTEN COMMENTS AND RESPONSES
ii
5-7
5-7
5-8
5-10
5-10
5-11
5-11
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TABLE
NO.
3-1
3-2
3-3
3-4
3-5
3-6
3-7
4-1
4-2
4-3
4-4
5-1
5-2
A-I
A-2
A-3
A-4
A-5
A-6
FIGURE
NO.
1-1
1-2
3-1
3-2
3-3
5-1
Table of Contents
LIST OF TABLES
TITLE
Contaminants of Concern
Current Potential Exposure Pathways
Future Potential Exposure Pathways
Slope Factors (CPFs)
Reference Doses
Estimated Risks from Future Use of Shallow Ground Water on Base
Estimated Risks from Future Use of Ground Water in the Sunset Aquifer
Alternatives for Ground-Water Remediation
Alternatives for Surface-Water Remediation
Alternatives For Landfill Contents Remediation
Alternatives For Air Remediation
Remediation Goals for Hill AFB Operable Unit 4
Costs and Process Components For Selected Remedy
Federal Chemical-Specific ARARs
Federal Location-Specific ARARs
Federal Action-Specific ARARs
State Chemical-Specific ARARs
State Location-specific ARARs
State Action-Specific ARARs
LIST OF FIGURES
PAGE
3-3
3-4
3-5
3-7
3-8
3-10
3-11
4-2
4-3
4-4
4-5
5-5
5-6.
TITLE
FOLLOWING
PAGE NO.
Location Map
Site Plan
Areal Distribution of Trichloroethene (TCE) in Ground Water
Vertical Distribution of Trichloroethene (TCE) in Ground Water
Conceptual Model of Contaminant Transport
Conceptual Remedial Action Implementation Schedule
ill
1-1
1-1
3-1
3-1
3-1
5-2
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Hill Air Force Base, Utah
Operable Unit 4
Dec'aration 'or the Record 0' Decision
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Site Name and Location
Operable Unit 4
Hill Air Force Base, Utah
Weber and Davis Counties, Utah
Statement of Basis and Purpose
This decision document presents the remedy for Hill Air Force Base (Hill AFB) Operable
Unit 4 (OU 4) in Utah. It was selected in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA), and, to the extent
practicable, with the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP). This decision is based upon the Administrative Record for Hill AFB.
The State of Utah, the U.S. Environmental Protection Agency (EPA), andHiU AFB
concur on the selected remedy.
Assessment of the Site
Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action selected in this Record of Decision (ROD), may
present an imminent and substantial endangerment to public health, welfare, or the
environment.
Current risks to human health associated with the contaminants at OU 4 are well below
levels considered by the EP A to be significant. Remedial action is warranted based on
possible future risks to human health and the environment and because maximum
contaminant levels (MCLs) are exceeded in ground water.
Description of the Selected Remedy
OU 4 is one of eight operable units at Hill AFB. The remaining operable units are at
various stages in the remedial investigation/feasibility study (RIlFS) process. This action
addresses contaminated ground water, surface water, and air at OU 4. This action also
addresses landfill contents, which are the source of OU 4 ground-water, surface-water,
and air contamination. The selected remedy for OU 4 addresses the threat to human
health and the environment by containing and treating the source area and. the
contaminated ground water, surface water, and air.
The major components of the selected remedy for Hill AFB OU 4 include:
. Extracting contaminated ground water using horizontal drains or vertical
wells, treating the ground water by air stripping, and discharging the treated
ground water to the local publicly-owned treatment works (POTW).
. Collecting surface water and treating it with carbon adsorption when a
sufficip.nt volume of water is produced to operate the treatment system..
. Capping the contents of Landfill 1 and treating the source 'of contamination by
soil vapor extraction.
-1 -
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.
Semi-annual air monitoring in the basements of residences overlying the
contaminated ground water. If air contamination is detected at concentrations
exceeding acceptable risk levels, the contaminated air in the affected
residences will be collected and treated~ .
Implementing institutional controls and access restrictions upon completion of
the construction of the remedial. action that include: (1) water rights and well
drilling restrictions and advisories to prevent exposure to contaminated ground
water; (2) a continuing order from the base commander concerning landfill
restrictions; (3) recording a notice to restrict exposure and maintain the
integri~y of the remedial action at Landfill 1; and (4) fencing with warning
signs to restrict access to exposure areas, active construction, and treatment
facilities. Leases or easements may be needed to enact some of these controls.
Upon transfer of the property, the Air Force will provide a deed covenant
notifying the transferee of the locations and the restrictions' on use of the
areas. . .
.
Statutory Determinations
The selected remedy is protective of human health and the environment, complies with
Federal and state requirements that are legally applicable or relevant and appropriate to
the remedial action, and is cost effective. This remedy utilizes permanent solutions and
alternative treatment or resource recovery technologies to the maximum extent
practicable, and satisfies the statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal element. Because this remedy will
result in hazardous substances on-site above health-based levels, a review will be
conducted within five years after signing of this ROD to ensure that the remedy continues
to provide adequate protection of human health and the environment.
1'"'\
UNITED SATES ENVIRONMENTAL PROTECTION AGENCY
DA0~~ :
ARTMENT OF ENVIRONMENTAL QUALITY
~
Dianne R. Nielson, Ph. .
Executive Director
cs-a~ -14-.
DAlE r
fiLL AIR FORCE BASE, UTAH
I~ I ~I{;;t{
P. Babbitt, .
Deputy Assistance Secretary of the Air Force
(Environment, Safe~, and Occupational Health)
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Hill Air Force Base, Utah
Operable Unit 4
Decision Summary lor tile
Record 01 Decision
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1.0 SITE NAME, LOCATION, AND DESCRIPTION
Hill Air Force Base (Hill AFB, Base) is located in northern Utah, about 25 miles north of
Salt Lake City and about five miles south of Ogden, Utah as depicted in Figure 1-1. Hill
AFB covers about 6,700 acres and is located on the Weber Delta, a terrace approximately
300 feet above the surrounding valley floors in Weber and Davis Counties. Operable
Unit 4 (OU 4) is one of eight operable units under investigation at Hill AFB. OU 4 is
located near the northern boundary of Hill AFB, as shown in Figure 1-1. OU 4, as
depicted in Figure 1-2, consists of the North Gate Dump Area, the Spoils Pit, the
Munitions Dump, and Landfills 1 and 2. .
OU 4 is located on a steep, terraced, north-facing escarpment of the Weber Delta. The
stratigraphy at OU 4 is heterogeneous, with ground water flowing mainly along thin sand
layers found between low permeability clayey materials. OU 4 overlies three aquifers.
The shallow aquifer consists of 200 feet of relatively low-yielding materials and lies
within about 30 feet of ground surface. The shallow aquifer is designated as Class II -
Drinking Water Quality based on the State of Utah classification criteria and the quality
of ground water taken from uncontaminated wells (USGS, 1992). The Sunset and Delta
Aquifers are approximately 300 and 600 feet below the OU 4 landfills, respectively. The
Sunset and Delta Aquifers are used by Hill AFB and surrounding communities as
domestic water supplies. The Sunset and Delta Aquifers are Class I - Irreplaceable
Source of Drinking Water or Class IIA - Current Source of Drinking Water (USGS,
1992). Ground-water flow in the shallow aquifer is to the north, discharging to off-Base
seeps along the north escarpment or to the floodplain deposits of the Weber River.
The Weber River and the Davis-Weber Canal are the primary surface water bodies near
OU 4. The Weber River is located over 3,000 feet north of OU 4 and approximately 300
feet below the terrace where Landfills 1 and 2 are located. The Davis-Weber Canal, a
privately owned irrigation canal used each year from April to October, is approximately
600 feet north and approximately 100 feet below Landfills 1 and 2. In the vicinity of OU
4, the canal flows in a northwesterly direction. Well response data presented in the final
remedial investigation (RI) report indicate that, in the past, water has infiltrated from the
canal to the shallow aquifer via leaks. However, portions of the canal were recently
relined with concrete, which. has decreased or eliminated infiltration from the canal and
reduced or cut off flow to some of the seeps. Results of analyses of canal water during
the RI indicated that the canal has not been a source of contamination, nor has it been
contaminated by chemicals from OU 4.
The areas adjacent to OU 4 to the north and northeast include the communities of
Washington Terrace, Riverdale, and South Weber, which are comprised mainly of
moderately developed residential areas separated by large tracts of agricultural land.
Further north, the City of Ogden is a densely developed community and county
government center. The adjacent land south and west of OU 4, which is owned by Hill
AFB, includes unimproved areas and waste disposal sites. There is a sand and gravel
borrow area on the south end of OU 4 which has commercial value as a natural resource.
1-1
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ROY
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OPERABLE UNIT 4
(Landfill #1)
(Landfill #2)
(North Gate Dump Area)
(Spoils Pit)
(Munitions Dump)
SUNSET
CLEARFIELD
LAYTON
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HILL AIR FORCE BASE
OPERABLE UNIT 4
LOCATION MAP
FIGURE 1-1
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Hill AFB OU 4 ROD
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@
EXPLANATION
- Ground surface elevation
contour (feet)
- - - Dirt road
- Canal, arrow denotes
.- direction of canal flow
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Source: Modified from USGS, 1992, Figure 3.4.4.1-1.
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Scale in Feet
500
I
HILL AIR FORCE BASE
OPERABLE UNIT 4
SITE PLAN
FIGURE 1-2
Hili AFB OU 4 ROD
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According to the Hill AFB Comprehensive Plan (USAF, 1989), there are no wetlands
located on-Base in au 4. However, the Davis-Weber canal, which is located along the
northern boundary of au 4, is designated a wetland according to the National Wetland
Inventory (NWI) map (USFWS, 1986). The Davis-Weber Canal is not considered a
jurisdictional wetland by the U.S. Army Corps of Engineers because it has a lined bottom
(Gallihugh, 1993).
1-2
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2.0 SITE mSTORY AND ENFORCEMENT ACTIVITIES
2.1 SITE HISTORY
Hill AFB has been the site of military activities since 1920 when the western portion of
the Base was activated as the Ogden Arsenal, an Anny reserve depot. In 1940 and 1941,
four runways were built, and the Ogden Air Depot was activated. During World War II,
the Ogden Arsenal manufactured ammunition and was a distribution center for motorized
equipment, artillery, and general ordnance. The Air Depot's primary operation was
aircraft rehabilitation. In 1948, the Ogden Air Depot was renamed Hill AFB, and in
1955, the Ogden Arsenal was transfC?rred from the U.S. Army to the U.S. Air Force.
Since 1955, Hill AFB has been a major center for missile assembly and aircraft
maintenance. Currently, Hill AFB is part of the Air Force Materiel Command.
On-Base industrial processes associated with aircraft, missile, vehicle, and railroad
engine maintenance and repair include metal plating, degreasing, paint stripping, and
painting. These processes use numerous chemicals, including chlorinated and non-
chlorinated solvents and degreasers, petroleum hydrocarbons, acids, bases, and metals.
In the past, chemicals and waste products were disposed of at the Industrial Waste
Treatment Plant (IWTP), in chemical disposal pits and landfills, and off base. Disposal in
chemical pits and landfills was discontinued by 1980. All waste products are currently
treated at the IWTP, recycled on Base, or sent to off-Base treatment or disposal facilities.
au 4 is comprised of Landfills 1 and 2, the Spoils Pit, the North Gate Dump Area, and
the Munitions Dump. The locations of these areas within OU 4 are shown in Figure 1-2.
The following sections describe the histories of the sites in OU 4.
Landfill 1. Solid wastes were dumped and burned daily in Landfill 1 from 1955 to 1967.
No records were found that indicate hazardous wastes were disposed of at Landfill 1.
However, Landfill 1 is the source of TCE contamination observed in ground water and
seeps at OU 4. Former Hill AFB employees reported that Landfill 1 received wastes
from the Ogden Arsenal that included waste oils and solvents from the vehicle
maintenance facility.
Landfill 2. Solid waste disposal took place. at Landfill 2 from 1963 to 1965, where
wastes were burned periodically. No records have been found indicating disposal of
hazardous or industrial wastes at Landfill 2. Based on investigation results, Landfill 2 is
not a source of contamination at OU 4.
Spoils Pit. Construction debris and yard waste from the Base were disposed of in the
Spoils Pit from 1971 to 1987. There have been no records found that indicate that the
Spoils Pit was used for disposal of hazardous or industrial wastes. Results of
investigations indicate that the Spoils Pit is not a source of subsurface contamination at
OU4.
2-1
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Munitions Dump. The Munitions Dump was operated as an aboveground munitions
storage area during W orId War n. Investigations have shown that the Munitions Dump is
not a source of contamination.
North Gate Dump Area. Several drums of waste solvent were reportedly dumped from
trucks in the North Gate Dump Area. No drums have been found in this area, and
investigations have revealed that the North Gate Dump Area is not a source of
contamination.
2.2 ENFORCEMENT ACTIVITIES
In July 1987, Hill AFB was placed on the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) National Priorities List (NPL) by the EPA.
In 1991, Hill AFB entered into a Federal Facilities Agreement (FFA) between the U.S.
Air Force (USAF), the State of Utah Department of Health (now the Utah Department of
Environmental Quality (UDEQ» and the U.S. Environmental Protection Agency (EPA).
. The purpose of the agreement was to establish a procedural framework and schedule for
developing, implementing, and monitoring appropriate response actions at Hill AFB in
accordance with existing regulations. Seven operable units were defined under the FFA.
An eighth operable unit has since been added. This Record of Decision (ROD) concludes
all of the remedial investigation/feasibility study (RIfFS) requirements for OU 4. There
have been no removal actions, remedial actions, notices of violation, or other
enforcement actions taken at OU 4 prior to this ROD.
2.3 INVESTIGATION HISTORY
Landfills 1 and 2 are two of 13 potential hazardous waste sites identified in the Phase I
Installation Restoration Program (IRP) investigation (ES, 1982). Results of ground-water
monitoring done during the Phase II IRP investigation (Radian and SAIC, 1988) found
trichloroethene (TCE) in ground water downgradient of Landfill 1. Results of the initial
RI (USGS, 1992), which was conducted from 1987 to 1990, indicated volatile organic
compounds (VOCs) and metals in ground water and seeps, The North Gate Dump Area
was identified as part of OU 4 during the initial RI, the Munitions Dump was included as
part of the Phase II RI investigation, and the Spoils Pit was designated as part of OU 4
under the FF A in 1991. A bas'eline risk assessment was developed from 1987 through
1991 as part of the RI (JMM, 1991). In 1992, an addendum to the RI was prepared
(USGS, 1993), in which findings of the initial RI were confirmed and revised, the extent
and quantity of the ground-water contamination were defined, and the primary source of
contamination was identified. An addendum to the risk assessment (MW, 1993) was also
prepared and included as part of the addendum to the RI. Results of the risk assessment
and its addendum are summarized in Section 3.2.
2.4 COMMUNITY RELATIONS HISTORY
The public participation requirements of CERCLA Sections 113(k)(2)(B)(i-v) and 117
were met. Hill AFB has a Community Relations Plan that is revised as frequently as
every six months. The community relations activities include: (1) a Techn~cal Review
2-2
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Committee (TRC) which meets quarterly and includes community representatives from
adjacent counties and towns, (2) a mailing list for interested parties in the community, (3)
a bi-monthly newsletter called "EnviroNews," (4) visits to nearby schools to discuss
environmental issues, (5) community involvement in a noise abatement program, (6)
semi-annual town council meetings, (7) opportunities for public comment on remedial
actions, and (8) support for the community for obtaining technical assistance grants
(T AGs). In addition, a public meeting was held for the communities north of the Base
that are affected by OU 1, OU 2, and OU 4 on April 28, 1993 to explain risk issues.
The RI Report (USGS, 1992), RI Addendum (USGS, 1993), Feasibility Study Report
(MW, 1993a), and the Proposed Plan for Operable Unit 4 (MW, 1993b) were released to
the public, and are available in the administrative record maintained in the Davis County
Library and at the Environmental Management Directorate at Hill AFB. The notices of
availability for these documents were published in the Salt Lake Tribune. A public
comment period was held from October 7, 1993 through November 5, 1993. In addition,
a public meeting was held on October 19, 1993. At this meeting, representatives from
Hill AFB' EPA, and the State of Utah answered questions about the site and the selected
remedy. A court reporter prepared a transcript of the meeting. Copies of the transcript
and all written public comments received during the comment period have been placed in
the administrative record. In addition, copies of the transcript were sent to all meeting
attendees who requested them. Responses to the comments received during the public
comment period are included in the Responsiveness Summary, which is part of this ROD.
The decision process for this site is based on the Administrative Record.
2.5 SCOPE AND ROLE OF OPERABLE UNIT 4 WITHIN SITE STRATEGY
.aU 4 is one of eight operable units at Hill AFB' The remaining operable units are at
various stages in the RIfFS process. The remedial actions planned for the operable units
are independent of one another. This action addresses contaminated ground water,
surface water, and air at OU 4. This action also addresses landfill contents, which are the
source of ground-water, surface-water, and air contamination. Risks to human health
associated with OU 4 are currently well below levels considered significant by EPA.
However, OU 4 poses a future threat to human health and the environment because of
risks from exposure to contaminated soil gas, exposure to the sourc(. area, and exposure
to contaminants via domestic use of contaminated ground water and surface water from
seeps. The purpose of this remedy is to: prevent exposure to contaminated ground water,
surface water, landfill contents, and air; reduce contaminant migration from the landfill
contents to ground water, surface water, and air; and reduce the volume of contaminants
in the source area. OU 4 will be the first final response action for Hill AFB.
2-3
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3.0 SUMMARY OF SITE CHARACTERISTICS
3.1 NATURE AND EXTENT OF CONTAMINATION
Landfill 1 is the source of contamination at au 4 based upon data collected during the RI
(USGS, 1993). The North Gate Dump Area, Landfill 2, the Munitions Dump, and the
Spoils Pit are ,not sources of contamination. Contaminants detected at au 4 consist of
the vacs benzene, chloroform, 1,I-dichloroethene (DCE), cis and trans 1,2-DCE,
1,2-dichloroethane (DCA), methyl ethyl ketone (MEK), tetrachloroethene (PCE), toluene,
TCE, and xylenes; and the metals arsenic, barium, boron, cobalt, nickel, and selenium.
vacs were detected in ground water, surface water from seeps, and soils, and metals
were detected only in ground water. TCE is the principal contaminant at au 4 because it
is the only vac consistently detected in ground water and seeps at concentrations
exceeding its maximum c'ontaminant level (MCL). Benzene and DCE were detected at
concentrations slightly above their MCLs. Metals were identified at concentrations
above background levels in various wells, but occurrences above MCLs are sporadic,
localized, and within the TCE plume. The metals that were found at concentrations
above MCLs are arsenic, nickel, and selenium. TCE was detected at concentrations
above its MCL in three seeps. There has been no contamination detected in the Davis-
Weber Canal.
The areal and vertical limits of the TCE contamination in ground water at au 4 are
shown in ~igures 3-1 and 3-2. These limits, which are defined by the "non-detect"
isoconcentration contours, were determined from the analytical results of soil, soil gas,
and ground water samples. The area of contaminated ground water is approximately 69
acr~s. As shown in Figure 3-2, the contamination is located in the upper 25 feet of the
shallow aquifer. Primary ground-water movement is lateral, and the vertical contaminant
profile indicates that contaminants have not migrated into the deeper aquifers. The
volume of contaminated ground water is approximately 200 million gallons. The volume
of landfill contents is approximately 140,000 cubic yards, based on a landfill area of
150,000 square feet and a landfill depth of 25 feet.
A conceptual model of contaminant transport mechanisms at au 4 is presented as Figure
3-3. The vacs at au 4 are soluble in water and volatilize into air; therefore, they are
quite mobile and likely to be transported via ground water and air. The metals detected at
au 4 have very low volatility and are not mobile via air. Arsenic, barium, nickel, and
selenium form ionic compounds which are mobile in water. Boron and cobalt are less
soluble and less mobile in water. Potential routes of contaminant migration, as indicated
in Figure 3-3, include infiltration of contaminated ground water from the landfill contents
to underlying soil and shallow on-Base ground water; volatilization from landfill contents
and soil to on-Base air; migration of contaminated on-Base shallow ground water to deep
ground water, shallow off-Base ground water, and seeps; transport of surface runoff from
the landfill to the Davis-Weber Canal; and volatilization from seeps and shallow ground
water to off-Base air. The population and environmental areas that could be affected, if
exposed, include Hill AFB personnel, off-Base residents north of au 4, future on-Base
residents, and on- and off-Base plants and animals.
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.
Location of existing residencas
fIID
Non-detact
o @ 500
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Scale in Feet
EXPLANA nON
.
Private or public well
General direction of
/' ground-water movement
@) Monitoring well
.... Seep
---. Dirt road
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Test hole
0- Trichloroethene isoconcan-
... , tration contour line (~gIL))
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Canal sampling site
- Canal, arrow denotes
..- direction of canal flow)
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A
Surfaca soil sampling site
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L...1' Location of cross section
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Browning Avenue
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Source: Modified from USGS, 1992; figure 4.7.2.1-3.
Contour plan based on the maximum TCE concentrations
reported in each well between 1986 and 1992.
Hill AFB OU 4 ROD
HILL AIR FORCE BASE
OPERABLE UNIT 4
AREAL DISTRIBUTION OF
TRICHLOROETHENE (TCE) IN GROUND WATER
FIGURE 3-1
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4600
Hill Air Force Base
Private Property
AI
EXPLANATION
4700
4700
'.._u_n_.'_"_"-"-"-"-"-"
I Seeps durtng June through
December durtng most years
before the canal was relined
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Zone of contamination
Monitoring well and number
(4,185) - maximum concentration of
trichloroethene during 1986 to 1992 time.
period as determined by laboratory analysis
(in micrograms per liter)
Screened interval
Profile of potentiometric surface
4600
Gravel
(ND)
Not Detected
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sand stringers
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.-..-.._u_u_n_u_.._.._u_n_.._u_oo-u_,,_U_"_U- .
-------------------------------------
..._u_..-.._u_u_u_u_u_.._oo_.._n_.._n_u_.'-"- .
------------------------------------
'_u-u_........_u_.._u_..-..-..-..-..-..-.._.._n_.. . .
.--------------------------------
~u_u_.._.._.._.._.._.._.._.._.._.._n_n_.._"
Note: Extent of contaminated ground water velSUS depth was not
fully defined with multi-level wells along this cross section.
The detection of 7.5 p(J/I TCE In well U4-36 was a result of
cross contamInation during drilling.
------------------------------
._u_.._u_..-.._u-.._n_.._n_.._n_.._n-
--------------------
_n_u-.._u-n_.._n_u_u
(ND)
o 100 200
I I . I I
Scale in Feet
Vertica1 Exaggeration x 4
FLOOD
PLAIN
~
4400
4400
LOCATION OF CROSS-SECTION SHOWN ON FIGURE 3-1
Source: Modified from USGS, 1992; Figure 4.7.2.1- 5 and USGS 1993; Figure ES-6.
HILL AIR FORCE BASE
OPERABLE UNIT 4
VERTICAL DISTRIBUTION OF TRICHLOROETHENE
(TCE) IN GROUND WATER
CROSS-SECTION A-A'
FIGURE 3-2
Hill AFB OU 4 ROD
-------
AIR
(ON-BASE)
EXPLANATION
MUNITIONS
DUMP
~
Predominant
Pathway
~
Minor
Pathway
I
I
.
Unlikely Pathway
(not thought to occur
based on available data)
LANDFILL 1
LANDFILL 2
SPOILS
PIT
VOCs
Note 1 .
Note 1
Note 1
Note 1
~
~
c~
.>
<:
AIR
(ON-BASE)
Soil Gas,
Volatilization
Predominant Pathway
Soil Gas, Soil Gas,
Volatilization Volatilization
Minor Pathway Unlikely Pathway
VOCs (TCE)
Sl.Ilta
-- Ce b
--'Tl.llloM
~-...'L
DAVIS-WEBER CANAL
(OFFwBASE)
SOIUUNSATURATED .lONE
No Contaminants
Detected
SHALLOW GROUND WATER
(ON-BASE)
t
SEEPS
(OFFwBASE)
VOCs (TCE)
t
DEEP GROUND WATER (ON-BASE)
VOCs (TCE)
Notes:
1. Recent data collection and analysis indicate that Landfill 1 is the likely source of TCE contamination. Data
collected from Landfill 2, the Spoils Pit, the Munitions Dump, and downgradient from Landfil/1 indicate no
additional sources of contamination.
SHALLOW
GROUNDWATER
(OFF-BASE)
VOCs (TCE)
SHALLOW. GROUND WATER
(OFF-BASE FLOODPLAIN)
NOTE 2
Hill AFB OU 4 ROD
t
DEEPER AQUIFERS
(OFF-BASE)
HILL AIR FORCE BASE
OPERABLE UNIT 4
CONCEPTUAL MODEL OF CONTAMINANT TRANSPORT
FIGURE 3.3
2. Contaminant discharges to Weber River flood plain deposits are subject to dilution. Elevated TCE concentrations
have not been detected northeast of South Weber Drive.
-------
3.2 PUBLIC HEALTH AND ENVIRONMENTAL IMPACTS
A Baseline Risk Assessment (JMM, 1991) was prepared for au 4 as part of the RI/FS.
The purpose of the risk assessment was to identify the contaminants of concern present at
au 4, the current and future exposure pathways for. humans and environmental receptors.
and the probability of the occurrence of hannful effects resulting from current and future
exposures. Based on the data collected and the risk assessment results, the media of
concern are shallow ground water and soil gCi)). The primary contaminant of concern for
each of these media is TCE. TCE is the primary contaminant of concern because it is the
most prevalent contaminant at the site and it contributes most to the risks. The risks
associated with exposure to metals were also evaluated in the risk assessment. The
current risks to human health due to au 4 cpntamination are well below levels
considered significant by EP A. Future risks to human health and the environment
include: (I) exposure to contaminated soil gas, and (2) exposure during domestic use of
contaminated ground water and surface water. Figure 3-1 presents the location of
residences in the immediate area of the TCE contamination.
3.2.1. Contaminant Identification
The initial step of the risk assessment was selecting the contaminants of concern, which
are toxic substances that have the potential to come in contact with environmental
receptors. Contaminants of concern were chosen for each medium of concern based upon
frequencies of detection, concentrations, and toxicities for the relevant exposure
pathways. The VOCs for ground water and surface water are considered contaminants of
concern via ingestion, inhalation, and dermal absorption ~uring domestic use. Soil gas
contaminants affect human health via the inhalation exposure route. Metals detected in
ground water above MCLs and background levels are considered contaminants of
concern by ingestion during domestic use of ground water and surface water. The
contaminants of concern for au 4, the media of concern, and the concentrations of
contaminants upon which the risk assessment was based are listed in Table 3-1.
Acute exposure to high concentrations of VOCs in air results in toxic affects. Chronic
exposure to VOCs can affect the central nervous system, liver, kidneys, bone marrow,
blood, and/or hematological system. Benzene is a proven human carcinogen; chloroform,
1,2-DCA, PCE, and TCE are probable human carcinogens based on evidence of
carcinogenicity in animals; and 1,1-DCE is a possible human carcinogen. Acute and
chronic exposure to arsenic by ingestion may cause severe toxic effects. Barium, boron,
cobalt, nickel, and selenium may produce toxic effects via acute and chronic exposure.
Arsenic is a proven human carcinogen.
3.2.2. Exposure Assessment
An exposure assessment was performed to identify current and future potential exposure
pathways through which contaminants of concern could travel to environmental
receptors. Current and future potential exposure pathways, media of concern, and
environmental receptors are presented in Tables 3-2 and 3-3. Inhalation of VOCs from
contaminated soil gas in off-Base residential basements is a significant current potential
exposure route. Future potential exposure routes that are significant include: inhalation
3-2
-------
TABLE 3-1
CONTANDNANTS OF CONCERN
Environmental Contaminant of Concentration Used in Risk
Media Concern Assessment(a)
Ground Water . Benzene 53
Chlorofonn 9.2
1,2- Dichloroethane 3.3
1,1- Dichloroethene 1.4
Tota11,2-Dichloroethene 130
Methyl Ethyl Ketone 77
Tetrachloroethene 1.2
Toluene 39
Trichloroethene 13,000
Xylenes 7.5
Arsenic 65
Barium 620
Boron 1,800
Nickel 2,100
Selenium 53
Surface Water Chlorofonn 12
(Seeps) Tota11,2-Dichloroethene 9.3
Trichloroethene 216
Indoor Air Trichloroethene 4.1 Jlglm3
(a) The value for trichloroethene in ground water is the upper 95 percent confidence limit
for the average concentration of five wells in the area of highest contaminant
concentrations. All other values are the maximum concentrations detected for the
compounds. All values are in Jlgll unless otherwise indicated.
3-3
-------
TABLE 3-2
CURRENT POTENTIAL EXPOSURE PA THW A YS
Environmental
Medium
Potential
Receptors
Potential Exposure Routes
GROUND WATER
Potentially Significant Pathway?
Shallow Aquifer
Sunset Aquifer
YJ
~
Delta Aquifer
SURFACE WATER
Davis- Weber Canal
Seeps
SOIL GAS
Nearby residents,
base personnel
Nearby residents
Nearoy residents.
base personnel
Nearby residents.
base personnel
Nearby residents,
base personnel
Nearby residents,
Nearby residents
Nearby residents
Nearby residents
Nearoy residents.
base personnel
Nearby residents.
base personnel
Residents of Cutler
house
Ingestion, inhalation, and dennal contact with potaole water.
Consumption of produce irrigated with water from the shallow aquifer,
consumption of beef or dairy products from cattle that drink this water,
consumption of oecf or dairy products from cattle consuming forage that was
irrigated wilh this waler.
Ingestion. inhalation. and dennal contact with potaole water.
Consumption of produce irrigated wilh water from this aquifer, consumption of
beef or dairy products from cattle thaI drink Ihis water, consumption of beef or
dairy products from cattle consuming forage Ihat was irrigate(:l with this water.
Ingeslion. inhalation. and dennal conlact with pol able water.
Consumption of produce irrigated with water from this aquifer, consumption of
beef or dairy products from cattle that drink this water, consumption of beef or
dairy products from cattle consuming forage that was irrigated with this water.
Consumption of produce irrigated with water from the canal, consumption of
beef or dairy products from cattle thaI drink Ihis water, consumption of beef or
dairy producls from callie consuming forage which was irrigated with this water.
Direcl contact wilh water or inhalation of contaminants volatilizing from seeps.
Consumption of produce irrigated with water from seeps. consumption of beef
or dairy products from cattle Ihat drink this water, consumption of beef or dairy
products from cattle consuming forage which was irrigated with this water.
Diffusion upward to surface followed by dispersion toward houses or base
buildings. where it is inhaled.
Diffusion upward. adsorption of volatiles to surface soil, ingestion of soil.
Diffusion of soil gas through the soil :1I1d foundation into the hasemenl.
Volatiles are inhaled.
No. Based on a survey conducted as part of this RI. the
shallow aquifer is not used for these purposes.
No. Based on a survey conducted as part of this RI.
there arc no private or municipal wells completed in the
shallow aquifer.
No. Wells in the Sunset Aquifer are not conlaminated.
No. Wells in the Sunset Aquifer are not contaminated.
No. Wells in the Delta Aquifer are not contaminated.
No. Wells in the Delta Aquifer are not contaminated.
No. Canal is not contaminated.
No. People not known to spend significant amounts of
time near seeps. .
No. Crops and animals do not significantly accumulate
VOCs. Concentrations of VOCs in seeps are low.
Metals are at background levels in seeps.
Yes.
Nearby residents. yes. Base personnel - no. Area on
Hill AFB which is contaminated is not near a normal
work area ;::OId receives little use.
No. Air monitoring did not delect any VOCs assodated
with au 4. lIowever. additional monitoring needs 10 be
performed to validate this conclusion.
-------
TABLE 3-3
FUTURE POTENTIAL EXPOSURE PA THW A YS
Environmental Potential
Medium Receptors
GROUND WATER
Shallow Aquifer Future on-base residents, base
personnel
Nearby residents
Nearby residents, future on-base
residents
Sunset Aquifer Nearby residents, future on-base
residents, base personnel
~ Nearby residents, future on-base
residents
VI
Davis-Weber Canal Nearby residents, future on-base
residents
Seeps Nearby residents
Potential Exposure Routes
Potentially Significant Pathway?
Nearby residents
Weber River
Nearby residents
SOIL GAS
Future on-base residents
Nearby residents, future on-base
residents, base personnel
Ingestion, inhalation, and dermal contact with potable water in
currently contaminated area.
Ingestion, inhalation, and dermal contact with potable water that
has migrated north.
Consumption of crops, beef, or dairy products from crops or
cattle exposed to currently contaminated water, contaminants in
water which have migrated north, or forage exposed to this
water.
Ingestion, inhalation, and dermal contact with contaminated
water which has migrated to the Sunset Aquifer.
Consumption of crops, beef, or dairy products from crops or
cattle exposed to contaminated water which has migrated to the
Sunset Aquifer, or forage exposed to this water.
Groundwater level rises, canal water becomes mixed with
contaminated water, water is used for irrigation, crops and
forage are consumed.
Direct contact with water or inhalation of contaminants
volatilizing from seeps.
Seeps increase in contaminant concentrations as contaminants
migrate north. Consumption of crops, beef, or dairy products
from crops or cattle exposed to this water, or forage exposed to
this water.
Contaminants migrate into the river. River water is used for
domestic purposes and exposed fish are consumed.
Diffusion of VOCs upward to surface followed by inhalation
of contaminants outside.
Inhalation from soil gas diffusing into basements and into the
air, ingestion of contaminated soil.
Future on-base residents - yes. Base personnel - no. Base
has a stable supply of water from the'Delta Aquifer.
Yes.
Yes - metals. No - YOCs. Crops and cattle do not
significantly accumulate YOCs.
Yes.
No. Crops and cattle do not significantly accumulate.
YOCs. Metals concentrations will not be distinguishable
from background levels in this aquifer.
No. VOCs are not significantly absorbed; canal water
would greatly dilute the contaminant concentrations.
No. Seeps are too small to wade in. Other activities that
would lead to significant exposure are unlikely, because
there are no features about the seeps that make it likely that
people would spend long periods of time near them.
No. YOCs are not significantly accumulated. Metals have
not been detected in seeps above background levels, and do
not form an identifiable plume in ground water that would
migrate coherently.
No. Available evidence indicates that the shallow aquifer
beneath au 4 does not extend to the Weber River.
Yes.
Yes. However, modeling difficulties prevent quantifying the
potential exposure from these pathways.
-------
of vacs in contaminated soil gas in residential basements; inhalation of vacs during
excavation of contaminated landfill materials; ingestion, inhalation and dermal absorption
of vacs during the domestic use of shallow ground water; and ingestion and dermal
absorption of metals during the domestic use of shallow ground water. The scenario of
future domestic use of shallow ground water assumes that the future land use at Hill AFB
includes building houses in the vicinity of au 4, that the houses will have untreated
domestic water supplied from wells that tap the shallow aquifer, and that untreated
ground water extracted from (he shallow aquifer will contain TCE concentrations
comparable to those observed in the most contaminated portion of the aquifer. The
"reasonable maximum exposure" was estimated for each exposure pathway to identify
conservative values within the ranges for possible exposures. Exposure concentrations
due to inhalation of contaminated air were estimated based upon measured soil gas
concentrations. The assumptions, models, and parameters used to estimate the
concentrations at the receptors and the chronic daily doses for each exposure pathway are
presented in the Baseline Risk Assessment (JMM, 1991) and its addendum (MW, 1993).
3.2.3. Toxicity Assessment
Cancer potency factors (CPFs), or slope factors, are used to provide conservative
estimates of excess lifetime cancer risks associated with exposure to potentially
carcinogenic chemicals. Cancer potency factors are derived from the results of human
epidemiological studies and chronic animal bioassays to which animal-to-human
extrapolation and uncertainty factors have been applied. Reference doses (RIDs) are used
to indicate the potential for adverse effects from exposure to chemicals exhibiting non-
carcinogenic effects. RIDs are estimates of lifetime daily -exposure levels for humans,
including sensitive individuals, which are compared to estimated intakes of chemicals
from environmental media. RIDs are derived from human epidemiological studies and
animal studies to which uncertainties have been applied. CPFs and RIDs for the
contaminants of concern at au 4 are presented in Tables 3-4 and 3-5. The most toxic
compound present at au 4 is TCE. TCE is the most prevalent contaminant of concern,
and it poses both carcinogenic and noncarcinogenic health risks. Contaminant toxicity is
discussed in detail.in the Baseline Risk Assessment (JMM, 1991) and its addendum
(MW,1993).
3.2.4. Risk Characterization
Carcinogenic and noncarcinogenic risks were calculated for each of the exposure
pathways for the potential contaminants of concern and compared to acceptable levels of
risk. For carcinogenic exposures, an excess lifetime cancer risk of 1 x 10-6 indicates a
one in a million chance that an individual will develop cancer after being exposed to a
carcinogen under the site-specific conditions for a 70-year lifetime. The target excess
lifetime cancer risk is 1 x 10-<> and the maximum limit for excess lifetime cancer risk is
1 x 10-4. For noncarcinogenic exposures, a total hazard index greater than one is
considered to be an unacceptable risk.
The incremental cancer risks for current exposures due to inhalation of TCE in outdoor
air are 2 x 10-8 for an on-Base worker and 6 x 10-8 for an off-Base resident, assuming
3-6
-------
TABLE 3-4
SLOPE FACTORS (CPFs)
Maximum Detected
Ground-Water Ingestion Inhalation Inhalation
Concentration Ingestion SF Weight SF Weight of
Compound (~g/L) (mg/kg/daytl of Evidence Source (mg/kg/day)-1 Evidence Source
Benzene 61 2.9 x to-2 A IRIS 2.9 x 10-2 A IRIS
Chloroform 12 6.1 x to-3 B2 IRIS 8.1 x 10-2 B2 IRIS
1.1 -Dichloroethene 1.4 6.0 x to-I C IRIS 1.8 x IO-I(b) C IRIS
1.2-Dichloroethane 3.3 9.1 x to-2 B2 IRIS 9.1 x 10-2 B2 IRIS
cis-I.2-Dichloroethene 6.4 NA D IRIS NA D IRIS
trans-I.2-Dichloroethene 270 NA NA IRIS NA NA IRIS
Methyl Ethyl Ketone 120 NA D IRIS NA D IRIS
Yo)
I
~ Tetrachloroethene 1.2 5.1 x 1O-2(a) B2(a) HEAST 1.8 x 1O-3(a) B2(a) HEAST
Toluene 67 NA D IRIS NA D IRIS
Trichloroethene 18.000 1.1 x 1O-2(a) B2(a) HEAST 1.7 x 1O-2(a) B2(a) HEAST
Xylenes 7.5 NA D IRIS NA D IRIS
Arsenic 94 1.75 x 100 A IRIS 1.5 x 101 A IRIS
Barium 620 NA NA IRIS NA NA IRIS
Cobalt 1.800 NA NA NA NA
Boron 40 NA NA IRIS NA NA IRIS
Nickel 2.100 NA NA IRIS NA NA IRIS
Selenium 53 NA. D IRIS NA D IRIS
NA No information or data were available A Known human carcinogen
IRIS Integrated Risk Information System. searched March and July. 1993 B2 Probable human carcinogen
HEAST Health Effects Assessment Summary Tables. 1992 C Possible human carcinogen
Not listed in HEAST or IRIS D Not classified in terms of carcinogenicity
(a) This information was withdrawn from the 1992 HEAST Tables.
(b) Revision since the Baseline Risk Assessment was issued.
-------
TABLE 3-5
REFERENCE DOSES
Chronic
Chronic Oral Inhalation
Reference Dose Uncertainty Reference Dose Uncertainty
Compound (~gIkg/day) Factor Source (mglkg/day) Factor Source
Benzene NA NA IRIS I x 10- 3 NA P
Chlorofonn I x 10-2 1000 IRIS 2 x 10-3 NA P
I,I-Dichloroethene 9 x 10-3 1000 IRIS 5 x 10-3 NA P
1,2-Dichloroethane NA NA IRIS NA NA IRIS
1,2-Dichloroethene (trans) 2 x 10-2 1000 IRIS NA NA IRIS
1,2-Dichloroethene (cis) I x 10-2 1000 HEAST NA NA IRIS
Methyl Ethyl Ketone 6 x 10- I 3000 IRIS 2.9 x 10-1 1000 IRIS
y)
I Tetrachloroethene I x 10-2 1000 IRIS NA NA IRIS
00
Toluene 2 x 10- I 1000 IRIS t. I x 10- I 100 HEAST
Trichloroethene 7 x 10-3 NA LHA NA NA NA
Xylenes 2 x 100 100 IRIS 9 x 10-2 100 IRIS
Arsenic 3 x 10-4 3 IRIS NA NA IRIS
Barium 7 x 10-2 3 IRIS NA NA IRIS
Boron 9 x 10-2 100 IRIS NA NA IRIS
Cobalt NA NA NA NA
Nickel 2 x 10-2 300 IRIS NA NA IRIS
Selenium 0.005 3 IRIS NA NA IRIS
NA No infonnation or data were available HEAST Health Effects Assessment Summary Tables, 1992
LHA Lifetime Health Advisory P Proposed RID, Hazardous Pollutant Assessment Branch,
IRIS Integrated Risk Infonnation System. Environmental Criteria and Assessment Office. EPA
searched March and July 1993 Not Listed in HEAST or IRIS
-------
receptors for both scenarios are exposed for 30 years out of a 70-year lifetime. The
cancer risk due to inhalation of outdoor air by residents was estimated to equal 2 x 10-7.
Hazard indices for these scenarios were not calculated because no accepted inhalation
RID for TCE exists. There are no significant risks associated with the current exposure
pathways, which are inhalation of TCE from soil gas and ingestion of TCE in surface
soil. This applies to on- and off-Base receptors.
For future on-Base use of the shallow ground water for drinking and showering, the total
hazard index is estimated at 50, and the total lifetime excess cancer risk is estimated at
7 x 10-3. For future off-Base use of shallow ground water and surface water for drinking
and showering, the hazard index was estimated at 6, and the excess carcinogenic risk is
estimated at 1 x 10-3. The risks associated with future use of shallow ground water for
domestic. purposes are significant. The risks associated with future use of ground water
from the Sunset Aquifer for drinking and showering are well below levels considered
significant by EP A. Future risks for domestic use of shallow ground water on Base and
for domestic use of ground water from the Sunset Aquifer are included in Tables 3-6 and
3-7.
A qualitative evaluation of risks to ecological receptors indicates low or insignificant
risks, so a quantitative ecological assessment was not perfonned. The only significant
exposure pathway for animals is through consumption of water in seeps in the low
agricultural areas off-Base below the slopes along the northeast boundary of au 4. The
contaminants of concern for surface water are TCE, chloroform, and DCE. Risks to
domestic animals and wildlife due to exposure to vacs in surface water are expected to
be low. or insignificant. The low bioaccumulation potential and high volatility of the
vacs indicate that exposures to animals would be low. Due to the volatility of the
vacs, concentrations in seeps will not be sufficient to affect crops or vegetation. Seeps
which contain contaminants do not flow to waters containing fish; there is no exposure
pathway.
No critical habitats have been identified in the vicinity of au 4. No threatened or
endangered animal or plant species inhabit the area, although there is a diverse population
of birds. The area may be within the hunting range of threatened raptors such as the bald
eagle and peregrine falcon, which have been sighted near au 4. However, the area is
likely to be only a small portion of their entire hunting range. The quantity of TCE
ingested by these birds will not be sufficient for bioaccumulation.
3.2.5. Summary of Site Risks
The decision to remediate the site is based upon possible future risks to human health and
the environment and because remedial action is warranted when MCLs are exceeded.
Future potential risks from au 4 contamination include inhalation of vacs in
contaminated soil gas which may enter off-Base residential basements, inhalation of
vacs by workers excavating contaminated landfill contents, inhalation of vacs during
showering with contaminated ground water and surface water, and ingestion of
contaminants while using contaminated ground water and surface water as a drinking
water source.
3-9
-------
TABLE 3-6
ESTIMATEO RISKS FROM FUTlJRE
USE OF SHALLOW (;ROUND WATER ON BASE
CARCINOGENIC RISKS
In~estion Inhalation Dermal
Oral Lifetime Inhalation Lifetime Ufetime Total
Slope A vera~e Cancer Slope A vera~e Cancer A vera~e Cancer Cancer
Contaminant Factor Dose Risk Factor Dose Risk Dose Risk Risk
Benzene OJI29 7.6 x 10-4 2 x 10-5 0.029 2.3 x 10-3 7 x 10-5 7.9 x 10-7 2 x 10-8 9x 10-5
Chloroform 0.0061 1.3 x 10-4 R x 10-7 0.081 3.4 x 10-4 3x 10-5 1.4 x 10-7 8xlO-1O 3 x 10-5
1.2-Dichloroethane 0.091 4.7 x 10-5 4 x 10-6 0.091 1.2 x 10-4 I x JO-5 4.9 x 10-8 4 x 10-9 I x 10-5
I.I-Dichloroethene 0.6 2.0 x JO-5 I x 10-5 1.2 5.7 x 10-5 7 x 10-5 2. I x 10-8 I x 10-8 8 x 10-5
Tetrachloroethene 0.051 1.7 x 10-5 9 x 10-7 0.0018 4.0 x 10-5 7 x 10-8 1.8 x 10-8 9 x 10-10 I x 10-6
Trichloroethene 0.011 1.3 x 10-1 I x 10-3 0.017 3.2xlO-1 5 x 10-3 1.3x 10-4 I x 10-6 6 x 10-3
Total Cancer Risk for Aquifer 1 x 10-3 6 J( 10.3 2 J( 10-6 7 x 10-3
HAZARD INDICES
w
I In'testion Inhalation Dermal
....
0 Oral Cronic Inhalation Chronic Chronic Total
Reference Dally Hazard Reference Daily Hazard Dally Ha7..ard Hazard
Contaminant nose Dose Index(a) Dose Dose Index(a) Dose Index(a) Index(a)
Benzene NA 1.8 x 10-3 NA 0.001 5.3 x 10-3 5 1.8 x 10-6 NA 5
Chloroform 0.01 3.1 x 10-4 0.03 0.002 8.0 x 10-4 0.4 3.2 x 10-7 3 x 10-5 0.4
1.2-Dichloroethane NA 1.1 x 10-4 NA NA 2.9 x 10-4 NA 1.1 x 10-7 NA NA
I.I-Dichloroethene 0.009 4.7 x 10-5 0.005 0.005 1.3 x 10-4 0.03. 4.8 x 10-8 5 x 10-6 0.04
1.2-Dichloroethene 0.01 4.3 x 10-3 0.4 NA 1.2 x 10-2 NA 4.4 x 10-6 4x 10-4 0.4
Methyl Ethyl Ketone 0.05 2.6 x 10-3 0.05 0.09 3.7 x 10-3 0.04 2.7 x 10-6 5 x 10-5 0.09
Tetrach loroethene 0.01 4.0 x 10-5 0.004 NA 9.2 x 10-5 NA 4.2 x 10-8 4 x 10-6 0.004
Toluene 0.2 1.3 x 10-3 0.007 0.6 3.7 x 10-3 0.006 1.4 x 10-6 7 x 10-6 0.01
Trichloroethene 0.007 3.0 x 10-1 40 NA 7.5x 10-1 NA 3.1 x 10-4 4 x 10-2 40
Xylenes 2 2.5 x 10-4 0.0001 0.09 6.8 x 10-4 0.008 2.6 x 10-7 I x J(}-7 0.008
Barium 0.05 1.4 x 10-2 0.3 NV NV NV 1.5 x 10-5 3 x 10-4 0.3
Boron 0.09 6.0 x 10-2 0.7 NV NV NV 6.2 x 10-5 7 x 10-4 0.7
Nickel 0.02 7.0 x 10-2 4 NV NV NV 7.3x 10-5 4 x 10-3 4
Total Hazard Index for Aquifer 50 6 0.05 50
(a) Values for individual contaminants are hazard quotients. The sum of the hazard quotients is Ihe hazard index.
NA Value not applicable because no reference dose is available.
NV Contaminant is not volatile. Inhalation roule is not applicahle.
-------
TABLE 3-7
ESTIMATED RISKS FROM FUTURE USE OF GROUND WATER
IN THE SUNSET AQUIFER
CARCINOGENIC RISKS
Ingestion Inhalation Dermal
Oral Lifetime Inhalation Lifetime Lifetime Total
Slope Average Cancer Slope Average Cancer Average Cancer Cancer
Contaminant Factor Dose Risk Factor Dose Risk Dose Risk Risk
Benzene 0.029 7.6 x 10-9 2xlO-10 0.029 2.3 x 10-8 7xlO-10 7.9x 10-12 2 x 10-\3 9xlO-1O
Chlorofonn 0.0061 \.3 x 10-9 8 x 10-12 0.081 3.4 x 10-9 3x 10-10 l.4x 10-12 8x 10-15 3x 10-10
1.2-Dichloroethane 0.091 4.7 x 10-10 4 x 10-11 0.091 1.2 x 10-9 I x 10-10 4.9 x 10-13 4x 10-14 I x 10-10
I.I-Dichloroethene 0.6 2.0x 10-10 I x 10-10 1.2 5.7 x 10-10 7 x 10-10 2.1 x 10- \3 I x 10-\3 8 x 10-10
Tetrachloroethene 0.051 1.7 x 10-10 9 x 10-12 0.0018 4.0 x 10-10 7xlO-\3 1.8 x 10- \3 9 x 10-15 I x 10-11
Trichloroethene 0.011 \.3 x 10-6 I x 10-8 (J.1t17 3.2 x 10-6 5 x 10-8 1.3 x 10-9 I x 10-11 6 x 10-8
Total Cancer Risk for Aquifer 1 x 10.8 6 x 10-8 2 x 10-11 7 x 10-8
HAZARD INDICES
VJ
I Ingestion Inhalation Dermal
-
- Oral Chronic Inhalation Chronic Chronic Total
Reference Daily Dose Hazard Reference Daily Hazard Daily Hazard Hazard
Contaminant Dose Index(a) Dose Dose Index(a) Dose Index(a) Index(a)
Benzene NA 1.8 x 10-8 NA 0.001 5.3x 10-8 5 x 10-5 1.8x 10-11 NA 5 x 10-5
Chlorofonn 0.01 3.1 x 10-9 3x 10-7 0.002 8.0 x 10-9 4x 10-6 3.2 x 10-12 3 x 10-10 4x 10-6
1.2-Dichloroethane NA 1.1 x 10-9 NA NA 2.9 x 10-9 NA 1.1 x 10-12 NA NA
I.I-Dichloroethene 0.009 4.7 x 10-10 5 x 10-8 0.005 1.3x 10-9 3 x 10-7 4.8 x 10- \3 5x 10-11 4xlO-7
1.2-Dichloroethene 0.01 4.3 x 10-8 4x 10-6 NA 1.2 x 10-7 NA 4.4 x 10-11 4 x 10-9 4 x 10-6
Methyl Ethyl Ketone 0.05 2.6 x 10-8 5 x 10-7 0.09 3.7 x 10-8 4 x 10-7 2.7 x 10-11 5 x 10-10 9 x 10-7
Tetrachloroethene 0.01 4.0 x 10-10 4 x 10-8 NA 9.2 x 10-10 NA 4.2 x 10-13 4xlO-1I 4 x 10-8
Toluene 0.2 1.3 x 10-8 7 x 10-8 0.6 3.7 x 10-8 6x 10-8 1.4 x 10-11 7x 10-11 I x 10-7
Trichloroethene 0.007 3.0 x 10-6 4 x 10-4 NA 7.5 x 10-6 NA 3.1 x 10-9 4 x 10-7 4 x 10-4
Xylenes 2 2.5 x 10-9 I x 10-9 0.09 6.8 x 10-9 8 x 10-8' 2.6 x 10-12 I x 10-12 8 x 10-8
Barium 0.05 1.4 x 10-7 3 x 10-6 NV NY NV 1.5 x 10-10 3 x 10-9 3x 10-6
Boron 0.09 6.0 x 10-7 7 x 10-6 NV NY NV 6.2 x 10-10 7 x 10-9 7 x 10-6
Nickel 0.02 7.0x 10-7 4 x 10-5 NV NV NV 7.3 x 10-10 4 x 10-8 4 x 10-5
Total Hazard Index for Aquifer 5 x 10-4 6xlO-S 5 x 10-7 5 x 10-4
(a) Value for individual contaminants are hazard quotients. The sum of the hazard quotients is the hazard index.
NA Value not applicable because no reference dose is available.
NY Contaminant is not volatile. Inhalation route is not applicable.
-------
Results of the risk assessment indicate that human health risks associated with
contamination present at OU 4 are currently below levels considered significant by EP A.
There is currently a potential that contaminated soil gas may enter residential basements
near OU 4. However, TCE was not detected at concentrations exceeding acceptable risk
levels in air samples taken from the residences located above the contaminated ground
water. Shallow ground water and seeps have TCE concentrations in excess of the MCL,
but these are not used as drinking water sources. Shallow ground-water contamination
has not affected the deeper aquifers. There are no current risks associated with exposure
to ground water from the deeper aquifers. .
Risks to vegetation, domestic animals, and wildlife due to exposure to VOCs in surface
water are expected to be low to insignificant. This is attributed to the volatility of the
compounds and the low potential for bioaccumulation. No critical habitats exist in the
vicinity of OU 4. No threatened or endangered plant or animal species inhabit OU 4.
The bald eagle and peregrine falcon may use part of the area for hunting, but exposures
are likely to be insignificant.
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, orthe environment.
Current risks to human health associated with the contaminants at OU 4 are well below
levels considered by EP A to be significant. Remedial action is warranted based on
possible future risks to human health and the environment and because MCLs are
exceeded in ground water.
3-12
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4.0 DESCRIPTION OF ALTERNATIVES
As part of the Feasibility Study (FS) for au 4 (MW, 1993a), medium-specific remedial
alternatives were developed for ground water, surface water, landfill contents, and air to
meet the remedial action objectives. Five alternatives were developed for ground water,
five for surface water, five for landfill contents, and three for air. The only contaminated
soils which require remediation will be addressed as part of the landfill contents.
Alternatives were assembled on a medium-specific basis to allow for flexibility in
selecting a site-specific remedy. Under Section 121 of CERCLA, a selected remedial
action must be protective of human health and the environment, and it must comply with
applicable or relevant and appropriate requirements (ARARs). The alternatives for each
medium were evaluated for short-term effectiveness, long-term effectiveness and
permanence, reduction of toxicity, mobility or volume through treatment, technical and
administrative implementability, and cost effectiveness. Alternatives were then
compared against these criteria for selecting the recommended remediation measures.
Additionally, state and community acceptance were also considered. This section
summarizes how the remedy selection process for au 4 addressed these requirements.
4.1 DEVELOPMENT OF ALTERNATIVES
Remedial alternatives were developed by assembling technologies into combinations that
are applicable for each medium. The steps that were used to develop remedial
alternatives for au 4 included development of response objectives, remedial action
objectives, and general response actions for each medium, followed by a preliminary
screening and evaluation of technologies and process options. Response objectives
include prevention of human exposure to contaminated media, protection of
uncontaminated ground water and surface water for current and future use, restoration of
contaminated ground water for future use, and prevention of cross-contamination of
media. Remedial action objectives were developed to define the extent of remediation.
These include preliminary cleanup goals, areas of attainment, and estimated restoration
time frames. General response actions for each medium identify basic actions that might
be undertaken as part of a remedial action. Several technologies may exist for each
general response action. The preliminary screening of technologies for each general
response action involved evaluation of technical implementability. In the process option
evaluation, technically implementable technologies were evaluated with respect to
effectiveness, implementability, and cost. Details of the technologies evaluated and the
evaluation process used are presented in the FS (MW, 1993a).
The alternatives assembled for each medium begin with the no action alternative, which
is required by the NCP to be included in the comparison process. Subsequent alternatives
represent an increasing degree of technical complexity. Each alternative contains
different processes and degrees of remediation for ground water, surface water, landfill
contents, and air. The alternatives assembled for each medium are presented in Tables
4-1 though 4-4.
4-1
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TABLE 4-1
ALTERNATIVFS FOR GROUND-WATER REMEDIATION
Ground-Water Ground-Water Ground-Water Ground-Water Ground-Water
Remedial Alternatives Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5
Collection! Collection!
On-Site On-Site Collection!
Treatment Treatment On-Site
General using Air using Treatment using
Response Technology Process No Limited Stripping! Oxidation! Reductive}
Action Type Option(s) Action Action Discharge Discharge Dehalogenation
Institutional Access Well Use
Controls Restrictions Advisories W~II
Drilling . . .
Restrictions. and
Water Rights
Restrictions
Collection Extraction! Drilled
Drainage WellslDrains
. .
Subsurface ImpermeableWalls
Baniers
.
Direct Treatment PhysicaV On-Site Treatment
Chemical (Air Stripping)
.
On-Site Treatment
(Oxidation)
.
In-Situ PhysicaV On-Site Treatment
Chemical (Reductive
(Dehalogenation .
Discharge Surface Weber River or
Discharge POTW
. .
All alternatives include ground-water monitoring
4-2
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TABLE 4-2
ALTERNATIVES FOR SURFACE. WATER REMEDIATION
Remedial Alternatives Surface- Surface- Surface-Water Surface-Water Surface- Water
Water Water Alternative Alternative Alternative
Alternative Alternative 3 4 5
1 2
Collectionffreat-
Collection! Collection! ment/Discharge
Treatment Treatment in Conjunction
General Using GAC Using With Ground-
Response Technology Process No Limited Adsorption! Reductive Water
Action Type Option(s) Action Action Discharge Dehalogenation Alternatives
/Discharge
Institutional Access Restrictions Fencing.
Controls Easements. Leases 8 8 8 8
Collection Surface Controls Diversion!
Collection 8 8 8
Treatment PhysicaV Carbon
Chemical Adsorption 8
Reductive
Dehalogenation 8
Treatment in See Ground-Water
Conjunction With Remediation 8
Ground-Water Alternatives
Alternatives (Table 4-1)
Discharge Surface Infiltration
Trenches 8 8
Discharge in See Ground-Water
Conjunction With Remediation 8
Ground-Water Alternatives
Alternatives (Table 4-1)
Each option includes surface-water monitoring.
4-3
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TABLE 4-3
ALTERNATIVES FOR LANDFILL CONTENTS REMEDIA nON
Landfill Landfill Landfill Landfill Landfill
Contents Contents Contents Contents Contents
Alternative Alternative Alternative Alternative Alternative
Remedial Alternatives 1 2 3 4 5
General
Response Technology Process No Limited In-Situ Excavation!
Action Type Option(s) Action Action Containment Treatment Disposal
Institutional Access Restrictions Fencing, ~ . . .
Controls Orders Concernin~'
Future Land Use
Restrictions .i!lli!.
Notice to Deed
Containment Surface Controls Grading and . .
Revegetation
Cap Clay or Multi-Media . .
In-Situ Treatment Physical Vapor Extraction .
Removal Excavation BackhodFront End .
Loader
Disposal Off-Site RCRA Subtitle C .
Landfill
4-4
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TABLE 4-4
ALTERNATIVES FOR AIR REMEDIATION
Air Air Air
Alternative Alternative Alternative
1 2 3
Collection!
General With or
Response Technology Process No Limited Without
Action Type Option(s) Action Action Treatment
Institutional Monitoring Air Monitoring 8 8
Controls
Access Land Acquisition 8
Restrictions
Collection foundation Active Pipe anellor 8
Ventilation Trench Vents
Treatment Physical Carbon Adsorption 8(T)
(1) If required by air emission regulations. air collected from foundation would be treated using
carbon adsorption.
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4.2 DETAILED ANALYSIS OF ALTERNATIVES
During the detailed analysis for OU 4, each alternative was assessed against nine
evaluation criteria developed by the EP A to compare the relative performance of the
alternatives and to identify the advantages and disadvantages of each. This approach was
designed to provide sufficient information to adequately compare the alternatives, select
an appropriate site remedy, and satisfy CERCLA remedy selection requirements. The
detailed analysis of alternatives included further definition of the volumes or areas of
contaminated media to be addressed, the technologies to be used, and the performance
requirements associated with those technologies. Also included was an assessment and
summary profile of each alternative, and a comparative analysis among the alternatives.
4.2.1. Ground-Water Alternatives
The following alternatives address remediation of contaminated shallow ground water.
The area of attainment for ground water is 69 acres, and the volume of contaminated
ground water is approximately 200 million gallons. The chemical-specific ARARs that
are currently exceeded in the shallow ground water are the drinking water MCLs for
TCE, DCE, benzene, arsenic, nickel, and selenium; these are the cleanup goals for
shallow ground water. Currently, the risk to human health and the environment due to
exposure to contaminated shallow ground water does not exceed the target of 1 x 10-6.
However, if a future well was installed in the contaminated part of the shallow aquifer for
domestic purposes, the excess lifetime cancer risk to an individual would be 7 x 10-3 for
on-Base shallow ground water and 1 x 10-3 for off-Base shallow ground water, and the
hazard index would be 50 on-Base and 6 off-Base.
Ground-Water Alternative 1- No Action
This alternative would involve implementing a ground-water quality monitoring program.
Ground-water alternative I would not reduce the risk associated with future exposure to
shallow ground water. Under the no action alternative, the concentrations of ground-
water contaminants would be expected to decline by natural attenuation. The time frame
required for natural attenuation would be greater than 160 years. Implementation.of this
alternative would involve: obtaining leases and/or easements to install monitoring wells
and to collect samples on private properties; collecting ground-water samples quarterly;
analyzing the samples for VOCs, metals, and other selected parameters; performing
quality assurance reviews on the data; compiling and reporting findings; and performing
an overall data review every five years. The total capital cost for this alternative is
$6,000. Operation and maintenance costs are $38,000 per year and $48,000 every fifth
year. Based on a 30-year monitoring period, the total present worth cost of ground-water
alternative I is $648,600. .
Ground-Water Alternative 2 - Limited Action
A ground-water quality monitoring program as described for ground-water alternative 1
would be implemented along with the following institutional controls: (1) restricting
water rights and well drilling, and issuing well use advisories, and (2) obtaining
4-6
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easements andlor leases on properties where monitoring is required. Short-term access
restrictions, such as fencing to prevent access to construction areas or treatment system
equipment, will also be used as needed. Ground-water alternative 2 would reduce the
risk associated with future exposure to shallow ground water because the institutional
controls would prevent domestic use of contaminated ground water. The concentrations
of ground-water contaminants would be expected to decline by natural attenuation,
provided the source is removed or contained. The restoration time frame would be
greater than 160 years. The total capital cost for this alternative is $231,500. Operation
and maintenance costs are $42,300 per year and $52,300 every fifth year. The total
present worth for the limited action alternative for ground water for a 30-year period is
$943,500.. . .
Ground-Water Alternative 3 - Collection/On-Site Treatment Usin2 Air Strippin~
Discharee
Contaminated ground water would be extracted using horizontal drains or vertical wells.
The ground water would be treated by air stripping and discharged to the Weber River or
to the local publicly-owned treatment works (POTW). Air emissions would be treated to
meet state emission requirements, and metals pretreatment would be performed as
necessary to meet discharge requirements. Institutional controls as described in ground-
water alternative 2 would be enacted, and ground-water quality would be monitored as
described in alternative 1. Ground-water alternative 3 would reduce the risk to human
health and the environment by removing contaminants from the ground water and
reducing the potential for future exposure. Ground-water extraction will cause flushing
of the aquifer, resulting in dilution and dispersion of the metals. Since the concentrations
of metals in the aquifer are slightly above MCLs, ground-water extraction is expected to
reduce metals concentrations in the aquifer to below the remediation goals. Ground-
water alternative 3 would reduce excess cancer risk and the hazard index to below 10-6
and to less than 1, respectively. The restoration time frame for this alternative is
estimated to be greater than 30 years. This alternative would provide hydraulic
containment, which would prevent further migration of contaminated ground water. The
total capital cost for this alternative is $1,829,800 for discharge to the POTW and
$1,909,400 for discharge to the Weber River. The operation and maintenance costs are
$164,800 per year and $174,800 every fifth year for discharge to the POTW, and
$154,800 per year and $164,800 every fifth year for discharge to t~e Weber River. The
total present worth for ground-water alternative 3 under a 30-year term is $4,437,200 for
discharge to the Weber River and $4,519,100 for discharge to the local POTW.
Ground-Water Alternative 4 - Collection/On-Site Treatment Usin2 Oxidation/
Discharee
Ground-water alternative 4 would be similar to ground-water alternative 3, except that the
on-site treatment facility would consist of an ultraviolet (UV) oxidation reactor.
Institutional controls as described in ground-water alternative 2 would be enacted, and
ground-water quality would be monitored as described in alternative 1. Ground-water
extraction will cause flushing of the aquifer, resulting in dilution and dispersion of the
metals. Since th~ concentrations of metals in the aquifer are slightly above MCLs,
4-7
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ground-water extraction is expected to reduce metals concentrations in the aquifer to
below the remediation goals. Metals pretreatment would be performed as necessary to
meet discharge requirements. This alternative would reduce the risk to human health and
the environment by removing contaminants from the ground water and reducing the
potential for future exposure. Implementation of ground-water alternative 4 would
reduce the excess cancer risk to less than 10-6 and the hazard index to less than one. The
time frame for ground-water restoration is estimated greater than 30 years. Ground-water
alternative 4 would provide hydraulic containment. The total capital cost for this
alternative is $1,838,300 for discharge to the POTW and $1,917,900 for discharge to the
Weber River. The operation and maintenance costs are $143,450 per year and $153,450
every fifth year for discharge to the potw, and $133,450 per year and $143,450 every.
fifth year for discharge to the Weber River. The total present worth cost associated with
implementation of ground-water alternative 4 under a 30-year term is $4,101,100 for
discharge to the Weber River and $4,182,900 for discharge to the local POTW.
Ground-Water Alternative 5 - Metal-Enhanced Reductive Dehalo2enation Funnel
and Gate System
Under ground-water alternative 5, contaminated ground water would be treated in-situ by
using funnels of impermeable walls to direct ground water through reductive
dehalogenation cells emplaced in the aquifer. The reductive dehalogenation cells would
contain iron filings that would degrade halogenated aliphatic compounds. Additional
monitoring wells would be necessary to evaluate system performance. Institutional
controls would be enacted, and ground-water quality would be monitored as in ground-
water alternatives 3 and 4. Ground-water alternative 5 would reduce the risk to human
health and the environment by removing ground-water contaminants and preventing
future exposure. A treatability study would be necessary to evaluate the effectiveness of
reductive dehalogenation technology. If results of the treatability study are lositive,
implementation of this alternative would reduce the cancer risk to less than 10- and the
. hazard index to less than one. The time frame for restoring shallow ground water using
alternative 5 is estimated at 160 years. This alternative would provide containment of
contaminated ground water. The total capital cost for this alternative is $3,963,000. The
operation and maintenance costs are $43,000 per year, $68,000 every second year, and
$148,000 every fifth year. The total present worth cost for ground-water alternative 5
under a 30-year term is $5,081,000. A treatability study is necessary to refine this cost
estimate.
4.2.2. Surface-Water Alternatives
The following alternatives address remediation of contaminated surface water in seeps at
OU 4. The risk to human health due to exposure to contaminated surface water is
currently below levels considered significant by EPA. However, there may be risks to
environmental receptors from exposure to OU 4 surface water. There are also future risks
to human health if the seeps are used for domestic purposes. The chemical-specific
ARARs identified for surface water are the drinking water MCLs. The MCL for TCE is
currently exceeded in surface water samples. Because of the hydraulic connection
4-8
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between ground water and surface water, the restoration time for all surface water
alternatives is the same as that for the ground-water alternative chosen.
Surface-Water Alternative 1- No Action
Under surface-water alternative 1, a surface water quality monitoring program would be
implemented. This program involves collecting surface water samples quarterly;
analyzing the samples for VOCs, and other selected parameters; reviewing the data for
quality assurance; compiling and reporting the data; and performing a data review every
five years'. This alternative would provide no means of reducing or eliminating the risk
associated with exposure to contaminated seeps. The total capital cost for this alternative
is $0. The operation and maintenance costs are $10,600 per year and $20,600 every fifth
year. The total present worth cost of surface-water alternative 1 is $200,300.
Surface-Water Alternative 2 - Limited Action
Surface-water alternative 2 would involve implementing a surface-water quality
monitoring program as described for alternative 1 and enacting the following institutional
controls: (1) water use advisories, and water rights restrictions for contaminated surface
water; (2) obtaining easements and/or leases on properties where monitoring is required;
and (3) fencing seeps which provide sufficient flow for consumption by humans and
livestock. Institutional controls implemented under this alternative would reduce risk by
preventing access and direct contact with contaminated surface water. The total capital
cost for this alternative is $25,400. The operation and maintenance costs are $13,000 per
year and $23,000 every fifth year. The total present worth cost of surface-water
alternative 2 for a 30-year period is $264,400.
Surface- Water Alternative 3 - Collectionffreatment Usine Carbon Adsorption!
Discharee
Surface-water alternative 3 would involve collecting surface water at each contaminated
seep and treating with granular activated carbon to remove organic compounds. The
treated effluent would be discharged using infiltration trenches. Surface water
monitoring as described for alternative I would continue, and institutional controls as
described for alternative 2 would be enacted. Surface-water alternative 3 would reduce
risk because it involves removal of contaminants from surface water. The total capital
cost for this alternative is $46,700. The operation and maintenance costs are $14,960 per
year and $24,960 every fifth year. The total present worth cost for surface-water
alternative 3 over 30 years is $317,400.
Surface-Water Alternative 4 - Collectionffreatment Usine Reductive
DehaloeenationIDischaree
This alternative would be similar to surface-water alternative 3, except the surface water
would be treated using reductive dehalogenation canisters. A treatability study would be
necessary to evaluate the effectiveness of the technology. Surface-water monitoring as
described for alternative I would continue, and institutional controls as described for
4-9
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alternative 2 would be enacted. Surface-water alternative 4 would reduce risk by
removing and destroying the contaminants dissolved in collected surface water. The total
capital cost for this alternative is $57,900. The operation and maintenance costs are
$16,050 per year and $26,050 every fifth year. The total present worth cost for surface-
water alternative 4 for a 30-year period is $346,200.
Surface-Water Alternative 5 - CollectionlfreatmentlDischar~e in Conjunction with
Ground- Water Alternative
Under surface-water alternative 5, contaminated surface water would be collected,
treated, and discharged in accordance with the treatment alternative selected for ground
water. This alternative would include collecting and transporting surface water to the
ground-water treatment system, and performing surface water monitoring and enacting
institutional controls as described in alternatives 1 and 2. Surface-water alternative 5
would reduce risk by treatment and destruction of the surface water contaminants. The
total capital cost for this alternative is $86,300. The operation and maintenance costs are
$18,400 per year and $28,400 every fifth year. The total present worth cost of surface-
water alternative 5 over 30 years is $412,500.
4.2.3. Landfill Contents Alternatives
The following alternatives address remediation of contaminated landfill contents.
Landfill contents include the landfill materials and contaminated soils associated with
Landfill 1. The area of attainment for landfill contents is approximately 150,000 square
feet, and the volume of landfill contents is approximately 140,000 cubic yards. The risk
to human health and the environment due to exposure to landfill contents is currently
below levels considered significant by EPA. However, the landfill contents are the
source of ground-water contamination at au 4.
Landfill Contents Alternative 1 - No Action
Landfills contents alternative 1 would involve no action. The no action alternative does
not reduce risk to human health and the environment because it poes not prevent leaching
of contaminants to underlying ground water. This alternative would involve no capital or
operation and maintenance costs. The total present worth cost of this alternative is $0.
Landfill Contents Alternative 2 - Limited Action
Landfill contents alternative 2 would enact institutional controls that restrict access at
Landfill 1. The purpose of these restrictions is to limit direct exposure to landfill contents
and contaminated soils and to protect the integrity of the remedial action. Deed
restriction should prevent subsurface development (excavation) and excessive vehicular
traffic. Implementing institutional controls would include:
.
A continuing order of the Base Commander requiring implementation of the
landfill restrictions as long as the property is owned by Hill AFB. .
4-10
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.
Upon completion of construction at Landfill 1, the Air Force will file notice of
these restrictions in the real property records of the county(ies) in which the
landfill is located. Upon transfer of the property, the Air Force will provide a
deed covenant notifying the transferee of the locations and the restrictions on
use of the areas.
.
Fencing the landfill area with warning signs for the duration of the remedial
action.
Additional deed restrictions may be required for effective implementation of other
technologies. Use of the ground water in the area of Landfill 1 as a drinking water source
would be restricted as described in the ground water alternative. Limited action would
not reduce risk because the potential for contamination of underlying ground water by
landfill leachate would not be eliminated. The total capital cost for this alternative is
$43,400, and the annual operation and maintenance cost is $3,040. The total present
worth cost of implementing the limited action alternative for landfill contents for a 30-
year period is $92,500.
Landfill Contents Alternative 3 - Containment
Under landfill contents alternative 3, a clay or multi-media cap would be placed over the
landfill to limit infiltration and reduce the leaching of contaminants from the landfill
contents into the underlying ground water. SoH overlying the landfill cap would be
graded and revegetated to further reduce the potential for infiltration and to control
runoff. Land use and access within the capped area would be limited by implementing
institutional controls as described under landfill contents alternative 2. The containment
. alternative would limit direct exposure to hazardous wastes and contaminated soils in the
landfill, and it would reduce the potential for contamination of underlying ground water.
Therefote, landfill contents alternative 3 would reduce risk to human health and the
environment. The total capital cost for this alternative is $1,181,000 for a clay cap and
$1,286,000 for a multi-media cap. The annual operation and maintenance costs are
$65,100 for a clay cap and $70,800 for a multi-media cap. The total present worth cost
for landfill contents altern~tive 3 for 30 years of operation is $2,231,800 for a clay
landfill cap and $2,428,800 for a multi-media landfill cap.
Landfill Contents Alternative 4 - Containment and In-Situ Treatment
Under landfill contents alternative 4, the containment options described for landfill
contents alternative 3 would be implemented. In addition, a vapor extraction system
would be installed to remediate VOCs in Landfill 1. This alternative includes installation
of air emission control equipment and enactment of the institutional controls described in
landfill contents alternative 2. Containment and in-situ treatment of landfill contents
would reduce risk to human health and the environment. Direct exposure to hazardous
wastes and contaminated soils in the landfill would be limited, and the treatment method
would reduce the concentrations of VOCs. Additionally, the potential for further
contamination of underlying ground water would be reduced. The total capital cost for
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this alternative is $1,520,000 for a clay cap and $1,626,000 for a multi-media cap. .The
annual operation and maintenance costs are $181,970 for years 1 through 5 and $83,365
for years 6 through 29 for a clay cap. The annual operation and maintenance costs are
$187,640 for years 1 through 5 and $89,035 for years 6 through 29 for a multi-media cap.
The total present worth cost for landfill contents alternative 4 for a 30-year period is
$3,391,100 for a clay landfill cap and $3,588,600 for a multi-media landfill cap.
Landfill Contents Alternative 5 - Excavation and Disposal of Landfill Contents
Under landfill contents alternative 5, the contents of Landfill 1 would be excavated and
disposed of at an off-Base RCRA Subtitle C hazardous waste landfill. Landfill contents
alternative 5 would remove the landfill contents as a potential source of ground-water
contamination. Treatment of the excavated material may be required prior to disposal.
This alternative would reduce risk to human health and the environment. The total
capital cost for this alternative is $47,150,000 without treatment and $90,620,000 with
treatment. There are no operation and maintenance costs associated with this alternative.
The total present worth cost of landfill contents alternative 5 over a one-year remediation
period is $47,150,000. If treatment by incineration or soil washing of the landfill
contents is required prior to disposal, the total present worth cost is $90,620,000.
4.2.4. Air Alternatives
The following alternatives address remediation of contaminated air. The area of
attainment for air is the residences located above the contaminated ground water. The
risk to human health and the environment due to exposure to contaminated air is well
below levels EP A considers significant. Results of air sampling in residences in the
vicinity of OU 4 indicated that contaminant levels are less than those that would pose risk
according to EP A. However, there are potential risks associated with air contamination if
the ground-water contamination continues to migrate. Implementation of ground-water
alternatives 3 or 4 would prevent further migration of contaminated ground water, which
would reduce risks associated with potential exposure to contaminants in air.
Ab: Alternative 1 - No Action
Air alternative 1 would involve semi-annual air monitoring in the basements of
residences located above the ground-water contamination. Implementation of this
alternative would require obtaining leases and easements required to perform monitoring,
collecting and analyzing air samples, performing quality assurance reviews on the data,
and compiling and reporting the data. This alternative would not reduce risk or
contaminant levels. The no action alternative involves no capital costs. Operation and
maintenance costs are $10,000 per year for years 1 through 10 and $12,000 per 'year for
years 11 through 30. The total present worth cost of the no action alternative for a
30-year term is $340,000.
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Air Alternative 2 - Limited Action
The limited action alternative for air would involve purchasing or . leasing residences
overlying the ground-water plume and building restrictions on property over the plume.
This alternative would reduce risk by preventing potential exposure to contaminated air.
The total capital cost for this alternative is $220,000. The operation and maintenance
cost is $0. The total present worth cost is $220,000.
Air Alternative 3 - ColiectionlWith or Without Treatment
Air alternative 3 would involve installing foundation ventilation systems around homes
containing concentrations of vapors from the underlying ground-water contamination that
exceed acceptable risk levels. The systems would consist of trenches excavated along
foundation walls and backfilled with permeable material and/or perforated vent pipes
with exhaust fans to purge infiltrating air from the system. The purged air would be
treated by carbon, as necessary, to meet state emission requirements. An air monitoring
program would be included to measure the effectiveness of the system. This alternative
would reduce risk to human health and the environment because contaminated air would
be prevented from entering residences, and the exposure pathway would be eliminated.
The total capital cost for this alternative is $4,500. The operation and maintenance cost is
$10,750 per year for years 1 through 10 and $12,750 per year for years 11 through 30.
The total present worth cost for this alternative for 30 years of operation is $192,900.
4.3 COMPARATIVE ANALYSIS OF ALTERNATIVES
Alternatives for each of the four media were compared to assess the relative advantages
and disadvantages among the alternatives and to identify key tradeoffs that were balanced
in selecting an alternative for each medium. Because the selected alternatives for the four
media were combined to form one complete site-specific remedy, it was necessary to
consider interactions and interdependencies among the different media and duplicate
actions among the treatment technologies when comparing the alternatives. The
preferred alternative was developed based upon the following comparisons, considering
the expected results of the combination of alternatives from each set. The alternatives
were compared with respect to nine evaluation criteria that have been developed under
CERCLA to address the technical and policy considerations associated with selecting
among the remedial alternatives. The evaluation criteria are described below.
Threshold Criteria
Threshold criteria include overall protection of human health and the environment and
compliance with Applicable or Relevant and Appropriate Requirements (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 describes whether
the alternative as a whole achieves and maintains adequate protection of human
health and the environment.
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2.
Compliance with ARARs describes whether the alternative complies with
ARARs, or, if ~ waiver is required, how it is justified. Other information from
advisories, criteria, and the guidance "to be considered" is also addressed.
Balancin~ Criteria
The five balancing criteria form the basis of the comparative analysis because they allow
tradeoffs among the alternatives requiring different degrees of performance.
3.
Long- Term Effectiveness and Permanence refers to the ability of an alternative
to provide reliable protection of human health and the environment over the long
term.
4.
Reduction of Mobility, Toxicity, and Volume Through Treatment refers to the
preference for treatment technologies that meet this criteria.
5.
Short- Term Effectiveness examines the effectiveness of alternatives in
protecting human health and the environment during the construction and
implementation of a remedy and until the response objectives have been met.
6.
Implementability evaluates the technical and administrative feasibility of the
alternatives and the availability of the goods and services needed to implement
them.
7.
Cost refers to the capital, indirect, and operation and maintenance costs of each
alternative. Costs are estimated and expected to provide an accuracy of plus 50
percent to minus 30 percent for a30-year period. The 30-year period is used as a
common point of comparison. Cost can only be a deciding factor for alternatives
equally protective of human health and the environment.
Modifyin~ Criteria.
The modifying criteria described below are generally addressed in response to comments
from the State and the public, after the issuance of the ROD.
8.
State Acceptance indicates the preferences of the UDEQ among or concerns
about alternatives.
9.
Community Acceptance reflects the community's preferences among or concerns
about the alternatives.
4.3.1. Ground Water
With the exception of ground-water alternative 1, all of the ground-water alternatives
would be protective of human health and the environment. Ground-water alternatives 3,
4, and 5 would comply with ARARs. However, the restoration time frames for these
4-14
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alternatives may exceed 30 years. Ground-water alternatives 3, 4, and 5 would
substantially reduce the level of ground-water contamination and provide containment of
the contaminated ground water. When implemented in conjunction with institutional
controls, ground-water alternatives 3, 4, and 5 would provide overall protection of human
health and the environment. Ground-water alternatives 3, 4, and 5 also would reduce
contaminant mobility. Ground-water alternatives 1 and 2 would not achieve long-term
effectiveness, nor would they reduce mobility, toxicity, and volume through treatment.
None of the alternatives for ground water would present any short-term risks to the
public. Implementation of ground-water alternatives 3,4, and 5 would present short-term
risks to workers constructing, operating, and monitoring the treatment equipment. These
risks would be minimized by following appropriate worker health and safety measures.
Ground-water alternatives 3, 4, and 5 may cause the following physical effects on the
environment: direct vegetation loss, minor habitat destruction, and some wildlife
disturbances. These physical effects will be minimized by restoring the cleared areas to
as close as their previous condition as practicable and maintaining the areas to prevent
manifestation of noxious weeds. Habitat destruction and wildlife disturbances would be
temporary and would not adversely affect population distribution or abundance. All the
alternatives are technically feasible.
Ground-water alternatives 3, 4, and 5 were comparable with respect to the five balancing
criteria. Ground-water alternative 5 was rated fair with respect to implementability due
to the innovative nature of the technology. Given the +50/-30 percent accuracy in the
cost estimates, the cost differential between alternatives 3 and 4 was considered
insignificant. Ground-water alternatives 4 and 5 would require treatability studies to
refine cost estimates and process requirements. Ground-water alternative 3 was chosen
because it utilizes a treatment technology that has been proven and successfully
implemented in removing TCE from ground water. The State of Utah agrees with the
alternative selected. The community has not raised any significant concerns related to the
proposed alternative. Therefore, the selected alternative is acceptable to the community.
4.3.2. Surfare Water
Except for surface-water alternative 1, all of the surface-water alternatives would be
protective of human health and the environment. The no action alternative for surface
water would not be protective of the environment. Surface-water alternatives 3 and 4
would comply with ARARs, and they would achieve long-term effectiveness and
permanence. Surface-water alternative 5 would comply with ARARs and achieve long-
term effectiveness and permanence to the extent that these criteria are met by the ground-
water alternative chosen. Surface-water alternatives I and 2 would not comply with
ARARs, nor would they achieve long-term effectiveness and permanence. Contaminant
mobility, toxicity and volume would be reduced through treatment under surface-water
alternatives 3, 4, and 5.
None of the alternatives present any short-term risks to the public. Implementation of
surface-water alternatives 3, 4, and 5 would pose short-term risks to workers
constructing, operating, and monitoring the treatment equipment. These risks would be
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minimized by following appropriate health and safety requirements. All of the surface-
water alternatives are technically and administratively implementable, although surface-
water alternative 4 would require a treatability study.
Alternatives 3, 4, and 5 were comparable with respect to the balancing criteria.
Alternative 4 would require a treatability study. Surface-water alternative 3 was chosen
because it is the least expensive of the three. The State of Utah agrees with the
alternative selected. The community has not raised any significant concerns related to the
proposed alternative. Therefore, the selected alternative is acceptable to the community.
4.3.3. Landfill Contents
Landfill contents alternatives 3, 4, and 5 would be protective of human health and the
environment, would comply with ARARs, and would provide long-term effectiveness
and permanence. Landfill contents alternatives 4 and 5 provide the most protection of
human health and the environment. Landfill contents alternatives 3, 4, and 5 would
supplement the ground-water alternative chosen by removing the source of ground-water
contamination. Only landfill contents alternative 4, which involves in-situ treatment,
would reduce contaminant mobility, toxicity, and volume through treatment. Landfill
contents alternatives 3 and 5 would reduce mobility of the contaminants, although no
treatment would be performed.
No short-term risks to the public would be associated with landfill contents alternatives 1,
2, 3, and 4. However, alternatives 3 and 4 would pose short-term risks to workers
constructing and maintaining the systems. These risks would be minimized by using
appropriate health and safety procedures. Landfill contents alternative 5 would present
short-term risks associated with excavation activities and transportation of the waste
through the surrounding communities. All five landfill contents alternatives are
technically and administratively implementable.
Landfill contents alternative 3 would reduce mobility and toxicity, but would not involve
treatment. Landfill contents alternative 5 may cause short-term risks. associated with
excavation, and it is over 10 times the cost of alternative 4. Landfill alternative 4 was
chosen because it would offer reduction of mobility, toxicity, and volume through in-situ
treatment, pose no short-term risks, and its cost .would be relatively reasonable. The State
of Utah agrees with the alternative selected. The community has not raised any
significant concerns related to the proposed alternative. Therefore, the selected
alternative is ac:ceptable to the community.
4.3.4. Air
The air alternatives were compared based on a future scenario in which concentrations of
contaminants in air in residential basements exceed acceptable risk levels. If air
concentrations corresponding to unacceptable risk levels are measured in residences in
the future and are attributable to OU 4 contamination, air alternatives 2 and 3 would be
protective of human health and the environment. All three air alternatives would comply
with ARARs. Air, alternative 3 would reduce mobility and volume of contaminants
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through treatment. None of the air alternatives would present any short-term risks to the
public. Air alternatives 1 and 3 are technically and administratively implementable.
Implementation of alternative 3 would pose short-term risks to workers installing and
operating treatment equipment. These risks would be minimized by following health and
safety procedures. In the event that air contamination levels remain at current non-
detectable levels, all three air alternatives would provide long-term effectiveness and
permanence.
Air alternatives 1, 2, and 3 were considered protective under current conditions. No
ARARs have been identified in association with these alternatives. Air alternatives 2
and 3 would provide more benefits for comparable cost than alternative 1, but they were
considered conservative based on the fact that no air contamination above risk levels has
been detected in the residences above the contaminated ground water. Air alternative 1
was chosen because it would be the least expensive choice, and it would detect air
contamination in residences. Air alternative 3 would be implemented in the future, if
results of air monitoring indicate that concentrations of vacs in residences exceed
acceptable risk levels due to au 4 contamination. The State of Utah agrees with the
alternative selected. The community has not raised any significant concerns related to the
proposed alternative. Therefore, the selected alternative is acceptable to the community.
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5.0 SELECTED REMEDY
5.1 DESCRIPTION OF THE SELECTED REMEDY
The selected remedy at Hill AFB Operable Unit 4 is a combination of ground-water
alternative 3, surface-water alternative 3, landfill contents alternative 4, and air
alternative 1. Surface-water alternative 3 will be implemented when a sufficient volume
of water is generated from the seeps to operate the surface water treatment system. If
contaminant concentrations in the air in residences overlying the contaminated ground
water exceed acceptable risk levels due to OU 4 contamination, air alternative 3 will be
initiated. .
Under the selected remedy for OU 4, contaminants in all four media will be addressed.
Contaminated shallow ground water will be extracted, collected, treated on site using air
stripping, and discharged to the local POTW. The surface water at each seep location
will be collected locally and treated using carbon adsorption when a sufficient volume is
produced to operate the treatment system. Treated surface water will be discharged
through infiltration trenches. The contents of Landfill 1 will be contained using a landfill
cap and treated using vapor extraction. The landfill cap will limit infiltration and
leaching of contaminants to underlying ground water. Air emissions from the soil vapor
extraction system will be treated if emissions exceed regulatory limits. Air will be
addressed with the no action alternative, which includes semi-annual air monitoring in the
basements of residences overlying the contaminated ground water. Institutional controls
would be dependent in certain instances on cooperation of property owners and
municipalities or other governmental entities, and satisfaction of legal requirements.
According to ground-water alternative 3, contaminated ground water will be extracted
and directed to an air stripping treatment facility. The emissions from the air stripper
system will be treated, as necessary, to meet state emissions limits. The treated ground
water will be discharged to the local POTW. Ground-water will be treated for metals as
necessary to meet discharge requirements. Institutional controls, including well use
advisories and water rights and well drilling restrictions, and easements and leases as
necessary for monitoring and installation of equipment, will be initiated prior to
construction of the remediation equipment. Ground-water quality will be monitored
quarterly to measure the progress of the remediation. .
Surface-water alternative 3 consists of local collection of contaminated surface water at
each seep site; treatment using carbon adsorption, and discharge to the subsurface using
infiltration trenches. Institutional controls will be enacted, including water rights
restrictions, easements and leases for monitoring and installing equipment, and fencing
seeps. A surface water monitoring program will be continued quarterly throughout the
remediation. The seeps at OU 4 are fed by ground water and flow rates vary with
climatological conditions. Extracting ground water may also affect the flow rates. The'
treatment system for surface water alternative 3 would be operated when there is
sufficient flow to operate the system, but will not operate when the flow is not sufficient.
5-1
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Under landfill contents alternative 4, the contents of Landfill 1 will be contained using a
landfill cap. Soil overlying the cap will be graded and revegetated to further reduce
infiltration and to control runoff. A vapor extraction system, consisting of vapor
extraction wells or trenches, blowers, and associated equipment will be installed in the
landfill. Air emissions from the soil vapor extraction ~ystem will be treated as necessary
to meet emissions requirements. Additionally, institutional controls will be enacted,
including: (1) continuing order from the Base Commander concerning landfill
restrictions, (2) recording a notice to restrict exposure to and maintain integrity of
remedial action at Landfill 1, and (3) fencing and warning signs;
The selected remedy includes air alternative 1, which is the no action alternative for
contaminated air. This alternative will involve semi-annual air monitoring in residences
overlying the contaminated ground-water plume. If concentrations of VOCs. exceeding
acceptable risk levels that are attributable to au 4 are detected within any residences
above the contaminated ground water, air alternative 3 will be initiated. Air alternative 3
is comprised of collection of contaminated soil gas with or without treatment of the
contaminated air. This alternative will involve installing a ventilation system along the'
foundations of affected residences. An emission control device will be used if emissions
exceed regulatory limits. Semi-annual air monitoring will be conducted along with air
alternative 3 to monitor the effectiveness of the ventilation system. Implementation of
ground-water alternative 3 is expected to provide hydraulic containment of the
contaminated ground water and prevent further transport towards off-Base residences.
The concentrations of VOCs available to volatilize and move into basements are expected
to decrease in time.
Figure 5-1 shows a schedule of remediation activities during the initial 30 years
according to the order of implementation of the components of the selected remedy. The
first activities will include ground-water and air monitoring and enactment of institutional
controls. The monitoring ensures that the extent of contamination remains well defined
prior to and during implementation of remediation. Institutional controls will limit access
to contaminated water and soil prior to and during the remediation. Installation of the
landfill cap and the vapor extraction system will occur at approximately the same time,
followed by installation of the ground-water extraction and treatment systems. Soil vapor
extraction will take place after the cap and vapor extraction systems are complete.
Ground-water extraction and treatment will commence after constructing the ground-
water extraction and treatment systems. The surface-water treatment system will be
installed and operated when a sufficient volume of flow is produced by the seeps to
operate the system.
5.1.1. Remediation Goals and Performance Standards
The goals of this remedial action are described for each of the four media of concern in
the following section. The performance of the remediation system with respect to
meeting the remediation goals will be monitored according to the performance
monitoring plan to be developed during the remedial design.
The remedial action goals for OU 4 ground water and surface water are to:
5-2
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o
5
10
YEARS
15
20
25
30
I I I I I I 1 , I I I I I
~Uillationofho~nUti Ground-water extraction
drains or vertical wells and treatment
~ I
Construction of air
stripper system
Ii' r
Ground-water
monitoring
I I I
Construction
of landfill cap
I I I
, , I
InsUtilation of Vapor extraction I I
I I I
vapor extraction treatment I '
system I I I I I I
Implementation of surface- I
water treatment, when needed I
I
Air Monitoring
Implementation of .more protective
air alternative, if and when needed
I I 'I I I
.
Initiation and implementation
of institutional controls
I I I I I I
o
-
IIIIIIIIIIII
Construction phase
Implementation phase
HILL AIR FORCE BASE
OPERABLE UNIT 4
CONCEPTUAL REMEDIAL ACTION
IMPLEMENTATION SCHEDULE
FIGURE 5-1
NOTE: "rime zero" Is defined as the beginning of substantial, continuous physical
Irrprovement, which wiD begin 15 months after this ROD Is signed.
Hill AFB OU 4 ROD
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.
Meet chemical-specific ARARs, which are drinking water MCLs.
.,
Limit cancer risk to less than 10-4 with a target of 10-6 due to accidental
ingestion, dennal contact, or inhalation of vapors.
.
Maintain contaminant concentrations low enough to avoid chronic health
effects (as indicated by a hazard index of less than 1).
.
Prevent further degradation of ground-water quality in accordance with the
Utah Corrective Action Cleanup Policy.
The area of attainment over which these cleanup goals are to be achieved is defined as
that portion of the aquifer and those areas of surface water where MCLs are exceeded. .
The area of attainment for ground water, which is where TCE exceeds its MCL (5 J.1.gll),
is 69 acres. Other chemicals in ground water that may exceed their MCLs are within this
defined area.
The remedial action goals for landfill contents at au 4 are to:
.
Limit cancer risk to less than 10-4 with a target of 10-6 due to accidental
ingestion, dennal contact, or inhalation of vapors.
.
Maintain contaminant concentrations low enough to avoid chronic health
effects (as indicated by a hazard index of less than 1).
.
Eliminate the source(s) of ground-water contamination either through removal
or source control in accordance with Utah Corrective Action Cleanup Policy.
The remedial action goals for landfill contents are applicable to Landfill I only. The area
of attainment for landfill contents is the Landfill I area, which is approximately 50,000
square feet.
The remedial action goals for air at au 4 are to:
.
Prevent the migration of contaminated soil gas into residences.
.
Prevent inhalation of carcinogens in excess of 10-6 cancer risk within off-
Base residences.
.
Prevent inhalation of noncarcinogens at levels exceeding a hazard index of 1
within off-Base residences.
The area of attainment for air includes the off-Base residences overlying contaminated
ground water.
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The remediation goals for au 4 are listed in Table 5-1. Specific performance standards
used to measure the degree of attainment of ground-water, surface-water, landfill
. contents, and air are:
.
Reduce contaminant concentrations within the areas of attainment to comply
with the remediation goals.
.
Meet all ARARs identified for each medium.
.
Remediate ground water, surface water, and landfill contents in a timely
manner in compliance with the selected remedy to achieve remedial action.
goals as soon as practicable.
A performance and compli,ance 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 remedial design (RD) and will include locations of
performance monitoring points, monitoring frequency, analytical parameters, sampling
and analytical methods, and statistical methods for evaluating data. The PCSP will be
designed to provide information that can be used to evaluate the effectiveness of the
respect to the extent and level of contamination, contaminant migration, containment,
mass removal, and treatment system performance. The PCSP may be modified during
the remedial action to take into consideration changed conditions.
5.1.2. Restoration Time Frame
The restoration time for ground water is estimated to be greater than 30 years. The
restoration time frame for surface water is also estimated at greater than 30 years because
of the hydraulic connection between surface water and shallow ground water. The
estimated restoration time frame for landfill contents is 18 months, assuming vapor
extraction is sufficient to remove vacs from the Landfill 1 area. There is no restoration
time frame for contaminated air because no air contamination exceeding acceptable risk
levels has been detected in nearby residences.
5.1.3. Costs
The estimated costs for remediating au 4 using the selected remedy are presented in
Table 5-2. The total capital cost of the project is estimated at $3.5 million. The total
capital cost includes: installing a ground-water extraction system, an on-site ground-water
treatment system, a discharge system for treated ground water, collection basins and
GAC for surface water treatment, a landfill cap, vapor extraction wells, a vapor extraction
system, emission control equipment, tankage, piping, controls, and equipment housings;
and enacting institutional controls. The indirect capital cost for the project is estimated at
$1.25 million. Indirect capital costs are included in the estimated total capital costs
above. Indirect costs include engineering, contingency, administration, permitting, and
treatability studies.
5-4
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TABLE 5.1
REMEDIATION GOALS FOR HILL AFB OPERABLE UNIT 4
Chemicals of Concern
Cleanup Standards
(llg/l)(a)
Ground Water
Benzene
Chloroform
1,2-Dichloroethane
1,1- Dichloroethene
cis 1,2-Dichloroethene
trans l,2-Dichloroethene
Methyl Ethyl Ketone
Tetrachloroethene
Toluene
Trichloroethene
Total Xylenes
Arsenic
Barium
Boron
Nickel
Selenium
5
100(b)
5
7
70
100
830(c)
5
1,000
5
10,000
50
2,000
2,700(c)
100
50
Surface Water
Chloroform
cis 1,2-Dichloroethene
trans 1,2- Dichloroethene
Trichloroethene
100(b)
70
100
5
Air
Trichloroethene
5 Ilglm3(d)
(a) Unless otherwise specified, the concentrations for ground water and surface water are
maximum contaminant levels (MCLs) established under the Safe Drinking Water Act.
(b) The cleanup standard for chloroform is the MCL for trihalomethanes.
(c) Concentrations for non-carcinogens without ARARs are reported at levels such that the
calculated hazard index (HI) is less than 1.0.
(d) Concentrations for carcinogens without ARARs are rep
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TABLE 5-2
. COSTS AND PROCESS COMPONENTS FOR SELECTED REMEDY
U1
I
0\
Ground Water Surface W!"ter Landfill Contents Air
Alternative 3: Collection/On-Site Treatment Alternative 3: Collectionrrreatment using GAC Alternative 4: Containment/In-Situ Treatment Alternative I: No Action
with Air StrippinglDischarge AdsorptionlDischarge
Time to Implement = 27 months Time to Implement = 15 months, minimum Time to Implement = 15 months Time to Implement = 15 months
Collection - Horizontal Drains Collection. Local Basins Containment. Landfill Cap Air Monitoring
System of drains and piping to treatment system Concrete collection basins at each seep and Landfill cap, revegetation, regrading, geotextile Collect duplicate air samples semi-annually,
piping to treatmen! unit draining, and gas. vent layers analyze the samples for VOCs, QAlQC of data
Treatment - Air Stripping Treatment - GAC Adsorption Treatment - Vapor Extraction
Air stripper system with vapor treatment and GAC adsorption system In-situ system of vapor extraction wells,
metals treatment, if necessary, and heated vacuum extraction system,
building air-water separator,
piping, controls, valves, instrumentation, vapor
treatment,
building to house equipment
Discharge - POTW Discharge - Infiltration Trenches
Ground-Water Treatment Costs Surface Water Treatment Costs Landfill Contents Treatment Costs Air Monitoring Costs
POTW Discharge Multi-Media Cap
Indirect Capital = $864,000 Indirect Capital = $11,200 Indirect Capital = $375,000 Indirect Capital = $0
Total Capital = $1,830,000 Total Capital = $46,700 Total Capital = $1,630,000 Total Capital = $0
Annual O&M = $165,000 Annual O&M = $15,000 Annual O&M (years 1-5) = $188,000 Annual O&M (years 1- 10) = $ I 0,000
Every 5th year O&M = $175,000 Every 5th 'year O&M = $25,000 Annual O&M (years 6-29) = $89,000 Annual O&M (yrs 11-29) = $12,000
Present Worth = $4,520,000 Present Worth = $317,000 Present Worth = $3,590,000 Present Worth = $340,000
Indirect Costs include engineering, contingency, administrative, treatability studies, and permiuing; O&M Costs include monitoring program costs; Present Worth assumes 30 years of operation.
Implementation times are approximate and based on the assumption that the ROD signing date is time zero. Time to implement is defined as the time from when the ROD is signed to when
construction begins.
-------
Operation and maintenance (O&M) costs change over the duration of the remedial action.
Operation and maintenance costs are calculated for a 30-year period and do not reflect
costs that may be incurred if the remediation period lasts longer than 30 years. Annual
O&M is estimated at $380,000 for years 1-5, $200,000 for years 6-10, and $281,000 for
years 11-29. An additional $20,000 will be required for O&M every fifth year. O&M
costs include monitoring program costs as well as maintenance of equipment and the
. landfill cap.
The total present worth cost of the selected remedy over a 30-year period, using an
interest rate of five percent, was estimated at $8.8 million. The process components for
each of the alternatives comprising the selected remedy as well as preliminary design
assumptions used to estimate costs for each process are listed in Table 5-2. These
estimates are preliminary and may change during the remedial design and construction
processes. The costs discussed here and in Table 5-2 are estimated with +50/-30 percent
accuracy for a 30-year period.
5.2 STATUTORY DETERMINATIONS
The selected remedy for Hill AFB Operable Unit 4 meets the statutory requirements of
Section 121 of CERCLA as amended by SARA. These statutory requirements include
protectiveness 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 OU 4 meets each of the requirements is
presented in the following discussion.
5.2.1. Protection of Human Health and the Environment
The selected remedy for OU 4 protects human health and the environment through the
following engineering and institutional controls:
.
Ground water will be collected and treated on site to lower contaminant
concentrations below drinking water MCLs and to reduce carcinogenic and
non-carcinogenic risks to within acceptable ranges. Institutional controls,
including well advisories and water rights and well drilling restrictions, and
easements and leases as necessary for monitoring and installation of
equipment, will be enacted.
.
Surface water will be collected and treated on-site until all contaminant
concentrations are below drinking water MCLs and are within an acceptable
range for both carcinogenic and non-carcinogenic risks.
.
Landfill contents will be contained using a cap to prevent migration of
contaminants from the landfill to underlying ground water via infiltration and
treated in-situ to remove VOCs. Institutional controls restricting ground-
water use and preventing direct contact with landfill contents will be enacted.
5-7
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.
Air quality will be monitored within residences overlying the ground-water
contamination plume to ensure that VOCs attributable to OU 4 contamination
are not present at concentrations exceeding acceptable risk levels in
residences.
Collecting and treating contaminated shallow ground water will reduce the health risks to
future users by reducing the mass of contaminants. Ground-water treatment will also
reduce the level of contamination reaching the surface water at OU 4. Collecting and
treating contaminated surface water will reduce human health risks associated with
potential future exposures to contaminated surface water. Also, protection of the
environment is provided by reducing .the potential exposure of wildlife and domestic"
animals to contaminants via surface water. Capping of the landfill contents will reduce
the potential of further contamination of underlying ground water with landfill leachate,
protecting ground water from continuing and future contamination. In-situ treatment of
the landfill contents will further reduce the potential for contaminants from the landfill to
leach to ground water by removing VOCs from the landfill area. Air monitoring reduces
the health risks to residents living in homes overlying the area of contaminated ground
water by determining whether this exposure pathway exists and providing a basis upon
which additional remedial measures for air will be based.
The selected remedy will not pose any unacceptable short-term risks. Institutional
controls and proper health and safety procedures will be implemented during construction
and monitoring to minimize short-term risks to site workers and off-Base residents. The
selected remedy will minimize cross media impacts. For example, contamination of
ground water will be reduced by remediating the landfill contents, and impacts upon
surface water may be reduced by collecting and treating contaminated ground water.
5.2.2. Compliance with Applicable or Relevant and Appropriate Requirements
Section 121 (d)( 1) of CERCLA as amended by SARA, requires that the remedial actions
at au 4 must attain a degree of cleanup that assures protection of human health and the
environment. In addition, remedial actions that leave any hazardous substances,
pollutants, or contaminants on the 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 the State of Utah environmental or facility siting regulations
that are more stringent than Federal standards. In addition, ARARs include State of Utah
regulations that have no corresponding federal regulations.
"Applicable" requirements are those cleanup standards, standards of control, and other
substantive environmental protection requirements, criteria, or limitations promulgated
under Federal or State law that specifically address the hazardous substances, pollutants,
or contaminants, remedial action, the location, or other circumstance at the au 4 site.
"Relevant and appropriate" requirements are cleanup standards, standards of control, and
other substantive ~nvironmental protection requirements, criteria, or limitations
5-8
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promulgated under Federal or State law that, while not "applicable" to the hazardous
substance, pollutant or contaminant, remedial action, location, or other circumstance at a
,remedial action site, address problems or situations sufficiently similar to those
encountered at the site that their use is well-suited to the particular site.
In evaluating which requirements are relevant and appropriate, the criteria differ
, depending on whether the type of requirement is chemical-specific, location-specific, or
action-specific. According to the NCP, chemical-specific ARARs are usually health or
risk-based numerical values that establish the acceptable amount or concentration of a
chemical that may remain in, or be discharged to, the ambient environment. Location-
specific ARARs generally are restrictions placed upon the concentration of hazardous
substances or activities solely because they are in special locations. Some examples of
special locations include floodplains, wetlands, historic places, and sensitive ecosystems
or habitats. Action-specific ARARs are usually technology or activity-based
requirements or limitations on actions taken with respect to hazardous wastes, or
requirements to conduct certain actions to address particular circumstances at the site.
Chemical-specific ground-water and surface-water quality ARARs for au 4 are based on
the Safe Drinking Water Act maximum contaminant levels (MCLs) or the maximum
pennissible level of ~ contaminant in water that is delivered to any user of a public water
system. MCLs are generally relevant and appropriate as cleanup standards for
contaminated ground water and surface water that is used or may be used for drinking.
The Utah Public Drinking Water Regulations are also relevant and appropriate to the
selected remedy. In addition, the Utah Ground-Water Quality Protection, air quality, and
solid and hazardous waste regulations are applicable to the selected remedy. Other
applicable or relevant and appropriate requirements include the Solid Waste Disposal
Act, the Clean Water Act, the Clean Air Act, and the Department of Transportation
(DOT) hazardous material transportation regulations. Federal and State chemical-specific
ARARs are presented in Appendix A, Tables A-I and A-2, respectively.
Federal location-specific ARARs for au 4 include the Fish and Wildlife Conservation
Act, the Policy on Floodplains and Wetlands Assessments for CERCLA Actions, the
E~ecu~ive Order on Floodplain Management, the Fish and Wildlife Coordination Act, the
Endangered Species Act, the Rivers and Harbors Act, and the EPA Ground-Water
Protection Strategy. The only Utah location-specific ARAR is the Division of Wildlife
Resources requirement regarding pollution of waters containing protected wildlife.
Federal and State location-specific ARARs are identified in Tables A-3 and A-4, of
Appendix A, respectively.
Federal action-specific ARARs that are relevant to the remediation activities at au 4
include the National Emission Standards for Hazardous Air Pollutants (NESHAPs), The
Solid Waste Disposal Act, the Safe Drinking Water Act, the Clean Water Act, DOT
regulations, and RCRA. State of Utah action-specific ARARs include standards for
drilling and abandoning wells, solid waste landfill rules, spill reporting requirements,
Utah Corrective Action Cleanup Policy for RCRA, UST and CERCLA sites, and Air
Conservation and Public Drinking Water Regulations. Federal and State action-specific
ARARs are identified in Appendix A, Tables A-5 and A-6, respectively.
5-9
-------
The remedy selected for OU 4 will meet ARARs, but the remediation time frame may
exceed 30 years. Site hydrogeology and contaminant sorption behavior may limit the
effectiveness of ground-water extraction, preventing the attainment of drinking water
MCLs. If it is determined, on the basis of the performance of the ground-water
remediation system, that certain portions of the aquifer cannot be restored to beneficial
use, all of the following measures involving long-term management may occur, for an
indefinite period of time, as a modification of the existing system:
.
Engineering controls will be continued as containment measures;
.
Institutional controls will be provided/maintained to restrict access to those
portions of the aquifer which remain above remediation goals;
.
Ground-water monitoring will be continued; and
.
Remedial technologies and process enhancements for ground-water
restoration will be re-evaluated periodically.
The decision to invoke any or all of these measures may be made during a periodic
review of the remedial action, which will occur at least every five years, in accordance
with CERCLA Section 121(c).
5.2.3. Cost Effectiveness
Overall cost effectiveness can be defined as the reduction of the threat to human health
and the environment per dollar expended on a remedy. The selected remedy for OU 4
was chosen to provide the necessary protectiveness to human health and the environment.
When two alternatives had an equal measure of protectiveness, the alternative with the
lower cost was selected. An example of this is capping the landfill and constructing a soil
vapor extraction system (selected remedy), versus excavating and disposing of the
contents of Landfill 1 in an off-site landfill. The selected remedy would provide
protectiveness by limiting surface-water infiltration and removing the TCE source by
vapor extraction. Excavation of the landfill materials would also remove the source of
TCE, but would cost approximately 13 to 25 times more than the selected remedy.
5.2.4. Utilization of Permanent Solutions
The selected remedy provides the best balance of tradeoffs among all the alternatives
with respect to the five summa!!' balancing criteria which include:
.
Long-term effectiveness and permanence;
Reduction of toxicity, mobility, or volume through treatment;
Short-term effectiveness;
Implementability;
Cost.
.
.
.
.
5-10
-------
The criteria that were most critical in the selection decision. were reduction of toxicity.
mobility, and volume through treatment and cost. The modifying criteria, which are State
and community acceptance, had no effect on selection of the remedy because the State
agrees with the alternative selected, and the community has not raised any concerns
related to the proposed alternative. The selected remedy meets the statutory requirement
to utilize permanent solutions and treatment technologies to the maximum extent
practicable.
5.2.5. Preference for Treatment as a Principal Element
The selected remedy for OU 4 utilizes permanent solutions and treatment technologies to
the maximum extent practicable. The use of air stripping to remediate contaminated
ground water, GAC to remediate contaminated surface water, vapor extraction to
remediate contaminated landfill contents, and vapor treatment to remediate contaminated
off-gases satisfies the statutory preference for treatment that permanently and
significantly reduces the volume, toxicity, and mobility of the hazardous substances.
These treatment processes are expected to permanently reduce the concentrations of
contaminants. The potential future risks are domestic use of contaminated ground water
and surface water, and exposure to contaminated air in residences. To ensure the
effectiveness of the selected treatment remedy, Hill AFB will conduct a review within
five years after starting the remediation.
5.3 DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for Hill AFB OU 4 was released for public comment in October 1993.
The Proposed Plan identified ground-water alternative 3, surface-water alternative 3,
landfill contents alternative 4, and air alternative 1 as the preferred combination of
alternatives. This remedy included: extracting contaminated ground water and treating it
using air stripping, collecting contaminated surface water and treating it using carbon
adsorption, capping the landfill contents and treating them with soil vapor extraction, and
monitoring air in residences overlying the ground-water contamination. All written and
verbal comments received during the public comment period were reviewed, and it was
determined that no significant changes to the remedy identified in the Proposed Plan were
necessary .
5-11
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Hill Air Force Base, Utah
Operable Unit 4
Responsiveness Summary
-------
Overview
This responsiveness summary provides information about the views of the community
with regard to the proposed remedial action for Hill Air Force Base (AFB) Operable
Unit 4 (aU 4), documents how public comments have been considered during the
decision making process, and provides responses to concerns.
The public was informed of the selected remedial action in the following ways:
.
All items contained within the administrative record have been on file at the
subject repositories since the final version of each document was issued .
.
A copy of the Proposed Plan was sent to all affected and interested parties just
prior to the public comment period
.
A public comment period was held from October 7, 1993 through November
5, 1993
.
A public meeting was held on October 19, 1993 at South Weber Elementary
School in South Weber, Utah
.
Written comments by the public were encouraged.
The public meeting was well attended and residents voiced numerous concerns about the
nature and extent of contamination. A transcript of the public meeting is attached as
Appendix B. No comments were made that would affect the proposed remedial action
for au 4. One written comment was received during the public comment period. This
comment and the written response are included in Appendix C.
Background on Community Involvement
The public participation requirements of CERCLA Sections 113(k)(2)(B)(i-v) and 117
were met. Hill AFB has a Community Relations Plan that is revised as frequently as
every six months. The community relations activities include: (1) a Technical Review
Committee (TRC) which meets quarterly and includes community representatives from
adjacent counties and towns, (2) a mailing list for interested parties in the community, (3)
a bi-monthly newsletter called "EnviroNews," (4) visits to nearby schools to discuss
environmentarissues, (5) community involvement in a noise abatement program, (6)
semi-annual town council meetings, (7) opportunities for public comment on remedial
actions, and (8) support for the community for obtaining technical assistance grants
(TAGs). In addition, a public meeting was held for the communities north of the Base
that are affected by au 1, au 2, and au 4 on April 28, 1993 to explain risk issues.
The RI Report (USGS, 1992), RI Addendum (USGS, 1993), Feasibility Study Report
(MW, 1993a), and the Proposed Plan for Operable Unit 4 (MW, 1993b) were released to
the public, and are available in the administrative record maintained in the Davis County
Library and at the Environmental Management Directorate at Hill AFB. The notices of
-1 -
-------
availability for these documents were published in the Salt Lake Tribune. A public
comment period was held from October 7, 1993 through November 5, 1993. In addition,
a public meeting was held on October 19, 1993. At this meeting, representatives from
Hill AFB, EP A, and the State of Utah answered questions about the site and the selected
remedy. A court reporter prepared a transcript of the meeting. Copies of the transcript
and all written public comments received during the comment period have been placed in
the administrative record. In addition, copies of the transcript were sent to all meeting
attendees who requested them. Responses to the comments received during the public
comment period are included in the Responsiveness Summary, which is part of this ROD.
The decision process for this site is based on the Administrative Record.
Summary of Public Comments and Agency Responses
Part I - Summary and Response to Local Community Concerns.
community concerns are discussed in the following section.
The major
Extent and Area of Contamination. Members of the local community were interested
in the location of OU 4 and the contaminated ground water with respect to the South
Weber Elementary School and Daren Cutler's property. In response to these comments,
the locations of the school and the Cutler Residence were indicated on a map of the
vicinity. South Weber Elementary School is approximately three miles from OU 4.
Exposure to contamination from OU 4 is not a concern for children attending the school.
The location of the OU 4 disposal sites was clarified. The community members were told
that the disposal sites are located on Hill AFB property and not on the property of Daren
-Cutler, that the ground-water contamination extends from the source to South Weber
Drive, which is about 1500 feet from the source, and that the depth of contamination is 30
to 40 feet.
Methods for Uetermining Costs. The methods used to estimate the costs of the
alternatives were of concern to community members. Citizens were concerned that the
less expensive alternatives may be of lower quality than more expensive alternatives and
whether the costs reported were maximum of average values. The public was told that
th~_alt~rnatives present a range of methods that could be used in the remedial design, that
costs were calculated based upon 30-year present worth estimates, and that the accuracy
of these values is plus 50% and minus 30%. An alternative that does not provide
adequate protection would not be chosen because it was less expensive. Costs are taken
into account in evaluating technologies that provide comparative protectiveness and
compliance with applicable or relevant and appropriate requirements (ARARs).
Potential Air Pollution. A community member asked about the potential air pollution
resulting from the air stripping process. The community members were told that the
remedial process used would be designed to comply with all appropriate environmental
regulations, including the state and Davis County air quality regulations. The exhaust
from the air stripper would be monitored and treated if necessary prior to discharge to the
atmosphere. Unsafe air discharges will not be allowed.
-2 -
-------
Property Values. The issues of the values of affected properties and compensation for
losses were raised several times. Community concerns included compensation for
relocation, land use restrictions, damage to crops, using private property for locating
treatment systems, and whether anyone was currently being compensated for land loss.
Residents were told that these issues would be handled on a case-by-case basis and that
the Air Force has a formal claims process that they can use to request compensation for
damages. The citizens were informed that the compensation made by the Air Force to
date has been in the form of leasing property to compensate land owners for the loss of
use of that property.
Types and Concentrations of Contam'inants. One community member inquired about
the presence of other contaminants in addition to TCE, such as heavy metals and semi-
volatiles, in the landfill area. In response to this concern, the citizen was told that there
have been low levels of metals detected in ground water. No semi-volatiles have been
detected. Members of the community were concerned as to whether the concentrations of
contaminants in ground water were increasing or decreasing with respect to the levels
observed when monitoring was first started and whether the plume is expanding. The
response to this concern was that the most recent monitoring data indicates declining
concentrations of TCE in ground water and that monitoring of the extent of the plume
continues.
Current Treatability Studies. Nearby residents expressed concern about risks posed by
contaminated ground water extracted during the current horizontal drain treatability
study. They were concerned about an open pit full of water resulting from the installation
of the horizontal drains for the treatability study. The community members were told that
the open pit had since been filled with gravel and that the water was being treated with an
air stripper and discharged to the Central Weber Sewer District. Also, one resident
thought that the treatability studies were part of the remedial action. He was told that the
treatability study is a short term, temporary system which is being used to collect data to
determine the effectiveness of the technology and to gather data for designing a full scale
remediation system.
Remedial Action Schedule. One community member asked when the construction for
the remedial action would, begin. The community was told that construction oJ the
remediation system would begin 15 months after the final Record of Decision is signed
for the site, and that the Record of Decision is expected to be signed in the Summer of
1994.
Risk Assessment Methods. Community members expressed concern about the accuracy
of the risk assessment results. The community members were told that, although risk
assessment is a blend of art and science and the results are estimates, that the assumptions
used are conservative. Additionally, several community members wondered why OU 4
was being remediated if there is no risk. The distinction between current and future risk
was clarified. The community members were told that current risk associated with the
contamination at OU 4 are well below levels considered significant by EPA, but that the
purpose of the remedial action is to prevent future risks to human health and the
environment.
-3 -
-------
Potential Health Effects. The issue of potential health effects on residents was raised by
Lola Patterson in her letter of August 3, 1992 and again upon resubroittal of this letter at
the public meeting. Her concerns included: risks associated with consumption of fruits
and vegetables produced on contaminated land, consumption of a~i6'..als raised 00
contaminated property, and long-term health effects. . Mrs. Patterson was toAd that there
are no health risks from consuming fruit, vegetables, or animals proo~ed on land
overlying contaminated ground water because the shallow root systems fot plants do not
extend to the contaminated zone of ground water. If ground water was to come in contact
with the root systems, organic chemicals would be broken down by the plants. Mrs.
Patterson was told that risk depends upon exposure to the contaminants and that exi~ing
information indicates that there have been no significant public health impacts. She was.
also informed that long-term risks are not expected because the clean up activities will
remove contaminants and prevent future risks.
Air Sampling. Lynn Coy requested that Hill AFB arrange to sample the air in the borne
of Vern Coy. Hill Air Force Base responded by arranging sampling of this home.
Part II - Comprehensive Response to Specific Legal and Technical Questions
Specific legal and technical questions raised by the community are described below.
Compensation for Damages. The issue of compensation for losses was raised by
several members of the community. Concerns included compensation for relocation,
damage to crops, using private property for locating treatment systems, and wh~ther
anyone was currently being compensated for land loss. The responses to these issues
included informing residents that these issues would be handled on a case-by-case basis
and that the Air Force has a formal claims process that they can use to request
compensation for damages. The citizens were informed that the compensa~ paid by
the Air Force to date has been in the form of lease payments made for access to property
to conduct remedial investigations and to compensate land owners for losses they suff-er
as a result of that investigation.
Remaining Concerns
There are no remaining public concerns that were not addressed directly during the RI/FS
process.
-4-
-------
REFERENCES
~ .
Engineering.Science (ES), 1982. Installation Restoration Program, Phase I - Records
Search, Hilt AFB, Utah. Prepared for U.S. Air Force Logistics Command. January
1982. .
OaUHmgh, Jt'aru:.~e. 1993. U.S. Army Corps of Engineers, Permits and Regulatory Office;
SaitL* tiiy, Utah. Personal communication, September 1993.
James M. Montgomery, Consulting Engineers, Inc. (JMM), 1991. Remedial Investigation
Report for O@erable Unit 4, Vol 2 - Draft Final Baseline Risk Assessment.
Prepared fr1t U.S. Air Force Logistics Command, November 1991.
Montgomery Watson (MW), 1993. Draft Final Baseline Risk Assessment Addendum,
Vol. 2 .. Arlde~uium to Remedial Investigation Report for Operable Unit 4. Prepared
for U.S. Air Force Logistics Command.
Montgomery Wat(;on (MW), 1993a. Final Feasibility Study Report Unit 4, Hill AFB,
Utah,. Prepared for U.S. Air Force Logistics Command, September 1993.
Montgomery Watson (MW), 1993b. Final Proposed Plan for Operable Unit 4, Hill AFB,
Utah. Prepared for V.S. Air Force Logistics Command, September 1993.
Radian Corporation and Science Applications International Corporation (Radian and SAlC),
1938. Installetion Restoration Program Phase II--ConfirmationlQuantification
Stage 2, Vol 1 - Retp. Final report: Prepared for U.S. Air Force Logistics
Command.
U.S. Air Force (USAF), 1989. Hill Air Force Base Comprehensive Plan.
U.S. Fish and Wildlife Service (USFWS), 1986. National Wetlands Inventory Map:
Ogden (SW) Quadrangle.
U.S. Geological Survey (USGS), 1992. Final Remedial Investigation Report for Operable
Unit 4. Prepared for U.S. Air Force Logistics Command, September 1992.
V.5. Geological Survey (USGS), 1993. Addendum to the Final RI Report for Operable
Unit 4. Prepared for U.S. Air Force Logistics Command, February 1993.
R-l
-------
FEDERAL AND STATE ARARs
Appendix A
-------
TABLE A-I
FEDERAL CHEMICAL-SPECIFIC ARARs
ApplicableJ
Relevant
Standard, Requirement, and
Criteria, or Limitation Citation Description Appropriate Comment
Safe Drinking Water Act 42 USC Sec. 300g
National Primary Drinking 40 CFR Part 141 Establishes health-based standards NoIYes Remediation Goals
Water Standards for public water systems
(maximum contaminant levels).
Clean Water Act 33 USC Sec. 1251-1376
Water Quality Criteria 40 CFR Part 131 Sets criteria for developing water NoIYes Relevant and appropriate since shallow aquifer
quality standards based on toxicity is a potential drinking water source and for
to aquatic organisms and human discharge of treated water to the Weber River
health.
Clean Air Act 42 USC Sec. 7401 -7642
National Primary and, 40 CFR Part 50 Establishes standards for ambient YesI-- Applicable to any activity which might result
Secondary Ambient Air air quality to protect public health in air emissions during remedial actions at OU
Quality Standards and welfare (including standards 4.
for particulate matter and lead).
National Emission Standards 40 CFR Part 61 Sets emission standards for YeslYes Applicable and relevant and appropriate to
for Hazardous Pollutants Subpart A designated hazardous pollutants. ground-water treatment facility air emissions
of trichloroethene. benzene. toluene. and
chloroform.
Occupational Safety and Health 20 USC Sec. 651-678 Regulates worker health and YesI- Applicable to all worker activities related to
Act 29 CFR 1910 safety. remedial action at OU 4.
D.O.T. Hazardous Material 49 CFR Parts 107. Regulates transportation of YesI- Applicable to remedial actions involving off-
Transportation Regulations 171 - 177 hazardous materials. Base movement of hazardous materials
(contaminated GAC) during remediation.
-------
TABLE A-2
FEDERAL LOCATION-SPECIFIC ARARs
Standard, Requirement,
Criteria, or Limitation
Citation
Description
Applicable!
Relevant
and
Appropriate
Comment
Policy on Floodplains and
Wetlands Assessments for
CERCLA Actions
Endangered Species Act
Executive Order on Protection
of Wetlands
Executive Order on
Floodplain Management
EP A Guidance
Aug. 6, 1985
16 USC Sec. 1531-1543
40 CFR 6-302(h)
50 CFR Part 200
50 CFR Part 402
Exec. Order # II ,990
40 CFR Sec. 6.302(A)
and Appendix A
Exec. Order # 11,988
40 CFR Sec. 6.302(B)
and Appendix A
Discusses situations that require preparation
of a floodplains or wetlands assessment and
the factors which should be considered in
preparing an assessment for response actions
taken under CERCLA.
Requires that Federal agencies insure that any
action authorized, funded, or carried by the
agency is not likely to jeopardize the
continued existence of any threatened or
endangered species or destroy or adversely
modify critical habitat.
Requires Federal agencies to avoid, to the
extent possible, the adverse impacts associated
with the destruction or loss of wetlands and
to avoid support of new construction in
wetlands if a practicable alternative exists.
Requires Federal agencies to evaluate the
potential effects of actions they may take in a
floodplain to avoid, to the maximum extent
possible, the adverse impacts associated with
direct and indirect development of a
floodplain.
Yes/---
YesI---
No/Y es
YesI-
Applicable as there are floodplains
designated in the vicinity of OU 4 that
may be affected by the remedial action.
Endangered species are known to frequent
the Ogden area (Le., Peregrine falcons,
Bald Eagles).
Based on information provided by the
State of Utah Division of Water Resource
and United States Fish and Wildlife
Service, the seep areas are not currently
identified as wetland areas, hence, no
wetlands are potentially endangered by
contaminants or remedial actions at OU 4
and Exec. Order No. 11,990 is not
applicable. May be considered relevant
and appropriate.
Applicable to remedial actions that affect
or impinge on the Weber River floodplain.
-------
TABLE A-3
FEDERAL ACTION-SPECIFIC ARARs
Standard, Requirement,
Criteria, or Limitation
Citation
Description
Applicable/
Relevant
and
Appropriate
Comment
National Emission Standards
for Hazardous
Air Pollutants
Solid Waste Disposal Act
Guidelines for the Land
Disposal of Solid Wastes
Criteria for Classification of
Solid Waste Disposal
Facilities and Practices
Standards Applicable
to Generators of Hazardous
Waste
Standards Applicable
to Transporters of Hazardous
Waste
40 CFR 61
42 USC Sec. 6901-6987
40 CFR Part 241
40 CFR Part 257
40 CFR Part 262
40 CFR Part 263
Designates substances as
hazardous air pollutants and
establishes emission standards.
Establishes requirements and
procedures for land disposal of
solid wastes.
Establishes criteria for use in
determining which solid waste
disposal facilities and practices
pose a reasonable probability of
adverse effects on health or the
environment.
Establishes standards for
generators of hazardous waste.
Establishes standards which apply
to persons transporting hazardous
waste within the u.S. if the
transportation requires a manifest
under 40 CFR Part 262.
Yes/-
NoNes
No/Yes
Yes/-
Yes/-
Applicable to benzene, trichloroethene, and
toluene emissions from ground-water treatment
facilities or soil vents.
Relevant and appropriate to capping of
Landfill I.
Relevant and appropriate to capping of
Landfill I.
Applicable to remedial alternatives involving
handling/transport/storage of contaminated
GAC.
Transport of hazardous materials (e.g.,
contaminated GAC) off-site may occur during
some remedial alternatives.
-------
TABLE A-)
FEDERAL ACTION-SPECIFIC ARARs
. (CONTINUED)
Standard, Requirement,
Criteria, or Limitation
Citation
Description
Applicablel
Relevant
and
Appropriate
Conunent
Standards for Owners and
Operators of Hazardous Waste
. Treatment, Storage,
and Disposal Facilities
.
General Facility
Standards
.
Preparedness
and Prevention
.
Contingency Plan
and Emergency
Procedures
40 CFR Part 264
SubpartB
264.11 - 264.18
Subpart C
264.31 - 264.37
Subpart D
264.51 - 264.56
. Manifest System, Record Subpart E
Keeping, and
Reporting 264.71 - 264.77
. Releases from Solid Subpart F
Waste Management
Units 264.91 - 264.101
Establishes minimum national
standards which define the
acceptable management of
hazardous waste for owners and
operators of facilities which treat,
store, or dispose of hazardous
waste. .
YesI-
YesI-
YesI-
YesI-
YesI-
See discussion of specific sections.
Applicable to off-site facilities .
handling/regenerating contaminated GAC.
Applicable to off-site facilities
handling/regenerating contaminated GAC.
Applicable to off-site facilities
handling/regenerating contaminated GAC.
Applicable to off-site facility accepting
contaminated GAC.
Applicable to off-site facilities
handling/regenerating contaminated GAC.
-------
TABLE A-3
FEDERAL ACTION-SPECIFIC ARARs
(CONTINUED)
Applicablel
Relevant
Standard, Requirement, and
Criteria, or Limitation Citation Description Appropriate Comment
. Closure and Post-Closure Subpart G
264.111 - 164.120 Yes/- Applicable to off-site facilities
handling/regenerating contaminated GAC.
Relevant and appropriate for Landfill I.
. Financial Requirements Subpart H
264.141 - 264.151 Yes/- Applicable to off-site commercial facilities
handling/regenerating contaminated GAC.
Federal government not bound by financial
requirements of RCRA.
. Use and Management of Subpart I
Containers
264.17" - 264.178 Yes/- Applicable to containers at off-site facility
handling/regenerating contaminated GAC.
. Waste Piles Subpart L
264.251............................... Design and operating requirements Yes/- Waste piles would be temporary.
264.254............................... . Monitoring and inspection Yes/- Waste piles would be temporary.
264.256............................... Special requirements for ignitable Yes/- Waste piles would be temporary. Applicable
or reactive waste to ignitable or reactive wastes.
264.257............................... Special requirements for Yes/- Waste piles would be temporary. Applicable
incompatible wastes to ignitable or reactive wastes.
-------
. TABLE A-3
FEDERAL ACTION-SPECIFIC ARARs
(CONTINUED)
Standard, Requirement,
Criteria, or Limitation
Citation
Description
Comment
.
Landfills
SubpartN
264.30 I............................... Design and operating requirements
264.303............................... Monitoring and inspection
264.309............................... Surveying and recordkeeping
264.310..............;................ Closure and post-closure care
264.312............................... Special requirements for ignitable
or reactive waste
264.313............................... Special requirements for
incompatible wastes
264.314............................... Special requirements for bulk and
containerized liquids
264.315............................... Special requirements for containers
Applicablel
Relevant
and
Appropriate
YesI-
YesI-
YesI-
YesI-
YeslNo
YeslNo
YeslNo
YesI-
Applicable to off-site facilities handling GAC.
Relevant and appropriate to capping of
Landfill I.
Applicable to off-site facilities handling GAC.
Relevant and appropriate to capping of
Landfill 1.
Applicable to off-site facilities handling GAC.
Relevant and appropriate to capping of
Landfill I.
Applicable to off-site facilities handling GAC.
Relevant and appropriate to capping of
Landfill I.
If ignitable or reactive wastesare encountered,
this requirement will be applicable.
If incompatible wastes are encountered, this
requirement will be applicable.
If liquids are encountered, this requirement
will be applicable.
Applicable to off-site facilities handling
contaminated GAC.
-------
TABLE A-3
FEDERAL ACTION-SPECIFIC ARARs
(CONTINUED)
Standard, Requirement,
Criteria, or Limitation
Citation
Description
Applicablel
Relevant
and
Appropriate
Comment
Clean Water Act 33 USC Sec. 1251-1376
National Pretreatment 40 CFR Part 403 Sets standards to control YesI- Applies to treated or untreated hazardous
pollutants which pass through or waste discharged to POTW.
interfere with treatment processes
in publicly owned treatment works
or which may contaminate sewage
sludge.
Occupational Safety and Health 20 USC Sec. 651-678 Regulates worker health and Yes/- Applicable to any remedial action at OU 4.
Act 29 CFR 1910 safety.
D.O.T. Hazar:dous Material 49 CFR Parts 107, 171 - Regulates transportation of Yes/- Applicable to remediation alternatives
Transportation Regulations 177 hazardous materials. requiring off-site disposal of wastes.
-------
TABLE A-3
FEDERAL ACTION-SPECIFIC ARARs
(CONTINUED)
Standard, Requirement,
Criteria, or Limitation
Citation
Description
Applicablel
Relevant
and
Appropriate
Conunent
. Landfills
(continued)
. Incinerators
Land Disposal Restrictions
General
EPA Administered Permit
Programs: The Hazardous
Waste Permit Program
Safe Drinking Water Act
Underground Injection
Control Regulations
264.3) 6............................... Disposal of small containers of
hazardous waste in overpacked
drums (lab packs)
Subpart X
264.601 - 264.603
40 CFR Part 268
Subpart A
Identifies hazardous wastes that are
restricted from land disposal.
268.3.................................... Dilution prohibited as a substitute
for treatment
268.7.................................... Waste analysis and recordkeeping
40 CFR Part 270
42 USC Sec. 300g
40 CFR Part) 36
40 CFR Parts 144-47
Establishes provisions covering
basic EPA permiUing
requirements.
Sets approved test methods for
waste constituent monitoring.
Provides for protection of
underground sources of drinking
water.
YesINo
Yes/-
Yes/-
Yes/-
Yes/-
NoNes
YesINo
If laboratory packing is encountered, this
requirement will be applicable.
Applicable to off-site facilities handling GAC.
See discussion of specific sections.
Applicable to regeneration or disposal of
contaminated GAC.
Contaminated GAC may need to be analyzed
prior to disposal.
Applicable to disposal of hazardous waste to
POTW or by injection wells (40 CFR
270.60[b,c D.
Relevant and appropriate for waste constituent
monitoring.
Regulates injection of treated ground water
and surface water. Applicable if used.
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TABLE A-4
STATE CHEMICAL-SPECIFIC ARARS
Standard, Requirement,
Criteria, or Limitation
Citation
Description
Applicable!
Relevant
and
Appropriate
Comment
Utah Public Drinking Water
Regulations
Utah Ground-Water Quality
Protection Regulations
Division of Solid and Hazardous
Waste, Department of
Environmental Quality
Division of Water Quality,
Department of Environmental
Quality
Utah Adm. Code (U.A.C.)
R449 Sections 3.1.1. and
3.1.2.
Utah Adm. Code R317-6
Title 19, Chapter 6, Utah
Code Annotated (U.C.A.)
U.A.c. R315-101
Title 19, Chapter 5, U.c.A.,
U.A.C. Rule R317-1
Title 19, Chapter 5, U.c.A.,
U.A.C. Rule R317-2
Establishes maximum
contaminant levels for inorganic
and organic chemicals.
Establishes groundwater quality
standards for the different
groundwater aquifer classes.
Corrective action clean-up
standards policy - RCRA, UST,
and CERCLA sites.
Definitions for Water Pollution
Rules and General
Requirements.
Standards for Quality for Waters
of the State.
NoNes
Yes/---
Yes/-
Yes/--
Yes/-
Requirements are relevant and
appropriate to OU 4. Some MCLs
established for contaminants not
Federally regulated (i.e. total dissolved
solids).
Standards are identical to Utah Public
Drinking Water Regulations but
contain MCLs for volatile organics
Lists general criteria to be considered
in establishing clean-up standards.
Refer to Safe Drinking Water Act and
Clean Air Act. Requires removal or
control of the source.
These rules are specific to Utah waters,
though they are derived in part by
using Federal criteria. See particularly
. the non-degradation policy in R448-2-
3.
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TABLE A-5
STATE LOCATION-SPECIFIC ARARS
Standard, Requirement,
Criteria, or Limitation
Citation
Description
Applicablel
Relevant
and
Appropriate
Conunent
Division of Wildlife Resources
Department of Natural Resources
Title 23, Chapter IS, U.CA
Water pollution -- pollution of
waters containing protected
aquatic wildlife (including
specified invertebrates)
unlawful.
Yesl--
Remedial actions at OU 4 may affect
surface waters adjacent to OU 4.
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TABLE A-6
STATE ACTION-SPECIFIC ARARs
Applicable!
Department, Division Relevant and
or Commission Statute Subject Appropriate Remarks
State Engineer, Department of Title 73, Chapter 3, V.C.A., Standards for drilling and YesI- Includes such requirements as
Natural Resources Rule R625-4, abandoning wells. performance standards for casing joints,
V.A.C requirements for abandoning a well, etc.
Industrial Commission Title 35, Chapter 9, V.CA. Vtah Occupational Safety and YesI- . These rules are identical to Federal
Rule R500, V.A.C Health Standards. OSHA regulations.
Division of Solid and Title 19, Chapter 6, V.CA. Solid Waste. Not yet codified; NoNes These rules govern solid waste
Hazardous Waste, Department copy available from the Division .land fi lis.
of Environmental Quality of Solid and Hazardous Waste.
Title 19, Chapter 5, V.CA., Solid and Hazardous Waste. Yesl- R450-0, regarding spill reporting
Rule R315, V.A.C requirements, has no corresponding
Federal provisions.
Title 19, Chapter 5, V.CA., Corrective Action Clean-up YesI- Lists general criteria to be considered
Rule R315-101 U.A.C Standards Policy - RCRA, in establishing clean-up standards
UST, and CERCLA sites. including compliance with MCLs in
Safe Drinking Water Act and Clean Air
Act. Requires removal or control of the
source.
Division of Water Quality, Title 19, Chapter 5, V.CA., Sewers and wastewater NoNes Construction and performance
Department of Environmental Rule R317-3, UAC treatment works. requirement.. for remedial works will be
Quality relevant and appropriate.
Title 19, Chapter 5, V.CA, Ground-Water Quality YesI-- There is no corresponding federal
Rule 317-6, V.A.C. Protection. program.
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TABLE A-6
STATE ACTION-SPECIFIC ARARs
(CONTINUED)
Department, Division
or Commission
Statute
Subject
Applicable!
Relevant and
Appropriate
Remarks
Division of Air Quality,
Department of Environmental
Quality
Title 19, Chapter 2, U.CA,
Rule R307, U.A.C.
Utah Air Conservation Rules.
Yes/-
Requires application of best available
control technology for any source, lists
criteria to be considered in establishing
visibility standards, sets visible
emission standards, regulates fugitive
dust emissions, allows the State to
require temporary closure of air
pollution sources in the event of an air
pollution emergency episode, and
includes a limit of 1.5 tons of annual
emissions of VOCs without obtaining a
permit.
. See particularly R449-1 03 establishing
drinking water standards. These
standards are identical to federal
standards except with respect to sulfate,
TDS and fluoride.
Division of Drinking Water,
Department of Environmental
Quality
Rule 309, V.A.C.
Utah Public Drinking Water
Rules.
NoIYes
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PUBLIC MEETING TRANSCRIPT
Appendix B
..h
I.:
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1
Public Meeting re Proposed Plan for Operable
2
unit 4 held on Tuesday, October 19, 1993,
3
7:12 p.m. at South Weber Elementary School,
4
1285 East Lester Street, South Weber, Utah,
5
reported by AMY STOLTENBERG, certified
6
Shorthand Reporter, Registered Professional
7
Reporter and Notary Public in and for the
8
State of Utah.
9
* * * * *
IN ATTENDANCE:
Ms. Gwen Brewer
Mr. Bob Elliott
Mr. Gary Colgan
Mr. Rob stites
Mr. Muhammad Slam
Lt. Col. Max Irshad
Lt. Col. George New
Mr. Mike Cox.
Mr. Duane Mortensen
Ms. Diane Simmons
Other Members of the
Public
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KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS
AMY STOLTENBERG, CSR, RPR
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1
SOUTH WEBER, UTAH, TUESDAY, OCTOBER 19, 1993, 7:12 P.M.
2
* * * * *
3
MS. GWEN BREWER:
Welcome to the public meeting for
4
the Hill Air Force Base Operable Unit 4.
5
My name is Gwen Brewer, and I am the
6
Environmental Public Affairs Coordinator at Hill Air Force
7
Base.
8
The main purpose of this meeting is to obtain
9
your input on the proposed actions.
Attending tonight's presentation are the
following people:
Mr. Rob stites, Environmental Protection
Agency; Mr. Duane Mortensen, Utah Department of Environmental
Quality; Mr. Muhammad Slam, Utah Department of Environmental
Quality; Mr. Hal Dunning, Community Involvement for the
Environmental Protection Agency; Ms. Diane simmons, Community
Relations, Utah Department of Environmental Quality.
These individuals are here to provide answers
to technical questions you may h~ve about the information
available to the Air Force for cleaning up the site.
Our presentation this evening will consist of
a description of the remedial alternatives and an explanation
of how each one would improve the environment.
FOllowing the presentation, if you think you
might want a little stretch, we will take a short break,
after which we will move to the most important part of this
KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS
AMY STOLTENBERG, CSR, RPR
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PUBLIC MEETING RE PROPOSED PLAN FOR OPERABLE UNIT 4, 10/19/93
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meeting this evening, the part where you tell us what you
2
think of the proposed plan.
3
First, however, I need to take care of some
4
administrative details.
As you can see, everything being
5
said here tonight is being recoraed word for word and by a
6
professional court reporter.
This is required as part of the
7
CERCLA requirements.
8
The transcript will become part of the
9
administrative record and will b~ available for anyone to
view or to read at our repository and. our administrative
site.
I hope all of you took the time to stop and
sign in at the door. We use those names and addresses to
make sure you get any information we have on the Hill
Environmental Restoration so you're kept up-to-date on what
we do and how we do it.
That way you can tell us about it as
we're doing it.
We will give everyone an opportunity to
comment.
There is a large crowd here tonight, so at the
begin~ing I would ask that you keep your comments to at 1ea$t
21
five minutes.
Everyone will have an opportunity to speak,
22
and then we'll come back to you.
That way we will get
23
everyone in.
24
If you have a prepared statement to read, you
25
may read.it out loud, turn it in without reading it or read
KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS
AMY STOLTENBERG, CSR, RPR
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PUBLIC MEETING RE PROPOSED PLAN FOR OPERABLE UNIT 4, 10/19/93
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it and turn it in.
In any case, your comments will become
2
part of the official record, and they are extremely important
3
to us.
4
If you later wish to make a comment or add
5
something that you have said or need something cleared up for
6
you, there is an address in the proposed plan.
Please send
7
any comments you have to that address.
Our phone number is
8
in there.
There is also a phone number
Just give us a call.
9
and address for Rob Stites, for Duane Mortensen, for
Muhammad Slam and for the community involvement from the
E.P.A. and U.D.E.Q.
I would like to emphasize that no final
decision has been made.
That's our purpose for being here
this evening.
However, based on all of the collected data
and the analyses, we do have a proposed plan to give to you.
What we will do this evening is to explain the
alternatives that we considered and then tell you why we
discounted those.
The final part of this presentation is our
primary purpose tonight, and that is to listen to you.
We
want to hear your comments on any issues, and we will try to
answer any questions.
If we can't answer them this evening, we can
certainly get back with you within the next couple of days
with an answer that is satisfactory to you hopefully.
We
KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS
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PUBLIC MEETING RE PROPOSED PLAN FOR OPERABLE UNIT 4, 10/19/93
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want you to be satisfied that the action that we take
2
properly and fully addresses the problems at this site.
3
As the presentation is made, please make note
4
of any questions that you might have.
You'll be given the
5
opportunity to express them following the presentation.
6
Bob Elliott is the chief of our Environmental
7
Restoration Division, and heuII begin the presentation this
8
evening.
9
MR. BOB ELLIOTT:
Thank you, Gwen.
This is a little bit awkward.
I~m going to
use some overheads and slides and try to step out of your way
so you can see this.
I want to be sure that if anybody has
trouble seeing, that you wave your hands or let me know.
Usually, that hasn't been a problem.
People usually speak up
in these meetings to us.
I guess initially I would like to say that
it's unfortunate that we have to be here tonight because of
the fact that there is contamination in the community, but I
think the positive side of that is that we are finally after
a long period of study and evaluation presenting some
proposals to the public to fix those problems.
So that's
certainly the positive side of the things that we're looking
at.
Can everybody see?
Are we okay with that?
Are there any problems seeing in the back?
KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS
AMY STOLTENBERG, CSR, RPR
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Okay.
I'll try to speak as loudly as I can.
2
If you have problems hearing me, please speak up.
3
Operable unit 4 is located on the north side
4
of Hill Air Force Base.
(Indicating. )
Here is Hill Air
5
Force Base.
The boundary is represented by the dotted line.
6
Most of you are very familiar with the base.
The site is
7
located adjacent to the North Gate exit at the base.
8
(Indicating. )
Here is South Weber Drive, Interstate 84.
9
MS. GWEN BREWER:
You can take the mike off if you
want to hold it in your hands.
MR. BOB ELLIOTT:
Can everybody hear me okay?
MEMBER OF THE PUBLIC:
Can you pull that back up
and show us where the school would be located?
MR. BOB ELLIOTT:
(Indicating. )
The school would
be located over here in this vicinity.
The Riverdale
City/South Weber City line essentially runs right down the
middle of the site, if you will.
Does that help?
Any other questions or
orientation that I can --
MEMBER OF THE PUBLIC:
Where is Mr. Cutler's
place?
Can you point that out to me, where it is on this
map?
MR. BOB ELLIOTT:
Mr. Cutler?
(Indicating. )
Yes.
He lives just off of South Weber Drive right here.
25
MEMBER OF THE PUBLIC:
Where the dump stations
KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS
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PUBLIC MEETINGRE PROPOSED PLAN FOR OPERABLE UNIT 4, 10/19/93
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are?
2
MEMBER OF THE PUBLIC:
Is that where it's located?
3
MEMBER OF THE PUBLIC:
That's where it's located?
4
MR. BOB ELLIOTT:
(Indicating. )
Directly to the
5
north of this green dot.
6
MEMBER OF THE PUBLIC:
On his land; right?
7
MR. BOB ELLIOTT:
I'm sorry?
8
MEMBER OF THE PUBLIC:
On his land; right?
9
MR. BOB ELLIOTT:
The sites are on Hill Air Force
Base.
We'll go through -- I think we'll go through
and answer those questions as to the location and give you a
feel for that.
80 if you can hold your questions until after
we do the presentation, I think we'll answer a lot of those
as we go through it.
I'm filling in for one of my colleagues who is
out with a back injury, and his name is Shane Hirschi.
Many
of you have worked directly with Shane.
As a result of that,
I asked Mr. Gary Colgan, who is one of the consultants who
has worked with us on this project for a number of years, to
do a presentation on the technical issues associated with the
site, the exact location of the site and to review the
alternatives.
I'd like to let Gary go through that
information right now.
MR. GARY COLGAN:
Thanks, Bob.
KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS
AMY STOLTENBERG, CSR, RPR
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Good evening.
I'm going to follow on from
2
Bob's presentation and discuss the situation at the site and
3
some of the sites that are involved and how the contamination
4
originated, what the principal contaminants are and talk
5
about some of the alternatives that we have looked at.
Then
6
Bob will talk about the evaluation process that we have used
7
to develop our preferred -- or the Air Force's preferred
8
alternative in this case.
9
As Bob indicated, O.U. 4 is located on. the
hillside above the South Weber -- above the Weber valley.
It's above the Davis-Weber Canal and South Weber Drive.
I'll
leave that on a second.
The investigations have focused on several
sites there, including these locations.
(Indicating. )
There
is a Spoils Pit area which received construction debris; a
Munitions Dump area, which was World War II -- was a location
for above-ground storage of munitions; Landfill 2, which was
a regular dump site basically for domestic waste, some
construction debris; North Gate Dump area, which is this area
here and this area here (indicating), which were -- These two
areas are where some drums of chemicals were suspected to be
dumped.
Landfill 1 is another -- basically a landfill where
domestic debris and some other materials were placed.
During our investigations, we have found that
Landfill 1 appears to be the main source -- really, the only
KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTER$
AMY STOLTENBERG, CSR, RPR
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PUBLIC MEETING RE PROPOSED-PLAN FOR OPERABLE UNIT 4, 10/19/93
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significant source of contamination to ground water and
2
surface water which we have found below the site which
3
extends beyond -- underneath the Davis-Weber Canal and out
4
into the valley here.
5
The primary contaminant at this site, although
6
-- There are several other ones, but this is really the one
7
we're looking at that drives all of the risk and is of the
8
most concern.
It's trichloroethene or trichlorethene.
The
9
acronym for that chemical is TCE, and I'll be referring
mainly to TCE.
There are several other compounds associated
-- other organic chemicals associated with this site also
which are at present at much lower concentrations and are not
as big of a concern.
There are also several metals that have been
detected, but these detections are very spotty, and they all
lie within the TCEplume.
We use the TCE as basically --
because it contains the aerial extent and is the largest of
any contamina~ts at the site.
Trichloroethene is a solvent that's been used
at the base -- was used at the base for quite a long time as
a degreaser and for cleaning up aircraft parts and things
like that.
So as you can see, there may be some questions
on -- (Indicating.)
As you can see, here is the base
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boundary again.
There is the Davis-Weber Canal.
2
Everyone was asking where Mr. Cutler's house
3
is.
His house is right in this crook here.
(Indicating. )
4
There is actually a steep hillside here whic~ defines the
5
northern extent of contamination as we found it, so it does
6
not extend north of South Weber Drive.
7
As far as levels or concentrations of
8
contamination, the highest levels detected have been 18,000
9
parts per billion.
A part per billion is equivalent to basically
one particle in a billion particles of either water, soil,
air or whatever media we're referring to.
Offsight, the highest contaminations detected
is 3,000 parts per billion.
So, really, the majority of the
worst of it is still on base.
There are definitely some
significant levels off base, (indicating) mainly in this area
with lower concentrations off in this northwesterly
direction.
Ground water is flowing -- as evidenced by the
plume and other factors which we examined, is basically
flowing off this direction.
(Indicating.)
That would be the
northeast.
MEMBER OF THE PUBLIC:
That would, be a thousand or
1500 feet down the North Gate road?
MR. GARY COLGAN:
Yeah.
The North Gate is
. KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS
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actually right here (indicating), so I don't know.
There is
2
probably a scale up here.
That sounds pretty close.
There
3
is 500 feet right there.
Here's the
(Indicating. )
4
North Gate d~mp.
The worst of it is 500, a-thousand,
5
1500 feet.
6
MEMBER OF THE PUBLIC:
Away from the North Gate to
7
the north?
8
MR. GARY COLGAN:
Okay.
Yeah, that would be a
9
thousand feet this way.
If you start from the
(Indicating. )
source to South Weber Drive, that looks like about 1500 feet,
so approximately, you know, a little over a quarter of a
mile, something like that.
(Indicating. )
This is another view of the
contamination.
This is a cross-sectional view looking at the
hillside.
This is a pretty steep hillside.
You're all
familiar with the hillsides above the school here.
This is
very similar.
It's part of the South Weber Landslide
Complex.
Contaminants have migrated from the landfill
to the water table or down to the shallow ground water and
have moved through the ground water in a pretty shallow area.
(Indicating. )
This is roughly 20 feet thick,
about 10 or 15 feet below the ground surface, so the maximum
depth of contamination is about 30 or 40 feet.
Most of the contamination is moving through
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sands and gravels which allow water and contaminants to flow
2
much more easily than through clays and other fine-grain
3
materials.
4
Below these areas where we have -- It's kind
5
of complicated by landslides and remnant landslide pathways.
6
Below this area where we have sand and gravel, it's a much
7
more coherent section of clays and silts and things that are
8
much harder for water and contaminants to flow through.
9
(Indicating. )
I
Several hundred feet below this ~
area, you know, down -- scalewise down here are where the
drinking water aquifers -- Sunset Aquifer and Delta Aquifer
are.
That's where drinking water in this area is taken from
by wells.
There are no wells using this shallow water in
this area.
No one is using the water for drinking or other
uses at this time.
MEMBER OF THE PUBLIC:
Excuse me.
When was the
last time they used that?
Do you know?
MR. GARY COLGAN:
I don't know, except maybe from
-- The seeps from the hillside may have been used for
watering cattle, but I don't think anyone has used it
directly as a water source.
If we went back 20, 30, 40
years, somebody could have used it at a limited basis from
the seeps.
The seeps only flow a few cups or so a minute.
They're slow producers.
They wouldn't be good water
supplies.
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Now, once we completed this study here, we
2
looked at the risks that this site may pose based on the
3
chemical sampling we did and the analyses that were
4
performed.
5
Now, the risk -- We did a detailed risk
6
assessment on tbis site to identify what the health concerns
7
really were.
The upshot of this risk assessment was that
8
there are no current risks opposed to the community because
9
of this site.
That's because the main contaminations are
10
confined to the ground water, which is not used.
There are
no -- Because no one is using the drinking water, there is
really no risk, so that's one point.
To look at this more closely, we examined the
current risks based on two scenarios.
The first one is the
inhalation of contaminated air by on-base workers, people
working on base.
What is the risk to them?
The cancer risk here was calculated as two in
100 million excess cancers.
Tha~ means out of 100 million
people, two additional cancers will result because of this
risk or could have the potential to result.
This is compared
to in your -- In all of our lifetimes, you have the potential
-- It's basically about a one in four potential of contacting
cancer sometime in your life.
(Indicating. )
This is the incremental risk
E.P.A. considers an acceptable cancer risk, something that is
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less than one in a million.
So you can see this cancer risk
2
is 50 times less than the acceptable risk.
3
For inhalation of contaminated air by the
4
Weber valley resident -- This is contaminated air coming up
5
through someone's basement, from the ground water
6
contamination itself.
The cancer risk is six in 100 million,
7
so this is actually slightly more than the risk to on-base
8
workers, but still much -- well below the acceptable cancer
9
risk.
Now you realize what are we talking about if there is
no current risk.
We also looked at future risk scenarios that
present a somewhat different story.
The future risk
scenarios we looked at were mainly associated with drinking
the contaminated water.
If someone in the future put a well
in the shallow aquifer and used it as a drinking water
supply, the risk was seven in 1,000.
This is compared to an
acceptable risk, as we talked about last time, of one in one
million.
This is considered a significant risk.
Also, another way we calculate risk is to look
at illnesses or other kinds of health problems, health
effects that could be caused that are not cancer or related
to cancer, and we used something called a hazard index.
23
If the hazard index is greater than one, it's
24
a significant risk.
In this case, 'it's 50.
So, therefore,
25
if someone put a well in a contaminated shallow aquifer in
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the future, there is a significant risk both for cancer and
2
noncancer health effects to -- that could be to them.
3
Another scenario was to look -- (Indicating.)
4
This was for on-base residents.
Say the base closed and
5
people started building houses in the area overlying the
6
ground water plume now in the valley where concentrations are
7
somewhat less than we have shown on the base for Weber River
8
residents.
9
These. risks are one in 1,000, seven times
less.
If you look at all the numbers, it's still a,
significant risk.
The hazard index is lower than the 50,
which we calculated -- estimated to be six, but it's still
greater than one.
Again, this is considered by the risk
assessors and E.P.A. -- these two things as a significant
risk for long-term.
If someone were to use domestic water from the
Sunset Aquifer, which is, as I said, several'hundred feet
below the aquifers that are contaminated or the shallow
aquifer that is contaminated -- We looked at that scenario,
and the risk there for cancer is three in 10 million compared
to the one in one million, so that is not a significant risk.
By the same token, on the hardard index, potential for
noncancer illnesses, it's .0005 compared to one.
Again, not
considered significant.
So to summarize the risks, there are no
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current risks because no one is drinking the water.
2
You say, well, is there potential for someone
3
to breathe air in their basements?
We have analyzed the air
4
from basements in some of the residents overlying the ground
5
water contamination.
Although there have been very low
6
levels -- some trace levels of TCE detected in one of the
7
houses, the risks indicate there is no significant risk to
8
those people.
9
However, there are some future risks that if
things change and people use the aquifer as a drinking water
aquifer, it could create serious health effects, but that
assumes someone will use it as a drinking water source.
So that's why we're here talking about a
solution.
The Air Force will propose a solution for this
situation to address future risks.
okay.
Now, in order to evaluate -- in order
to come up with some ideas for potential solutions, we
divided our alternatives into four groups.
You can fo~low
along in your proposed plan with me if you would like since
you have that.
It's the section called Summary of Remedial
Alternatives on Page 8.
The first set of these alternatives are broken
into Ground-Water Alternatives, Surface-Water Alternatives,
Landfill Contents Alternatives -- That's directed primarily
-- or specifically at Landfill 1 -- and Air Alternatives.
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Ground water.
It's fairly obvious what the
2
ground water is.
It's that shallow aquifer that I indicated
3
is contaminated.
4
Surface water.
We're referring to the seeps
5
that are on the hillside.
To date, we have sampled the
6
Davis-Weber Canal.
In fact, well water runs well underneath
7
that canal.
There's no connection between the two of them,
8
and there is no contamination in the canal.
9
Landfill Contents refers to what's in
Landfill 1.
Air relates to the potential for contaminated
air to be in people's basements where they could breathe it
and become exposed.
The Ground-Water Alternatives -- I'll give you
a quick rundown on these -- include No Action, which is
something we're required under E.P.A. guidance to evaluate,
what happens if we do nothing.
That's the base line we need
to compare everything else to.
Limited Action in this case would mean
continuing to monitor the ground water that -- to make sure
ground water contamination does not travel further and, also,
we could be restricting -- basically asking the State of Utah
to restrict people from drilling wells in the shallow
aquifer.
Alternative 3 is the collection and on-site
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treatment of contaminted ground water using air stripping,
2
which is one technology to treat ground water and then
3
discharge it to the Weber River or the local sewer system.
4
Alternative 4 is similar to Alternative 3, but
5
we would be directing the water and treating it using a
6
different treatment technology, using oxidation, also called
u.v. oxidation, ultraviolet oxidation.
8
Alternative 5 is more interesting, and it's an
9
emerging technology that we will study further.
It's
Metal-Enhanced Reductive Dehalogenation.
That's a long trip,
but basically what it is is putting a wall which is composed
of iron filings and sand into the ground and allowing water
. naturally -- the ground water which flows under its natural
motion to flow through the wall.
Researchers have found that the combination of
iron -- It's really that the iron creates a chemical system
such that these contaminants such as TCE will be completely
degraded.
This would be configured in a funnel and gate
system because we would be putting barriers like -- metal
walls would be driven into the ground and direct contaminated
ground water to the wall, which would be composed of iron
filings and sand.
24
So this is something we will be researching,
25
and we are carrying out studies.
It shows great promise for
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possibly helping us with this site.
2
Surface-Water Alternatives include No Action.
3
Again, this includes continuing to monitor the seeps and
4
evaluating whether the chemical concentrations change with
5
time.
6
Limited Action, which could be things like
7
fencing the seeps to keep children and livestock away from
8
them.
9
Alternative 3, collecting and treating at the
seep locations using carbon absorption similar to the carbon
you would use in a filtering system at home and discharging
this back to the ground and into the aquifer.
Alternative 4 would be collection and using
on-site treatment, using the same technology I just described
with the iron filings in a canister above the ground.
The
other one was below the ground.
Alternative 5 would be to collect and treat
the water and discharge it the same way we would with the
ground water alternatives.
That involves running pipes from
the seeps to the ground water system.
The Landfill Contents Alternatives include
No Action; Limited Action, which would include surrounding
the landfill with a fence to keep people out; Containment,
which would be putting a clay or some kind of polyethylene
capon top of the landfill to prevent water and rainwater,
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snow melt from moving through the landfill contents and
2
carrying with it contaminants which would move into the
3
ground water.
4
Alternative 4 is Containment and In-situ
5
Treatment, meaning in-place treatment.
This would involve
6
both the cap from water moving in and an active treatment
7
system.
In this case, soil vapor extraction where we hook up
8
wells with vacuums on them to suck out the contaminants.
TCE
9
is very volatile.
It will evaporate quickly.
Alternative 5 is Excavation and Disposal.
This means dig up the landfill, segregate what we can and
dispose of it in a hazardous waste facility, such as
U.S.P.C.I out west of Tooele.
The last set of alternatives is alternatives
for air directed at making sure people are not affected by
contaminated air in their basements.
Alternative 1 includes No Action.
No Action
in this case includes monitoring in people's homes as long as
we feel there is still a ground water problem to make sure
they're not exposed to significant levels of contamination.
Limited Action could include the leasing of
people's property if it becomes a problem or asking the city
to impose certain building restrictions or codes to prevent
contaminated air from moving into people's basements.
Alternative 3 could be to collect any
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contaminated air in people's basements and either discharge
2
it to the atmosphere, if it's a minor concentration, or treat
3
it.
4
So those are the alternatives that we have
5
looked at for Operable Unit 4, and they focus mainly on what
6
to do with land and contaminated ground water and surface
7
water coming from it.
8
Now Bob Elliott will explain the criteria we
9
used to sift through these alternatives and how the Air Force
10
has come up with their preferred alternative that they would
11
like you to comment on tonight.
12
MR. BOB ELLIOTT:
It's important to understand
13
that, in addition to the alternatives that Gary just talked
about, many other alternatives were looked at.
Some of those
alternatives were eliminated in a screening process for the
following reasons.
One, the technology may not reduce the
contamination to an acceptable level.
The technology might
not be amenable.
A simple case of that would be technology
that, because of the steep hillsides associated with this
site, could not be constructed or put in place on those
hillsides or an excessive cost where there was some other
technology that would achieve an equal protective standard.
The remaining alternatives were based on --
I were evaluated based on nine criteria.
I. .
I would like to go
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through those nine criteria with you.
2
Okay.
It's important to note that the first
3
two criteria must be met.
There is no option ~s far as
4
looking at an alternative that will not meet those first two
5
criteria.
6
The first one is the most important, being
7
protection of human health and the environment, protection of
8
people's health.
9
The second one is wrapped around insuring that
we comply with any state or federal laws that apply to the
site and that are relevant to the site.
We must meet any of
those laws.
,
Okay.
The other criteria are what we call
balancing criteria, and they are used to help sift through
the list full of technologies and alternatives that are
available for the site.
One of the things we have to look at is
short-term risks of anything that we do associated with this
technology.
Will it protect the short-term risks of the
resident, and will it protect the short-term risks of
construction workers, . for example.
So that's one thing we
have to look at.
Then the long-term effectiveness.
Will this
remedy solve the problem long term.
\
Reduction of the toxicity at the site.
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Mobility or the ability of the contaminants to
2
move away from the site or to further degrade the environment
3
and propose additional risks.
4
Can the technology be implemented.
We already
5
talked a little bit about that.
6
What is the cost associated with the
7
technology.
We must, as mandated by congress, look at the
8
cost.
9
State acceptance associated with having the
state involved in our review, as we have had them involved
for -- since the inception of our program.
Finally, community acceptance, and that's the
important reason why we're here this evening.
MEMBER OF THE PUBLIC:
Excuse me.
The cost -- Is
it your cost or our cost?
MR. BOB ELLIOTT:
Well, it's your cost as the
taxpayer, I guess.
MEMBER OF THE PUBLIC:
Our cost for our' land or
your cost?
MR. BOB ELLIOTT:
No, it's the cost associated
with the cleanup alternative.
Okay.
I would like to talk about the
alternatives that we have sorted out of all of this.
You can
follow along -- Let's see -- on Page 9.
MR. 'GARY COLGAN:
Page 13.
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MR. BOB ELLIOTT:
Here we go.
There is a table on
2
Page 13.
There is some background information associated
3
with those alternatives.
4
As you can see, for Ground Water,
5
Alternative No.3 has been proposed by the Air Force, and it
6
consists of ground water collection by various means,
7
horizontal drains in the hillside, wells and then collection
8
and treatment by stripping -- air stripping.
9
Again, as Gary mentioned, these compounds are
volatile in nature.
They evaporate easily.
Air stripping is
a mechanism to get them to evaporate and get them out of the
water.
As you may note, time of implementation would-
be approximately 15 months.
That would be the time to design
the system and begin construction.
You can see the costs
associated with that.
Surface Water.
We've proposed collection and
treatment with carbon.
The primary reason associated with
that is because these small springs are scattered along the
hillside.
These carbon filters, if you will, will treat
those springs very easily without the high cost of running
extensive pipelines along the hillside.
We can go back through these during the
question and answer period if you would like some more
clarification.
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Okay.
The Landfill Contents.
Alternative 4
2
is being proposed.
It consists of capping the landfill and
3
treating it with a vapor removal. system to remove those
4
highly evaporative or volatile chemicals that are in the
5
landfill.
6
Okay.
Air is Alternative 1, which includes
7
sampling and monitoring of any basements or exposure areas
8
where people would be exposed to the air to insure that those
9
levels do not change or increase.
MEMBER OF THE PUBLIC:
Sir, could you elaborate on
the chart?
You indicate that the costs of those preferred
alternatives is based on the discharge option or the type of
cap.
Are we saying that this is the more expensive method
here, or is this the lower grade of the type of disposal
capping or discharging as another option?
MR. BOB ELLIOTT:
Okay.
Can I hold that question
until we get into the question and answer period?
Then we
can go through that. . I want to try to do that so that --
otherwise, we tend to grade into a whole bunch of questions~
and we don't move forward.
Essentially, that identifies the alternatives
that the Air Force is proposing.
I would like to allow
Mr. Stites from the E.P.A. and Mr. Muhammad Slam from the
Department of Environmental Quality, if they have any
comments they'd like to make, to make some comments, and then
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I think Gwen wants to begin the questioning period.
2
MR. ROBERT STITES:
I'll be very brief.
I just
3
wanted to welcome everybody and thank you all for coming.
4
I'm gratified to see this kind of a turnout for this.
5
I wanted to let you know this is your meeting.
6
We want your input on what you're hearing here, whether you
7
like it, whether you don't like it, what things you do like,
8
what you don't like.
9
Also, if you have some significant information
that you think we're overlooking, let us know because this is
the one big.best shot at having your good input into what
we're going to be doing about things here.
Now, if you don't have any comments tonight,
don't think that you have to say anything, but if there is
something that's bothering you and you want to think about
it, keep in mind the comment period is open until
November ~th.
There is a name and address here for
Gwen Brewer.
You can. send in written comments to that
address, and they will be responded to in the -- as part of
the decision.
Just one last little item.
We did not
deliberately schedule this meeting opposite a World Series
game.
It was just poor luck.
Now, if you have any comments Muhammad Slam.
MR. MUHAMMAD SLAM:
Good evening, ladies and
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gentlemen.
I'm with the State of
My name is Mahammad Slam.
2
utah Environmental Quality.
The State of Utah has been the
3
support agency working with Hill Air Force Base and E.P.A~
4
toward the cleanup o~ this site.
5
With me tonight are Diane Simmons, our
6
Community Relations Coordinator, and Duane Mortensen, our
7
Section Chief.
8
I would like to say it's sincerely a pleasure
9
to be here tonight.
~he proposed plan you just heard being
presented today has been a long time in coming.
All the
parties, the E.P.A. and Hill Air Force have worked long and
hard to reach this point, but I would like to say that this
is only a beginning.
I also would like to thank all the people that
took time out of their schedule to be here and miss the
World Series.
The Department of Environmental Quality wishes
to hear from you all, the people, all the concerns you have.
Our names and addresses are in the proposed
plan, which is the handout for today.
Like Rob and everybody
said,. the comments here are open until November 5th.
You can
present your comments either to Hill Air Force Base, the
E.P.A. or the State of Utah.
We'll welcome your input.
Thank you very much.
MS. GWEN BREWER:
Are you all okay?
You're
comfortable in going on?
Okay.
Let's start hearing from
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you.
What do you have to say?
2
MR. THAYNE THOMAS:
I'm Thayne Thomas.
3
T-h-a-y-n-e T-h-o-m-a-s.
4
My question was on this Preferred Alternative
5
Table 2.
The footnotes here indicate that the cost depended
6
on discharge options and are evidently variable.
My. question
7
was, the dollar amount up there, would that be considered a
8
maximum amount or would that be considered an average amount?
9
The same applies to the lower --
MR. GARY COLGAN:
The costs in there -- There is a
way we calculate costs.
It's present worth -- It's basically
if you can put the money in the bank and have a certain
interest over a 30 year period, how much would it cost.
At this point, we haven't designed these
systems.
The estimates are minus -- range from what's kind
of a middle ground, but it could be minus 30 percent of that
up to plus 50 percent of that value.
So that's kind of our
best estimate at this time, but it could have quite a bit of
variability.
For the Ground Water, there are a couple of
options built in there.
One is the discharge to the sewer
after we treat the water, and the other one is the discharge
~
to the Weber River, which would mean constructing a pipeline
to the Weber River.
We'd need a permit with the state and
everything, and that's why the range in the cost.
They are
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reflecting two options.
2
The same thing for the Landfill options.
We
3
have two different kinds of caps that we looked at, a clay
4
cap and then a cap which would involve clay and -- They call
5
it multi-media.
It's basically -- They call it high density.
6
It's some kind of polyethylene or plastic liner which would
7
be part of the clay, and the clay together would be the cap
8
or the multi-media.
So that's why there is a range for the
9
Landf ill.
MS. GWEN BREWER:
,(Indicating. )
I'll take this
gentleman and then work toward the back.
MR. RAY GIBBONS:
My name is Ray Gibbons,
Riverdale area.
G-i-b-b-o-n-s.
In this air stripping process, what happens to
the contaminants after it gets into the air?
Is there any
air pollution problem then?
MR. BOB ELLIOTT:
Again, as I mentioned, as part
of our criteria, we must meet all of the environmental
regulations and requirements that are appropriate.
If we are
discharging something into the air that's above an acceptable
level to the state air quality people and to the Davis County
air quality people, we must treat that air.
There are
treatment alternatives built into those alternatives.
MR. MUHAMMAD SLAM:
Basically what he's saying is
the air would be monitored and treated if necessary before it
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escapes into the air.
2
MR. GARY COLGAN:
On Page 9, midway down in the
3
left column it talks about, "Air emissions would be captured
4
and treated by a catalytic oxidizer to destroy the organic
5.
contaminants in compliance with the state and federal air
6
quality standards."
7
So it's basically a catalytic converter
8
similar to a catalytic converter in a car.
It would be
9
treated.
MS. GWEN BREWER:
In the maroon .jacket in the
back.
MR. KEN PARKINSON:
Ken Parkinson,
P-a-r-k-i-n-s-o-n.
What I wanted to talk on was the alternatives
chosen for the ground water and surface water.
How
equivalent, per se, would that be located on Deran Cutler's
ground that would deem his ground actually worthless as far
as he was concerned?
I think there should be some kind of a
compensation of fair market value for his ground for
relocation or whatever.
MS. GWEN BREWER:
Sir, right now we are checking
out ways that we can take care of that problem for
Mr. CUtler.
MR. PATTERSON:
What about for the rest of the
residents?
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If it's a situation where in the
MS. GWEN BREWER:
2
conduct of a cleanup action we need to purchase that
property, we will go to the Air Force for it. Normally, the
Air Force does not purchase property. Each of those would
have to be taken on a person-by-person basis.
3
4
5
6
(Indicating. )
Yes, ma 'am.
7
I'm Lola Patterson.
I'd like
MS. LOLA PATTERSON:
8
to know how long you propose this will take until we can get
9
our land back.
MR. BOB ELLIOTT:
This is part of the painful
part.
I guess these cleanups take -- are estimated to take
quite some time, and there has been some discussion that it
could take up to 20 years.
Let me explain the reason why that occurs.
The contaminants that -- TCE -- that are in the aquifer
material tend to stick, if you will, to the soils that are
there.
So as water moves through those sands and gravels,
the contaminants tend to like to stick on those soils and not
move very well.
If you think of oil and water together, they
don't mix very well, and that's a common analogy with the
chemicals that we're talking about, the organic chemicals
that tend not to go into -- dissolve into water very easily.
So it could take a long time.
The challenge
is that we don't know how long -- we don't have a very good
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estimate right now of how long it's going to take because we
2
haven't run a treatment system out there.
We are currently
3.
doing some studies to evaluate those and to get some better
4
estimates associated with those projects, but I want to be
5
real honest with you so that you understand the kind of time
6
tables that are associated with these cleanups.
That's not
7
an easy thing to tell people, that it's going to take that.
8
period of time.
9
HS. LOLA PATTERSON:
I'm concerned on it because
you have a meeting like this and basically freak out this
city.
South Weber freaks out and puts all these caps on us
for everything, and our land is virtually rendered useless to
us for this length of time.
Now you tell me it could take as many as
20 years.
At the end of that time, are you going to come
back and tell us that it's free and clear and we can build
and use our land like we could, or do you let it go and hold
onto it so the restrictions will stay on the property
forever?
MR. BOB ELLIOTT:
I guess the important thing to
recognize is that in cases where some building has not been
allowed, it's really been your city people who in conjunction
with us and working with us have made those decisions.
They
have been made, I think, in the interest of public health,
not in the interest of tying up anyone's property for
KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS
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20 years.
2
It's important to recognize also that if your
3
property has been damaged, that there are alternatives
4
available to you through the Air Force to recover damages
5
through the Air Force claims system.
You need to understand
6
that.
7
MS. LOLA PATTERSON: . I'understand that, but I
8
don't see that you're going to pay me for the value of the
9
land.
I mean, we were here before Hill Air Force Base was.
The property has been in our family for bookoo years.
Now
all of a sudden the Air Force has damaged it.
We can't
subdivide it.
We can't do anything on our property.
In fact, we have tried recently, and I have a
letter from you people telling me that there is no damage to
the crop, there is no damage and no potential problems for
what we have on it.
I asked about trees and apples and things like
that, and he tested for me and told me it was fine.
Then I
read in the cotton-picking paper that all these things are
there and they're damaging to us and potentially a health
hazard.
What am I to believe?
How can I believe you when I
get hit with things like this?
MR. WAYNE PATTERSON:
Another down winder.
MR. BOB ELLIOTT:
The important message here is
we've been working for a number of years with the
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Environmental Protection Agency, with Environmental Quality
2
and Davis County.
We hope you can use those people as
3
resources.
4
I understand your frustration.
When you look
5
at this situation on a person-by-person basis and people
6
owning properties, it's a tragedy that the Air Force.put
7
whatever they put into that landfill, put those solvents into
8
that landfill.
9
I can't change that other than to do today
,something to try to fix and remedy that problem.
I can't go
back in time and change what was done, and that's the
tragedy.
MS. LOLA PATTERSON:
I wish too I could get the
straight story.
I'm frustrated with this because I hear one
thing one time, and I turn around and there is another story.
Be straight with me.
I'm an adult.
I'll accept it.
But
when you lie to me and I get one story from you and get
another one from the planning commission, what am I to
believe?
See, that's where I'm coming from.
I think if
you're straight with me, you'll have it.
If you're not --
MR. BOB ELLIOTT:
We went on the record tonight as
saying we're being straight with you.
We're telling you,
yes, these are the conditions at the site, and this is the
story.
If there is a conflict in the past in
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. AMY STOLTENBERG, CSR, RPR
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statements, we apologize, for that.
We try our best not to
2
allow that situation to occur.
3
MS. GWEN BREWER:
If you read something in the
4
papers about it, we would appreciate you're not just sitting
5
there thinking about it.
If it's something that we told you
6
that's different from what Hill Air Force Base told you,
come
7
and ask and/or call Mr. stites at the E.P.A. or call U.D.E.Q.
8
MS. LOLA PATTERSON:
I'll do that.
9
MR. WAYNE PATTERSON:
Can we do this on the
record?
MS. GWEN BREW~:
Absolutely.
MR. WAYNE PATTERSON:
That way you know what you
said in the past and can back it up.
MR. CLYDE GAYLERS:
My name is Clyde Gaylers.
You're addressing only the TCE contaminate in
the chemical pit.
Are there other things, heavy metal
semivolatiles that wouldn't be ,easily treated with air
'stripping that you need to address, --
MS. GWEN BREWER:
Different system --
MR. CLYDE GAYLERS:
-- that haven't migrated very
well?
MR. BOB ELLIOTT:
There is no chemical pit here.
MR. CLYDE GAYLERS:
Again, in the landfill area.
MR. BOB ELLIOTT:
We have detected no other
,
compounds coming out of that ground water that would not be
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AMY STOLTENBERG, CSR, RPR
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PUBLIC MEETING RE PROPOSED PLAN FOR OPERABLE UNIT 4, 10/19/93
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tr~atable through this method.
. ,
2
MR. CLYDE GAYLERS:
So there is nothing like heavy
3
metal arsenals that may have been dumped there?
4
MR. ROBERT STITES:
We have a level we need to
5
address.
In other words, there is trace amounts of some
6
metals and other organics, but their risk and levels of
7
contamination are so low that they're below any cleanup
8
standard that would be set anyway.
9
MS. GWEN BREWER:
Yes, sir.
MR. LYNN COY:
My name is Lynn Coy, C-o-y.
You're proposing something that's already in
place.
The unit is operational.
I was there tonight, and
there is six horizontal wells currently drilled.
The
strippers were running tonight, and they're discharging water
into the sewer system.
My comment is:
Why are you proposing
",j,
. ..'
something that's already in place?
MR. BOB ELLIOTT:
Okay.
The work that's currently
'in place is what is known in our business as a treatability
, -
..
study.
We have essentially put those six horizontal drains
. , <".
or wells into the hillside to evaluate their effectiveness.
, .
, \'.'
Okay?
The proposed alternative will have -- I don't know the
..
",.' ;'" t.')
specific number.
Gary, you can probably help me answer that.
MR. GARY COLGAN:
It could be 30 or 40 of them or
something like 'that.
KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS
AMY STOLTENBERG, CSR, RPR
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MR. BOB ELLIOTT:
Some of the information that
2
will be gathered from the study will be used to design the
3
additional wells needed to be put in place to correct the
4
problem and treat the contaminants.
5
To figure out how many we really
MR. GARY COLGAN:
6
would need because, without doing a test, we really -- it's
7
just a wild guess.
8
More than that, it's to figure
MR. ROBERT STITES:
9
out how long a horizontal drain will work and then how many
we need.
This is only a small component of the final
preferred alternative, which is also the other stuff
addressing the air and landfill materials and that sort of
thing.
I need to point out that when you do a
. treatability study, you're only allowed to do it to a limited
degree and limited amount.
You're not allowed to use a
treatability study as an excuse to clean up outside of your
final decision.
It'$ not actual~y cleanup in advance.
This
19
is just a test to see if what we would like to do works.
MR. GARY COLGAN:
It's a small-scale temporary
21
system basically.
22
MS. GWEN BREWER:
(Indicating. )
Back here.
23
MR. MARK PERKINS:
Mark Perkins, P-e-r-k-i-n-s.
24
On Table 2 on Page 13, Time to Implement,
25
15 months.
When does the clock start ticking on that
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AMY STOLTENBERG, CSR, RPR
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15 months?
2
MR. ROBERT STITES:
When the Record of Decision is
3
signed.
Basically, this meeting is going to contribute
4
information that the Air Force is going to use to compi~e a
5
document called a Record of Decision.
That would be probably
6
coming out in the summer is my guess, next summer.
7
MR. MARK PERKINS:
Summer of '94?
8
MR. ROBERT STITES:
Well, I'm talking about the
9
signing, not the draft.
When that document is signed by the
Air Force, the State and the E.P.A., that's when this clock
starts ticking for the 15 months.
This 15 months is a
statutory requirement for a federal facility.
In other
words, they can take no longer than 15 months to get going.
MR. MARK PERKINS:
In 15 months after the final
document is signed, the cleanup procedures will be operable
or construction will start on them?
MR. ROBERT STITES:
Construction must start --
Hopefully, certain phases will already be operable.
We've
already discussed how we can phase things and expedite
construction on the initial phases.
MR. MARK PERKINS:
When would you anticipate being
fully operable and going full bore on the cleanup?
MR. BOB ELLIOTT:
We would estimate that the
construction period would be less than a year, possibly a
year in time frame.
KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS
AMY STOLTENBERG, CSR, RPR
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You have to remember that we've got winter
2
conditions and those kinds of things.
50 looking at that
3
construction season, it would take a construction season to
4
construct the alternative.
5
As far as landfill caps, those could be
6
constructed in probably two to three months once a design is
7
completed.
,
8
The horizontal drilling takes a little more
9
time so -- but in one construction season.
MS. GWEN BREWER:
(Indicating. )
Mr. Stark and
then the lady in the pink.
MR. REID STARK:
Reid Stark, S-t-a-r-k.
I was wondering about the station you have on
the Coy property.
Is there more contaminants coming in now
or less?
Is it the same as when you started?
MR. BOB ELLIOTT:
Gary, I'll let you answer.
You
know the details.
MR. GARY COLGAN:
The most recent set of data
indicates that the concentrations have been decreasing.
So
it appears like a pulse had gone through the system, and now
it seems to be falling off because our drain -- these test
drains are located right in that area.
We're actually
pulling out the worst contaminated water right now.
We think
that the worst has sort of passed, but there is still levels
there that are of concern if someone were to drink that
KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS
AMY STOLTENBERG, CSR, RPR
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water.
2
MS. GWEN BREWER:
(Indicating. )
In the back.
3
MS. KATIE PARKINSON:
My name is Katie Parkinson.
4
My concerns were like he says.
A lot of what
5
you have been talking about -- I've gone on that land and
6
seen it too.
One of my concerns is that there are three. of
7
the horizontal wells that go through the canal -- I guess
8
underneath the canal and up on Hill Air Force land.
That is
9
draining directly onto what we've been. talking about on
cutler's land there.
Is that part of your plan to use his
land for all of this cleanup?
I mean, I know the wells are
directly under the canal, so what's coming out of them can't
be contamination under his land.
MR. BOB ELLIOTT:
The wells in length are
approximately 300 feet, go back into the hillside
approximately 300 feet.
I really can't answer the question
as to whether or not they are.
I don't believe that they're
drilled back into' -- under Hill Air Force Base property., but
I'd really have to check that before I --
MR.' GARY COLGAN:
There is really three sets of
three.
One set is on -- starts and goes underneath the
landfill totally on Hill Air Force property.
The middle set
does go underneath the canal and would access water that is
under Hill Air Force Base.
They do extend three to 400 feet
back, and' they're at a slight incline so we can use gravity
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PUBLIC MEETING RE PROPOSED PLAN FOR OPERABLE UNIT 4, 10/19/93
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to drain.
Then there is a lower set which is above
2
Mr. Cutler's house that we drain.
Basically, that wouldn't
3
go onto Hill Air Force Base property.
4
MR. ROB STITES:
I would like to aad what is
5
currently happening is a temporary condition.
The permanent
6
remedy would not call for water to be openly dumped on any
7
ground anywhere.
8
I think it's also important to
MR. BOB ELLIOTT:
9
note that that water is going to end up there anyway because
that's a natural flow pattern of the water.
The water is
eventually going to move to Mr. cutler's property, and so the
concept is the sooner we can get it out and treat it, the
sooner we can clean things up.
MS. KATIE PARKINSON:
Just concerning what you
have done so far -- I know you're testing.
I realize you.
guys caused the problem and, yeah, you really need to clean
it up.
I have no problem with that.
Have you considered the people it effects,
what you're putting them. through now while you're doing this?
Are you going to compensate anybody for what you're doing to
them now?
I'm with Mrs. Patterson.
I went by her
house --
24
MR. KEN PARKINSON:
The ground that's basically
25
been --
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MS. KATIE PARKINSON:
I went within a few miles of
2
the place, just the publicity that's happened here --
3
MS. GWEN BREWER:
We do know we did something bad.
4
In the future -- We can't change that.
We're trying to clean
5
that up now.
That's all we can do.
6
If there are individual cases, we can refer
7
those to -- or you can call us at the base, and we'll take
8
care of them on an individual basis.
We can't say, yes,
9
we're going to take care of all your monetary problems and
reimburse you on everything that you have.
MS. KATIE PARKINSON:
You are not going to
compensate for what you're doing?
MS. GWEN BREWER:
I didn't say that.
I said we
have to consider each individual case.
MS. KATIE PARKINSON:
You're saying --
MS. GWEN BREWER:
We're required to consider each
case on an individual basis.
MS. KATIE PARKINSON:
Doing what you've done up
there on the property --I have gone up and seen it.
To me,
it seems like there is a total disregard for the people
living around there.
I, for one, like to go out there and let my
children chase that hillside.
I went up there the other day.
There is this big old pond of murky water that's draining out
of the wells, and there is nothing preventing any animal or
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anything to go in it.
Why is that condition there?
2
MR. BOB ELLIOTT:
Let me explain what happened.
3
With the rain conditions that we have had -- understanding
4
that from what I heard from the weather service that this has
5
been the sixth wettest October in history here, we -- more
6
water has gone into that hillside than we ever had the
7
capacity to treat and to store in the tanks that we have on
8
site.
9
We approached the Central Weber Sewer
Improvement District for an emergency permit to discharge
water from that site to eliminate that condition.
That
permit was granted to us early this morning, so that
situation has been resolved.
MS. KATIE PARKINSON:
I asked you too -- If a dog
or child would have got into that water, could it have done
them damage to the extent -- Was that the higher risk?
That
water is the actual water that's contaminated.
MR. BOB ELLIOTT:
Yes.
I'm not a health expert.
Maybe Colonel New could better answer that question for us
or, Lieutenant Irshad, if you would like to discuss that.
LIEUTENANT COLONEL MAX IRSHAD:
The contaminants
are at low concentrations.
As we have discussed on the
slides, the concentrations that are there are not
concentrations that, if you walk by and breathe something or
drink some of the water, that you would, you know, die.
It's
KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS
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PUBLIC MEETING RE PROPOSED PLAN FOR OPERABLE UNIT 4, 10/19/93
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not at those kinds of concentrations.
2
Would you guys like to --
3
LIEUTENANT COLONEL GEORGE NEW:
I'm
George New.
4
with the hospital at Hill.
5
We have looked at that situation.
Right now I
6
don't have any results of what's in that pond.
Especially
7
with the runoff, you would expect it to be lower.
What's'
8
going to happen is the rain will dilute it.
9
The levels are very, very low compared to
what's allowed in drinking water and even in what we normally
use in hospitals.
You may not be aware, but we use TCE in
hospitals for anesthesia.
We're below levels that would
cause acute affects.
What we can do is work with you and go down
and get samples and see if you're concerned about it.
I
don't have any samples right now.
MS. KATIE PARKINSON: What I'm concerned about is
the safety.
That should be roped off.
That shouldn't be
accessible to animals.
You're not sure yourself --
MR. BOB ELLIOTT:
I think the situation occurred
over the weekend and our --
MS. KATIE PARKINSON:
It's been a couple weeks
since I was out there.
MR. BOB ELLIOTT:
Okay.
We were not aware of
that.
KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS
AMY STOLTENBERG, CSR, RPR
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MS. KATIE PARKINSON:
It was a ditch that had been
2
dug out by a backhoe and had been filled up with water.
3
MR. BOB ELLIOTT:
Okay.
Yes.
4
MR. GARY COLGAN:
(Indicating. )
Mike is back
5
there.
6
MR. BOB ELLIOTT:
(Indicating. )
This is Mike Cox
7
with Montgomery Watson.
8
MR. MICHAEL COX:
I'm working on the site up
9
there, and we did -- After that pit was dug, we did put a
small fence around it.
Then recently we did dig out that
sump and filled it full of gravel, so there is no pond there.
It's been taken care of.
We did take care of it.
MS. KATIE PARKINSON:
Good.
I would still like to stress I'm not going to
go out and let my children chase on the hill anymore.
It's worthless.
I mean, I wish there was some
way of compensating the people.
It seems like it's not a
full compensation.
Just get them out of there.
Just do
something to help them not have to be around this area, and
make it fair because these people lived there a long time.
Like Mrs. Patterson says, I don't think
anybody will want it anymore for some time.
My dad is 72.
He's not going to give a rat's ass in 20 years whether that
property is any good or not.
MS. GWEN BREWER:
Thank you.
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(Indicating. )
Yes, sir.
2
MR. REX FEUSTEL:
Rex Feustel, F-e-u-s-t-e-l.
3
Is anybody currently being compensated for
4
land loss?
5
And, if you dump the stuff in the sewer, some
6
of the proposal costs shown here -- Is any of the cities
7
involved going to be compensated for the use of their sewers?
8
MR. BOB ELLIOTT:
In fact, that's part of our
9
contractual agreement with -- or will be part of our
contractual agreement with the Central Weber Sewer
Improvement District and also with the City of Riverdale.
As many of you know, the sewer improvement
district is also the Mayor of Riverdale, so it has helped
facilitate insuring that we compensate the City of Riverdale
for the use of those sewer lines.
We will be charged and pay
a fee just like anybody would to discharge down those sewer
lines.
It's important to understand that what we are
putting into the sewer lines after we treat it is essentially
water.
The contaminants are at a level at or below the
drinking water standard.
So the contaminants that are
Okay?
being discharged into that sewer system could actually be
found in your drinking water.
It's not as if what we're
putting in there is going to eat away those sewer pipes or
anything.
It's pretty much just water by the time we treat
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it.
2
MR. REX FEUSTEL:
The first part of my question is
.3
is somebody currently being compensated for land loss.
4
MR. BOB ELLIOTT:
The compensation we have made to
5
date is leasing pieces of property to compensate land owners
6
for the loss of use of that property.
That's the primary
7
vehicle that we have available to us right now, so that is
8
the compensation that's been taken to date or been done to
9
date.
10
MS. GWEN BREWER:
(Indicating. )
Yes, sir.
11
MR. JOE THOMSEN:
Joe Thomsen.
From what I understand, you've known about
this -- Oh, shoot -- since the early 'SOs.
What's the plume
grown like since. you know, you first -- your first studies
on it?
Obviously, you know, you can't control the
recent water.
You can't even keep it in the pipe.
You know,
" the Corp of Engineers can't keep the Mississippi in the dams.
What about Option No.5 on that?
Remove the
sucker.
Dig it up and take it out to Tooele and have it
disposed of right.
MR. THAYNE THOMAS:
That's $47 million.worth to do
that type of program.
MR. WAYNE PATTERSON:
(Indicating.)
All in favor?"
MR." BOB ELLIOTT:. Let me answer your first
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question by deferring to Gary Colgan, who has worked on this
2
project for a number of years and has the most information in
3
his head about where the contaminants have gone.
4
Let me preface by saying you have to
5
understand how an investigation of a site like this takes
6
place.
You find contaminants, and then you kind of start
7
marching out away from where you found them to find out where
8
they have moved.
So back in 1980, we probably didn't have a
9
good data point to say, well, the plume is here today.
The
contaminants have moved to this point, and in 1993 we can say
that it's moved this far.
We can make some estimates of that
based on the flow of ground water and the movement of the
contaminants.
Prefacing that, I'll let~ary talk about the
details of that.
MR. GARY COLGAN:
Most of the investigation work
done has been done by the united States Geological Survey out
.of their Salt Lake City office.
My company took over the
19
feasibility study side of it.
20
It wasn't until about a year ago that we had
21
enough wells in place to understand the complete extent of
22
the contamination.
Since then, they have been collecting
23
samples quarterly to get snapshots every three months as to
24
whether the contamination has spread, so we don't have a long
25
history to know whether the plumes spread out with time very
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much.
We've just recently, a year ago, figured out what the
2
full extent was, so it's hard to know whether it has spread.
3
In this kind of aquifer system, the spread of
4
the contamination is on the order of tens of feet per year.
5
It's not something that's moving much greater.
6
MR. JOE THOMSEN:
I have a whole lot in front of
7
my place, and they check it once a week, if not twice.
8
MR. GARY COLGAN:
Lately -- We've been checking a
9
lot of water levels in connection with the horizontal drain
study recently, in the last month or so, to see what the
effect of the water on the drain-out of water levels in the
area.
That doesn't mean we're takinqsamples all that time.
We're just checking the water level in the wells.
So, in fact, you know, up to a year ago, we
thought the main source. was the North Gate dump area because
we had information to suggest people kicked off a couple of
drums of TCE in some.area.
We checked allover there and
never could find the. source in ~he soil contamination or
anything like that.
The more wells we put in, we finally
narrowed it down, and it became very apparent that Landfill 1
was the source of the contamination.
So as Bob said, these investigations kind 'of
evolve.
Now we have a very good picture of what it looks
like.
MR. JOE THOMSEN:
Is the plume expanding?
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MR. GARY COLGAN:
It could be expanding very
2
slowly, and that's something we'll monitor.
As I said a
3
little while ago, the latest ground water samples taken
4
indicate the concentrations are decreasing.
5
MR. BOB ELLIOTT:
Let me answer the second half of
6
our question, which is why not dig up everything and haul it
7
away.
8
There is certainly a number of issues
9
associated with that.
I think the primary issue is that the
chemical TCE that we're finding in the ground water is much
more easily removed through vapor extraction and through
evaporation than by going in and digging up a hillside and
removing it.
MR. JOE THOMSEN:
What I'm getting at is, if the
plume is expanding or still expanding, you don't hedge around
it and try to not move it.
MR. BOB ELLIOTT:
That's the important concept by
the horizontal drain~.
They will collect that water and stop
if there is no more water moving through the system.
If
we're collecting that ground water, the contaminants, there
is no water to push the contaminants further.
That's the
general concept, if that makes sense.
MR. JOE THOMSEN:
You hear, oh, so much money from
these folks over here.
(Indicating. )
When you sit in, you
know, hundred and fifty thousand dollar houses and all the
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sudden they're worth 65, how much are you paying individually
2
for the same thing?
So when you say I'd rather the
3
government pay for this and chip in a few bucks on my taxes
4
to do it, individually, you ought to think about that.
5
MR. BOB ELLIOTT:
I think the issue of the loss of
6
property value is a tremendous burden that the people that
7
are associated with this site carry, and the Air Force
8
certainly recognizes that.
9
We do not have the authority to, as the
federal government, just go and give people money, but there
is a formal claims process through which,' if you have been
damaged by the Air Force, that you can be compensated for
those damages.
It's important that everyone understand that..
Okay?
If you would just please call our office, we
can get you in touch with the people you need to be in touch
with so that you can -- if you have been damaged, you can be
compensated for those losses, if you will.
MR. ROBERT STITES:
It's also important to note on
that .that, essentially, we have the authority to come up here
and tell you what we would like to do here.
We don't have
the authority to settle any claims with you.
What would
really happen is you would be referred to the appropriate
people.
MS. GWEN BREWER:
(Indicating.)
Let's take the
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one in the back here, and then we'll come back to you.
2
MR. ALAN MANUEL:
My name is Alan Manuel,
3
M-a-n-u-e-l.
4
Given the amount of time that things were
5
placed in this dump -- How was it stored?
Was it in metal
6
containers or openly dumped?
What type of degression do you
7
predict has happened to these containers, if there are any,
8
and what future degressionwill happen?
9
In other words, right now my question is:
You
may have "X" amount coming out.
If these containers have
degraded and fallen apart in the future, could the volume go
up?
I would assume it could.
What will this process that
you're proposing do in that case?
MR. BOB ELLIOTT:
That's a very important
okay.
consideration.
There are not in any municipal -- The
landfills that are up here are especially related to any
other landfill that someone may have gone to in the '50s or
'60s.
There were things dumped in those landfills, and we
don't have a crystal ball to see inside of those landfills.
Records were not kept.
I mean, they were the good old dumps
you backed up into the hillside, and you dumped stuff into
it.. The bulldozer covered it up.
The concern that maybe there is a drum of --
another drum of TCE sitting in that landfill that hasn't
degraded 'is a possibility that exists that we can't discount,
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but I think the important part to recognize is that there is
2
an extensive network of monitoring systems around that
3
landfill and down below that landfill that will be monitored
4
through this entire process.
5
Once we finish the remedial action, we go into
6
a period of long-term monitoring of the site.
You never get
7
rid of the site.
You have them forever essentially as far as
8
a monitoring responsibility to make sure that there are no
9
additional contaminants showing up in the ground water.
That long-term monitoring process runs for,
what, Rob, 30 years?
MR. ROB STITES:
A minimum -- Well, until you're
clean, which, if you don't get clean, could be forever at
least in the absence of a change of the laws.
Iid point out as part of the monitoring that
if there was something detected coming out, there would be
action taken on that before it ever got away from the base.
MR. BOB ELLIOTT:
Can I -- Let me just say one
more thing.
Because we make a decision sometime next spring
or summer and sign a document which we call a Record of
Decision, the process does not end there.
We have a
five-year review requirement in which we have to go back to
the E.P.A. and go through a full blown review of the site,
how well the treatment is working.
In that review, a
determination is made as to whether or not the alternative
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that is being used is being effective.
If it's not
2
effective, other alternatives can be implemented at the site
3
to enhance the cleanup.
4
MR. JOE THOMSEN:
Isn't it better to do it right
5
the first time than to have to go back?
6
MR. BOB ELLIOTT:
As I mentioned to
7
Mrs. Patterson, we believe we are doing the right thing.
8
This business tends to make liars out of us
9
sometimes because we may not understand some specific element
of the geology that changes or that some condition changes or
something and we didn't understand.
So the reason that is
there is to afford a review and just not let the Air Force
walk away from the problem.
We sincerely believe that this alternative is
the best approach to solving the problem at the site.
MR. JOE THOMSEN:
It seems like it's the
government -- it's the military's or the Air Force's priority
that is a problem here because cleaning up contamination is a
lower priority than that ,red flag operation.
That red flag
opera ton that they just had out there probably shot up more
in munitions than what it costs, to dig up that landfill.
MR. BOB ELLIOTT:
Okay.
Yeah, I guess that's a
statement for the record.
Thank you.
MR. ROBERT STITES:
I would like'to suggest that
you make that statement to your appropriate congressperson.
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Let them know your feelings on what you believe the priority
2
should be.
3
MS. GWEN BREWER:
(Indicating. )
4
MR. RICHARD PEEK:
Richard Peek.
The last name is
5
P-e-e-k.
I-
6
I livej~st east of this site, approximately a
7
quarter of a mile from where Deran CUtler lives.
There are.
8
springs that run off that hill in which the state has drained
9
underneath the road into an agricultural drain that we have.
10
I was wondering if that water has been tested for any of this
contamination, or has that plume evolved eastward. to involve
that area because I don't see -- I see a lot of trucks down
in the corner there by Deran, but no one has ever approached
me or -- myself or my father to ask about that ground water
coming off the hill.
MR. BOB ELLIOTT:
Okay.
I don't know specifically
the area that you're talking about, but, essentially, a
quarter of a mile east of Mr. CUtler's.
As we have
identified, the contaminants -- I think that is to the east
of where there are contaminants, but we would be more than
happy to come and sample those areas for you to determine if
there is a problem there.
If you would just check with me
right after the meeting, I'll get your phone number.
MR. RICHARD PEEK:
Because if the canal -- The
canal is not water tight, okay, because I notice an increased
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flow when there is water in the canal.
Now, if that's
2
leaking down through the hill and picking this stuff up, that
3
would be a concern because that water comes across and is
4
consumed by cattle and other livestock.
5
MR. BOB ELLIOTT:
Thank you.
6
MS. GWEN BREWER:
(Indicating. )
We have a comment
7
back here on that.
Michael Cox.
8
MR. MICHAEL COX:
On Mr. CUtler's property, we
9
have drilled a number of wells.
There is a number of wells
on the east side of the property, and we have basically seen
that we don't have much contamination, if any, on that side
of the property.
It always appears to be moving toward the
north and northwest, so there doesn't appear to be a lot of
contamination there.
MR. BOB ELLIOTT:
Please, again, get in touch with
me because we haven't solved the problem if we haven't
addressed all the issues.
MS. GWEN BREWER:
In the suit and then back here.
(Indicating. )
MR. MARK PERKINS:
Mark Perkins, P-e-r-k-i-n-s.
Are there other sites on the base that have
similar problems that have been identified or potential sites
that haven't been identified where we would run into the same
24
thing?
25
MR. BOB ELLIOTT:
Could you clarify the same --
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what you mean by the same thing?
2
MR. MARK PERKINS:
The same kind of pollution
3
that's moving out into the town.
4
There are additional sites on
MR. BOB ELLIOTT:
5
the base.
The sites that have been identified on the base
6
have been broken up into groups of sites, and these sites are
7
called Operable Units.
Under these Operable Units -- That's
8
why we call this Operable unit 4, which is a group of sites.
9
We're working on very similar -- through the exact same
process to come to a cleanup resolution for each of those
sites as well.
There are some areas in the industrial complex
of the base, some buildings, that have not been fully
evaluated to our satisfaction, and we are currently working
on a study to better understand if there were chemicals used
in those buildings.
That's in the center of the industrial complex
of the base, so it doesn't -- it isn't up against the
South Weber/Hill Air Force Base boundary.
, MR. ROBERT STITES:
I would like to add that if
you want detailed information on the sites we know about, you
can go to the Davis County Library and look at the
administrative records for Hill Air Force Base.
There will
be a lot of technical information in there, but there is a
lot of information.
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MR. BOB ELLIOTT:
That's the library in Layton.
2
MR. ROBERT STITES:
In Layton.
3
MS. GWEN BREWER:
(Indicating. )
You sir, and then
4
back to you.
5
MR. REX FEUSTEL:
Rick Feustel.
6
I live in the 500 block of. South Weber Drive.
7
Across the street on the hillside, you've had a shack for
8
three or four years now.
Once and sometimes twice a day five
9
to six days a week, somebody goes up there.
At first they
came with white suits and shoes and gas masks and threw
everything in a barrel with crossbones on it.
(Laughter. )
MR. REX FEUSTEL:
Don't laugh.
I'm serious.
When I asked the people what was going on,
they as much told me to mind my own damn business.
Then they drilled holes back in my property
and on Mr. Peterson's property.
You know, nobody has come
one time or sent letters as to what the hell is going on.
When I ask, they ignore me.
I would like to know what the
hell is going on over there.
MR. BOB ELLIOTT:
We apologize for that.
What can
I say, other than whoever didn't treat you courteously --
MR. REX FEUSTEL:
Can't you send a letter saying
what's going on directly across the street from this thing?
Mr. Coy lives across the street from me, and
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he sees what's going on here too.
When you ask them, they
2
won't tell you what time of day it is.
3
Sir, any time anybody gives you
MS. GWEN BREWER:
4
an answer like this, contact us.
You have our numbers.
5
Contact the command section at the base.
No one should get
6
an answer like that.
7
You give up after awhile because
MR. REX FEUSTEL:
8
it's Air Force
9
MS. GWEN BREWER:
That's not an acceptable --
MR. REX FEUSTEL:
They're the biggest bunch of
damn liars I've ever worked for.
MS. GWEN BREWER:
That's not an acceptable answer.
MR. REX FEUSTEL:
I know because I worked for
them.
MR. BOB ELLIOTT:
If you check with me, I'll get
your name and phone number and address and make sure we
follow up with you on the activities that happen around your
.property.
MR. KEN PARKINSON:
We've talked to our
congressman like you suggested.
We've already done that.
He
already went to the Air Force,. and the Air Force says we've
got it covered.
MS. KATIE PARKINSON:
They sent him the most
sugar-covered letter I've ever read.
25
What I was referring to on
MR. . ROBERT STITES:
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that is if you want -- (Indicating.) I believe it was a
complaint over here about the military priority on things.
If it's a case where you want the priority shifted, approach
2
3
4
a congressman.
5
Some of the other politics involved here --
6
I'm sure there's stuff going on that is probably very sad and
7
very unpleasant to all of us, including me.
What I was
8
suggesting though is to let your congressman know where you
9
want this program going.
I wasn't discussing the issues in
particular.
MS. GWEN BREWER:
(Indicating. )
Mr. Poll.
MR. BRENT POLL:
Brent Poll is my name, P-o-l-l.
There was a question asked by I think Rex over
here.
There are three operable units that affect South Weber
city.
There is Operable Unit 1 above the school,
Operable unit 2 above Cook property, and there is
Operable unit 4 that we're talking.about this evening.
You don't have to go to the Davis County
Library to see that.
Hill Field has been open, I think, in
having the public meetings and town council and explaining
just where these things are and at least the preliminary
steps to do things, but there are three succinct separate
operable units they'll address like this Operable Unit 4.
MS. GWEN BREWER:
Each is addressed differently.
MR. BOB ELLIOTT:
We update the city council.
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So
Every six months we go and brief them in their meetings.
2
if you would get in touch with your city council --
3
MS. GWEN BREWER:
4
MR. BOB ELLIOTT:
5
Or us.
-- or us,
we would be glad to
let you know when that schedule is, and you can get an
6
update.
7
MS. GWEN BREWER:
8
If you want us to arrange
another meeting, we can also do that at your request.
9
MR. BRENT POLL:
While I was talking, I wanted to
10
bring up that quite a lot is predicated on your risk
assessment.
You put a lot of weight on risk assessments.
Is
this risk assessment an exact science?
MR. ROB STITES:
MR. BRENT POLL:
MR. ROBERT STITES:
two.
MR. BRENT POLL:
No.
Is it an art?
,It's a little bit between the
So when you put up there one in a
billion or one in a million, that's a guesstimate.
MR. ROB STITES:
conservative assumptions.
MR. . BRENT POLL:
not?
MR. ROB STITES:
on what the risk is later?
MR. BRENT POLL:
It's a guesstimate, but based on
But it is very dynamic; is it
Do you mean weill change our mind
It vacilates frequently.
For
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example, someone called you a liar, and I know you don't like
2
that.
Bob said sometimes this business makes liars of us
3
all.
4
Over the years, you've said we're safe here
5
and there is no problem.
Now we're spending all this time
6
and meeting, and there is a problem.
Over the years-- Over
7
the last 25 years, we went from there is no problem to
8
spending millions and millions of dollars and conducting
9
countless meetings to resolve what you once said didn't need
to be addressed.
MR. ROBERT STITES:
We need to clarify current
versus potential risk.
You are safe here right now.
MR. BRENT POLL:
Thank you.
MR. ROBERT STITES:
You have no current risk.
MR. MUHAMMAD. SLAM:
There is two risks, present
versus future risk.
We're trying to address the future risk
so the public is safe in the future.
Right now the public is
safe.
We want to shQw you're safe in the future.
MR. BRENT POLL:
The point I'm making is you can
read U.S.A. Today or a news article when they talk about
pollution, and they'll say we don't know very much about this
new science or what's going to happen when you plant your
garden.
Some of these things are going to be absorbed in the
vegetables.
There's no succinct
We don't know that yet.
studies.
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How about when the animals eat it and you eat
2
their flesh?
We think
We don't know what it will do to you.
3
we do, but there is no succinct studies.
4
It's like finite, like absolute when you put
5
it on your screen.
When you do your risk assessments, you do
6
it as if it's factual; but the truth is it's not necessarily
7
factual.
It's our best guess we can make at this point in
8
time.
9
MR. BOB ELLIOTT:
Colonel New is re~lly an expert
in the area of risk assessments, and he can give you a better
feel for the dynamics of the science.
LIEUTENANT COLONEL GEORGE NEW:
Let me tell you a
little bit about it.
For one thing, it is a blend of an art
and a science, but also what they say is we have taken the
worst case.
One thing you see in your brochures is that
TCE is reported here as a carcinogen, and much of the
analysis is on that.
We have now where people are refuting
that.
In our case -- In the hospitals, we know we
have used that for years and years as anesthesia.
We get
levels thousands of times greater than what you're exposed to
here with no indications.
We have no cases right now of
documented humans with TCE.
We're talking about levels literally less than
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thousands of times what we have put people in in either one
2
operation or another.
Many of you that drink decaf coffee
3
have been exposed for years and years at many higherleveis
4
than this level in this population here.
We see no cancer
5
trend, so these are facts we do know.
6
The actual science of putting it together in a
7
risk assessment is, as you know, a combination of this art.
8
We try to look at the worst case.
If this thing does
9
20 years from now turn out to be a carcinogen, are we going
to have a problem.
But right now, to let you know better, 'I
agree with you.
We really feel we have no problem with our
health.
We worked with the National Cancer Institute,
l'
with our workers on the base that are exposed to TCE at
thousands of times these levels.
Again, in a work situation,
degreasers and things like that, we see no pattern there that
we're looking at it.
I have a multimillion dollar base that I look
at trends in.
Basically, among ,our workers, we look for
chemicals they're using and look for health trends, but we're
looking at levels again thousands of times over what we're
talking about here.
Yet we have seen no increased cancer
trends.
In cases where we have seen a cancer, where
somebody 'quoted in the paper where he had cancer, we looked
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into it with a medical staff.
That was the cancer you can
2
get from the high altitude.
We have none now on where we see
3
incidents of cancer at the base, and we have these same
4
people exposed in the industry.
If you look at the aircraft
5
industry in general, we don't see those trends.
6
MR. WAYNE PATTERSON:
I have a question.
If you
7
guys are -- if you're not concerned about the health hazards
8
and stuff, why are we pUblicizing everYthing and telling us
9
it's such a bad thing, putting it out in the public,
devaluing the land, causing building planning commissions to
zone things so you can't build houses with, you know,
10 acres of land?
Why are we pushing all this stuff then?
LIEUTENANT COLONEL GEORGE NEW:
From my
experience, it's politics.
I was involved here in a case many years ago
where we had an indication of TCE exposure.
People claimed
they had problems with -- liver problems, cancer problems.
18
Cancer was the basis.
19
The cancer was from high altitude.
The liver
20
problems were from alcoholism.
Some of the guys had mental
21
problems.
One was from -- One in particular had a vasectomy,
22
and it destroyed his feeling of manhood.
We had nothing
23
connected there.
24
Now, what happened though when all their stuff
25
got out about the same time?
We took -- I took about 500
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samples.
Here we're talking about a health standard that's
2
-- Basically, a hundred parts per million is the health
3
standard for occupational exposure.
Now, we went in there --
4
At the time we had a chemical similar to this called
5
trichloroethane whose standard was 250.
We took about 500
6
samples, and it was like less than about a 20th of that level
7
that we found.
8
Papers took all this and put it together
9
because what was happening at the same time was the Holocaust
10
was shown on T.V.
11
Here's this clean room at the base where we
have levels over one -- the electronic cleaning room.
We had
a health standard of 350.
The highest I got was 18 parts per
million.
They take that and combine it with the
Holocaust, and we're creating a Holocaust on the Air Force
Base.
They get blown up, and sometimes they're used to
magnify and sell news.
I think some of that happens here.
I
really believe that, and I've had 20 years in the field.
We don't have all the answers.
Mr. Poll is
right.
We don't have all the answers on TCE.
We do have
good track records, and at much higher levels we don't see
cancer.
MR. WAYNE PATTERSON:
Tell the planning commission
and the newspapers about it instead of having them print that
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there are these kinds of things.
2
LIEUTENANT COLONEL GEORGE NEW:
I think there is a
3
general tendency --
4
MR. WAYNE PATTERSON:
The planning commissions say
5
they're going to do this and this to our land.
They say
6
we've just devalued your. land.
When the newspapers say this,
7
what are we to do?
You're expecting a Holocaust, I think. .
8
MS. LOLA PATTERSON:
You're planning a Holocaust
9
for us.
MS. GWEN BREWER:
(Indicating. )
Let's take the
gentleman back here.
MR. ALAN MANUEL:
My name is Alan again.
Have there been current risk studies done
other than those contracted by the federal government?
MR. BOB ELLIOTT:
On this particular site, no,
there have not.
I guess the only thing that we can tell you is
that the risk assessments that we did have gone to the
Department of Environmental Quality, who has evaluated them,
which we see as an independent.
The Department of Environmental Quality for
the State of Utah is very interested in what goes on on the
23
patch of ground called Hill Air Force Base in the State of
24
Utah as it relates to environmental issues and many other
25
issues.
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Also, those risk assessements have been sent
2
to the E.P.A., and they have had their risk assessment people
3
review them, comment on them.
4
We have gone through and changed things that
5
they have not liked, that they felt were not maybe
6
conservative enough.
7
So they have been through, I guess, an
8
independent review, but no separate document has been written
9
and published that would be an independent health risk
assessment.
MS. GWEN BREWER:
Mr. Poll?
Oh, okay.
(Indicating.)
Here, and then I'll go to the back.
MR. DARRELL BYRAM:
Darrell Byram, B-y-r-a-m.
I want to make a statement.
I don't want to
discourage anybody, but I have a gut feeling that this will
be going on for a hundred years, this cleanup, and I don't
see that -- You have already indicated probably 20, 30 years,
but I think you'll'find that this will be going on for a
hundred years, and a lot of us in this room will be gone.
MS. GWEN BREWER:
(Indicating. )
In the back.
MR. LEON BIRK:
Leon Birk, B-i-r-k.
I want to take some exceptions to the comments
that was made here the very first of this meeting.
One of them was they've looked at this water
around and nobody has used it.
I take exception to that
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because how do you know nobody has used it?
Because you
2
didn't see nobody drinking it or you didn't see animals there
3
the day you was up there, so you assume nobody uses that
4
water?
5
Then we hear that, hey, everything is okay.
6
No problem.
Then all of a
Just like we're going back.
7
sudden there is all this commotion going on, and they've been
8
100 percent.
When I've tracked them down and say, hey, come
9
and test this water and do this, blah, blah, blah.
When this thing very first broke, I had
50 head of cattle running up here.
The first thing I know
that anything is even going on is I go up there, and there is
a fence that wouldn't hold out nothing been put up there
around where some water is running.
When I started aSking
questions, oh, that's some pollution that's coming out there.
My question is just like several has alluded
to here tonight that related to nobody will come and say
nothing to the owner of the property.
I dare say that I can take you on that
property down there, and I can show you water that's coming
out of that hill that probably you don't even know was there.
On this map you've got two or three seeps.
Then it says a seep is something that gives so many gallons
of water over "X" amount of time.
I dare say everyone I know of will exceed
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that by quite a bit, but nobody has come and ever once asked
2
me or told me or whatever what's going on without I haven't
3
pried it out of them.
But if they want property, they darn
4
sure know where to come after me.
They darn sure know how to
5
try. and get it out of me for nothing and threaten me with a
6
lawsuit if I don't sell it to them.
7
Then you're telling these people that they
8
have the right to complain or go through this process.
I
9
agree they've got the right.
I was born in the night, but I wasn't born
last night~
What is the sense of spending a thousand dollars
to collect a dollar?
That's the bottom line.
That's what
this whole thing revolves around is bucks.
A lot of them are
just being passed, but that is what it's all about.
When you say that no one is using that water,
I take a big exception to that because you do not know if
I've got animals or if I'm drinking it.
MR. PATTERSON:
Same on the Patterson place.
MR. BOB ELLIOTT:
Let me clarify a statement made
earlier.
That statement was made in too general of terms.
When the discussion was made about using the
water, the reference was to a well that someone might have,
f
that they were taking that water and drinking it, using it in
their house on a day-to-day basis.
What I would like to do, Mr. Birk, is go walk
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along that hillside and have you show us those springs
2
because we have found that the local people that have owned
3
the land in many cases have been able to take us and say,
4
hey, I know that in August water comes out right here and
5
that's the only time it comes out.
So that's been very
6
beneficial to us, so we'll get in touch with you.
7
MR. LEON BIRK:
That seems to be like -- Why
8
hasn't that been done in the past?
That seems to be the
9
pretty logical thing.
If you're looking for water or trying
to test water, come and do that to start with.
Why should we
have to trace you down?
MR. BOB ELLIOTT:
I wouldn't expect you have to.
Our -- We've been attempting to talk to land owners and try
to evaluate the conditions along --
MR. LEON BIRK:
I will say this:
Every time that
I run somebody down or say check that water, they'll do it,
you know, but that's little consolation when, you know, they
. say, well, your water is a hundred percent yet right next to
it they're saying now we've got this problem.
So it just all goes back to what we have been
talking about.
What do we sort out and believe?
Thank you.
MS. GWEN BREWER:
(Indicating.)
Yes, sir.
24
MR. DARRELL BYRAM:
Darrel Byram, B-y-r-a-m.
25
. They send me a letter about every three months
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telling the reading on the wells that they have on our place,
2
so maybe you ought to get on the mailing list and find out
3
what is coming out of there.
I really don't know how to read
4
it myself, but I get it.
5
(Laughter.)
6
MR. ROBERT STITES:
I know the Air Force was
7
recently putting together a little pamphlet explaining how to
8
read those results.
You have not received that yet, or has
9
it not been sufficiently explained to you?
MR. BOB ELLIOTT:
It hasn't been sent out.
MR. DARRELL BYRAM:
But we get information as to
what the wells are reading.
MS. GWEN BREWER:
(Indicating. )
Let me get this
one.
MS. GINNY ODEKIRK:
My name is Ginny, G-i-n-n-y.
The last name is Odekirk, O-d-e-k~i-r-k.
My question was if South Weber decides to do
. its own risk assessment study on the Operable Units 1, 3 and
4, is that something we could maybe have an Air Force fund
for or is that some type of grant from the E.P.A. or the
E.Q.A.?
MR. ROB STITES:
Mr. Poll, would you care to
address the joys of the TAG grant?
MR. BRENT POLL:
Of getting a grant?
MR. ROBERT STITES:
Yes.
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MR. BRENT POLL:
Brent Poll again.
2
We have acquired a Technical Assistance Grant.
3
It's been a while since I had one.
Doctor John Carter has
4
been secured through that grant to review the data collected
5
by Hill Air Force Base and give us his independent opinion of
6
what it means.
Thus, there is a lot of paperwork, a lot of
7
red tape, but they'll give you as much help as they can.
8
It's been worth our time to secure his services.
9
Would I advise anyone else to go through that
same process?
I don't think so.
He has been deemed the most
serious of all the Hill Air Field, and we felt for our
protection we needed to do something such as that.
MR. ROBERT STITES:
I need to emphasize there is
one TAG grant --
That stands for Technical Assistance Grant.
stop me if I use an acronym you don't understand.
There is one Technical Assistance Grant per
site for a maximum of $50,000, ~xcept under some extreme
circumstances.
That grant has already been awarded to the
South Weber Landfill Coalition.
That's Mr. Poll's
organization.
If other work -- If the coalition is willing
to discuss doing other work, that may be an avenue.
I do
know that is going to lead to a lot of extra paperwork and
effort not only for you, but Mr. Poll too.
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MR. BRENT POLL:
But there is $25,000
2
approximately that has not been consumed yet of that $50,000
3
that has been awarded.
If somebody wants to be with us, it's
4
worth the money.
5
MS. GINNY ODEKIRK:
Is that an annual grant?
6
MR. ROBERT STITES:
No, $50,000 total onetime.
7
MS. GINNY ODEKIRK:
I have one other question.
8
MR. BOB ELLIOTT:
Can I answer this first?
9
We have never explored the possibility of
trying to do -- have an independent -- I don't know how if we
pay for it someone could call it independent, but we have not
explored that option.
We would like to do that, so we will
take an action item to explore that with our people and see
if there is a possibility that we can provide some assistance
in that way.
MS. GINNY ODEKIRK:
That may be good.
I want to refer back to Rex Feustel's question
in regard to the people he saw across the street from him in
the white suits and the holes they were digging there twice a
day.
He said they would not answer his question as
to what they were doing.
I was wondering:
Do you know who
they were?
Were they sent by you?
Were they getting
samples?
Do you know what they were doing?
MR. BOB ELLIOTT:
We really need to know the
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specific time table in which that occurred and exactly where
2
it occurred.
We can probably go back and look at who they
3
were and identify who was there.
4
MS. GINNY ODEKIRK:
Have you sent people to that
5
area across the street from Rex?
6
MR. BOB ELLIOTT:
Across the street from.--
7
MR. REX FEUSTEL:
530 East South Weber Drive.
8
They're still coming there almost every day of the week.
Not
9
always in white clothing, but it's all civil vehicles, not
government vehicles.
MR. BOB ELLIOTT:
We'll check into that.
MR. REX FEUSTEL:
530 East South Weber Drive.
MR. BOB ELLIOTT:
I'm not familiar on the map with
where that exists.
MS. GWEN BREWER:
I have one here.
MR. BRAD HOLBROOK:
Brad Holbrook,
H-o-I-b-r-o-o-k.
I just live several houses west of Mr. CUtler
on the same side of the street as him.
The Pattersons live
between us in that area.
My comment is along the same lines as
Mr. Birk's.
It was mentioned just several cups of water per
hour come out of these seeps.
I have lived there for some time and am still
raising my children.
Some neighbors raised children from
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children to adults too in that area.
2
There is much more water that comes out of
3
there some times of year and especially when the canal is.
4
full.
That canal is certainly not sealed, which was
5
mentioned previously, and there is a lot of water that comes
6
through there that would seem to me to be a real critical
7
portion of this cleanup plan and what kind of problems you
8
could end up with in years to come from that.
So I want to
9
point that out, as was already done.
Also, I don't really apologize for the emotion
of me and my neighbors.
We have raised our children here.
We're concerned about -- You know, property values have been
mentioned, but, much more direct than that, with this scare
we have to be concerned about health problems as well with
our children playing in the water.
They played in the dirt
before we were aware there was any problem that had certainly
occurred.
Before I let you go, if you could comment on
that as well.
Also, can we get -- Those of us who are
concerned and especially have land that'e directly effected
by this, can we get a complete copy of whatever plan you
decide to execute before it's done, some kind of a written
plan to us?
MR. BOB ELLIOTT:
Yes.
Again, we would be -- we would like to have
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the opportunity to go and have you show us where some of
2
these things are in the thicket of trees that we haven't seen
3
with our eyes.
4
You know, some of those things on those
5
hillsides are tough to find.
They're in a thicket of trees.
6
They run down the hillside for 10 or 15 feet, and they go
7
back in the ground.
8
We have spent a lot of time along. that
9
hillside looking for springs, trying to evaluate where there
10
might be water moving out of the hillside, but we would
certainly welcome the opportunity for the easiest approach,
to go and say there it is right there.
MR. BRAD HOLBROOK:
You just have to ask.
MR. BOB ELLIOTT:
Thank you.
Can we answer his question?
LIEUTENANT COLONEL GEORGE NEW:
One more part too.
One thing that does -- It may not sound too good, but you
actually have a better condition when you have this big
runoff because the aquifers don't release the water quickly
when you have runoff like this.
It's surface water.
What it
does is dilutes it even more.
So what may be a problem is
even less of a problem.
It's really to your advantage in
diluting these concentrations to get them down lower.
MR. GARY COLGAN:
We are aware in how the canal
affects the flow and the aquifer system.
In fact, there is
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about a third of a mile that -- Was it last year or the year
2
before -- was relined with concrete by the canal company
3
which goes from the North Gate to the east across the top of
4
mainly Mr. Cutler's property.
By lining that and preventing
5
that water from going down, it's probably actually slowing in
6
migration of contaminants.
7
MR. ROBERT STITES:
But that's not the entire
8
canal line.
It's one of those helpful things.
9
MR. GARY COLGAN:
It's just a piece.
MR. BRAD HOLBROOK:
Will we get copies of the
plan?
MR. BOB ELLIOTT:
Yes.
We like to get as much
information out to people as we can.
We have a mailing list
we keep, and we send information out.
So we'll be sure and
put your name on that list to make sure you get. that
information.
MR. ROBERT STITES:
I hope this is helpful.
Once
that design is complete, there is supposed to be a fact sheet
out saying, look, we completed this design.
These are the
pertinent features of it.
A meeting can also be arranged at
that time too.
In other words, once we finally decide we need
this here, that there, all that -- What we have here is a
very general plan of action.
We're going to have to look
into specifics, like which seep is where, what spring is
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where, what is flowing, is it contaminated.
We have to look
2
-- We have to dot those I's and cross those T's, so to speak.
3
MR. BOB ELLIOTT:
Our interest is in keeping you
4
as well-informed as we can.
So if you as residents want us
5
on a monthly basis to come down here to the school and say
6
this is what we're doing or on a quarterly basis -- You tell
7
us what you want us to do to keep you informed, and we'll do
8
it because we can't solve the problem without your
9
involvement.
MS. GWEN BREWER:
If we keep sending things to you
and none of you respond, we also don't know how you feel
until you're about up to here with everYthing.
(Indicating. )
Then everything blows up.
So if we're not doing what you
want, let us know because we have to work with you to get
this thing done.
Mr. Poll?
MR. BRENT POLL:
On your risk assessment -- In
conjunction with Mr. Holbrook's question about the health of
his children, are you just looking at cancer-causing agents
in your risk assessment?
Are you looking at birth defects?
Are you looking at skin disorders and other maladies of this
nature that are commonplace around toxic dumps?
LIEUTENANT COLONEL GEORGE NEW:
In a risk
assessment, you have to look at all the routes of exposure
and contact versus inhalation versus digestion.
KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS
AMY STOLTENBERG, CSR, RPR
80
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PUBLIC MEETING RE PROPOSED PLAN FOR OPERABLE UNIT 4, 10/19/93
1
Maybe you can --
2
Our lead risk assessor just
MR. GARY COLGAN:
3
left, but we looked at all the contaminants that we did find
4
at this site and conducted risk assessments using
5
accumulative and singular effects of all those chemicals for
6
both cancer risks andnoncancer risks.
7
So we didn't just focus on TCE.
I use TCE .
8
because it's the most widespread contaminant of the highest
9
concentration, and it's the thing -- If we focus on TCE in
the cleanup, we'll clean up everything else in the process.
LIEUTENANT COLONEL GEORGE NEW:
One of the
omissions -- Often, that's what drives your carcinogenic
compounds because it has the low level you're looking at.
Then you're required to look at a longer period of time, like
70 years.
Some of the other contaminants you don't have to
evaluate that long.
You look at acute versus chronic, and
the chronic one, based on carcinogens, is what drives you to
these high p~otection levels.
MS. GWEN BREWER:
Are there any more questions or
comments?
MR. BOB FLINDERS:
I have a question.
My name is
Bob Flinders, F-l-i-n-d-e-r-s.
M~ questiop. is:
The record that's being kept
here tonight will become a public record, I assume, and we
can obtain copies of that if we need them.
Where would we
KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS
AMY STOLTENBERG, CSR, RPR
81
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PUBLIC MEETING RE PROPOSED PLAN FOR OPERABLE UNIT 4, 10/19/93
1
obtain those copies at?
2
MS. GWEN BREWER:
This will be in the repository
3
at Layton at the library.
We'll also have it at Hill Air
4
Force Base in the administrative record there.
It will be an
5
official record, and it will be open.
6
MR. BOB ELLIOTT:
Maybe we can suggest too that we
7
. could send copies to the city council and have them av~ilable
8
if that's a little more convenient for you.
9
MS. GWEN BREWER:
You can go over there.
MR. BOB ELLIOTT:
They can keep in touch with us
so that -- if they need some additional copies of it.
MR. BOB FLINDERS:
Will you make a statement that
that will take place?
MS. GWEN BREWER:
We'll make a statement that that
will take place.
(Indicating. )
Yes, sir.
MR. RAY GIBBONS:
Ray Gibbons.
May I suggest maybe the Riverdale area be
implemented in the copies, the city council of Riverdale?
MS. GWEN BREWER:
Yes, sir.
We also brief the
Riverdale City Council, and we send documents to them to make
sure they're current on the things happening here too.
MR. RAY GIBBONS:
Thank you.
KS. GWEN BREWER:
Are there any more questions or
comments?
KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS
AMY STOLTENBERG, CSR, RPR
82
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PUBLIC MEETING RE PROPOSED PLAN FOR OPERABLE UNIT 4, 10/19/93
1
We're very pleased all of you came tonight.
2
Remember, if you think of anything that you didn't say
3
tonight or if you didn't say something that you wanted to
4
say, we will be taking comments until the 5th of November.
5
Once we reach the 5th of November, then they
6
will compile all of those comments and questions and then try
7
to work out a proper solution.
8
We're really happy to see all of you here this
9
evening.
You've got our names and
Please don't hesitate.
our numbers in the book.
Just give us a call.
Thank you all
for coming.
(At 9:15 p.m., the foregoing proceedings were
concluded. )
* * * * *
KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS
AMY STOLTENBERG, CSR, RPR
83
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1
C E R T I F I CAT E
)
STATE OF UTAH
2
SSe
COUNTY OF SALT LAKE )
3
4
I, AMY STOLTENBERG, C.S.R., R.P.R. and. Notary Public for
5
the State of Utah, residing in Salt Lake County, certify:
6
That the Public Meeting re Proposed Plan for
7
Operable Unit 4 was taken before me pursuant to notice at the
8
time and place herein set forth;
9
That all proceedings had of record at the time of
the Public Meeting were recorded stenographically by me and
were thereafter transcribed into typewritten form by me, and
I hereby further certify that the foregoing typewritten
transcript as typed by me is a full, true and correct record
of my stenographic notes so taken;
I further certify that I am neither counsel for nor
related to any party to said action nor in anywise interested
in the outcome thereof.
IN WITNESS WHEREOF, I have subscribed my name and
affixed my seal this 31st day of .October, 1993.
6'H~~
u" '.11
~.."\o,,,._~,,~
l,,~":::':~l:'i~ ~:1~\
~~!~:Yg~'.::W
~..~!J...""
R.P.R. ,
NOTARY PUBUC
AMY S. STOLTENgERG
~~.;~ ~;:~J~:~.~.:. :~~~;)~,1~
h"~
:', . ',"J zs
,""-', .
~;.'~":;: (.~:. .~':.;.rI
KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS
AMY STOLTENBERG, CSR, RPR
84
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WRITTEN COMMENTS AND RESPONSES
Appendix C
-------
08/05/92
15:53
'Zt801 iii .1306
OO-.~LC/EH
~~~ JHH
1a)002
Mr Shane Hershey
EMR
Hill AFB~ UT
3 A!..(g 92
Dear "'r Hershey:
I rQ~cntly tel Ked with y~~ &bout our conc&rns with ha%ard~us
waste de~asi~ on our hillsiae. As we mentioned, thw
Government has placed several WQlls in th& vicinity ~T & l~t
where our dauQhter and her ~amily would like to build a home.
You sUQQested we list our Questions and you would &n8Wer them
in ~etail. We would like to know:
1. Would this contamination give us re.~.n to worry aoout
toe fruit/vEgetables pro~uc:d on this property? Even now WQ
Qccasiun.lly eat the fruit on this hillside.
2. Is tnere concern _bout the 9ra~&eS and or hay the _nlmals
e.'t? These animals M'e raiSiild f.:.f'" my families f~I~.d .and 1
w.:.uld 11 ~.;e to know if the Qras~es .re also c.:.ntamin.tWd.
3. I would like to know iT there are .ny re&50nS regardin~
hazardous wa.te, why it should be a concern if ~ home war.
built 1n this _re- suen as children playino in dirt, long
term ~TTects. etc.
4. I would 1 H(e to knclL" how long y.:.u e~peet this cle_n-up tc::.
tak~~ if it will Ever reQuire large vehicles, heavy duty
equipment ~Id/or buildinQs suc~ as ~~VQ been buil~ in the
South WeQEr areA.
5. l"d 'really like te. knc.w what tnep\:.!!sibility is \:.f lClng
term effect5 fQr tne family I ~ave already raised on this
pr~.perty .
! w~ulo appreciate any ln~ormat1~n you may haVE reoard1n9
these Qu~~t1ons and the ~lean-up. 1 'hope you will b~ kind
an':'lloh t.:. keep ale inoiormQd .Si more information is ,..~leas.d.
Than.~ you!
,''''
- I
<.p', i J" - J
~;P..J:., ~;t~..~ cJ./-Jt-/
Le.la Pe.tterson
cOSO So Web~r Dr'
0oder,. Ut 84405
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APR-21-1993 13:28
OO-ALC/EM HILL AFE UT
8211 777 43216
p.ee2/eB4
JAMES M. MONTGOMERY, CONSULTING ENGINEERS, INC.
MEMORANDUM
To:
Mr. ShaDe HirsdU
Program Manager
Hill AFB0114
Dr. Ruddie Clarkson
IMM
Date:
August 31. 1992
From:
Client:
Hill ArB
Subject: Response to Mr!. PatterSon IS
Lcner About HiU AFB
OU4 Risk .I..f.JS"'~t
Fi1e No.: 2208.0128
The folJowing wormuion is a response to Mrs. Patterson's letter regarding her cuncerns
about potential impaclS!rom Hill Air Force Base. OU4. I have wriam the response u a
narrative in an attempt to discuss her concerns with her and not just provide 1:1iniCal
:answers to her mdividual questions.
The response is u foUo.ws:
In order to evaluale potential public health risks due to siuN'elaced. ex~SUfl:S. two
componentS need to be considered. These tWO evaluation componems lie as (oUaws:
. Toxicity - The potmua] (or the compound to cause harm to human health.
. Esposun. What are the potential activities in which a person may cOlne into
contaCt with site compounds. This also includes evaluation of hotl often
(frequency) and-how lenS (duration) the activity is performed.
Both of these componentS need to occur for even the potenual for risk to be avw'Jle.
Thus. the by to potential risk from this site should focus on potencial expcsurc to
canwnin.~ pt)undwater.
The Air FOI'Ce site investigation has indi~ated that contamination has been deu:ctcd in
groundwstC' off-site.
The root systems « 5 ft) for your fruit uea would not be expccu:ci to l'e2.ch this
groundwa= thus the trees would not be exposed ta the contamination. Any venctablcs
arown on the I'ro~rtY would also he unaffected.. due to their Ahal1nw rnnt !:y~tSm~
« 1 ft). .
In a.cidition. the compounds detected m the groundwater would be metabolized ('~d by
the plant) and not expected to bioacc:amulate (be stared) in the tissues of the p1lnl:5. This
means that even if the room reached 1he groundwater me the plant woulci Wee; up the
compound with the water; the compound would then be broken down by natUral
processes m the plam (ca11cd metabolism) and released from the plant. Very little of the
compound would remain or be stored in the portions of the plant you or your .1n1mals
may cat. '
-------
APR-21-1993 13:29
Relpcmse to Citizen's
Let=s about Hill AFB
OO-ALC/EM HILL AFB UT
-2-
SB1 777 43B6 P.BB3/BB4
August 31. 1991
With regard to the grasses and hay eaten by your animals, again, mere is nc 1'C:tSOn 10
expect thar. me grasses or hay your animals cat are contamina~ci from the Hill AiJ' Force
Base site... The root systems for 1hcsc plantS arc very slWlow « 1 ft) and would net reach
the deeper groundwater where contamination hu been detected. Thus. the plan~ would
not come into contact with site contamination. so your animals woulc1 not be &t r.:sk and
neither would you and your family if you consume these animals. .
Risk A.uessment is a scientific tOOl used to ch&raC1erizc potemial ~nt and futu::'e riW
to public health and the environment thrcugh ex~osure to si.s~c chemicals. The
procaa is designed to be conservative and thus. protective ot public health ulc1 the
environment.
Past risks from the site cannot be evaluated qUlnr: ..w.vely, because no iniormaaon on
oast concentrations' levels is available but investigation does not inciica'z past
contamin:uion offsite. Theretore tte sampl1Dg data. in Lbc:: 1\1 ~.~i1c::~t~ .;urrcnt
concentracion levels on site. However. we can look at the present body of inioJmation
about the site and make some qualitative judgmentS about past exposure and p"tcnnal
public health impact.
Acute (shon-tenn) exposure to trichloroethylene (TCE) may produce central nervous
system depression tha~ can range ftOm minimal light-headedness It lower concentrations
to headache. incoorc:iination. dizziness. deC:teascd reaction time. loss of inhioitions.
mental confusion and anesmesia. and loss of consciousness at hiah concentrations.. These
effects usually sub.side quickly upon terminauon of exposure to the ~mpound. Nausea
and gastrointestinal disU'eSl sometimes occur after exposure to high concencra.ul,ns and
liver damage has also been observed in heavy usea of l1cohoL
TCE may be absorbed.by inhaWion. ingestion or dermally. It is not corrosive. hut may
be an irritant to muccUi membranes. p:uticularly to the nose and throat when inluled and
to the mouth when ingested. Repeated contac~ with the skin may cause a dr:f. .scaly
fissured (cracked) dermaatis. High conccnuacions may cause eye ane nose iniguicn and
eye injury can result from direct contact with the liquid compound.
The available data indicates that TeE can produce cancer in rats and mice. but present
stUdies have not shown this to be trUe in huma.ns. Epidemiologic stUdieJ of ceDUQunities
coasumms TCE conwninaJed groundwater for over 10 yetU'5 have not shown an :ncrcasc
ill cancer rates.
Other long-term .stUdies with animals have shown that inhalation or oral expusun: to high
levels oC TCE: produced liver and kidney damage, effeCtS on the immune system and
blood. and cancer of the liver. kidney, and lun&: thus some poatiallonl-tenn hu.ard to
humans is possible. it exposure is prolonged and concentrauoDS are .il!2ificant.
Long-term epidemiologic StUdies of humans have not inciicated effectS "' kidne)'s. liver,
immanologjc sYStl:m and blood system as shown with animal stUdies.
Catdiac teratogenesis has been indicated in epidemiologic stuciies of areas where drinking
water wu contaminated by halogenated aliphatic hydrocarbons. TrichlortX:thylene
(TC'E) and other organic compound£ were the major contaminantS. A greaorcr than
expected number of pediatric patientS with congenital heart disease wen: the primary
effects noted in these studies.
-------
APR-21-1993 13:29
OO-ALC/EM HILL AFB UT
eel 777 43136
?ee4/004
Response to Citizen's
Leaas about Hin A1=B
.3-
August 3]. 1992
Aglin. the important consideratioD is POtential exposure. The offsite conuuninuion is
limiw! to deep groundwa1er. thus reducing potential for you or your family CD cor~e into
contact with this compound (TCE).
Thus. given our present knowledge of the range of toxicity lSIociateci wi:th the
compounds at the site and our understanding of potential =posure romes, we do :not see
any patterns to indicate past e~posure would have resulted in significant public health
~p~ .
The potential for futUre rius from railing your family on this ~:openy would again
depend upon exposure. Site cleanup ace vities should ebmmace my rurther
cOluamination offSite. The risk assessmeat hu looked at potential exposure throup
contact with soil. ingesuon ot aroandwa=r. &ad inhalation of TCE vapon. All risJa were
predicted in tbe absence of cleanup activities at the site. 'I'hus.long t.enft risk.s would not
be expected for you and your family because cleanup wiU make sure mat contamination
docs not reach your property. ,
NOTE:
fou should chICk my asseSSlMnt of potential IZPOSUrll with responsts prlviously
prtMiUd tD Mr!. Pantl's01l 01' oflu1' 1',sitUntl to elUW'e colVistmcy. .
n. risk GlSUS1Ml1t intJjcatfd pot~l1zial soil gas probu1IU, hur w,d sDil gas tU:l4 wirJI
high unell'tlJinry. How,ve1', the ri.rla calculated art witlai1l th, range sp,dfie,! by riae
NariD1ull CD1Ili1Ig",cy PI4n 101' $uperftwi Sills as acctpmbk lor cIJrciMg,nic 1i:/a. Le.,
1:%1 0.4 to J zJ 0-6 and IDr nD1ICarcinog,lIS, i.I., Mrard ;11.% Ii'.. less than.r. $oil
i1l8e.rriDn t1Ni ail' caJcuI4rioru do not DpplGT tD be a probkm.
lr app,an frDm 1M risk a.r.r,.rsmenr that shtUlow groundwal,1' nury b, 4 prDblel'l in dr,
Jutun, but site r~1Mditzricm acriviriu should p1'lWl1t this. You need 10 CDnfirm: what 1
havt wriatll in the tat tD Mrs. PatUrson.
llyolllulv, I11I'J quuritm.f. pl,ase contact me at (j04) 835-4252.
/jdci
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~
r~~
REGULATORY PKOCEDlIKES MAmJAL fOOD and DRUG ADMlNlSTKADON
Part 9. Imports Division of Import Operations and Policy. HI"C 170
Chapter 9-79 Roc~e.M~and20857
IMPO RT ALERT S
IMPORT ALERTS TRANSMITTAL NO. 94-08 I DATE: 5/31/94
Manual Maintenance
Remove
Insert
Import Alert Index, Revised Import Alert Index, Revised
Dated 04/29/94 Dated 05/31/94
1. None Import Alert #03-10
Dated 05/11/94
2. Import Alert #16-02, Revised Import Alert #16-02, Revised
Dated 09/21/93 Dated 05/17/94
3. Import Alert #16-04, Revised Import Alert #16-04, Revised
Attachment A only, 04/12/94 Attachment A only, 05/11/94
4. Import Alert #16-08, Revised Import Alert #16-08, Revised
Attachment only, 04/21/94 Attachment only, 05/17/94
5. Import Alert #16-18, Revised Import Alert #16-18, Revised
Attachment only, 04/28/94 Attachment only, OS/25/94
6. Import Alert #16-35, Revised Import Alert #16-35, Revised
Attachment only, 04/28/94 Attachment only, OS/25/94
7. Import Alert #16-39, Revised Import Alert #16-39, Revised
Attachment only, 04/28/94 Attachment only, OS/23/94
8. Import Alert #16-81, Revised Import Alert #16-81, Revised
Attachment only, 04/19/94 Attachment only, OS/25/94
9. Import Alert #16-94 Import Alert #16-94, Revised
Attachment only, 04/21/94 Attachment only, 05/31/94
10. None Import Alert #16-108
Dated 05/03/94
otl.S. GOVEPNMENT PRINTING OFFICE:1 994 - 3 8 6- 541/03407
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