United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R07-90/034
September 1990
Superfund
Record of Decision:
Hastings Ground Water Contamination
(East Industrial Park), NE
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50272-101
REPORT DOCUMENTATION 11. REPORT NO.
PAGE EPA/ROD/R07-90/034
2.
3. A8c:1pIent'. Acce88lon No.
4. Tit.. Ind SubtItle
SUPERFUND RECORD OF DECISION
Hastings Ground Water Contamination
First Remedial Action
7. Aulhor(.)
5. A8part D818
09/28/90
(East Industrial Park), NE
..
8. ~armlng o.g....utlon R8pt. No.
D. Performing Orgelnlzltion Name Ind Addte..
10. Proj8ctlTe8klWarII Unit No.
11. Cantr8Ct{C) or Gran"G) No.
(C)
(G)
12. SponlOring OrglniZition Nlme end Addrel.
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of A8part . Period Cover8cf
Agency
800/000
14.
15. Supplementory NolIIl
16. Abetrlct (Umll: 200 warda)
The Hastings Ground Water Contamination site is a contaminated aquifer in and near the
city of Hastings, Adams County, Nebraska. The site consists of seven source areas, or
subsites, contaminated with industrial chemicals. This Record of Decision (ROD)
addresses contaminated surface soil (1-10 feet) on approximately 14 acres of the
2,600-acre Hastings East Industrial Park subsite. The subsite is on a portion of the
former Hastings Naval Ammunition Depot (NAD). Investigations have detected three major
types of contaminants in onsite soil, including explosives such as trinitrotoluene
(TNT), carcinogenic and noncarcinogenic polynuclear aromatic hydrocarbons (PAHs) and
metals. The remedy is designed to control the migration of contaminants from surface
soil to the underlying aquifer. One or more future RODs for this subsite will address
contaminated ground water, and possibly vadose zone remediation. The primary
contaminants of concern affecting the soil are organics including PAHs; metals including
arsenic, chromium, and lead; and TNT.
The selected remedial action for this subsite includes excavating and treating
approximately 125,900 cubic yards of contaminated soil. Treatment of the excavated soil
(See Attached Page)
17. Document Anllyail I. Delcriptor. -
Record of Decision - Hastings Ground Water Contamination (East Industrial Park), NE
First Remedial Action
Contaminated Medium: soil
Key Contaminants: organics (PAHs), metals (arsenic, chromium, lead), TNT
b. JdenlifieraJOpen-Ended Terml
c. COSA TI Field/Group
t8. Availability Stolllment
1D. Security CI... (TN. Report)
None
21, No. of PIli"
64
20, Security CII.. (TNI Plge)
None
22. PrIce
(See ANSI-Z39.18)
See InslrucUonl an Reve-
vr..~"..
(Formerly NTlS-35)
Deplrtment of COIIIIMrC8
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EPA/ROD/R07-90/034
Hastings Ground Water Contamination (East Industrial Park), NE
First Remedial Action
Abstract (continued)
includes onsite incineration of an estimated 16,400 cubic yards of soil containing
high levels of organic contaminants (e.g., TNT exceeding 660 mg/kg, PAHs exceeding
1.8 mg/kg) with final residue disposition based on residual analysis results;
stabilizing approximately 39,000 cubic yards of metal-contaminated soil followed by
placing the soil in an onsite RCRA Subtitle C hazardous waste landfill; and
stabilizing approximately 70,500 cubic yards of soil with low levels of organic and
explosive contamination (less than 10-4 excess cancer risk), if effective, and
placing the stabilized soil in the constructed onsite landfill. If stabilizing the
low-level organic-contaminated soil is ineffective, the soil will be placed directly
in the landfill. If soil is RCRA characteristic hazardous waste, it will be treated
to the appropriate RCRA best demonstrated available technology treatment standard or
to the soil and debris variance levels prior to placement in the landfill. The
estimated present worth cost for this remedial action is $45,000,000, which includes
an estimated annual O&M cost of $86,000 for 30 years.
PERFORMANCE STANDARDS OR GOALS: Soil with concentrations exceeding TNT 660 mg/kg or
PAHs 1.8 mg/kg (carcinogenic risk exceeding 10-4) will be remediated by
incineration. Cleanup goals for the surface soil contaminants include TNT 2.5 mg/kg
(based on carcinogenic risk), total PAHs 50 ug/kg (based on analytical detection
limits), arsenic 11 mg/kg (background levels), chromium 230 mg/kg (noncarcinogenic
hazards), and lead 69 mg/kg (noncarcinogenic hazards).
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implementation of the remedy set forth in this ROD will be
allowed for investigation of non-subsite areas of
contamination.
At the end of this three year period, implementation of
the incineration portion of the remedial action will begin.
If during this period, a comparable but less costly innovative
destructi9n technology has been identified, the design for its
implementation, in place of incineration, will begin.
Design and imple.entation of the other components of
the remedy are not subject to the three year delay and will be
initiated in a timely manner upon signature of this ROD.
Any fundamental changes to the remedy set forth in this ROD
will be issued in a ROD amendment upon completion of the
appropriate public participation and documentation procedures
specified in Section 117 of CERCLA.
DECLARATION OF 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 it
satisfies the statutory preference for remedies that employ
treatment that reduce toxicity, mobility, or volume as their
principal element. Since residual contamination will remain on-
site after completion of this remedy, a review will be conducted
within five years of commencement of remedial action to ensure
that the remedy continues to provide adequate protection of human
health and the environment.
q - 7-? - Cf ()
)/~~:.-./,(r .
1// /~
1/ '
Morris Kay
Regional Administrator
Date
Attachments:
Decision Summary
Responsiveness Summary
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RECORD OF DECISION DECLARATION
SOURCE CONTROL OPERABLE UNIT
SITE ImMI AIm LOCATION
Hastings East Industrial Park Subsite
Hastings Ground Water Contamination Site
Hasting, Nebraska
STATEMENT Ql' BASIS 11m Pt1RPOSE
This decision document presents the selected remedial action
for the Hastings East Industrial Park Subsite chosen in
accordance with the comprehensive Environmental Response,
compensation and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA)
and consistent with the National Oil and Hazardous Substance
Pollution Contingency Plan to the extent practicable. This
decision document explains the factual and legal basis for
selecting the remedy at this subsite.
The Nebraska Department of Environmental Control concurs on
the selected remedy. This decision is based upon the contents of
the administrative record for the Hastings East Industrial Park
subsite.
ASSESSMENT OF THE SITE
Actual or ~hreatened 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 threat to pUblic health, welfare or the
environment.
DESCRIPTION OF THE REMEDY
This surface soils operable unit is the first operable unit
for this subsite. The focus of this operable unit is remediation
of the subsite's contaminated surface soils (0 - 10 feet in
depth). The principal threats addressed by the remedy include
the possibility of further contamination of the aquifer by soil
contaminants and the potential public health threat posed by
direct contact with the soils. The remedy will control the
migration of contaminants present in the subsite's surface soils,
thus limiting the potential for these soils to act as a future
source of aquifer contamination. The remedy mitigates the
potential public health threat through permanent destruction of
the highly concentrated organic contaminants present in subsite
soils and through stabilization of the soils and treatment
residuals contaminated by metals. Soils containing low levels of
organic contaminants pose a lesser potential public health
threat. These soils will also be stabilized if stabilization is
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shown to be effective. Stabilized materials will be placed in an
on-site RCRA Subtitle C Hazardous Waste Landfill.
Future activities will be addressed in additional operable
units. This operable unit will include a ROD presenting a
decision on possible remediation of contaminated ground water and
subsurface soils for this subsite.
The major components of the selected remedy are as follows:
.
. Excavation of approximately 125,900 cubic yards of
contaminated soils. The soils will be tested to determine
whether they are RCRA characteristic hazardous wastes. RCRA
characteristic hazardous wastes exhibit one of four
characteristics: ignitability, corrosivity, reactivity, or
toxicity.
. Treatment dependent on type and concentration of
contaminants:
- On-site incineration of approximately 16,400 cubic
yards of soils containing high levels of organic
contaminants.
- Stabilization of an estimated 39,000 cubic yards of
metal contaminated soils and placement in an on-site
RCRA Subtitle C Hazardous Waste Landfill.
- Stabilization of the approximately 70,500 cubic yards
of soil with low levels of organic and explosive
contamination, if effective, and placement in an on-
site RCRA Subtitle C Hazardous Waste Landfill. Should
stabilization prove to be ineffective due to the nature
of the contaminants, these soils will be placed
directly in an on-site RCRA Subtitle C Hazardous Waste
Landfill unless they are RCRA characteristic hazardous
wastes. RCRA characteristic hazardous wastes will be
treated to the appropriate RCRA BDAT (best demonstrated
available technology) treatment standard or soil and
debris variance level prior to placement in the on-site
landfill.
. A period of three years will be allowed for further study of
two adjacent areas of similarly contaminated soils (currently
under investigation by the U. S. Army Corps of Engineers) and
possible development of an innovative destruction technology
which would provide a comparable level of destruction to that
achieved by incineration. At the end of three years a
determination will be made whether the contaminated soils from
the two adjacent areas or other similarly contaminated areas
of the former Hastings Naval Ammunitions Depot will need to be
treated along with the subsite soils with a destruction
technology. However, no additional delay in the
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RECORD OP DECISION
DECISION SUMMARY
BASTINGS GROUND WATER CONTAMIHaTIOR
HASTINGS BAST INDUSTR~ PARK SUBSITE
BASTINGS, NEBRASKA
Prepared By:
u.s. Environmental Protection Agency,
Region VII
Kansas City, Kansas 66101
september 1990
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Section
I.
II.
III.
IV.
V.
VI.
VII.
VIII.
IX.
X.
XI.
XII.
Attachments
RECORD OF DECISION
DECISION SUMKARY
CONTENTS
LOCATION AND DESCRIPTION
.
HISTORY AND ENFORCEMENT ACTIVITIES
COMMUNITY PARTICIPATION ACTIVITIES
SCOPE AND ROLE OF SURFACE SOILS OPERABLE UNIT
SITE CHARACTERISTICS
SUMMARY OF SITE RISKS
SUMMARY OF ALTERNATIVES
EVALUATION OF ALTERNATIVES
SELECTED ALTERNATIVE
STATUTORY DETERMINATIONS
DOCUMENTATION OF SIGNIFICANT DIFFERENCES
REFERENCES
A:
DETAILED COSTS OF SELECTED REMEDY
B:
CONCURRENCE LETTER FROM THE
NEBRASKA DEPARTMENT OF ENVIRONMENTAL CONTROL
~
1
2
4
5
6
20
45
63
76
83
86 .
87
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DECISION SUMMARY
BASTINGS EAST INDUSTRIAL PARK SUBSITE
BASTINGS GROUND WATER CONTAMINATION
I. LOCATION ~ DESCRIPTION
The Hastings Ground Water contamination site is located in
south central Nebraska (Adams County) and consists of an aquifer
contaminated'with industrial chemicals. The locations of Adams
County and Hastings are shown by Figure 1. This site is divided
into several source areas referred to as "subsites". These
subsites are identified with various industrial chemicals which
may contribute (or have contributed in the past) to the area of
ground water contamination extending from beneath the city of
Hastings to the southeast. The Hastings East Industrial Park
(HEIP) subsite, approximately two miles east of Hastings, is
associated with a portion of the aquifer that is contaminated by
explosives, metals and volatile organics.
The subsite is located approximately one mile west of the
Adams County - Clay County line, in the western portion of the
former Hastings Naval Ammunitions Depot (NAD). Approximate
boundaries for the HElP subsite include u.s. Highway 6 on the
north and Maxon Gate Road on the east, as shown on Figure 2.
The subsite encompasses an approximately 2,600 acre portion
of the 3,600 acre Hastings East Industrial Park. The land
surface is relatively flat and generally slopes to the south-
southeast. Various ephemeral streams provide drainage for the
subsite. Surface water drainage from the HElP flows into the
drainage basins for the West Fork of the Big Blue River, Pawnee
Creek and Big Sandy Creek.
Although there are no managed wetlands on the site, the U.S.
Fish and wildlife Service maintains the Thessen Lagoon two miles
east of the site near Glenvil, and the McMurtrey Marsh six miles
east of the site. An analysis of U.S. Geological Survey
topographic maps reveals that neither of these areas are
connected to the site by surface water drainage (Figure 3, Final
RI Report, U.S. Army Corps of Engineers (USACE) 1990b). An
analysis of ground water flow from the site (Final Ground Water
Modeling Report, US ACE 1990c) indicated no ground water connection
between the site and these areas.
Another large, privately-owned wetland, Ayr Lake,
about two miles southwest of the site. It is also not
by surface drainage or ground water flow from the site
Report, USACE 1990b).
CUrrent land use at the subsite is predominantly
agricultural and light industrial. Prior to development of the
industrial park, the land was a portion of the former Hastings
is located
affected
(Final RI
1
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Haval Ammunition Depot (HAD). Most of the site and surrounding
area is cropland (69%) and grassland (22'). The types of crops
planted on and in the vicinity of the subsite include wheat,
corn, and grain sorghum. Another four percent is unused,
developed (as residential or industrial properties) or represents
surface water features. Eight residences and over 20 businesses
currently occupy or have recently occupied the subsite (figure
2). Central community College is located west of the subsite.
The college ~nd these industries and residences are supplied by
the Community & Municipal Services (CMS) public supply system
(the former HAD water distribution system) and private water
wells. The former HAD sewage treatment plant still serves the
area.
II.
HISTORY ~ BNPORCEMENT ACTIVITIES
The Hastings East Industrial Park (HEIP) was established on
a portion of the former HAD. The former HAD's primary mission
during periods of activity was to load, assemble and pack
conventional medium and major caliber ammunition and to provide
associated support functions (e.g. storage facilities). The HAD
was active between 1943 and 1966. Periods of peak production
occurred during World War II and the Korean Conflict. Prior to
1942, the area which comprised the HAD was used primarily for
agricultural purposes. From approximately mid-1942 to late 1945,
over 1,800 buildings, 270 miles of roads, 200 miles of railroad
tracKs, and an extensive network of utilities were constructed
for the HAD.
Several HAD production areas were located in the area
currently known as the HEIP subsite and include:
o
o
o
o
o
o
o
o
Rocket Motor Loading Area
40 mm Loading and Filling Area
Bag Charge Filling Plant
Major Caliber Projectile Loading Plant
Medium Caliber Projectile Loading Plant
Case OVerhaul and Tank Repair Facility
Case Filling Plant
20 mm Loading and Filling Area
Little specific information is presently available regarding the
. actual manufacturing procedures and waste management practices
during HAD operations. Facility wastewaters generated from
washdown operations of equipment, conveyors, etc., were
discharged through the floor drains and catch basins to man-made
ditches or unlined impoundments located adjacent to the
production buildings. Historical and topographic information
identify several trenches, pits, and burn areas that were used
for waste disposal during operations at the former NAD.
Accidental spills of raw materials, oil, gasoline, and solvents
2
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(although not documented) were likely during the active life of
the facility.
The NAD underwent decommissioning, reportedly including the
decontamination of production facilities, during the eight-year
period from about 1958 to 1966. Historical reports indicate that
decontamination activities for buildings included application of
decontamination chemicals and steam cleaning. In some instances,
building interiors were subjected to brief controlled burns using
fuel oil. Spme of the machinery contaminated with explosives
were decontaminated by dipping and washing with solvents or by
spraying the machinery with fuel oil and setting fire to it.
Characterization of potential contaminants discharged to the
environment through normal operations, accidental spills, and
decontamination activities at the former NAD has been based on
limited available facility records and review of general industry
practices during World War II and the Korean Conflict.
After final decommissioning in 1966, portions of the NAD
property were transferred to the Central Community College, the
U.S. Department of Agriculture, several military branches, and
the City of Hastings. The city immediately sold their property
to the businesses and industries which began the present Hastings
East Industrial Park. The CMS public supply system, composed of
the former NAD's water distribution system and supply wells,
serves the Hastings East Industrial Park.
In 1983, the Nebraska Department of Health (NDOH) and the
Nebraska Department of Environmental Control (NDEC) began
investigating the wide-spread ground water contamination in the
Hastings area as a result of citizen complaints of a foul odor
and taste in drinking water. The aquifer contamination led to
the decommissioning of several water supply wells by the City of
Hastings and the CMS system. The U.S. Environmental Protection
Agency (EPA) began to sample ground water wells on a quarterly
basis in 1985. Based on results of investigations by NDOH, NDEC
and EPA, the Hastings Ground Water contamination site was added
to the National Priorities List in 1986.
EPA began investigation of possible contamination at the
HElP subsite in 1986. On the basis of this investigation, EPA
and USACE have determined that the previous manufacture, use and
disposal of hazardous substances at the former NAD has given rise
to the actual release or threatened release of hazardous
substances, and that the actual or threatened release has
contaminated and/or could cause further contamination of soil,
ground water and surface water unless the release or threatened
release is abated. The USACE, on behalf of the Department of
Defense (DOD), entered into an interagency agreement (IAG) with
EPA in June of 1986 to effectuate the remedial action at the HEIP
subsite.
3
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Under the terms of the IAG, USACE agreed to undertake the
investigation of the HEIP subsite, address the potential
remedies, and implement the appropriate response action at the
HEIP subsite to protect public health and the environment. USACE
began the remedial investigation and development of remedial
alternatives for the HEIP in 1987. Results of USACE's studies
are available in the Final Remedial Investigation (RI) Report
(USACE, 1990b) and the Final Feasibility study (FS) Report
(USACE, 1990a). NDEC and EPA have conducted oversight activities
throughout t~e ongoing investigation as required by the
Comprehensive Environmental Response, Compensation and Liability
Act of 1980 (CERCLA), as amended. This record of decision (ROD)
is one result of this investigation.
If other potentially responsible parties are identified for
the site in the future, appropriate action will be taken.
Several of the past and present industries at the HEIP have been
involved with the manufacture of plastics, metal finishing,
production of agricultural equipment, and formulation of
chemicals for agricultural applications. Additionally, at least
one waste disposal area was developed and used at the Hastings
East Industrial Park since its creation.
III.
COMMUNITY PARTICIPATION ACTIVITIES
Community relations activities for the Hastings Ground Water
Contamination site were initiated by the EPA in 1984 with the
development of a Community Relations Plan. Since December 1984,
EPA has conducted meetings periodically with Hastings city
officials to update them regarding site work and findings. In
addition, technical review committee (TRC) meetings, attended by
representatives of the city of Hastings, Adams County, the Little
Blue Natural Resource District, NDEC, EPA and US ACE are held to
discuss investigations and potential response actions at the HEIP
subsite. The EPA Region VII, Office of Public Affairs in Kansas
City, Kansas and the USACE, Office of Public Affairs in both the
Kansas City District and Huntsville Division offices respond to
inquiries from news media and members of the public regarding the
site.
Several documents relative to the HEIP subsite have been
released to the public for review. The public comment draft of
the RI report was issued in February 1989. A public meeting was
held by USACE on July 31, 1989 to present the findings in the RI
report. The Final FS Report and Proposed Plan for this action
and Interim Final Baseline Risk Assessment (USACE, 1990d) were
submitted to the public during June of 1990. These documents
were made available in the administrative record and information
repositories maintained in several locations: Hastings, Nebraska
(Hastings Public Library, Central Community College Library,
Hastings College); the NDEC office in Lincoln, Nebraska; and EPA
regional office in Kansas City, Kansas. The notice of
4
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availability for these documents was published in the Hastings
Tribune on June 19, 1990.
A public comment period was held from June 19, 1990 through
July 20, 1990. In addition, a public meeting was held on June 28,
1990. At this meeting representatives of EPA, USACE and NDEC
answered questions regarding the problems at the HEIP subsite and
the remedial alternatives under consideration for the HEIP
surface soils operable unit. June 1990 fact sheets, prepared by
the EPA Region VII Office of Public Affairs for the HElP subsite
and the other Hastings Ground Water Contamination subsites, were
provided at the public meeting. A response to comments received
during this period is included in the Responsiveness Summary,
which is part of this ROD. This decision document presents the
selected remedial action for the surface soils operable unit at
the HEIP subsite in Hastings, Nebraska, chosen in accordance with
CERCLA, as amended by SARA and, to the extent practicable, within
the provisions of the NCP. The decision regarding the
appropriate remedial action for the contaminated surface soils at
this site is based on documents and information contained in the
administrative record.
IV.
SCOPE AND ROLE OF SURFACE SOILS OPERABLE UNIT
The problems at the Hastings Ground Water contamination Site
are complex due to the number of contamination sources, the
geographic distribution of the sources, the variety of
contaminants, and the large area of ground water contamination.
Due to this complexity, the site has been divided into subsites
based on potential sources of contamination. Investigations are
being undertaken at each of the subsites to identify and
characterize the areas of contamination and define any potential
public health threats posed by the various contaminant sources or
the contaminated ground water.
At the HEIP Subsite, three major types of contaminants,
explosives, polynuclear aromatic hydrocarbons (PARs) and metals,
exist in the surface soils (0-10 feet in depth) at levels of
potential public health concern. These contaminants present a
potential public health threat and some are among the
contaminants which have been detected in the ground water at the
subsite.
The surface soils remedial action presented in this ROD will
be the first HElP operabl~ unit (i.e. the first cleanup phase).
Only remediation of contaminated surface soils at the subsite
will be addressed in this action. EPA has elected to conduct the
surface soils remedial action as the first HElP subsite operable
unit in order to mitigate the principal threats posed by further
contaminant contribution from these soils to the ground water and
the potential public health threats posed by inadvertent
ingestion of or direct contact with contaminated soils.
5
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Sufficient information is available to select an appropriate
remedy for this problem.
One or more future RODs will address the remaining problems
at the site. Explosives, volatile organic compounds (VOCs), and
metals have been detected in the ground water at the subsite.
Remediation of the ground water, the second operable unit, will
be addressed upon completion of the ongoing subsite ground water
investigations. Another ROD may be necessary to address
contaminatioh of the vadose (unsaturated) zone between the
surface soils and the contaminated aquifer.
This action for the HElP subsite is consistent with the
cleanup strategy for the Hastings Ground Water Contamination
site. The phased (operable unit) approach is part of the overall
site strategy to address potential public health threats or
contaminant sources as soon as investigations of the individual
subsites have provided sufficient information upon which to
evaluate and select a cleanup option which will not be
inconsistent with subsequent operable units.
v.
SITE CHARACTERISTICS
This ROD addresses the principal threats at the HElP subsite
posed by the contaminated surface soils. These threats include
the potential health hazards associated with exposure to these
soils (these potential health hazards are discussed in detail in
Section VI) and the potential for the contaminated soils to ~ct
as a source of additional ground water contamination. Human
exposure to lead and high concentrations of TNT in the
contaminated soils is the principal health threat at the subsite.
Potential health threats due to the presence of carcinogenic PAR
compounds, lower concentrations of TNT, and the remaining metal
contaminants represent public health concerns of a lesser degree.
The potential health hazards associated with the individual
chemicals of concern are provided in greater detail below.
The extent of contamination in the HElP surface soils has
not been completely characterized. The contamination boundaries
(e.g., the lateral and vertical extent of the contamination) have
not been fully defined. The volumes and areas of contamination
discussed below, are calculated from the contamination boundaries
identified in the remedial investigation. These boundaries, and
subsequently the corresponding volumes and areas of contaminated
soils, will be better defined through additional soil sampling
during the remedial design phase of the remedial action.
The HElP surface soils, as mapped by the Soil Conservation
Service, belong to either the Crete, Hastings, or Holder Series.
Soil development typically extends 2-4 feet beneath ground
surface. The soils are generally found capping 30 - 65 feet
thick Pleistocene loessial deposits (windblown clayey-silt and
6
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silty-clay). The Hastings and Crete Series soils consist
primarily of silt loam. The Holder Series soils are generally
restricted to drainage areas and may consist of silt loam o~
silty clay loam.
The subsite is located in a region that is characterized by
a continental-type climate. The region typically experiences a
wide range in monthly and annual temperature extremes with short,
hot summers, cold winters, and uneven rainfall distribution
throughout the year. The average annual precipitation and
temperature 'for Hastings from 1932 to 1986 was 26.4 inches and
SO.S8F, respectively. Precipitation during the winter months.is
generally snow and during the summer is generally localized
thunderstorms. The prevailing wind direction is southerly in May
through October and north-northwesterly in November through
April. The average wind speed is about 12 miles per hour (mph).
A.
Natural and CUltural Resources
The following discussion is based on information provided by
the U. S. Fish and wildlife Service (Final Rl Report, USACE
1990b, and U.S. Fish and wildlife Service, 1987), telephone
conversations with the Nebraska state Historical Society,
Lincoln, Nebraska (Final Rl Report, USACE, 1990b) and
observations and data gathered during field activities and
investigations at the subsite. More detailed information is
provided in the Final Rl Report (USACE, 1990b). A field survey
of plant and animal species present at the subsite was not
conducted as part of the remedial investigation.
There are several small surface water bodies in the vicinity
of the former NAD production areas and several low-lying areas in
the natural drainages of the site. Several of these depressions
collect surface runoff during seasonal periods of precipitation.
All of the natural drainages of the site flow intermittently.
The aquifer of major importance to the regional area has been
termed the Pleistocene Aquifer. Ground water from this aquifer
is used for irrigation, industrial and municipal supplies, and
rural domestic and livestock uses.
There are no wetland areas within the boundaries of the
subsite. Two wetland areas located 3 to 5 miles east and
southeast of the site, Thessen and McMurtrey lagoons, are managed
as refuges by the U.S. Fish and wildlife Service. Another large,
privately-owned wetland, Ayr Lake, is located about two miles
southwest of the site.
The land of Adams and
farming. Farming is based
corn, and grain sorghum as
also important. There are
sites or structures within
Clay Counties is used extensively for
primarily on the growing of wheat,
cash crops; livestock production is
no known historic or archeological
the HElP subsite.
7
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Animal populations other than livestock in the vicinity of
the site include wildlife and fish populations. wildlife (e.g.,
deer, prairie dogs and songbirds) were commonly observed on site
during the site investigations. Because surface water bodies on
site are relatively shallow and contain water only seasonally,
fish populations are not believed to be significant on site.
However, the channel catfish and flathead catfish are listed as
key species for the segment of the Little Blue River into which
Pawnee Creek drains. This implies the presence of significant
populations of these species far downstream of the site.
.
The black-footed ferret (Mustela niariDes) and five species
of birds are listed by the Fish and Wildlife Service (Fish and
Wildlife Service, 1988) as threatened or endangered wildlife
species and may occur in the vicinity of the site. The presence
of prairie dogs on the subsite may indicate suitable habitat for
the black-footed ferret. No endangered plant species are present
in the vicinity of the NAD.
B.
Volumes and Areas of contaminated Soils
The total volume of contaminated surface soil to
up is approximately 125,900 cubic yards. This volume
divided into the soil subgroups based on the type of
contamination as follows:
Type ot contamination
be cleaned
can be
Volume
(cubic yards)
TNT and total PAHs
Metals
TNT, total PAHs, and metals
64,800
39,000
22,100
The total surface area of contaminated soils is approximately 14
acres of the 2,600 acre subsite. Estimates of volumes and areas
will be better defined during remedial design. Additional
information on the above estimates can be found in Appendix H of
the FS report (USACE, 1990a).
C.
Concentrations and properties ot Subsite contaminants
Sampling and analysis of surface soils have revealed the
presence of detectable levels of explosives, volatile organic
compounds (VOCs), semi-volatile organic compounds (PAHs), and
metals at the HEIP subsite. Soil borings were drilled to depths
of 10 feet below ground surface at various locations across the
subsite. Samples were obtained at the 0-2, 3-5, and 8-10 foot
intervals (measured from ground surface) within these borings.
Contaminant concentrations generally decrease with depth.
Samples from the 8-10 foot interval were only analyzed for
explosives. A summary of the contaminants detected in the upper
five feet of surface soil is provided below and in Tables V-1
through V-4. Further information is available on the
8
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characteristics of subsite contaminants and their potential
health effects in the RI report (USACE, 1990b).
Concentrations of organics and explosives detected in the
subsite's surface waters were found at levels which do not
present an unacceptable threat to public health or the
environment. Discussion of the analysis of metals in surface
water samples is included with the discussion of the surface
soil's metal contaminants.
1.
Explosive compounds
Several explosive compounds were detected in soil samples
(Table V-1). Trinitrotoluene (TNT) was the most prevalent
compound detected at the subsite. The highest concentration of
TNT detected in the soil samples was 9,700 milligrams per
kilogram (mg/kg). Tetryl, HMX, RDX, 2,4-dinitrotoluene (2,4-
DNT), and 2,6-dinitrotoluene (2,6-DNT) were also detected at
several locations. Tetracene, PETN, lead styphnate, and picric
acid were detected in only a few soil samples. In general, the
highest concentrations and most frequent detections of explosive
compounds were in the shallow soils (0-2 foot depth). Decreasing
concentrations and detections were experienced with increasing
depths. Only TNT (3.16 mg/kg) was detected in the 8 - 10 foot
sampling. interval.
Explosive compounds are not typical contaminants at
hazardous waste sites. The existing body of knowledge regarding
the physical, chemical and toxicological properties and the fate
and transport of explosive compounds in the environment is
somewhat limited. The following summarizes the physical
properties and processes expected to be of the greatest
significance to the persistence of explosives in the subsite
soils. The Final RI Report (USACE, 1990b) provides greater
detail on the available information regarding the physical
properties and environmental fate and transport of explosives.
Photolysis1 is believed to be an important process in the
breakdown or removal of TNT, RDX, 2,4-DNT and 2,6-DNT from
surface soils. Available information suggests that
biodegradation processes are al~o important to the breakdown of
TNT. The relative solubilities in water of TNT, RDX, and 2,4-
DNT are low. No data was found in the available literature on
the solubility of 2,6-DNT. Low solubility in water is one factor
affecting the ability of the surface soils to retain the
explosive contaminants. Low solubility implies that the
--------------------
1. Photolysis - chemical decomposition induced by radiant
energy, especially light.
2. Solubility - a measure of the amount of a particular
substance that will dissolve- in a particular solvent.
9
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chemicals are less easily dissolved and removed by waters passing
through the surface soils. The available dfta suggest that
volatilization (evaporation) and sorptivity of 2,4-DNT and 2,6-
DNT may also be significant factors affecting the retention of
these explosives in the subsite soils. The exact mechanism by
which the explosive compounds have migrated from the surface
soils to the ground water at the subsite is unknown at this time.
TNT is a possible human ~arcinogen which may cause liver
cancer, 1euk~mia, or lymphoma. Noncarcinogenic effects o~
exposure to TNT may result in hepatitis or aplastic anemia.
The explosives 2,4-DNT and 2,6-DNT are probable human carcinogens
which have been found to cause liver cancer and the development
of benign skin and breast tumors in laboratory animals.
Potential noncarcinogenic health effects of exposure to ihese
exp10s~ves include testicular injuries, aspermatogenesis ,
anemia and liver injury.
No data documenting the toxicity of explosives to
terrestrial wildlife was discussed in the available literature.
However, the toxic effects to wild terrestrial mammals may be
similar to the effects on laboratory animals discussed above.
Susceptibility to the toxic effects of TNT in particular, varies
considerably among species and among individual members of the
same species. In general, cats, dogs and humans are more
sensitive than rabbits and rats.
The potential noncarcinogenic effects resulting from human
exposure to surface soils contaminated with high concentrations
of TNT represent one of the principal potential public health
threats addressed by the remedy. Surface soils with lower
--------------------
1. Sorptivity - a measure of the ability of a chemical to adsorb
to a particulate matter (i.e. soil), thereby being removed from
solution.
2. Lymphoma - a malignant, cancerous tumor of the lymphoid
tissue (e.g. lymph nodes, spleen, thymus, tonsils) characterized
by the proliferation or accumulation of cells native to lymphoid
tissues.
3. Aplastic Anemia - anemia caused by a suppression of bone
marrow function resulting in a reduced synthesis of red blood
cells and hemoglobin.
4. Aspermatogenesis - a condition marked by the inability to
produce sperm.
5. Anemia - a blood disorder marked by a significant decrease in
the concentration of red blood cells and hemoglobin (the oxygen
carrying components).
10
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concentrations of TNT and other explosives, presenting a public
health threat of a lower magnitude, are also addressed by the
remedy. "
2.
Metals
Five metals were detected in the shallow soils at levels of
potential health concerns and at concentrations exceeding the
background levels (the naturally occurring level) established for
the site. Tpose metals are arsenic, barium, chromium, cadmium,
and lead (Table V-2). The highest concentrations detected for
these metals were 22 mg/kq, 1,000 mg/kg, 10,600 mg/kg, 167 mg/kg
and 6,730 mg/kg, respectively.
Background levels for metals in surface water are difficult
to determine for the site. Analysis of surface water samples
indicated higher levels of magnesium, calcium, and sodium than
the range expected based on regional surface water quality data
for the Big Blue River and the Little Blue River. Concentrations
of beryllium, cadmium, mercury, nickel, selenium, silver, and
thallium were below laboratory detection limits.
Significant processes which may influence the persistence of
metals in the surface soils include:
. Adsorption/Desorption - Adsorption is the attraction
(adhesion) of chemical ions or molecules to the soil surface or
soil solids. Adsorption is a reversible process (desorption)
which causes an increase in the pollutant concentration on the
soil surface over the concentration present in the soil moisture;
Hydrolysis - the chemical transformation process in which a
chemical compound reacts with water to form one or more new
compounds. Hydrolysis is an important process with respect to
arsenic, cadmium and lead;
. Oxidation/reduction reactions - chemical reactions in
one or more electrons are transferred from one molecule to
another. Oxidation reactions are of particular importance
presence of arsenic, barium and chromium;
which
to the
. Precipitation of metals with hydroxides, carbonates and
sulfides in the soils may be a significant factor in the
persistence of chromium and lead;
. uptake of metals by plants and bioaccumulation in plant
tissues. Lead, barium and cadmium are known to be taken up by
plants.
The persistence of metals in the HElP surface soils contributes
to the magnitude of the principal health threat posed by the
presence of these contaminants.
11
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The potential health effects of exposure to these metals may
result in a variety of both carcinogenic and noncarcinogenic
health effects. Arsenic is knowp to produce both lung and skin
cancer in humans. It also causes ~oncarcinogenic health effects
including skin lesions, neuropathy and gastrointestinal
irritation. No carcinogenic effects are known for barium.
However, hypertension, loss of weight and impaired liver function
are possible noncarcinogenic health effects. Cadmium is a
probable carcinogen which may produce lung cancer in those
exposed through inhalation. The primary noncarcinogenic effect
of cadmium is damage to kidneys. Exposure to chromium may result
in lung cancer and irritation or atrophy of the nasal membranes.
Lead has a number of toxic effects if ingested in significant
quantities. These effects include central nervous system
impairment (especially in children), anemia, brain and kidney
damage, and hypertension. Young children, pregnant women and the
elderly are especially at risk from exposure to lead. Lead is
also a possible human carcinogen and may cause tumor development
in kidneys.
Depending on soil composition, some inhibition of plant
growth is expected in soils containing 1,000 to 10,000 mgjkg of
lead. 50i1 microorganisms are also sensitive to lead, and
changes in bacterial populations may be an early indicator of
lead effects on soil ecosystems.
Lead poisoning has been reported in many species of domestic
animals and lead has been found in the tissues of many wildlife
species. Most reports of lead poisoning in wildlife are in water
fowl. Ar~enic poisoqing in domestic animals is associated wi~h
hyperemia and edema of the gastrointestinal tract, lung
congestion and edema, hemorrhaging of abdominal cavity membranes
and of the heart, and sometimes liver necrosis. No data on the
toxicity of arsenic, cadmium, barium, or chromium to terrestrial
wildlife were discussed in the available literature. However,
the toxic effects to wild terrestrial animals resulting from
exposure to these metals, or exposure to lead, may be similar to
the effects on laboratory animals and, in the case of arsenic, to
the effects on domestic animals described above.
--------------------
1.
Neuropathy - any disease of the kidney.
Hyperemia - an abnormally large blood supply.
2.
3. Edema - presence of abnormally large amounts of fluid in the
intercellular spaces of body tissues.
4. Necrosis - the death of one or more cells or a portion of a
tissue or organ, resulting from irreversible damage.
12
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Inadvertent exposure of sensitive populations (i.e.,
children, pregnant women and the elderly) to the lead '
contaminated surface soils is one of the principal potential
health threats at the subsite. The presence of other metal
contaminants in the subsite soils also represents potential
public health concerns. The remedy addresses all of these
concerns. .
3.
Semi-Volatile orqanic Compounds
Of the semi-volatile organic compounds detected in the
surface soils, the majority belong to a group of compounds
referred to as polynuclear aromatic hydrocarbons (PAHs) (Table V-
3). The highest reported concentration of total PAHs was 163
mg/kg. The PAHs were detected primarily in the shallow soils (0-
2 foot depth).
Sorption to soil and sediments is an important factor in the
persistence of PAHs in soils. The molecular weights of the
detected PAHs are relatively high. These semi-volatiles with
higher molecular weights are less likely to volatilize.
Degradation of PAH compounds by soil microbes can be a major
factor in breaking down the PAH compounds present in the soils.
Aside from a limited potential for adverse skin reactions
following direct contact with high concentrations, there are no
reports of PAH-related noncarcinogenic health effects in humans.
However, there is substantial evidence from animal and human
studies that several PAH compounds are carcinogenic. Exposure to
PAHs may result in the development of lung, stomach and skin
cancers. Only seven of the PAH compounds detected at the subsite
are considered probable or possible human carcinogens (denoted by
"*" in Table V-3).
No
located
of PAHs
effects
data on the toxicity of PAHs to terrestrial wildlife were
in the available literature. However, the toxic effects
to wild terrestrial animals may be comparable to the
on laboratory animals.
The presence of the PAH compounds considered probable or
possible human carcinogens is a potential health concern at the
subsite. A conservative approach which assumed all PAH
carcinogenic potency to be equal to that of benzo(a)pyrene was
used to estimate the potential carcinogenic risk due to exposure
to these compounds in the Baseline Risk Assessment (Appendix D,
Final RI Report, USACE, 1990b). Other carcinogenic PAHs are
generally considered to be no more potent than benzo(a)pyrene
(and some may be less potent). As a result of this conservatism,
--------------------
1. Molecular Weight - the sum of the atomic weights making up
the molecule of the chemical compounds in question.
13
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the estimated potential carcinogenic risks for the PAH compounds
are likely to be overestimated for the subsite. However, the
estimated potential risks are addressed by the remedy.
4.
Volatile orqanic compounds (VOCs)
Ten VOCs were detected in the upper 5 feet of soil at very
low concentrations [less than 50 micrograms per kilogram (ugjkg)
(Table V-4)]. Compounds detected include chloroform, benzene,
toluene, tet~ach10roethene, trich10roethene, methyl ethyl ketone,
acetone, xylene, ethy1benzene, and methylene chloride. None of
the VOCs detected in soil were found in more than 2 percent of
the samples analyzed except chloroform which was found in
approximately 17 percent of the soil samples.
Several of the detected volatiles are probable human
carcinogens which have been shown to cause liver cancer, lung
cancer or lymphoma in laboratory animals. Noncarcinogenic health
effects from exposure to these volatiles may cause depression of
the central nervous system and damage to the liver and kidneys.
These volatiles, however, were not detected in surface soils at
levels of potential health concern.
The concentrations of VOCs detected in the surface soils
were very low. However, concentrations of VOCs in excess of the
established primary drinking water standards have been detected
in the ground water at the subsite. Drinking water standards
have been developed for the protection of public health.
Exceedance of these levels is a cause for potential concern.
Further investigations are necessary to determine if significant
quantities of VOCs are also present in the unsaturated zone
between the water table (approximately 120 feet below the ground
surface) and the surface soils (0-10 feet below ground surface).
These investigations will be conducted as part of the ground
water operable unit for the HEIP subsite. The potential public
health threats attributable to the presence of VOCs in the ground
water and vadose zone will be addressed in the ground water
operable unit ROD(s).
14
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Table V - 1
Bxplosive Compounds
Chemical Data summary
Freq. Min. Max Mean
ComDound Detec. Conc. Conc. Conc.
Surface Soil (0-2 ft.)
HMX 7/117 0.1 2.1 0.8
RDX 5/117 0.43 5.2 17.0
Tetryl 6/117 0.1 27.0 0.99
TNT 28/118 0.1 9700.0 610.0
2,6-DNT 8/117 0.2 14.0 3.8
2,4-DNT 7/117 0.22 17.0 8.5
Petn 2/117 4.1 30.0 17.0
Tetracene 4/117 1.3 5.2 3.2
Lead Styphnate 1/117 1.2
Picric Acid 2/117 1.3 230.0 110.0
Near Surface soil (3-5 ft.)
HMX 4/69 0.1 .36 0.2
RDX 5/69 0.5 2.3 6.8
Tetryl 3/69 0.1 1.1 0.44
TNT 16/69 0.1 200.0 36.0
2,6-DNT 3/69 0.63 3.3 1.7
2,4-DNT 7/69 0.3 5.3
Picric Acid 1/69 770.0
Surface Water
HMX 1/13 .0012
FDX 2/13 .0002 .0043 .0023
Nitroglycerin 2/13 .02 .18 0.1
Picric Acid 0/13 .001
IIOTES
- Concentrations are expressed in ~/k; for 80il and ~/l for water.
- DaU presented in these tables are fran the 1987 and 1988 field investigation. Refer to ~ix I of
the Final RI Report (USACE, 1990b) for detailed analytical su.maries.
- The frequency of detection is reported a, All where A represents the number of samples where the compound
was detected; I represenu the toul !'UlCer of samples analyzed with field ~licates at indivio.;al
sampl in; locations considered 8S one sample.
15
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Arsenic
Barium
Chromium
Lead
Table V - 2
Selected Xetala
Chemical Data SWlUliary
Freq. Min. Max. Mean
Metal Detec. Cone. Cone. Cone.
Surface Soil (0-2 ft.)
Arsenic (Ag) 86/119 2.0 22.0 5.4
Barium (Ba) 86/119 110.0 3500.0 330.0
Cadmium (Cd) 21/119 .86 170.0 7.7
Chromium (Cr) 86/119 7.0 11000.0 430.0
Lead (Pb) 86/119 10.0 6700.0 170.0
Selenium (Se) 9/119 16.0 16.0 3.0
Near Surface Soi1 (3-5 ft.)
Arsenic 66/74 1.7 20.0 5.2
Barium 66/74 140.0 640.0 240.0
Cadmium 1/74 28.0
Chromium 66/74 7.8 1100.0 30.0
Lead 66/74 3.3 75.0 18.0
Selenium 1/74 .53
Surface Water
11/11 .0013 .013 .0059
11/11 .059 .33 .17
3/11 .0080 .014 .0076
11/11 .0023 .013 .0073
NOTES
- Concentrlti~ 8re expressed in -U/kg for soil end 88/l for wlter.
- D8U presented in these table. are from the 1987 and 1988 field investig8tion. Refer to Appendix I of
the Finel RI Report (USACE, 19900) for det8iled analytic8l au.meries.
- The freq.lenCY of detection i. reported 8. All where A represents the r&JIt)er of .~le. where the cOft1:IO\I'd
was detected; 8 represents the total rulber of Hllples analyzed with field ~l icates at individual
.~l ine locati0n5 c0n5idered a. one Nlllple.
16
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Table V - 3
Semi-Volatile orqanic Compounds
Chemical Data Summary
Freq. Min. Max. Mean
ComDound Detec. Cone. Cone. Cone.
Surface soil (0-2 ft.)
Acenaphthene 7/109 .041 4.8 .87
Acenaphthylene 1/109 .32
Anthracene 10/109 .046 6.3 .91
*Benzo (a) Anthracene 24/109 .041 11.0 .97
Benzo(ghi)Perylene 16/109 .049 4.4 .78
*Benzo(a) Pyrene 22/109 ,.047 8.1 .9
*Benzo(b) Fluoranthene 31/109 .051 16.0 1.4
*Benzo(k) Fluoranthene 31/109 .051 17.0 1.5
Benzoic Acid 6/109 .054 .25 .13
Bis(2-Ethylexyl)
Phthalate 45/109 .039 3.1 .39
*Chrysene 30/109 .045 12.0 .88
*Dibenz(a,h) Anthracene 6/109 .047 2.0 .47
Dibenzofuran 4/109 .15 2.8 .88
Di-n-Butylphthalate 9/109 .041 .25 .13
Diethylphthalate 1/109 .073
Di-n-Octylphthalate 1/109 .092
Fluoranthene 36/109 .037 22.0 1.5
Fluorene 6/109 .044 4.2 8.8
*Indeno(123-cd) Pyrene 16/109 .041 4.4 .74
2-Methylnaphthalene 2/109 .12 .55 .34
Naphthalene 4/109 .15 2.7 .89
4-Nitrophenol 1/109 .1
Pentachlorophenol 4/109 .070 .11 .08
Phenanthrene 25/109 .041 28.0 2.0
PCB 1254 1/109 .18
Pyrene 36/109 .043 20.0 1.4
2,4-Dinitrophenol 1/109 .35
Near Surface Soil (3-5 ft.)
Acenaphthene 1/66 .23
Anthracene 2/66 .053 .6 .33
*Benzo (a) Anthracene 3/66 .15 3.0 1.1
Benzo(ghi)Perylene 1/66 1.5
*Benzo(a) Pyrene 3/66 .090 2.3 .85
*Benzo(b) Fluoranthene 4/66 .16 4.8 1.4
*Benzo(k) Fluoranthene 4/66 .16 4.8 1.4
Benzoic Acid 1/66 .051
Bis(2-Ethylexyl)
Phthalate 10/66 .041 .46 .14
*Chrysene 4/66 .1 2.9 .84
*Dibenz(a,h)Anthracene 1/66 3.7
17
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Table V - 3 (eont . )
Freq. Min. Max. Mean
ComDound Detee. Cone. Cone. Cone.
Near Surface Soil (3-5 ft.) - continued
Dibenzofuran 1/66 .095
Di-n-Butylphthalate 1/66 .37
Fluorene 1/66 .086
Fluoranthene 4/66 .12 6.2 1.7
*Indeno(123-ed) Pyrene 2/66 .065 1.4 .73
2-Methylnaphthalene 1/66 .27
Naphthalene 1/66 .045
4-Nitrophenol 1/66 .11
Phenanthrene 4/66 .085 3.5 1.0
PCB 1248 1/66 .097
Pyrene 4/66 .12 5.5 1.6
Surface Water
Bis(2-Ethylexyl)
Phthalate 4/11 .003 .0054 .0039
* . Polynucleer Aromatic Hydrocerbons (PAHs) which ere considered probable or possible human cercinogens.
These PAHs were grouped es en indicetor chemicel for the baseline risk assessment.
NOTES
- Concentretions ere expressed in mg/kg for soil end mg/l for weter.
- Dete presented in these tables ere from the 1987 end 1988 field investigetion.
the Finel RI Report (USACE, 1990b) for deteiled enelyticel summaries.
Refer to Appendix B of
- The frequency of detection is reported es AlB where A repres.entl the nurtler of .~les where the c~
wes detected; B represents the totel nurtler of samples analyzed with field duplicetes et individual
sampl in; locetions considered es one s~le.
18
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Table V - 4
"\
Volatile orqanic Compounds
Chemical Data Summary
Freq. Min. Max. Mean
ComDound Detee. ~one. Cone. Cone.
Surface Soi1 (0-2 ft.)
Benzene 2/93 .0011 .0025 .0018
2-Butanone 1/93 .007
Chloroform 10/93 .0014 .004 .0025
Ethylbenzene 1/93 .29
Tetrachloroethene 1/93 .026
Toluene 1/93 .0050
Trichloroethene (TCE) 3/93 .0012 .0029 .002
Near Surface Soil (3-5 ft.)
Benzene 2/52 .0017 .0021 .0019
2-Butanone 1/52 .016
Chloroform 13/52 .0012 .0059 .0029
Ethylbenzene 1/52 .046
Toluene 2/52 .0024 .0091 .006
Xylenes (total) 1/52 .0027
NOTES
- Concentrations are expressed in ~/kg for soil and ~/l for ~ater.
- No .etals ~re detected in the lurface water samples.
- Data presented in these tables ..re from the 1987 and 1988 field investigation.
the final RI Report (USACE, 1990b) for detilled analyticil 8Uln8rles.
Refer to Appendix B of
- The fr~y of detection is reported as A/B where A represenu the rureer of lemples where the c~
was detected; B represents the total rureer of 18q)les analyzed with field ISAplicates at fndiviul
lampl in; locations considered as one semple.
19
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VI.
SUMMARY OF ~ RISKS
The baseline risk assessment conducted for the HEIP subsite
was based on the guidance and requirements set forth in the EPA
Superfund Public Health Evaluation Manual (SPHEM) (EPA, 1986).
The procedures followed during the baseline risk assessment are
summarized in this section. The primary purpose of the baseline
risk assessment was to evaluate the potential human health risks
at the subsite for each of the contaminated media including
ground water and soils. A limited ecological assessment of
potential environmental concerns was also conducted. The
complete baseline risk assessment is provided in Appendix D of
the Final RI Report (USACE, 1990b).
The potential excess cancer risks which exceed the
protective range and the potential noncarcinogenic health
hazards present a current or potential threat to public health.
Nearly all of the health hazards associated with the surface soil
are attributable to TNT contamination.
A.
INDICATOR CHEMICALS
The first step in the baseline risk assessment was selection
of indicator chemicals. Indicator chemicals are representative
of the chemicals possessing the greatest potential for health
risks at a site in terms of physical, chemical and toxicological
properties, concentrations, and distribution. Selecting
indicator chemicals insures that the health evaluation is focused
on the chemicals of greatest concern. The rest of the baseline
risk assessment process evaluates only those chemicals selected
as indicator chemicals for a site. While the indicator chemicals
represent only a subset of all of the chemicals present at the
subsite, evaluation of these chemicals in the baseline risk
assessment process accounts for the majority of the risk of
adverse health effects posed by the site contaminants.
The selection of indicator chemicals for the HEIP subsite
was based on SPHEM procedures and. guidance (EPA, 1986). The
SPHEM sets forth procedures for ranking site contaminants based
on toxicity constants, assigned media-specifically (e.g., soil,
water, etc.), to the toxicity and potential carcinogenicity of
each site contaminant and the detected concentrations of these
contaminants in each media. A media-specific concentration times
toxicity (CT) score is calculated for each contaminant. These
scores are added up across media to yield indicator chemical
scores for potential carcinoqens and noncarcinoqens.
Indicator chemical scores are ranked, and the chemicals
having the highest potential carcinogen and noncarcinoqen
indicator scores are selected as indicator chemicals for the
site. The indicator score is an index of the relative
contribution of a chemical in terms of its concentration in
environmental media and inherent toxicity, to the total health
risk posed by a site to the public. Therefore, the chemicals
20
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with the highest indicator score values are selected because they
present the greatest overall contribution to potential risk at
the site.
The available EPA contaminant-specific toxicity constants
for the HElP subsite contaminants were used in the selection of
indicator chemicals. No air sampling data were available for the
subsite, so contaminants were not scored as indicator chemicals
for exposure through inhalation. Where EPA toxicity constants
were unavailable for compounds of potential significance to the
subsite in terms of their occurrence (TNT and RDX) , appropriate
toxicity constants were derived using EPA procedures. The
arithmetic average concentrations of contaminants in ground
water, surface water, soil and sediment samples were used to
calculate indicator scores for chemicals which were present in
two or more samples.
The eleven indicator chemicals selected for the HElP subsite
include:
o
Metals:
arsenic, barium, cadmium, chromium, and lead.
o
Organic compounds:
trichloroethene, tetrachloroethene,
and total carcinogenic PAHs.
o
Explosive compounds:
2,4-DNT, 2,6-DNT, and TNT.
The baseline risk assessment evaluated both the contaminated
soil and ground water media with respect to the chosen indicator
chemicals in order to estimate an overall baseline risk for the
current and future conditions at the HElP subsite. However, this
surface soils ROD only addresses the cleanup of metals, explosive
compounds, and total carcinogenic PAHs in the contaminated
surface soils. These indicator chemicals are present in
significant quantities in the surface soils and were determined
to be the chemicals of concern in the surface soils. Several of
these chemicals have both carcinogenic and noncarcinogenic
adverse health effects (see previous discussion, Section V) and
have been evaluated for both.
B.
EXPOSURE ASSESSMENT
The baseline risk assessment next evaluated the factors at
the subsite which could contribute to potential human health
risks. These factors include exposure pathways (routes by which
humans come into contact with contaminants), the populations that
may be exposed to contaminants (human receptors), areas where
potential exposure pathways link contaminant sources to potential
human receptors (exposure points), and the frequency and duration
of potential receptor exposures. These factors were evaluated
during the risk characterization stage to identify the potential
noncarcinogenic health hazards and carcinogenic risks for both
current and projected future uses of the site (primarily
agricultural and industrial).
21
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1.
Exposure Pathways:
Three exposure pathways were evaluated to assess the degree
of potential exposure for populations on the subsite. These
exposure pathways include:
o
Incidental ingestion of the contaminated soils.
Dermal contact with the contaminated soils.
o
o
Ingestion of the contaminated ground water.
The significance of exposure to contaminants through the
inhalation of air containing volatilized (gaseous) organics or
fugitive dust emissions cannot be evaluated quantitatively due to
the lack of data on emission rates and air quality at the
subsite. It is reasonable to assume that exposures to air
releases from the site are potentially greater to on-site
receptor populations than to off-site populations due to the
source and release proximity. A number of factors are likely to
mitigate or minimize inhalation exposures, including degradation
of contaminants and dispersion into the atmosphere at increasing
distances from the point of release. Inhalation exposures and
their significance at the HEIP subsite are discussed
qualitatively in the following paragraphs.
It is acknowledged that inhalation of fugitive dust can be
an important pathway at sites with contaminated surface soils.
However, this potential exposure pathway is not believed to be of
concern at the HEIP subsite because of the low potential for
fugitive dust emissions from areas of contaminated surface soil.
Most of the contaminated surface soil consists of scattered,
noncontiguous areas primarily in drainage ditches, low-lying
areas and former impoundments associated with activities of the
former NAD. site observations indicate that these low-lying
features are moderately to heavily vegetated. Collectively,
these areas comprise only two percent (54 acres) of the 2,600
acre sub site. These factors (topography and vegetative cover)
and seasonal climate conditions (precipitation and frozen ground)
tend to preclude the generation of fugitive dust. Also, areas at
the subsite that have the greatest potential to emit airborne
particles (e.g., roads, unpaved parking lots, and cultivated
farmland), are generally not associated with the areas of known
contamination.
Inhalation exposures associated with irrigation releases
might be significant at the immediate location where water is
used, but are not expected to be significant elsewhere because of
the seasonal nature of irrigation water use and the potential for
high dilution in the atmosphere. As a supplement to the baseline
risk assessment, the potential health hazards resulting from
inhalation of volatilized irrigation water contaminated with VOCs
were quantitatively analyzed at a screening level. The results
of this analysis are discussed in the Risk Characterization
portion of this section.
22
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2. Receptor populations:
sixteen adults and five children are known residents of the
HEIP; 350 to 400 additional off-site residents are employed on
the subsite; and both on- and off-site residents are among the
agricultural workers on the subsite. All of these populations
could potentially be adversely affected by the contaminated
surface soils. As a result, potential public health risks at the
subsite were evaluated for five different populations which could
come into contact with contaminants on a daily basis. These
populations include:
o
Resident/Agricultural Worker - a person who lives and
farms on the HEIP subsite for his/her entire lifetime.
Adult Resident - a person who lives on the HEIP subsite
for his/her adult years.
o
o
Child Resident - a child who lives on the HEIP subsite
for his/her childhood years only.
o
Resident/Industrial Worker - a person who lives on the
HEIP subsite and works in a business also located on
the subsite for his/her entire lifetime.
o
Industrial worker - A person who works in a business
located on the HEIP subsite but lives elsewhere.
3. Exposure Point Concentrations:
Exposure points are those areas on-site or off-site where
exposure pathways link contaminant sources to potential receptor
populations. On-site, these potentially include all areas where
contamination occurs. Off-site exposure points are located
downwind, down gradient or downstream of the site. Because of
the size of the HEIP subsite and the diversity of activities at
the subsite, numerous exposure points are likely to exist, some
more significant than others. Specific receptor populations and
exposure points at the subsite were initially identified based
primarily on the distribution of indicator chemicals in soil and
sediment. Using this approach, the site was divided into four
regions containing different exposed populations and pathways.
These four regions (exposure points) are designated as the
Northeast, Southeast, Northwest, and Southwest exposure areas.
For each exposure point, an exposure point concentration
must be identified for use in the quantitative risk assessment
process. Best estimates (arithmetic average) and upper bound
estimates (a statistical measurement of the upper 95% confidence
limit) of the exposure point concentrations were calculated
media-specifically for each of the indicator chemicals at the
HEIP subsite.
23
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Exposure point concentrations for the HEIP surface soils
were based on samples collected in exposure point areas described
above. Most receptor populations in the four areas of the site
currently are exposed to ground water through the CMS Well 119
water supply system. Sample results from the CMS Well '19
drinking water system were used to characterize indicator
chemical exposure point concentrations for current drinking water
supplies. In order to evaluate ground water contamination at the
site, a hypothetical future water supply located in the vicinity
of the inactive CMS Well '20, an area of known ground water
contamination, was evaluated as an potential source for ground
water exposure. Characterization of the hypothetical future
drinking water supply exposure point concentrations in the
vicinity of inactive CMS Well '20 was based on sampling results
from CMS '20 and nearby monitoring wells. It should be noted
that CMS Well 120 is an inactive water supply well and is not
presently used as a source of drinking water.
4.
Estimation of Chemical Intake
Indicator chemical-specific average daily chemical intakes
were calculated for the different exposure pathways for use in
the quantitative risk characterization. The basic equation used
to calculate chemical intake of chemical "X" in medium "M" (e.g.,
water~ soil, etc.) is:
DI = C x HIF
where:
DI = Daily Intake (mg of chemical X
C = Concentration of chemical X in
HIF = Human Intake Factor, expressed
body weight per day)
This basic equation is used to calculate daily intake for
three exposure durations: subchronic (10- to 90-day exposure),
chronic (90 days to several years of exposure) and lifetime
(exposure over a 70-year lifespan).
per kg body weight per d~y)
medium M (mg of X/unit of M)
as units of medium per kg
The value of the HIF depends upon the specific exposure
scenario being evaluated. Individual HIF values are required for
each exposed population, for each medium, for each route of
exposure and for each exposure location. Each HIF value must be
adjusted to account for physiological variables (body weight,
breathing rate, skin area, etc.) and activity-dependent
parameters (frequency and duration of exposures). For dermal
exposures, chemical specific properties are also required.
24
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In general, most HIF terms are comprised of three types of
terms:
.
A body weight term.
.~
A contact rate term that
medium by a person on a day
example, this term might be
of air breathed per day, or
describes the amount of intake of a
when exposure has occurred. For
2 L of water ingested per day, 10 m3
100 mg of soil swallowed per day.
. A unitles~ Time Correction Factor (TCF) to account for the
fact that exposure may not occur on every day within the time.
interval of interest (i.e., the time periods for subchronic,
chronic and lifetime exposures). For example, a person exposed
five days/week would have a subchronic TCF of 5/7. If exposure
were six months/year, an additional correction of 6/12 would be
used in the chronic TCF. If exposure were 30 years out of a
lifetime, a factor of 30/70 would be used in the lifetime TCF.
If exposure is continuous over an exposure period, the TCF is
1.0.
Evaluation of the exposure to soils and sediments through
ingestion requires an additional factor, the bioavailability
factor (BAF). When chemicals are adsorbed to matrices such as
soil or sediment, absorption of the chemicals in the body may be
reduced. This is accounted for by use of a BAF, which is the
ratio of the amount absorbed from the matrix compared to the
amount absorbed when not bound to the matrix. A value of 1.0
signifies that the matrix does not reduce absorption, while a
value of less than 1.0 signifies a reduced absorption efficiency
(i.e., less absorption of the chemical in the body). The BAF
value is highly chemical-specific and also depends on the
physical-chemical properties of the matrix. In the absence of
site-specific data, it has been conservatively assumed that the
BAF is 1.0 for all indicator chemicals.
Dermal contact with soils and sediments also requires
evaluation of additional factors: the area of skin exposed (a
function of the total body surface area and the' fraction of total
body surface area exposed), the soil adherence factor (SAF) and
the dermal adsorption factor (DAF) for chemicals bound to soil.
The exposed skin area is determined from estimates of the total
skin surface area of an individual's body multiplied by
assumptions of the percentage of skin exposed (e.g., exposure of
just the hands vs. exposure of the arms ~ the hands). The soil
adherence factor (SAF) is a measure of the how much of the soil
matrix adheres or sticks to the exposed skin surfaces. Data on
SAFs is very limited. cgmmercial potting soil adheres to hands
at a l~vel of 1.45 x 10- kilograms per square centimeter
(kg/em). In ab~ence of better information, an assumed value of
2.0 x 10-6 kg/cm is used as representative for dermal adherence
of soil and sediment to skin. The dermal absorption factor (DAF)
is a chemical specific value. Available data describing DAF
values are limited. In general, metals have very low dermal
absorption.
25
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The estimates or assumptions discussed above for the
calculation of daily intake rates depend on the details of the
assumed exposure scenario. These values for the HEIP subsite are
presented in Tables VI-l, VI-2 and VI-3.
C.
TOXICITY
ASSESSMENT
critical toxicity values (CTVs) have been derived by EPA by
which the noncarcinogenic and carcinogenic risk of oral or
inhalation eKposure to a chemical can be evaluated. The CTVs for
the HEIP subsite are summarized in Table VI-4.
For noncarcinogenic effects, the CTVs are termed the
Acceptable Intake for Subchronic exposure (AIS) and the
Acceptable Intake for Chronic exposure (AIC). These values,
expressed in units of mgjkg-day, are estimates of lifetime daily
exposure levels for humans, including sensitive individuals.
Estimated intakes of chemicals from environmental media (e.g.,
the amount of a chemical ingested from c~ntaminated drinking
water) can be compared to AIS and AIC values. Estimated intake
levels at or below the AIS or AIC levels are believed to pose no
significant risk of noncarcinogenic effects, while exposure
levels above these values may pose a risk. The AIS and AIC
values are based on quantitative data from studies in animals or
humans on the relationship between intake and noncarcinogenic
health effects. ~hey are designed to be protective, with an
adequate margin of safety, of the most sensitive population to
ensure that the potential for adverse noncarcinogenic effects is
not underestimated.
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinoge~ic
chemicals. CPFs, which are expressed in units of (mgjkg-day)- ,
are multiplied by the site-specific estimated intake of a
potential carcinogen, in mgjkg-day, to provide an upper-bound
estimate of the excess lifetime cancer risk associated with
exposure at that intake level. The term "upper bound" reflects
the conservative estimate of the risks calculated from the CPF.
Use of this approach makes underestimation of the actual cancer
risk highly unlikely. Cancer potency factors are derived from
the results of human epidemiological studies or chronic animal
bioassays to which animal-to-human extrapolation and uncertainty
factors have been applied. Large CPF values are associated with
high cancer potency, while low CPF values are associated with
weak carcinogenic potential.
since dermal exposure to soil and sediment are of concern at
this subsite, dermal CTVs are also required. It is important to
note that the dermal CTV units must be based on the absorbed dose
(rather than the exposed or administered dose), since dermal
intakes are calculated as absorbed doses. Since the EPA has not
yet established any dermal CTVs, approximate values for dermal
CTVs were derived by extrapolation from oral CTVs. This was done
26
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by multiplying the oral AIS or AIC values by the oral absorption
fraction (the fraction of the dose which is absorbed orally) or
by dividing the oral CPF by the oral absorption fraction. This
approach is based on the assumption that equal absorbed doses are
equally toxic. Dermal CTV values are provided in Table VI-5. No
extrapolation from oral to dermal was performed for PAHs, since
they have their effect at the point of contact (skin, stomach,
lungs), and inter-route extrapolation is inappropriate. Dermal
CTVs were not calculated for metals, since it is generally
considered that dermal absorption of metals is so small as to be
of no practical health concern.
D.
RISK CHARACTBRIZATION
The risk characterization quantifies present and/or
potential future threats to human health that result from
exposure to the indicator chemicals. A potential excess
carcinogenic risk and a hazard index for noncarcinogenic health
hazards were calculated based on indicator chemical-specific
exposure scenarios and toxicity information.
A number of uncertainties are inherent in the risk
assessment process. Some of the uncertainties result from the
limited availability of toxicological data, a limited
understanding of the fate and transport of the various
contaminants, and a lack of information regarding the metabolism
of contaminants in humans and other species. Based on available
data and professional judgment, the evaluation of risk was
conducted on the indicator chemicals, exposure pathways, and
potentially exposed populations believed to be most significant
at the HEIP subsite.
1.
Potential carcinogenic Risks:
Excess lifetime cancer risks are determined by multiplying
the carcinogenic potency factor (CPF) by the projected chemical
intake level. These risks are probabiliBies that are expre~sed
in scientific nota~ion (e.g., 1 = 1 x 10 , 0.0001 = 1 x 10- ,
0.000001 = 1 x 10-). Excess cancer risk is defined as the
additional probability that an individual exposed to a particular
chemical for his entire lifetim~ will develop cancer. An excess
lifetime cancer risk of 1 x 10- indicates that, as a plausible
upper bound estimate, an individual has a one in one million
chance of developing cancer as a result of site-related exposure
to a carcinogen over a 70-year lifetime under the site-specific
exposure conditions.
To put calculated risk estimates into perspective, they
should be evaluated against a baseline rifk level~ Risk levels
for known or suspected carcinogens of 10- to 10- can be used to
determine the "environmental significance" of the risk incurred.
This range is defined by the National oil and Hazardous
Substances Pollution Contingency Plan (NCP) as a target range for
remedial purposef. Using this range as a baseline, a risk level
greater than 10- is considered a "significant" risk with regard
27
-------
to human health in an environmentat contex:; requiring
remediation. Levels less than 10- are co~sidered
"insignificant" and do not by themselves ~:~ovide a gasis for
remedial action. A risk level between 10.l.j, and 10- is a
classified as "potentially significant." Individual site
characteristics, including but not limited to the exposed
populations (e.g., adults, children, etc.), land use (industrial,
residential, agricultural), the uncertainties such as those
associated with exposure to the lead contaminated soils, and the
contaminated media (ground water, soil, air, etc.), are factors
considered in deciding whether to conduct a remedial action at
sites where the estimated excess potential carcinogenic risk
falls within this range. The use of the terms "significant,"
potentially significant," and "insignificant" are not meant to
imply acceptability; however, they help to put numerical risk
estimates developed in risk assessment into perspective.
Table VI-6 summarizes the calculated potential carcinogenic
risks for exposure scenarios evaluated at the HElP subsite. The
total excess carcinogenic risk (cumulative risk) for a given
scenario represents the sum of the risks calculated for each
media-specific route of exposure to all the indicator chemicals.
Future exposure estimates assumed the use of a hypothetical well
in the vicinity of CMS Well #20 (an area of known ground water
contamination) as a source for drinking water. No differences in
the exposures to surface soils were assumed between the current
and future scenarios. No potential excess carcinogenic risks are
associated with the current drinking water supplies (CMS Well #19
water supply system).
The exposure scenarios for the resident/agricultural worker
population yielded ihe highest fstimated cumulative excess cancer
risks (from 1 x 10- to 3 x 10- for both current and future land
uses (Table VI-6». The risks at the subsite fall along the
border between "significant" and "potentially significant" excess
carcinogenic risks, as discussed above. Under the current land
use conditions at the HElP, nearly all of the estimated potential
excess cancer risks are associated with the inadvertent ingestion
of arsenic- and PAH-contaminated soils or direct dermal contact
with the TNT-contaminated soils. These risk estimates are
provided in Table VI-7.
2.
Noncarcinogenic Health Hazards:
The potential for noncarcinogenic adverse health effects are
described differently than the risks associated with exposure to
carcinogenic substances. Rather than determining the likelihood
(probability) that an individual will receive a noncarcinogenic
injury from exposure to a contaminant, as in the determination of
potential excess carcinogenic risk, a hazard index (HI) approach
is used.
Noncarcinogenic effects of a single contaminant in a single
medium are expressed as the hazard quotient (HQ), or the ratio of
estimated intake derived from the contaminant concentration in a
28
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given medium to the contaminant's acceptable chronic intake (AIC)
or acceptable subchronic intake (AIS). The HI is generated by
adding the HQs for all contaminants within a medium or across all
media, to which a given population may reasonably be exposed.
The HI provides a useful reference point for estimating the
potential significance of multiple contaminant exposures within a
single medium or across media. .
If the estimated HI is equal to or less than one (i.e., if
the daily intake by a human is less than or equal to the daily
amount estimated to be "safe" with no adverse health effects)
then a noncarcinogenic injury is not expected to occur. If the
HI exceeds the value of 1 (or the daily intake of an individual
is greater than the "safe" dose) the potential for a
noncarcinogenic injury exists.
For the HElP, a number of exposure scenarios resulted in
estimated HI values which exceed the value of 1 for long-term
(chronic) exposure to site contaminants with noncarcinogenic
health effects. These HI values are provided in Table VI-B. The
estimated HIs for subchronic exposures were all less than or
equal to one (see Appendix D, Final RI Report USACE, 1990b, for
further information on subchronic exposures). In all cases, most
of the health hazard is due to oral or dermal contact with soil,
and in all cases the largest contributor to the total HI is the
TNT hazard quotient for each exposure scenario.
Lead, a contaminant of noncarcinogenic concern, is known to
have adverse effects on both fetuses and children, even at
relatively low concentrations. Evaluation of potential adverse
health effects for lead, however, is not accomplished using the
HI approach. The methods for determining the potential health
hazards resulting from exposure to lead require estimation of the
level of lead likely to be present in the blood of a receptor
based on his or her estimated exposure. These methods are
discussed in detail in the Baseline Risk Assessment (Appendix D,
Final RI Report, USACE, 1990b).
The following range of blood lead levels are estimated for
children exposed to lead contaminated soil at the HElP: 5.6 to
13.3 ug/dl (micrograms per deciliter). The higher values fall
within the range of blood lead levels EPA has identified as a
range of concern for health effects in children (10 to 15 ug/dl).
3. Screening-Analysis of Potential Cancer Risks and Health
Hazards to Ose of Irrigation W.ll Water
A screening-level study was conducted to evaluate the
potential risks to field workers and residents posed by
inhalation of contaminants released by volatilization (i.e.,
evaporation into the air of VOCs) from irrigation water,
ingestion of irrigation water, and contamination of soils by
these waters. The study was conducted to consider the effects of
the trichloroethene (TCE) and l,l,l-trichloroethane (TCA)
contaminants found in two of the irrigation ground water supply
29
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wells currently in use 2 months of the year
at the HEIP subsite. The study results are
provided in greater detail in Appendix 4 of
Report (U5ACE, 1990b).
for crop irrigation
summarized below and
Appendix D, Final RI
These potential risks were evaluated by assuming that
irrigation workers work inside a semi-covered box and breathe
contaminants as they are released. This approach may have
overestimated exposures since a box represents an enclosed
breathing space and does not account for the diffusion and
degradation bf breathable contaminants which occurs in an open-
air working space. An assessment was also made of potential
exposures/risks due to ingestion of or dermal exposure to soils
contaminated by irrigation water (assuming that a certain amount
of contaminants reach ground surface during irrigation of crops)
and potential risks due to the ingestion by field workers of the
irrigation water at the well head.
The data and assumptions used to estimate potential cancer
risks and health hazards to workers and residents potentially
exposed to the irrigation water are presented in Table VI-9. The
model exposure scenarios were calculated using two different
assumptions: 1) 100 percent volatilization of the TCA and TCE
contaminants before contact with the soil (as is likely for an
overhead irrigation system), and 2) 50 percent of the
contaminants contact the soils (emulating a gravity irrigation
system) .
The cumulative potential cancer risks calculated using this
"box model" approach are summarized in Table VI-10. The
potential cancer risks do not exceed those estimated for ground
water ingestion.
A value greater than one denotes a potential noncarcinogenic
health hazard. The calculated cumulative noncarcinogenic health
hazards for this approach were all values less than one.
Consequently, a potential noncarcinogenic health hazard does not
appear to exist as a result of irrigation activities.
E.
POTENTIAL BNVIRONKENTAL IMPACTS
A limited ecological assessment of the HEIP site was
qualitatively conducted based on information including the
results of USACE's investigation of the subsite, published
reports and correspondence with the u.s. Fish and Wildlife
Service. There is no evidence that wildlife or vegetation is
currently experiencing any adverse environmental harm at the HEIP
subsite. The information required for a more thorough evaluation
of impacts to environmental populations includes the following:
a biological survey of organisms exposed to the subsite areas of
contamination, ecotoxicity tests on contaminated media, and
measurements of the levels of indicator chemicals in the tissues
of exposed vegetation and wildlife.
Potentially exposed environmental populations include plant
30
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and animal populations on- and off-site. More detailed
information on the potential environmental receptors
(populations) for the HElP subsite may be found in Chapter 2 and
Appendix 2 of Appendix D, Final RI Report (USACE, 1990b). A
field survey of plant and animal species present at the subsite
was not conducted.
The black-footed ferret (Mustela nigripes) and five species
of birds are listed by U. S. Fish and wildlife Service as
threatened or endangered wildlife species and may be present in
the vicinity of the site. The presence of prairie dogs on the
subsite may indicate suitable habitat for the black-footed
ferret. No endangered plant species are listed in the vicinity
of the NAD.
The surface water drainage basin for McMurtrey Marsh is
topographically separate from the surface water drainage area of
the HElP. Surface water drainage from the HElP flows into the
drainage basins for the West Fork of the Big Blue River, Pawnee
Creek and Big Sandy Creek. None of these drainages discharge to
Thessen lagoon. An analysis of ground water flow from the site
(Final Ground Water Modeling Report, USACE, 1990c) indicated no
ground water connection between the site and these areas. Lake
Ayr is also unaffected by surface drainage or ground water flow
from the HElP subsite (USACE 1990b). It is unlikely, based on
this information, that surface water or ground water
contamination at the HElP poses a threat to environmental
populations at the Thessen Lagoon or McMurtrey Marsh.
Exposure pathways involving on-site environmental
populations are assumed to be more important than off-site
exposure pathways, based on the lack of evidence of specific
sensitive environmental populations (e.g., endangered species,
significant populations of recreational or commercial species or
significant natural areas) in nearby off-site areas. Migratory
wildlife are more likely to visit nearby off-site wetlands than
the limited surface water resources on site.
Exposure of terrestrial plant and animal populations by air
pathways may occur but is not believed to be significant. These
populations may be exposed to contaminated surface soils and
sediments on site. Wildlife may be exposed by ingesting
contaminated vegetation. The scattered nature of soil and
sediment contamination suggests that these possible exposures are
limited. Exposure pathways involving surface waters on site may
be significant for wildlife drinking water from irrigation return
ponds. Ground water is not considered a significant exposure
pathway for other wildlife populations at the subsite. Ingestion
of water from surface water runoff collecting in ditches and
drainages is not likely to be an important exposure pathway for
wildlife since barium and chromium are the only indicator
chemicals detected in the medium. Because of the temporary
nature of on-site surface water, exposure of aquatic species is
not considered significant.
31
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The only adverse impact to environmental populations on the
subsite noted during site characterization field work was
distressed vegetation, particularly in areas of site drainage.
The cause of the distress cannot be determined with available
sampling data, given that some component of the apparent distress
may be associated with seasonal drought and not the toxicity of
contaminants.
Tissue samples from wildlife were not analyzed to evaluate
whether or not bioaccumulation is a concern as a result of
exposure to contamination. No surface water areas occur on-site
where migratory waterfowl may experience an acute exposure to
elevated levels of indicator chemicals. other wildlife may
experience exposures to indicator chemicals, but these are
expected to result in doses much lower than those producing
adverse health effects in laboratory test animals. other than
the stressed vegetation noted above, no other evidence of
contaminant-specific impacts to environmental populations is
available for this site. The relative importance of site
contaminants and other factors influencing the environmental
populations in the vicinity of the subsite cannot be evaluated at
this time.
F.
CLEANUP GOALS
The potential noncarcinogenic health hazards (HIs greater
than one) and the potential excess cancer risks which border the
10-4 to 10 -6 significant risk range, present a current or
potential threat to public health at the HEIP subsite. Nearly
all of the potential health hazards are associated with the
exposure to the surface soil. This ROD addresses these hazards
through remediation of the soils which have contaminant
concentrations exceeding the health-based cleanup goals.
Since no currently established federal or state cleanup
standards exist for soil contamination, cleanup goals for the
HEIP subsite were established using a health-based approach
similar to the approach used to calculate potential health risks.
This health-based approach identified cleanup goals for the
noncarcinogenic and carcinogenic indicator contaminants. To
address the current and possible future residence of sensitive
populations (i.e., children and pregnant women) at the HEIP
sub~ite, taiget levels were established at the lower end of the
10- to 10- target excess carcinogenic risk range established by
the NCP. For HEIP subsite contaminants with carcinogenic
effects, cleanup goals are established rglative to a target
cumulative excess cancer risk of 1 x 10- : soils exceeding this
level would require remediation. For contaminants with
noncarcinogenic health effects, a hazard index (HI) is used to
determine cleanup goals. contaminated materials with estimated
HI values greater than one would require remediation.
The cleanup goals presented in Table VI-11 were developed
using this health-based approach for contaminated soils at the
HEIP. The cleanup goals were calculated for the
32
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resident/agricultural worker soil ingestion pathway. The
baseline risk assessment indicated that this receptor group and
exposure pathway had the highest intake factors, reflecting the
greatest potential for exposure to 6ubsite contaminants.
In order to ensure that the potential cancer risks and
hazard indices for individual contaminants and pathways do not
cumulatively exceed the target values, the target cancer risk and
hazard index must be apportioned (i.e. divided) among exposure
pathways and contaminants. For carcinogenic risk, the two
exposure patpways of in~estion and dermal conta~t with 60ils are
apportioned a 5.0 x 10- level of risk (1 x 10- divided by two
exposure pathways). This level is in turn divided by three, for
the three potential carcinogens (arsenic, TNT and ,AHS). Each
contaminant, therefore, is apportioned a 1.7 x 10- level of
risk. Similarly, each exposure pathway is apportioned a HI of
0.5 (1.0 divided by two exposure pathways). There are five
noncarcinogenic contaminants per pathway (TNT, cadmium, lead,
arsenic, and chromium), therefore, each contaminant is
apportioned a 0.1 HI.
Using the exposure scenarios, exposure assessment and intake
factors developed in the baseline risk assessment and previously
discussed, contaminant-specific concentration levels are
calculated. This contaminant-specific concentration lev;l
(cleanup goal) is that which would result in a 1.7 x 10- excess
cancer risk or 0.1 HI. Remediation of the soils which exceed
these levels ensures that exposure to residual contaminants
(e.g., contaminants remaining in the soils below the cleanup
levels) would not result in a cumulative (total) excess cancer
risk of greater than 10-6 or a HI greater than 1.
Two of the indicator chemicals (arsenic and PARs) at the
HEIP have non-health based cleanup goals. The background
concentration of arsenic (11 mg/kg) has been established as the
cleanup goal in order to address the soil contamination due to
the result of man's activities at the site. The calculated
health-based concentration for arsenic is below this background
concentration. The health-based cleanup concentration for the
PARs is lower than the analytical detection limit. Achievement
of this level is therefore unverifiable. As a result, the
analytical detection limit (50 micrograms/kilogram (ug/kg» has
been established as the PAR cleanup goal as the lowest measurable
concentration.
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 or the environment.
33
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TABLE VI'1
ASSUMPTI~S USED TO ESTIMATE CHEMICAL .NTAKES IT INGESTI~ OF DRINKINe WATER
Plremeter/Populltion
Source (I)
Vllue
Wlter Intlke (L/dey)
..........--.-......
Industrill Worker
Industrfll WOrker-Resident
Agriculturll Worker-Resident
Resident ill Adult
.esldentill Child
lody Weight (kg)
-.-.............
Industrill Worker
Industrial Worker-Resident
Agricultural Worker-Resident
Residential Adult
Residential Child
Time Correction Factors
(E~sure Frequencies)
.-.-................---........
Industrill Worker
Industrill Worker-Resident
Agriculturll Worker-Resident
Residentill Adult
Residentill Child
1 (b)
2
2
2
,
70
70
70
70
10
5 days/week, 50 weeks/year,
for 30 years (c)
Continuous exposure for
70 yelrs (d)
Continuous exposure for
70 years (d)
Continuous e~sure for
70 years (d)
Continuous exposure for
10 years (d)
Aaa~t f on
USEPA 1987b
USEPA 1987b
USEPA 1987b
itA
USEPA 1986
USE!>" '986
USEPA 1986
USE!>A 1986
USEPA 1986
Ass~t I on
Ass~t i on
Ass~t i on
Ass~t i on
A..~t i on
ItA & Source not evl; leble frC18 texttut of ..,.1 fne Rf,t A"esl8ent
(App. D, USACE, 199Ob)
(a) Sources cfted in the text of '.,elfelfne li.k A"es8lent
(App. D, USACE, 199Ob)
(b) Industrill workers .re ...UM8d to Con&UI8 h.lf their deity
intlke of drinting Meter Mh;le It work (2 L/2 . 1L)
(c) a'"d on ...~t;ons hwotvfrw IIIpIO)'8ent.
(d) ContiruIUS exposure i, 24 hour'/dey, 7.YS/week, 128onths/year,
34
-------
YAiLE VI-2
/'
ASSUMPTIONS USED TO ESTIMATE CHEMICAL INTAKES IT INCESTION OF SOIL AND SEDIMENT
'Irl8eter/populltion Vilue Source (I)
Soil lreestion (1IIiI/dly)(b)
-----.....................
Industrill WOrker 10 USEPA '987b
Industrill Worker-Resident 10 USEPA 1987b
Agriculturll WOrker-R..ident 100 (c) AUUlpt i on
I..identill A~lt 10 USEPA 1987b
lesidentill Child 200 USEPA 1987b
"
lody Weight (kg)
................
Industrill Worker 70 USEPA 1986
Industrill Worker-Resident 70 USEPA 1986
Agriculturll Worker-Resident 70 USEPA 1986
Residentill Adult 70 USEPA 1986
Residentill Child 10 USEPA 1986
Time Correction Flctors
(Exposure Frequencies)
...............................
Industrill Worker 5 dlys/~k, 68Onthslyelr. Ass~t ion
for 30 yelrs Cd)
Industrill Worker-Resident 7 dlys/~k, 68OnthsIYllr, A"~t i on
for 70 yelrs (d)
Agricultur.1 Worker-Resident 7 daYS/week, 6 8Onthslyelr, Ass~t ion
for 70 yelrl (d)
Resident ill Adul t 7 deys/~k. 6 8Onths/yelr. Ass~t ion
for 70 yelrs (d)
Residenti.l Chi Id 7 dlys/~k, 68Onths/yelr. AII~t i on
for 10 yelrl (d)
liOlV.illbility Flctors (unitlels)
.................-................
All populltions
All dI..iclls 1 Ce) Aa~t ion
CI) Sources cited fn the teat of "'II fN If,t alleslllllnt CApp. D, usaCE, 199Ob)
Cb) To COf'I\tert frCIIII lllil/day to ta/day, ILl I tfply by "10-6-
Cc) Unlite other 8C1Jlu.."o Ire ..,1.8Id to freest 10 IIIiI/dly of 8011,
8Iriculturll tfOrker'-"esidenu '1" 8I11.81d to f"lllt 100 lllil/day of 8011
becluse of their Iitensive IJIPO$ure to this -.dil.
Cd) The 'elsonal adjustment of ,il 80nths I yelr is included on the
III~tion thlt soil ingestion occurs outside ~ri"" periods when
there is no snow cover.
e) Conservltively ISsUMed to be 1.0 in the 8bcence of lite-specific dati.
35
-------
TAiLE VI-]
ASSUMPTIONS USED TO ESTINATE tHE-ICAL INTAKES IT DERNAL CONTACT
WITH SOIL AND SEDIIENT
'ar8leter/population
Vilue
Source (I)
Total lody SuTfaee Ar.a (C82)
......-......................
Industrial WOrker
Industrial WOrker-Resident
Agricultural WOrker-Resident
Residential Adult
Resident ill Child
Fraction of Totll lady
Surf.ce Are. Exposed (unit less)
.....-....................-.-..
Industri.l Worker
Industrial Worker-Resident
Agricultural Worker-Resioent
.esl~~:la: Adwlt
Residenti.l Child
lody Weig~t (kg)
..................
Industrill Worker
Industrial Worker-Resident
Agricultur.l Worker-Resident
Reside~ti.l Adult
Residenti.l Child
Time Correction flctors
(E~posure frequencies)
.............................
Industrial Worker
Industrill WOrker-Resident
AgriCUltur.l WOrker-Resident
R.sidential Adult
Residential Chi ld
18.150
18.150
18.150
18.150
9.1000
USEPA 1987b
USEPA 1987b
USEPA 1987b
USEPA 1987b
USEPA 1987b
.05 (hinds)
.05 (hinds)
.'6 (hands and arms)
.05 (hinds)
.16 (hinds Ind arms)
Anderson et
Anderson et
Arderson et
Arderson et
Arder50n et
70
70
70
70
10
USEPA 1986
USEPA 1986
USEPA 1986
USEPA 1986
USEPA 1986
1 dlY/week. 68JnthS/yelr. As."",tion
for 30 yair. (b)
2 dlys/llfMt. 6 8onth./year, As8UllPt i on
for 70 year. (b)
Z dlys/llfMk, 6 8onths/yelr, As~t i on
for 70 year. (b)
, d8Y/llfMt, 6 8Onths/year, As~tion
for 70 year. (b)
Z d8ys/w.t. 6 8onths/year. As.~t i on
for 10 year. (b)
36
.l. 19BJ.
II. 19f.l.
al. '984
al. 19BJ.
al. 1984
-------
,
TABLE IV.3 (Con't.)
Soil Adherence FI~tor (kg/cm2)
..-.-...................-.-........
All Populltions
2.oe.06 (~)
USEPA '987b
D....l Ab5orption FractiC)"" (llIitless)
..................................-.-.
All PCIp.Illtions
Al"8eni~, "ri~,
ChrC8i l1li, Lead
C8c*ni un,
s..ivolltiles (2,4-DNT, 2,6-DNT,
PAHs, 2,4,6.TNT)
o Aul8Pt i on
O. , Iy8n at al. 1987
0.25 IYln et Il. '987
Volatiles CTri~hloroethene,
Tetrl~hloroethene)
CI) References ~ited in the text of 8aseline Risk Assessment
CAppo 0, USACE, '990b)
(b) The seasonal adjustment of six ~ths . year is included on the
assumption that ~ont.~t ~;th soil oc~urs outside during periods
when there is no I~ ~over.
\ (~) Value is geometri~ ..an of soil 8dheren~e fa~tors for commer~i.l
potting soil ('.~SE.6 kg/cm2) Ind kaolin dust (2.77E.6 kg/cmZ).
37
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TABlE VI . 4
SUIWIY Of ORAL. CRITiCAl TaKICI" VAI..1£SC8>
I!!Ab I "KAlA TI (II
IrdiC8tor AIS AIC D'F AIS AIC D'F
0Ie8iC81 (8IIIk.a -cf8y) (8IIIk.a-cf8y)( 8IIIk.a-cf8y) ., (8IIIk.a- cf8y)( 8IIIt.a -cf8y)(8IIIk.a-cf8y) .,
Arsenic(b) 0.001 0.001 15.0 NA NA 15.0
Bari~ 0.05 0.5 NA 0.001 0.0001 NA
Cachi~(c> NA 0.0005 NA NA NA 6.1
Chrami~ (VI) 0.02 0.005 NA NA NA 41.0
ChrCllli ua (III) 10.0 1.0 NA NA NA NA
Lead NA NA NA NA NA NA
PAHs(d) NA NA 12.0 NA NA 6.1
2,I.-DNT NA NA 0.68 NA NA NA
2,6-DI/T NA NA 0.68 NA NA NA
TNT NA 0.0005 0.03 NA NA NA
Tetrachloroethene 0.1 0.01 0.051 NA NA 0.0033
Trichloroethene NA NA 0.011 NA NA 0.017
(a)
All values taken fram EPA Health Effects Assessment Summary Tables, fourth quarter FY 1989, October 1989
(EPA. 1989a) and the EPA Integrated Risk Infonmation Sy$tem (IRIS) (EPA, 1989b).
(b) The CPF for inhaled arsenic reported in IRIS (EPA, 1989b) is 50(~/kg-day)-1. This is based on the ab-
sorbed dose of arsenic, which was assuned by the EPA to be ~ of the inhaled dose. This value has
therefore been ~ltiplied by 0.3 to yield a CPF applicable to the inhaled (rather than the absorbed) dose.
(c) The EPA has proposed two AIC values for cachiLIII, one appl icable to cachiLIII In water (5 x 10.'> and one
applicable to cadmi~ in food (1 x 10-3>. In order to be conservative, the lower value (the AIC in water)
has been take to apply to cadmium in loil, Ii nee there are no lub8ite-lpecific data regarding the
bioavailability of cachiua in on-lite loil. If the ab8orption of cachiLIII il reduced by the loil, this
approach will result in an overesti..te of rilk.
(d) These values are based on benzo(a)pyrene, use of these values for all carcinogenic PAHs is likely to
result in an overestimate 01 risk.
38
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TAIlE VI - 5
DElIVATICII OF DEIML CRITICAL TalnCI" VAL1£S
AIS
AIC
OIF
AF"
AIS
DElML(8)
AIC OIF
Irw:ficator
Otmical
CItAL
2,4-DNT NA ItA 0.68 1.0(C) ItA ItA 0.68
2,6-DNT NA JIA 0.68 1.0 (c) ItA NA 0.68
TNT NA 0.0005 0.003 O.6(d) MA 0.003 0.018
Tetrachloroethene 0.1 0.01 0.051 1.0(.) 0.1 0.01 0.051
Trichloroethene NA ItA 0.011 1 .O(f) MA ItA 0.011
(a)
Dermal
Derma I
Dermal
AIS = Oral AIS x AFo
AIC = Oral AIC x AFo
CPF . Oral CPF/AFo
(b)
Dermal CTVs were not derived for arsenic, berilJll, cacinilJll, chramilJll or lead since dennal absorption
of !lleuls is generally considered to be so smell 85 to be no health concern. DeMll8l CTVs for PAHs were not
derived since their toxic actions are route-specific and extrapolation across routes is inappropriate.
Source: Agency for Toxic Substances and Disease Regiatry (ATSDR), Toxicolog;cal profile for 2,3-DNT
and 2,6-DNT (draft), (ATSDR 1988a).
(c)
(d)
Source:
EPA Office of Drinking Water TNT Health Adv;sory (EPA, 1989c).
(e)
Source:
EPA Off;ce of Drinking Water Tetrachloroethene Health Advisory (EPA, 1987).
(f)
Source:
ATSOR Toxicological Profile for Trichloroethene (TCE) (draft), (ATSDR 1988b).
39
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hble VI "6: ~ry of Potential C8reinogenic liat
Potential lislt futureCa>
CUrrent
EJIpoced bpo8ure EJIpo&re ~ "t ""' ''t URJer
Poculatian Point lledh. loute Estf_te ~ Estf-te IcUd
IrWstrial SE Drinking Water Ingestion 0 0 1 It 10.5 2 It 10.5
Worker Soi l/Sedhnent Ingestion 4 It 10.6 6 It 10"6 4 It 10.6 6 It 10.6
Soi l/Sedille!'lt Dermal 1 It 10.8 1 It 10"8 1 It 10.8 1 It 10.8
Total 4 It 10.6 6 It 10.6 1 It 10.5 3 It 10.)
Incklstrial liE Drinking Water Ingestion 0 0 1 It 10"5 2 It 10.5
Worker Soi l/Sedille!'lt Ingestion 4 It 10"6 6 It 10"6 4 It 10.6 6 It 10.6
Soi l/Sedilllent Dermal 6 It 10'6 1 It 10"5 6 It 10.6 1 It 10.5
Total 1 It 10"5 2 It 10.5 2 It 10.5 4 It 10.5
Incklstrial IIW Drinking Water Ingestion 0 0 1 It 10.5 2 It 10.5
Worker Soil/Sediment Ingestion 3 It 10"6 3 It 10.6 3 It 10'6 3 I( 10.6
Soi l/Sediment Derme l 7 It 10.,0 8 It 10.,0 7 It ,0.,0 B x ,0.,0
Total 3 It 10.6 3 I( 10.6 1 It 10.5 2 x 10')
Industrial SW Drinking Water Ingestion 0 0 9 x 10.5 1 II 10.4
Worker/ Soil/Sediment Ingest ion 7 It 10.6 9 It 10.6 7 It 10-6 9 It 10.6
Resident Soil/Sediment Dermel 8 II 10.6 2 x 10.5 8 x 10.6 2 x '0.5
Total 2 x 10.5 3 x 10.5 1 It 10"4 1 It 10.4
Agricultural SW Drinking Water Ingestion 0 0 9 It 10.5 1 It 10.4
Workerl Soi l/Sediment Ingestion 7 x 10.5 9 II 10-5 7 x 10.5 9 x 10.5
Resident Soi l/Sediment Derma l 3 x 10.5 6 x 10-5 3 x 10.5 6 x '0.5
Total 1 It 10'4 2 It 10.4 2 It 10.4 3 It 10.4
Resident HE Drinking Water Ingestion 0 0 9 x 10.5 1 It 10.4
Adult Soil/Sediment Ingestion 1 It 10-5 2 It 10.5 1 II 10.5 2 x 10.5
So; l/Sediment Derme l 2 It 10.5 3 It 10.5 2 It 10.5 3 x '0.5
Total 3 II 10.5 5 It 10.5 1 II 10.4 2 II 10.4
Resident SW Drinking Water Ingestion 0 0 9 II 10.5 1 II 10.4
Adult Soi l/Sediment Ingestion 7 It 10.6 9 II 10.6 7 It 10.6 9 I( 10.6
Soi l/Sedillle!'lt Dermel 4 II 10'6 9 II 10'6 4 It 10.6 9 x 10.6
Total 1 II 10.5 2 It 10.5 1 II 10.4 1 II 10.4
C8> Future exposures assume a hypothetical well in the vicinity of CMS Well 120 replaces current drinking water
supplies. 110 other differences are assumed between current and future scenarios.
40
-------
T8ble VI - 7: ~ry of Principal Potential C8rCfnogenic liab
to CUrrent end Future Papul8tiana frc8 Cant_fNted Sof la
Potential Cancer lialt (8)
EJIpa&ed Expo5Ure Eati_te
PCIIUl.tion Point ~ Arsenic(b) PAIIa(b) m(C)
InctJstrial SE Best Estill8te 2 x 10.6 2 x 10.6
Worker Upper lOIIId 3 x 10.6 3 x 10.6
InctJstrial NE lest Eltl_te 2 x 10.6 7 x 10.6
Worker Upper BOIIId 3 x 10.6 1 x 10.6 1 x 10.5
Jnc1Istrial NW Best Esti_te 2 x 10.6
Worker Upper lOIIId 2 x 10.6
Inc1Istrial SW lest Eatill8te 5 x 10.6 1 x 10.6 9 x 10.6
WOrker I Upper lOIIId 5 II 10.6 2 x 10.6 2 x 10.5
Resident
Agricultural SW Best Estimate 5 x 10.5 1 x 10.5 4 x 10.5
Workerl Upper BOIIId 2 x 10-5 2 x 10.5 8 x 10.5
Resident
Resident NE Best Estimate 7 x 10-6 2 x 10-6 2 x 10-5
Adult Upper BOIIId 1 x 10-5 4 x 10-6 4 x 10-5
Resident SW Best Estimate 5 x 10.6 1 x 10.6 5 x 10.6
Adult Uppe r BOIIId 5 x 10.6 2 x 10.6 1 x 10-5
(a) Only risks equal to or greater than 1 x 10.6 ere listed. See Baseline Risk Assessment,
Appendix D of Final RI Report CUSACE, 1990b) for greater detail.
(b) Risks mainly from ingestion of soil.
(c) Risks mainly from denmal contact with soil.
41
-------
Tele VI - 8: ~ry of au'onle IonCarcinogenle lle81th llazarda
llazard Index
Oorrent Future(a)
~ ~ EJIpa8ure Expo8&re "t ~ "t ~r
pogulation Point Medil.- Route Eati_te IcUd Eatt_te Iou1d
Industrial SE Drinking Water Ingestion 0.03 0.04 0.1 0.1
Worker Soli/Sedlilent Ingestion 0.D1 0.04 0.01 0.04
Soi l/Sedilnent Dermal 0.00006 0.00007 ~ g,.,QQQQl
ToUI 0.04 0.08 0.1 0.1
lnc1Jstrlal NE Drinking Water Ingestion 0.03 0.04 0.1 0.1
WOrker Soll/Sedillent Ingestion 0.2 0.4 0.2 0.4
Soi l/Sedillent Dermal .LQ L.2 1.& l:J2
Total 1.0 2.0 1.0 3.0
lnc1Jstrlal NW Drinking Water Ingestion 0.03 0.04 0.1 0.1
Worker Sol t/Sedillent Ingestion 0.003 0.007 0.003 0.007
Soll/Sedillent Dermal 0.0001 0.0001 0.0001 0.0001
ToUI 0.03 0.05 0.1 0.1
Industrial SW Drinking Water Ingestion 0.08 0.1 0.2 0.5
Worker/ Soil/Sediment Ingestion 0.06 0.1 0.06 0.1
Resident Soi I/Sediment Dermal 0.5 1.& M !:.Q
Total 0.6 1.0 0.8 2.0
Agricultural S\J Drinking \Jater I nges t i on 0.08 0.1 0.2 0.5
Worker/ Soil/Sediment Ingestion 0.6 1.0 0.6 1.0
Resident Soi I/Sedilllent Derma I iJ! Y iJ! 4.0
Totel 3.0 5.0 3.0 6.0
Resident NE Drinking Water Ingestion 0.3 0.4 1.0 . 1.0
Chi Id Soi l/Sediment Ingestion 30.0 70.0 30.0 70.0
Soi I/Sediment Derma I ~ ~ ~ 50.0
Total 50.0 100.0 50.0 100.0
Resident S\J Drinking Water Ingestion 0.3 0.4 1.0 1.0
Ch lid Soi I/Sediment Ingestion 9.0 20.0 9.0 20.0
Soli/Sedilllent Derma I y ~ y 10.0
Totel 20.0 30.0 20.0 30.0
Resident NE Drinking Water Ingestion 0.08 0.1 0.2 0.5
Ac1J I t Soil/Sediment Ingestion 0.2 0.5 0.2 0.5
Soll/Sedillent Dermal .LQ 1Jl .LQ iJ!
Total 1.0 3.0 1.0 3.0
Resident SW Drinking Water Ingestion 0.08 0.1 0.2 0.5
Ac1Jl t Soil/Sed i lllent Ingestion 0.06 0.1 0.06 0.1
Soli/Sedilllent Perma 1 y ~ y 0.6
Total 0.4 0.8 0.6 1.0
(8) Future exposures assume a hypothetical well In the vicinity of CMS well 120 replaces current drinking water
luppl I es. No other differences are alsumed between current and future Icenarlos.
42
-------
TABLE VI - 9
Potent i al Can:er Ii 50 end Ile8l th 1lazard5
ciJe to Use of Irrigation Well W8ter
Date end Asst8)tiona
"'
DATA:
Irrigation Water Contaminant Concentrations:
TCA . 680 and 4' _icr08r8l&/liter (ug/l)
TCE . 460 and 2 ug/l
ASSUFTJ CIIS:
Representative daily.pumping rate:
',000 gallons/_inute
Field Surface Area:
40 acres (overhead irrigation SystM)
80 acres (gravity irrigation ayst..)
Average Wind Speed (July end August):
'0.6 _Iles per hour
TCE Carcinogenic Potency Factor (CPF): 0.017 (8;/k9/day)"'
TCA Allowable Subchronic Intake (ASI): 0.90 8;/kg/day
Receptor Populations: Adult Worker/Resident and Child Resident
Exposure Duration: Z months/year for: 30 years (adults) and 10 years (children)
Table VI - 10
Potential Can:er liab end Ile8lth 1lazard5
u to use of Irrigation Well W8ter
Su88Brv of Cu8ulative Potential Cancer lisks
Receptor
Area
Potential Cancer lists
1 Year
.
30 or 10 Yeers
100 PERCENT YDLATILIZATICli
(Inhalation + Ground Water Ingestion Exposure Pathways)
Adul t 40 acres "7 -5
4.0 It 10 1.2 x 10
80 acres 4.0 x 10.7 1.2 x 10"5
Chi ld 1,0 acres .7 9.5 x 10'6
9.3 It 10
80 acres 9.3 x 10.7 9.6 x 10'6
50 PERCENT YDLATILIZATICli
(Inhalation + Ground Water Ingestion + Soil Ingestion + DenDIl Contact Exposure Pathways)
Adult 40 acres 4.0 It 10"7 1.2 x 10'5
80 acres .7 1.2 x 10'5
4.0 x 10
Chi ld 40 acres 9.3 It 10'7 9.4 x 10'6
80 acres 9.3 x 10.7 .6
9.4 x 10
*
30 for adult, 10 for chi ld
43
-------
'rable VI - 11
CLEANtJP GOALS
POR
SURFACE SOIL CON'l'AHIItUlTS
Bastings East Industrial Park SUbsite
Contaminant Cleanup Goal
TNT. 2.5 mg/kg
(analytical
Total PAHs 50 ug/kg detection
limit)
Arsenic 11 mg/kg (background)
cadmium. 25 mg/kg
chromium . 230 mg/kg
Lead. 69 mg/kg
.
The cleanup goal for TNT is based on carcinogenic risk: the
cleanup goals for cadmium, chromium, and lead are based on
noncarcinogenic (toxic) hazards.
44
-------
VII.
SUMMARY OP ~LTERNATIVES
Several alternatives were developed and evaluated during the
remedial investigation and feasibility study of the HEIP subsite.
These alternatives were designed to address the potential health
hazards present at the subsite and to prevent future migration of
contaminants to the ground water.
six alternatives for remediation of the contaminated surface
soils exceeding levels the cleanup goals established for the
protection of human health and the environment (see Table VI-11),
were considered during the detailed evaluation in the Final FS
Report (USACE, 1990a). These remedial action alternatives
include:
1.
2.
3.
4 .
5.
6.
No Action
Excavation - On-site Landfill
Excavation - Stabilization
In-situ Stabilization
Excavation - On-site Incineration - Stabilization
Excavation - Soil Washing and Solvent Extraction
- Off-site Treatment and/or Disposal of Residuals
These alternatives have been numbered 1 - 6 for purposes of
discussion in this ROD. The Final FS Report (USACE, 1990a)
provides greater technical detail for each of the components of
these evaluated alternatives.
An additional alternative was developed, discussed and
identified as the preferred alternative in the proposed plan
which was published for public comment in June 1990 (EPA, 1990).
This alternative has been chosen for remedial action at the HEIP
subsite. It combines elements of several of the other
alternatives and with an additional component addressing the
potential need for temporary storage of the excavated soils on-
site. It has been designated as follows:
7.
Excavation - On-site Incineration
- Stabilization - On-site Landfill.
Cost estimates, soil volume estimates and other information
relevant to the additional alternative which are unavailable in
the Final FS Report (USACE, 1990b) are provided in the appendices
to the proposed plan (EPA, 1990) and this ROD.
Descriptions of the seven alternatives are provided below.
These descriptions include the estimated costs, the applicable or
relevant and appropriate requirements or standards (ARARs), and
technological aspects of each remedy. Capital costs include the
direct and indirect costs associated with construction of the
alternative. The annual operation and maintenance costs (O&M)
are the post-construction costs necessary to ensure the continued
effectiveness of the alternative. The present worth cost
represents the amount of money that, if invested during the
current year, would be sufficient to cover all expenditures over
45
-------
the life of an alternative. All of the estimated costs should
provide a range of accuracy of +50 percent to -30 percent.
Some of the alternatives are complex and utilize more than
one treatment technology since different types of contamination
may require different types of treatment. For example, soils
contaminated with organics such as TNT and PAHs are likely to
require different treatment technologies than soils contaminated
with inorganics (i.e., metals). The soils contaminated with all
three contaminants (TNT, PAHs, and metals) may require the
application 9f multiple treatment technologies.
A detailed discussion of ARARs is also provided below.
Compliance with ARARs is also briefly discussed in the
description of each alternative description.
A.
APPLICABLE OR RELEVANT AND APPROPRIATB REQUIREMENTS
section 121(d) of CERCLA as amended requires that remedial
actions comply with all applicable or relevant and appropriate
requirements or standards (ARARs) under Federal or State
environmental laws. Such standards must be attained if they are
determined to be either directly applicable or both relevant and
appropriate. Some of the requirements discussed in this section
are directly applicable to a particular aspect of a remedial
alternative; other requirements are identified as being both
relevant and appropriate to a remedial alternative. Both of
these categories of requirements constitute ARARs and must be
attained by the selected remedial alternative.
The following potential ARARs have been identified and
evaluated for the remedial alternatives in this Record of
Decision:
o
Resource Conservation and Recovery Act and
regulations promulgated thereunder
o
Clean Air Act and regulations promulgated
thereunder
o
The Occupational Safety and Health Act
Clean Water Act
o
o
Nebraska Environmental Protection Act and
regulations promulgated thereunder
These ARARs, which have the greatest impact on the remedy
selection, are discussed below. Additional discussions regarding
potential ARARs may be found in the Final FS Report (USACE,
1990a) for the HElP subsite and the Proposed Plan (EPA, 1990) for
the HElP Source Control Operable unit. Because this Operable
Unit deals only with contaminated soils, ground water ARARs
46
-------
discussed in the Final FS Report do not apply to the surface soil
alternatives described in this Record of Decision.
ARARs may be contaminant-specific, action-specific or
location-specific. No contaminant-specific ARARs have been
identified for the contaminated soils at the HElP subsite. Most
location-specific ARARs do not apply because the HElP subsite is
not in or near a floodplain, wilderness area, historic site, or
other protected environment. However, action-specific ARARs
apply to several of the alternatives.
On-site actions, such as the on-site disposal of soil and
debris, are exempt from the need to obtain a state permit, which
is considered an administrative requirement. Nevertheless, such
on-site actions are required to meet the substantive requirements
of all ARARs.
section 121(d) of CERCLA requires that remedial actions
shall require a level or standard of control for hazardous
substances, pollutants, or contaminants that attains ARARs.
Levels or standards of control are basic performance objectives
for the remedial action. These basic performance objectives are
defined by so-called substantive ARARs.
Superfund actions conducted on-site are exempt from
administrative requirements of ARARs. Requirements which do not
in and of themselves define a level or standard of control are
considered administrative. Administrative requirements include
the approval of, or consultation with, administrative bodies,
issuance of permits, documentation, and, generally, reporting and
recordkeeping requirements. The Superfund program imposes its
own reporting and recordkeeping requirements to ensure that
substantive levels or standards of control are being met.
1.
Resource Conservation and Recoverv Act (RCRA)
RCRA, as amended, regulates the generation, transportation,
treatment, storage and disposal of RCRA hazardous wastes. The
contaminants at the HElP subsite are found in the soils, and
several alternatives call for excavating the contaminated soils,
treating the contaminated soils by various treatment technologies
and/or placing treated or untreated soils into an on-site
landfill.
A substance is defined as a RCRA hazardous waste if it is a
solid waste which satisfies one of the following conditions:
(1) are waste streams or discarded chemical products listed in
the RCRA regulations as hazardous wastes (40 CFR Part 264
Subpart D);
(2) the wastes exhibit one of four characteristics
(ignitability, corrosivity, reactivity, or toxicity); or
47
-------
(3) are mixtures of solid waste and waste listed as hazardous by
RCRA regulations.
The soils at the HElP subsite do not meet the specifications for
listed wastes in the RCRA regulations since little is known of
the actual practices at the former NAD.
The HElP soils will have to be tested to determine whether
they exhibit any of the four RCRA hazardous characteristics and
are therefore subject to the treatment standards and regulations
for RCRA hazardous wastes. The test which the HElP surface soils
will most likely fail is the Toxicity Characteristic LeaChing
Procedure, or TCLP. This procedure was promulgated in March of
1990 in the Toxicity Characteristics (TC) Rule. The TCLP tests
leachate from samples of contaminated soil to determine whether
the levels of contaminants extracted during the leaching
procedure is sufficiently high to render the leachate toxic. The
outcome of these tests will dictate which RCRA treatment (or
disposal) ARARs must be met.
Much of the contaminated soil at the HElP subsite is also
classifiable as a "hazardous substance" under CERCIA.
Contaminated soil may be defined as a "hazardous substance" under
CERCIA if it contains contaminants regulated under certain other
environmental statutes or designated sections of CERCIA. Many of
the contaminants in the HElP soils are regulated under the Clean
Water Act and the Clean Air Act.
The standards developed for the handling and treatment of
RCRA hazardous wastes, while not necessarily applicable to CERCIA
hazardous wastes which are not RCRA listed or characteristic'
hazardous wastes, are nevertheless relevant and appropriate to
the handling and disposal of these hazardous substances since
they are designed to address problems similar to those
encountered at a CERCIA site (i.e., the containment of hazardous
wastes to protect public health).
Administration of the RCRA program is delegated to the state
of Nebraska, with the exception of certain recently-promulgated
regulations. Rules promulgated pursuant to the Nebraska
Environmental Protection Act are substantially identical to RCRA
in the regulation of solid waste disposal units, thermal
treatment units, and storage requirements. specifically, the
Nebraska regulations applicable to treatment, storage or disposal
of hazardous wastes are the Rules and Regulations Governing
Hazardous Waste Management in Nebraska, Title 128. Because RCRA
is comprehensive in its regulation of all aspects of hazardous
waste management, it represents the dominant regulatory scheme
affecting the implementation of the remedial action for the HElP
subsite. The most important of the RCRA issues are summarized
below (citations are to Federal regulations).
48
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a.
Landfill Design and Construction Requirements:
For any alternative which calls for disposal of wastes
-------
It is possible that some portion of the soils at the HEIP
subsite will not pass the TCLP test. LDRs would therefore
preclude the land disposal alternatives which call for placement
of untreated soils into a land disposal unit. However, LDRs
would not preclude land disposal of the portion of the HEIP soils
which pass the TCLP test. To meet the LDR ARARs for any selected
alternative, additional testing would be required to determine
which soils at the HEIP subsite pass the TCLP test. Therefore,
it will be necessary to require that the soils at the site be
subjected to the TCLP test as part of the any the implementation
of any alternative in order to comply with LDR requirements. In
addition, if 'the soils at the HEIP subsite display any other
hazardous characteristic (ignitabi1ity, corrosivity or
reactivity), appropriate treatment standards must be applied and
met prior to placement.
The National contingency Plan provides that a treatability
variance may be automatically obtained when dealing with soil and
debris (see 55 FR 8761-62, March 8, 1990). Therefore, when
performing remedial actions on the contaminated soils at the HEIP
subsite, information obtained from treatability studies will be
used to determine whether treatability standards can be met.
While it is anticipated that the LDR treatment standards will be
met using the proposed treatment technologies, it is possible
that treatability standards may not be attainable for some of the
contaminated soils. Should this occur, it will be necessary to
obtain a treatability variance and appropriate procedures will be
followed.
d.
Thermal Treatment standards:
RCRA regulations found at 40 C.F.R. Subpart 0, and
specifically ~ 264.363, provide performance standards for
hazardous waste incinerators. These regulations constitute ARARs
for incineration of explosives and PARs at the HEIP subsite. The
regulation states that incinerators burning hazardous waste must
achieve a destruction and removal efficiency (DRE) of 99.99%
(four nines) for each principal organic hazardous constituent.
compliance with these regulations will apply to any alternative
which calls for incineration. It is anticipated that all thermal
treatment options will attain the identified applicable or
relevant and appropriate thermal treatment requirements.
In addition, any thermal treatment unit which would be used
to treat wastes from off-site would have to obtain a RCRA Part B
permit.
e.
Hazardous waste storage Requirements:
The requirements of 40 C.F.R. Part 264 regulate the
operation of hazardous waste treatment, storage and disposal
facilities. If the 50i1s would be stored at the HEIP subsite and
they exhibit any hazardous characteristic, the storage
requirements found ~n subpart I would be applicable. Any storage
50
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area constructed must comply with these requirements. It is
anticipated that storage ARARs will be attained in carrying out
any of the alternatives.
2.
Clean Air Act
The Clean Air Act and the Nebraska Air Pollution Control
Rules and Regulations (Title 129) contain permitting requirements
for sources of certain types and quantities of air pollutants.
During the pre-construction design of the thermal treatment
facility, an-assessment will be made of the type and quantity of
potential emissions. If this assessment indicates that a permit
is required, a permit will be obtained. The Clean Air Act
requirements include some of the more conventional pollutants
which are not addressed by the RCRA incineration standards.
This ARAR is applicable or relevant and appropriate only to
those alternatives which call for thermal destruction of
contaminants at the HElP subsite. A permit would be obtained if
the assessment discussed above demonstrates that a it is
necessary.
3.
OccuDational Safety and Health Act
All activities conducted at the site must comply with the
substantive requirements of the Occupational Safety and Health
Act (OSHA) in order to protect the health and safety of the
workers implementing the remedial action. OSHA sets forth
guidelines for safe work practices and procedures designed to
ensure worker safety. This ARAR is applicable to all remedial
alternatives, and it is anticipated that the Site Health and
safety Plan accompanying the Work Plan for alternative selected
for the remedy will comply with all identified requirements of
OSHA.
4.
The Clean Water Act
In the course of carrying out remedial activities at the
site, waste water will be generated from three possible sources.
Waste water may be generated by decontamination of equipment used
in performing on-site work, as effluent from the treatment of
leachate water from an on-site landfill, or from the cleaning of
pollution control equipment on the incinerator. The Clean Water
Act regulates the discharge of these waters.
There are two options for the discharge of these waters.
First, it is possible that the water may be discharged through
one of the publicly-owned treatment works (POTWs) in the area.
If it is not possible to discharge the decontamination water
through one of the already-existing POTWs, it will be necessary
to treat the waters on-site and then obtain a National Pollutant
Discharge Elimination system (NPDES) permit for the discharge of
the water into the surface waters located in the area.
51
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These requirements are applicable to all alternatives,
because all alternatives would require at least that equipment
used for on-site work be subjected to decontamination procedures.
It is anticipated that this ARAR will be attained in carrying out
all of the alternatives.
Dredge and fill permit requirements under section 404 of the
Clean Water Act apply to any filling operation in the waters of
the United States, including wetlands. A floodplain, including
the floodway, is not necessarily considered to be "waters of the
United States. II EPA and USACE have determined that there are no
wetlands within the HEIP subsite and the HEIP subsite is not
located within a floodplain. Therefore, Section 404 requirements
will not apply to remedial activities conducted at the HEIP
subsite.
5.
Nebraska Environmental Protection Act
This statue provides for the promulgation of rules and
regulations pertaining to solid waste management facilities
(Title 132), hazardous waste treatment, storage and disposal
facilities (Title 128), air pollution control, including
incineration emissions and fugitive emissions from excavation
activities (Title 129), and discharge of pollutants from a point
source into the waters of Nebraska (Titles 117, 118, and 119).
The substantive requirements of these regulations must be met for
all on-site activities. Any off-site activities must comply with
all requirements of these regulations, including permitting
requirements.
a.
Nebraska Regulation of Disposal sites
Neb. Rev. stat. paragraph 19-4101 ~ ~ sets forth
criteria for consideration in construction and establishment of
any disposal site. This statute is regulates disposal sites in
cities but is relevant and appropriate to this remedy because its
primary purpose is to permit the controlled disposal of materials
for the protection of public health and the environment. The
same statutory requirements are made applicable to all solid
waste disposal areas requiring a license by Title 132 (rules and
regulations pertaining to the management of solid wastes).
6.
Nebraska Water We11 Contractors Licensina Act
Neb. Rev. stat. paragraph 46-1201 g1 ~ Title 178 are
rules and regulations promulgated jointly with the Nebraska
Department of Health which regulate well construction and
abandonment. The substantive requirements of this statute will
be applicable to anyon-site well construction.
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B.
COMMON ELEMENTS OP ALL THE ALTERNATIVES
Several components are common to all alternatives except the
No Action Alternative. Each alternative (except the No Action
Alternative) would ensure that soils with concentrations
exceeding the cleanup goals (Table VI-ll) would be removed,
contained and/or treated. Residual concentrations in the surface
soils after completion of the remedy would be below the levels
established for the protection of public health and the
environment (i.e., the soil cleanup goals).
For all 'alternatives (except the No Action Alternative),
surface water from drainage pathways in the northeast and
southeast portions of the subsite would have to be temporarily
diverted during excavation or treatment, to prevent ponding,
surface water run-on damage, erosion or further contamination of
the ground water.
Dust suppressants would be used for all of the alternatives
during implementation of the remedial action. Dust suppression
is necessary during any excavation or handling of contaminated
surface soils to minimize fugitive dust emissions.
All alternatives which include excavation (Alternatives 2,
3, 5, 6, and 7) would include soil sampling to confirm that the
horizontal and vertical extent of excavation was sufficient to
remove the contaminated soils exceeding the established cleanup
goals. After excavation, clean soil would be placed in the
excavated areas, compacted, graded, and reseeded.
C.
DESCRIPTION OP ALTERNATIVES
1)
NO ACTION:
Capital Costs: 0
Annual O&M Costs: $57,000 (30
Present Worth Cost: $800,000
Months to implement: 0
The No Action Alternative would not involve any remedial
action, and the subsite would remain in its present condition.
Limited monitoring of surface water and sediments would be
conducted to assess the migration of contaminants within the
drainage pathways. This alternative, consideration of which is
required by the NCP, is a baseline alternative against which the
effectiveness of other alternatives can be compared.
years)
Because limited monitoring is requiredi annual operation and
maintenance costs would be required to cover the cost of sampling
and analysis.
Because no remedial activities would be conducted with the
No Action Alternative, human health is not protected. The
potential for ingestion of or direct contact with contaminated
53
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surface soil would remain. contaminants would still have the
potential to migrate and possibly increase the volume of ground
water contamination, thus increasing the potential risk to human
health if the contaminated ground water is used as a drinking
water supply in the future. A remedy must be protective of human
health to be considered for selection as a remedial action.
No ARARs apply to the No Action Alternative.
2)
EXCAVATION - ON-SITE LANDFILL:
Capital Costs: $8,000,000
Annual O&M Costs: $86,000 (30 years)
Present Worth Cost: $9,000,000
Months to implement: 30-48
This alternative would include the excavation of
approximately 125,900 cubic yards of surface soils with
contaminant concentrations exceeding the cleanup goals in Table
VI-11. The untreated soils would be placed in a hazardous waste
landfill constructed on the subsite and covered with a multi-
layer cap as required by the RCRA closure regulations.
Major technological components and institutional controls of
this alternative would include: placement of a security fence
around the landfill; periodic site inspections for the lifetime
of the landfill: ground water, leachate, and unsaturated zone
monitoring; land purchases or easements for the construction of
the landfill and access roads would be obtained from private
parties; land use and development restrictions for the landfill
to protect the integrity of the cap: possible installation an5
operation of a water treatment facility for decontamination and
leachate waters: and appropriate health and safety precautions to
protect the public and the site workers. Decontamination of
trucks and site equipment that have been in contact with
contaminated soils would be conducted prior to the equipment
leaving the excavation and landfill areas.
RCRA Hazardous Waste Landfill construction and closure
requirements are ARARs for this alternative. If any of the HEIP
soils are RCRA characteristic wastes, these requirements are
applicable. Since this alternative calls for placement of soils
with contaminant levels above health-based levels in a on-site
landfill RCRA landfill, construction and closure requirements
would also be appropriate and relevant. It is anticipated that
these requirements would all be met by this alternative.
LDR restrictions may be applicable to this
the soils contain RCRA characteristic hazardous
alternative will not meet the LDR ARARs because
disposal of the untreated soils.
It is anticipated that other ARARS for this alternative,
including the Nebraska Regulation of Disposal sites statute,
would be met.
alternative. If
wastes, this
it calls for land
54
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3)
EXCAVATION - STABILIZATION:
Capital Costs: $25,000,000
Annual O&M Costs: $73,000 (30 years)
Present Worth Cost: $26,000,000
Months to implement: 36-48
,
This alternative would include the excavation of
approximately 125,900 cubic yards of surface soil with
contaminant concentrations exceeding the cleanup goals in Table
VI-11. Upon excavation, the soils would be segregated based on
the type of contaminant(s) present. The excavated surface soils
would be stabilized at a central location on the HEIP subsite'by
mixing the soil with water and compounds that immobilize and/or
encapsulate the contaminants. After the soil is stabilized, it
would be placed in an on-site lined disposal cell designed with a
synthetic liner and a drainage layer to collect and remove
leachate. After the stabilized soil is placed in the cell, it
would be covered with a multi-layer cap consisting of a synthetic
liner, drainage layer, and soil cover.
Compounds used to stabilize the contaminants vary greatly
depending on the type of contaminant and specific site
conditions. Stabilization of metals in soils is a proven
technology. A moderate degree of testing would be required to
determine the most effective method of stabilizing the 39,000
cubic yards of metal-contaminated soil. Since stabilization of
TNT- and PAR-contaminated soils has not been previously
implemented as a remedy, a variety of tests would be necessary to
determine the most effective type of stabilizing compounds for
the 64,800 cubic yards of soil containing these contaminants.
Approximately 22,100 cubic yards of soil contains both organic
(i.e., PARs and TNT) and inorganic (metal) contaminants.
Additional testing would be required to determine the most
effective method of stabilizing the soils in the presence of both
organics and inorganics. '
Major technological components and institutional controls of
this alternative would include: placement of a security fence
around the disposal cell; periodic site inspections for the
lifetime of the disposal cell; ground water, leachate and
unsaturated zone monitoring; land purchases or easements for the
construction of the disposal cell and access roads would be
obtained from private parties; land use and development
restrictions for the disposal cell to protect the integrity of
the cap; possible installation and operation of a water treatment
facility for decontamination and leachate waters; and appropriate
health and safety precautions to protect the public and the site
workers. Decontamination of trucks and site equipment that have
been in contact with contaminated soils would be conducted prior
to the equipment leaving the excavation and disposal cell areas.
This alternative would comply with LDR ARARs because this
alternative calls for application of the appropriate treatment
technology to the soils prior to placement in the land disposal
unit. If RCRA characteristic wastes are present in the soils, it
55
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is anticipated that the appropriate RCRA BDAT (best demonstrated
available technology) treatment standard or soil and debris
treatability variance level will be met. However, if
stabilization of the PAH- and TNT-contaminated soils is not
effective and these standards are not met, this remedy would not
meet the LDR ARAR. It is anticipated that other ARARS for this
remedy, including the Nebraska Regulation of Disposal sites
statute, would be met.
4)
IN-SITU STABILIZATION:
Capital Costs: $22,000,000
Annual O&M Costs: $467,000 (30 years)
Present Worth Cost: $30,000,000
Months to implement: 36-48
This alternative would include the in-situ (in place)
stabilization of 125,900 cubic yards of surface soil with
contaminant concentrations exceeding the cleanup goals in Table
VI-11. Since contamination is located in discrete areas, the
solidifying constituents and supplemental water would be injected
into the soil and mixed (in place) to obtain a uniform mixture at
each discrete area of contamination. After the soil is
stabilized, it would be covered with 12 to 18 inches of clean
soil. The areas would then be seeded to establish a vegetative
cover to minimize erosion.
Compounds used to stabilize the contaminants vary greatly
depending on the type of contaminant and specific site
conditions. Stabilization of metals in soils is a proven
technology. A moderate degree of testing would be required to
determine the most effective method of stabilizing the 39,000
cubic yards of metal-contaminated soil. Since stabilization of
TNT- and PAH-contaminated soils has not been previously
implemented as a remedy, a variety of tests would be necessary to
determine the most effective type of stabilizing compounds for
the 64,800 cubic yards of soil containing these contaminants.
Approximately 22,100 cubic yards of soil contains both organic
(i.e., PAHs and TNT) and inorganic (metal) contaminants.
Additional testing would be required to determine the most
effective method of stabilizing the soils in the presence of both
organics and inorganics. Additionally, a monitoring system would
be required to ensure that the technology performs as expected.
Prior to treatment, more extensive characterization of the
extent of contamination would be required than for the
excavation alternatives, since verification sampling (which would
be conducted during excavation for the other alternatives) would
not be performed.
Major technological components and institutional controls to
be implemented for this alternative would include: monitoring
of the unsaturated subsurface soil and ground water in the
vicinity of each stabilized area: land use restrictions for
stabilized areas to minimize contact with the stabilized
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material; periodic site inspections: land purchases or easements
for the construction of access roads and implementation of in-
situ mixing would be obtained from private parties; and
appropriate health and safety precautions to protect the public
and the site workers. Decontamination of trucks, mixing
equipment and other site equipment that have been in contact with
contaminated soils would be conducted prior to the equipment
leaving the excavation and disposal areas.
It is anticipated that this alternative would attain all
ARARs. RCRA.LDRs do not constitute an ARAR for this alternative
because no "placement" of wastes occurs.
5)
EXCAVATION - ON-SITE INCINERATION - STABILIZATION:
Capital Costs: $82,000,000
Annual O&M Costs: $73,000 (30 years)
Present Worth Cost: $83,000,000
Months to implement: 36-52
This alternative would include the excavation of
approximately 125,900 cubic yards of surface soils with
contaminant concentrations exceeding the cleanup goals in Table
VI-11. Excavated soils would be segregated and treated based on
the type of contamination.
An estimated 86,900 cubic yards of soil contaminated with
TNT and PARs would be treated by incineration in an on-site
incinerator. These contaminants would be destroyed in the
incineration process. Operation of the incinerator would include
safety and emissions control equipment. An estimated 22,100
cubic yards of incinerated soils would also contain metal
contaminants. Because metals are not destroyed by incineration,
soil contaminated with only metals (an estimated 39,000 cubic
yards) and metals-contaminated incineration residues (ash) would
be stabilized. Stabilization of metals in soils is a proven
technology. A moderate degree of testing would be required to
determine the most effective method of stabilizing metal-
contaminated soil and ash. Stabilized materials would be placed
in a lined disposal cell with a multi-layer cap as previously
described in Alternative 3.
The metal-free incineration soil residue would be replaced
in excavated areas and supplemented with clean backfill if
necessary. The incineration soil residue would then be covered
with 12 to 18 inches of clean soil.
Treatment residuals, including sludges from the scrubber
system and material from the electrostatic precipitator, may
require treatment prior to on- or off-site disposal.
Major technological components and institutional controls to
be implemented for this alternative would include: placement of
a security fence around the disposal cell: periodic site
inspections and maintenance for the lifetime of the disposal cell
57
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to monitor the effectiveness of the remedy: ground water,
leachate and unsaturated zone monitoring: land purchases or
easements for placement of the incinerator and the construction
of the disposal cell and access roads would be obtained from
private parties: land use and development restrictions for the
disposal cell to protect the integrity of the cap: possible
installation and operation of a water treatment facility for
process (including scrubber), decontamination and leachate
waters: decommissioning and removal of the incinerator upon
completion of site activities: and appropriate health and safety
precautions to protect the public and the site workers.
Decontamination of trucks, mixing equipment and other site
equipment that have been in contact with contaminated soils would
be conducted prior to the equipment leaving the excavation and
disposal areas.
The Clean Air Act and Nebraska Air Pollution Control Rules
and Regulations contain applicable requirements for incineration.
Based on the pre-remedial action assessment discussed above, a
permit would be obtained if required under these regulations
Performance standards for hazardous waste incinerators are
provided in the RCRA regulations. These regulations constitute
ARARs for hazardous waste incineration of explosives and PAHs.
It is anticipated that all thermal treatment options will attain
the identified applicable or relevant and appropriate thermal
treatment requirements.
This alternative would comply with LDR ARARs because this
alternative calls for application of the appropriate treatment
technology to the soils and incineration residues prior to
placement in the land disposal unit. The residue from the
incineration process will then be tested to determine whether it
exhibits any RCRA hazardous characteristics. If RCRA
characteristic wastes are present in the soils or incineration
residues, it is anticipated that the appropriate RCRA BDAT
treatment standard or soil and debris treatability variance level
will be met. However, if stabilization of the PAH- and TNT-
contaminated soils and incineration residues is not effective and
these standards are not met, this remedy would not meet the LDR
ARAR. It is anticipated that other ARARS for this remedy,
including the Nebraska Regulation of Disposal Sites statute,
would be met.
6)
EXCAVATION - SOIL WASKING AND SOLVENT EXTRACTION
- OFF-SITE TREATMENT AND/OR DISPOSAL OF RESIDUALS:
Capital Costs: $52,000,000
Annual O&M Costs: 0
Present Worth Cost: $54,000,000
Months to implement: 66-84
This alternative would include the excavation and on-site
treatment of approximately 125,900 cubic yards of surface soil
with contaminant concentrations exceeding the cleanup goals in
Table VI-II. Excavated soils would be segregated and treated
58
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based on the type of contamination. Two extraction processes
would be required: one to remove metals and the other to remove
organics and explosive contaminants from the soil.
The approximately 64,800 cubic yards of soils contaminated
with TNT and PAHs would be treated using a solvent extraction
process. This process would remove TNT and PAHs from the soil by
washing the soil with a solvent. The solvent used in the process
would then be treated by flash evaporation and steam stripping to
remove the contaminants so the solvent could be reused in the
treatment process. However, heating these explosive bearing
solvents is a known explosive hazard and therefore not an
acceptable procedure for remediation of these soils. The
extracted organic contaminants would be transported off-site to a
RCRA-permitted treatment facility and incinerated. Soils treated
by the solvent extraction process would be analyzed for
contaminants and residual solvent. If concentrations are below
the cleanup goals, the soil would be returned to excavated areas.
Waste water generated from this process may require treatment.
The soil contaminated with metals (approximately 39,000
cubic yards) would be treated using a soil washing process. This
process is similar to solvent extraction but an acid or alkaline
solution would be used as the washing fluid followed by
neutralization of the soil. The extracted metals would then be
separated from the washing fluid by a chemical precipitation
treatment system. After the metals were removed from the washing
fluid, the fluid would be recycled through the soil washing
process. The precipitated metal sludge woul~ be de-watered and
transported to an off-site RCRA-permitted disposal facility,
where the metal sludge would be stabilized and 1andfilled.
An estimated 22,100 cubic yards of soil containing both
inorganics (metals) and organics (i.e., TNT and PAHs) would
require treatment by soil washing followed by solvent extraction.
Several soil washing and solvent extraction processes are
currently under development. Testing would determine which
processes would be most effective for the HEIP subsite.
After treatment, the soil would be placed back in the
excavated areas, covered with 12 to 18 inches of clean soil and
seeded to establish a vegetative cover to minimize erosion.
Residuals from the treatment processes, including extracted
contaminants and any non-recyclable treatment fluids, would be
transported off-site to a RCRA-permitted facility for treatment
and/or disposal.
Major technological components and institutional controls to
be implemented for this alternative would include: access
restrictions during site activities; continued management of
residual wastes leaving site for off-site treatment and/or
disposal; land purchases or easements for preparation of
treatment site and access roads would be obtained from private
parties; possible installation and operation of a water treatment
59
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facility for process and decontamination waters; and appropriate
health and safety precautions to protect the public and the site
workers during the site activities including the off-site
transport of residuals. Decontamination of trucks, excavating
equipment, treatment equipment and other site equipment that have
been in contact with contaminated soils would be conducted prior
to the equipment leaving the excavation and treatment areas.
It is anticipated that this alternative would attain all
ARARs. RCRA LDRs do not constitute an ARAR for this alternative
because no "placement" of wastes occurs. Treatment residuals
transported off-site would be handled and disposed of in a manner
consistent with RCRA regulations. .
However, conversations with USACE, since the development of
the proposed plan, have indicated that the u.s. Army Toxic and
Hazardous Materials Agency health and safety policies forbid the
use of solvent extraction for treatment of explosives-
contaminated soils due to the known explosive hazard that results
from concentrating and heating the explosive contaminants during
this process. This alternative, therefore, is not an acceptable
remedy for the surface soils operable unit.
7)
EXCAVATION - ON-SITE INCINERATION - STABILIZATION
- ON-SITE LANDFILL
capital Costs: $44,000,000
Annual O&M Costs: $86,000 (30 years)
Present Worth Cost: $45,000,000
Months to implement: 40-60
This alternative would include excavation of approximately
125,900 cubic yards of surface soil with contaminant
concentrations exceeding the cleanup goals in Table VI-II.
Based on the type and concentrations of contaminants present, the
excavated surface soils would be either (1) stabilized at a
central location on the HElP subsite by mixing the soil with
water and compounds that immobilize and/or encapsulate the
contaminants or (2) treated in an on-site incinerator. The
excavated soils would be segregated by contaminant and
contamination level prior to treatment.
Surface soils to be treated by on-site incineration would
include approximately 16,400 cubic yards of soil contaminated
with TNT or total cariinogenic PARs exceeding the excess cancer
risk level of 1 x 10- for on-site residents. These soils have
concentrations which exceed the following levels:
660 mg/kg for TNT
1.8 mg/kg for PARs
The TNT and PAH contaminants would be destroyed in the
incineration process. Operation of the incinerator would include
safety and emissions control equipment.
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The incineration residue (ash) would be tested for residual
contamination. The contaminant-free incineration soil residue
(ash) would be replaced in excavated areas and supplemented with
clean backfill if necessary. The incineration soil residue 'would
then be covered with 12 to 18 inches of clean soil. Incineration
residues containing metal contaminants would be stabilized.
Treatment residuals, including sludges from the scrubber system
and material from the electrostatic precipitator, may require
treatment prior to on- or off-site disposal.
.
.
Approximately 39,000 cubic yards of surface soil
contaminated'with metals at levels exceeding the cleanup goals
would be stabilized. Since stabilization of metals is a proven
technology, only a moderate degree of testing would be required
to determine the most effective method for the HEIP subsite-
specific conditions.
The remaining 70,500 cubic yards of soil would also be
stabilized. This portion of the excavated soils includes surface
soils contaminated with total carcinogenic PAHs, TNT, or both, at
concentrations exceeding the levels established fir the
protection of public health but below the 1 x 10- increased
excess cancer risk levels discussed above. Since stabilization
of TNT- and PAH-contaminated soils has not been previously
implemented as a remedy, a variety of tests would be necessary to
determine the most effective type of stabilizing compounds for
soil containing these contaminants. Soils which contain both
organic (i.e., PAHs and TNT) and inorganic (metal) contaminants
would require additional testing to determine the most effective
method of stabilizing the soils in the presence of both organics
and inorganics.
Stabilized soils and contaminated incinerator residues would
be placed in an on-site RCRA Subtitle C Hazardous Waste Landfill
and capped as required by RCRA regulations.
If stabilization is not effective for the low-level PAH- and
TNT- contaminated soils, the untreated soils would be placed into
the on-site RCRA Subtitle C Hazardous Waste Landfill. However,
if these soils fail to pass the TCLP and are therefore RCRA
characteristic wastes, RCRA LDRs would prohibit the placement of
these untreated soils directly into the landfill. Prior to
placement, the appropriate RCRA BDAT treatment standard or soil
and debris variance level would be met through the application of
a treatment technology which can achieve theses levels.
Parameters for determining the effectiveness of stabilizing
technologies would be addressed in the design of the planned
treatability studies.
A three year period would be allowed in which the USACE may
further investigate the Explosives Disposal and Yard Dump areas,
areas of similar contamination adjacent to the HEIP subsite.
During this time any emerging destruction technologies which may
provide a comparable level of contaminant destruction to that
achieved by incineration but at a lower cost may also be studied
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by USACE. Excavated soils
temporarily stored on-site
requirements for temporary
this period.
Major technological components and institutional controls to
be implemented for this alternative would include: placement of
a security fence around the landfill: periodic site inspections
and maintenance for the lifetime of the disposal cell to monitor
the effectiveness of the remedy: ground water, leachate and
unsaturated zone monitoring: land purchases or easements for the
construction of the landfill and access roads would be obtained
from private parties: land use and development restrictions for
the landfill to protect the integrity of the cap: possible
installation and operation of a water treatment facility for
decontamination, process (including scrubber) and leachate
waters: and appropriate health and safety precautions to protect
the public and the site workers. Decontamination of trucks,
mixing equipment and other site equipment that have been in
contact with contaminated soils would be conducted prior to the
equipment leaving the excavation and disposal areas.
designated for incineration may be
in a manner consistent with RCRA
storage of hazardous wastes during
The Clean Air Act and Nebraska Air Pollution Control Rules
and Regulations contain applicable requirements for incineration.
Based on the pre-remedial action assessment discussed above, a
permit would be obtained if required under these regulations.
Performance standards for hazardous waste incinerators are
provided in the RCRA regulations. These regulations constitute
ARARs for hazardous waste incineration of explosives and PARs.
It is anticipated that all thermal treatment options will attain
the identified applicable or relevant and appropriate thermal
treatment requirements. If soils from off-site would be
incinerated on the subsite, a RCRA Part B permit would have to be
obtained.
This alternative would comply with LDR ARARs because this
alternative calls for application of the appropriate treatment
technology to the soils and incineration residues prior to
placement in the land disposal unit. The residue from the
incineration process will then be tested to determine whether it
exhibits any RCRA hazardous characteristics. If RCRA
characteristic wastes are present in the soils or incineration
residues, it is anticipated that the appropriate RCRA BDAT
treatment standard or soil and debris treatability variance level
will be met. However, if stabilization of the PAR- and TNT-
contaminated soils and incineration residues is not effective and
these standards are not met, this remedy would not meet the LDR
ARAR and an alternative treatment technology which achieves the
appropriate RCRA BDAT or soil and debris variance levels would be
applied for this portion of the remedy.
Construction and closure of the on-site RCRA subtitle C
Hazardous Waste Landfill would be consistent with RCRA
regulations. If the soils to be stored at the HEIP subsite
exhibit any hazardous characteristic, the RCRA storage
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requirements would be applicable to the storage option.
anticipated that storage ARARs would be attained by this
alternative.
It is
It is anticipated that other ARARSfor this alternative,
including the Nebraska Regulation of Disposal Sites Statute,
would be met.
VIII.
EVALUATION OP THE ALTERNATIVES
The remedial alternatives described in Section VII were
evaluated using the following nine criteria developed by EPA and
set forth in the National Contingency Plan CNCP} 40 CFR Part 300
to address CERCLA statutory requirements and technical, cost, and
institutional considerations. The advantages and disadvantages
of each alternative were compared to identify the alternative
providing the best balance among these nine criteria.
1. OVERALL PROTECTION OP HUMAN HEALTH AND THE ENVIRONMENT
This criterion provides an overall assessment of whether an
alternative would adequately protect human health and the
environment. Protectiveness focuses on whether an alternative
would achieve adequate protection and how site risks would be
eliminated, reduced, or controlled through treatment,
engineering, or institutional controls. This criterion is
considered a threshold criterion: that is, overall protection
must be provided for an alternative to be considered a remedy for
the site.
With the exceptions of the No Action Alternative 1 and the
Soil Washing/Solvent Extraction Alternative 6, all the
alternatives provide protection of human health and the
environment by removing, reducing, or controlling risk through
treatment and engineering controls. The potential health risk
resulting from exposure to the contaminated soils is
significantly reduced by all of the "action" alternatives. In
addition, the potential for further migration of contaminants to
the ground water is also significantly reduced, thus preventing
increased health risks from further contamination of the aquifer.
.
The u.S. Army Toxic and Hazardous Materials Agency health
and safety policies forbid the use of solvent extraction for
treatment of explosives contaminated soil due to the known
explosive hazard that results from concentrating and heating the
explosive contaminants during this process. Alternative 6,
therefore, is not an acceptable remedy for this surface soils
operable unit.
Since they are not protective of human health and the
environment the No Action and Soil Washing/Solvent Extraction
Alternatives will not .be evaluated further. This criteria must
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be met to allow an alternative to be an eligible remedy for
further consideration.
If testing demonstrates that stabilization of the TNT- and
PAH-contaminated soil is not effective, then the In-situ
Stabilization Alternative 4 would not be protective since no
secondary containment is utilized by this alternative.
2. COMPLIANCB WITH APPLICABLE OR RELEVANT AND
APPROPRIATB REQUIREKENTS
CERCLA requires that remedial actions comply with all
(ARARs) under Federal or State environmental laws. The following
potential ARARs have been identified and evaluated for the
remedial alternatives in this Record of Decision:
o
Clean Air Act and regulations promulgated
thereunder
o
The occupational Safety and Health Act
o
Clean Water Act
o
Nebraska Environmental Protection Act and
regulations promulgated thereunder
o
Resource Conservation and Recovery Act and
regulations promulgated thereunder
The following summarizes the impacts of the major ARARs on each
alternative. A more thorough discussion of these ARARs is
provided in section VII.
A.
Resource conservation and Recoverv Act
RCRA, as amended, regulates the generation, transportation,
treatment, storage and disposal of RCRA hazardous wastes. The
HEIP soils will have to be tested to determine whether they
exhibit any RCRA hazardous characteristic and are therefore
subject to the treatment standards and practices for RCRA
hazardous wastes. The TCLP is used to determine whether a waste
is a toxic characteristic waste. other tests will be conducted
for ignitability, corrosivity and reactivity. The outcome of
these tests will dictate which treatment ARARs must be met.
1)
Landfill Desiqn and Construction Requirements:
These requirements are applicable to the construction of any
landfill which will serve as a disposal unit for untreated RCRA
hazardous wastes, and would therefore be applicable to the
Excavation - On-site Landfill Alternative 2 if the contaminated
soils prove to be RCRA characteristic wastes. It is anticipated
that Alternative 2 would meet this ARAR.
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It is anticipated that a RCRA Subtitle C Hazardous Waste
Landfill would be constructed in a manner consistent with these
regulations as part of the Excavation - On-site Incineration -
Stabilization - On-site Landfill Alternative 7.
RCRA landfill construction requirements are not ARARs for
the other alternatives.
2)
Landfill Closure and Post-Closure Requirements:
RCRA lahdfill closure requirements constitute possible ARARs
for Alternative 2 if placement of soils with contaminant (RCRA
characteristic wastes or CERCLA hazardous wastes) concentrations
above health-based levels occurs. It is anticipated that RCRA
landfill closure requirements would be met by this alternative,
if required.
RCRA landfill closure requirements
other alternatives. It is anticipated,
the Subtitle C hazardous waste landfill
consistent with these requirements.
would not apply to the
however, that closure of
in Alternative 7 would be
3)
Land Disposal Restrictions (LDRs):
In order to satisfy LDR requirements, any RCRA
characteristic waste soils will have to be treated to levels
which achieve the appropriate RCRA BDAT standard or soil and
debris treatability variance level.
LDR ARARs are not applicable to the Alternatives 1 and 4
because no placement occurs.
LDR requirements are applicable to Alternative 2. But this
alternative would not attain LDR ARARs if the soils are
characteristic hazardous wastes, because this alternative calls
for placement of untreated soils into a land disposal unit.
The Excavation - Stabilization Alternative 3 would comply
with LDR ARARs because this alternative calls for application of
the appropriate treatment technology to the soils prior to
placement in the land disposal unit. It is anticipated that the
appropriate RCRA treatment standards or soil and debris variance
levels would be met.
The Excavation - On-site Incineration - Stabilization
Alternative 5 would also ~omply with LDR ARARs. The LDRs would
be applicable to the portion of the alternative which calls for
stabilization of metals-contaminated soils (if they are RCRA
characteristic wastes) prior to placement in a RCRA-compliant
landfill.
Alternative 7 will meet LDR ARARs by stabilizing metals-
contaminated soils and soils containing low levels of PAH and TNT
contaminants prior to placement in a land disposal unit.
However, as mentioned above, soils will have to be tested to
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determine whether they exhibit the characteristic of toxicity or
any other RCRA hazardous characteristic. If the tests reveal
that the metals-contaminated or the PAH- and TNT-contaminated
soils designated for stabilization are characteristic wastes, LDR
treatment standards will apply and the appropriate treatment of
these soils will be required prior to placement in a landfill.
In addition, the explosive- and PAH-contaminattd soils at
the HEIP subsite which present a health risk of 10- or greater
will be subjected to thermal destruction. The residue from the
incineration process will then be tested to determine whether it
exhibits any RCRA hazardous characteristics. If the residue is a
characteristic hazardous waste, LDR treatment standards will be
applicable.
It is anticipated that all treatment technologies selected
for any characteristic hazardous wastes discussed above will meet
the treatability requirements of the LDR regulations. Where the
selected remedy calls for treatability studies, only those
treatment technologies which meet LDR requirements will be
applied.
4)
Thermal Treatment standards:
RCRA regulations also provide performance standards for
hazardous waste incinerators. These regulations constitute ARARs
for hazardous waste incineration of explosives and PAHs at the
HEIP subsite.
Thermal Treatment ARARs only apply to Alternatives 6 and 7
because these are the only alternatives calling for incineration
of contaminated soils. It is anticipated that all the thermal
treatment options evaluated will attain all identified applicable
or relevant and appropriate thermal treatment requirements,
including the requirement that the incinerator attain a
demonstrated destruction efficiency of 99.99%. In addition, any
thermal treatment unit used to treat off-site wastes would have
to obtain a RCRA Part B permit.
5)
Hazardous waste storage Requirements:
The requirements of 40 C.F.R. Part 264 regulate the
operation of hazardous waste treatment, storage and disposal
facilities. If the soils to be stored at the HEIP subsite
exhibit any hazardous characteristic, the storage requirements
found in Subpart I are applicable to the storage option in
Alternative 7. Any storage area constructed must comply with
these requirements. It is anticipated that storage ARARs will be
attained in carrying out the this alternative.
storage is not a component of the other alternatives.
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B.
Clean Air Act
Clean Air Act requirements are less stringent than RCRA
standards in most respects. However, these requirements reg~late
the emissions of some the more conventional pollutants which are
not addressed by the RCRA standards.
This ARAR is applicable or relevant and appropriate only to
those alternatives which call for thermal destruction of
contaminants at the HElP subsite. These requirements will apply
to Alternatives 5 and 7. If pre-construction testing indicates
that a permit is required, one will be obtained. It is
anticipated that the implementation of these alternatives will
meet this ARAR.
C.
OccuDational safety and Health Act
This ARAR is applicable to all remedial alternatives, and it
is anticipated that the Site Health and Safety Plan accompanying
the Work Plan for the all of the alternatives will comply with
all identified requirements of OSHA.
D.
The Clean Water Act
All of the alternatives generate waste waters which are
regulated under this ARAR. These waters would require treatment
priorr to discharge. Any necessary NPDES permit would be obtained
prior to discharge into local surface waters. It is anticipated
that all of the alternatives would meet this ARAR.
E.
Nebraska Environmental Protection Act
It is anticipated that all of the alternatives will comply
with this ARAR.
F.
Nebraska Water Well Contractors Licensinq Act
It is anticipated that all of the alternatives will comply
with this ARAR.
3. LONG-TERM EFFECTIVENESS AND PERMANENCE
This criterion assesses the risk that would remain at the
site after the remedial action objectives are achieved. The
extent and effectiveness of the controls needed to manage any
treatment residuals or untreated wastes is assessed by
qualitatively determining the magnitude of any residual risk
remaining at the site at the conclusion of the remedial
activities. Also, the adequacy and reliability of the controls
that are used to manage any treatment residuals or untreated
wastes that remain at the site are assessed.
The soils contaminated with organics such as TNT and PAHs
are likely to require different treatment technologies than soi1
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contaminated with inorganics (i.e., metals). The degree to which
each technology utilized in a remedy achieves permanence and
long-term effectiveness needs to be considered in order to assess
the overall degree to which each alternative meets this
criterion.
Of the treatment technologies considered for the subsite,
incineration of the TNT- and PAH-contaminated soils provides the
greatest degree of permanence and long-term effectiveness.
Destruction of these contaminants during the incineration process
results in permanent removal of a potential source of future
ground water contamination and elimination of the potential
threats to human health posed by these contaminants. Incineration
technology destroys organic compounds with greater than 99.99
percent destruction removal efficiency. Metals-contaminated
treatment residuals (i.e., ash, scrubber waters, etc.) may
require additional treatment prior to disposal. The relative
magnitude of risks posed by these residuals is small. Both
Alternatives 5 and 7 utilize incineration for PAH- and TNT-
contaminated soils.
Stabilization of contaminated soils provides long-term
effectiveness by immobilizing contaminants and preventing
exposure to the contaminants. Stabilization of metals is a
proven technology with a high degree of effectiveness. The
permanence of the technology, however, is not well-documented. A
variety of techniques are available for stabilization. Many of
these techniques immobilize contaminants by binding and
encapsulating them into a mass, usually solid, with low
permeability. Often, stabilization materials form chemical bonds
between the contaminants and the matrix. The exact nature of
these bonds, however, is uncertain. The primary concern with
this technology is potential leaching of the contaminants from
the stabilized matrix, although the physical-chemical changes to
the contaminants as they are bound into the matrix should reduce
the likelihood of leaching.
Although stabilization is a proven technology for metals,
stabilization of organics has not been previously implemented as
a remedy. Its long-term effectiveness and its permanence for
organics are unknown. Some stabilization techniques for these
soils may encapsulate the organics without chemically binding
them. The major difficulty in implementing a stabilization
remedy for explosives and PAHs would be ensuring that the
contaminants do not leach from the matrix. If sample analyses
indicate leaching, the remedy would not be effective.
Placement of the stabilized soils in an on-site RCRA
Subtitle C Hazardous Waste Landfill or lined disposal cell
provides a greater degree of long-term effectiveness. The soil
cover, the secondary containment system in the disposal cell, and
future land-use restrictions would minimize further contact with
the contaminants and the possibility of contaminants re-entering
the environment, thereby reducing the long-term risks in the
event of failure of the stabilized matrix for as long as the
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integrity of the disposal unit is maintained. Proper operation
and maintenance of the on-site RCRA Subtitle C Hazardous Waste
Landfill or lined disposal cell, including continued monitoring
and the application of land-use restrictions, would be required
since contaminated material would remain on-site. This would
help ensure that the landfill or disposal cell effectively
contained the contaminated soil and that any releases were
promptly identified.
Alternatives 3, 5, and 7 provide for containment of
stabilized materials. Alternative 2 calls for placement
untreated soils directly into an on-site RCRA Subtitle C
Hazardous Waste Landfill.
of the
Alternative 5 calls for incineration of all of the TNT- and
PAR-contaminated soils, and thus provides the greatest degree of
permanence among the alternatives. This alternative only
utilizes stabilization for the metals-contaminated soils and
treatment residuals. Since this is a proven technology, a high
degree of long-term effectiveness is associated with this
alternative. Since only the metals-contaminated materials remain
on-site, the residual risk at the subsite is minimized.
Alternative 7 calls for the incineration of only the soils
believed to pose the highest potential h~an health hazards
(soils with concentrations exceeding 10- levels) thereby
permanently eliminating the risks attributable to these soils.
This alternative stabilizes t~e soils ~ith low concentrations of
TNT and PARs (between the 10- and 10- levels), as well as the
metals-contaminated soils and treatment residuals. Due to the
uncertainties associated with stabilization of organics, this
alternative's long-term effectiveness is less certain. The
secondary containment of these materials in a RCRA Subtitle C
Hazardous Waste Landfill, however, reduces the uncertainties and
increases the degree of long-term effectiveness by minimizing
potential exposure and migration of contaminants if stabilization
fails to immobilize the contaminants over the long term.
If stabilization of the TNT- and PAR-contaminated soils is
ineffective, Alternative 7 calls for direct placement of the
soils containing low concentrations of these contaminants in the
on-site RCRA Subtitle C Hazardous Waste Landfill. If TCLP
testing reveals that these soils are RCRA characteristic
hazardous wastes, an alternative treatment technology would be
applied to the soil to achieve the appropriate BDAT treatment
standards or soil and debris variance levels, prior to placement
in the landfill.
Alternative 3 calls for stabilization of all of the
materials and places them in an on-site lined disposal cell. The
same uncertainties are associated with this alternative as with
Alternative 7, but since the soils containing the higher
concentrations of TNT and PARs remain on-site, (i.e., none of the
contaminants are permanently destroyed) a lesser degree of
permanence is associated with this alternative, although its
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long-term effectiveness is likely to be comparable to other more
permanent alternatives as long as the disposal cell's integrity
is maintained.
The lack of secondary containment in Alternative 4 provides
a greater degree of uncertainty as to the potential for leaching
of the stabilized organics and explosives than the other
alternatives where stabilized materials are contained in some
form of lined disposal unit (a RCRA subtitle C Hazardous Waste
Landfill or a lined disposal cell). The proposed monitoring
system for this alternative would be necessary to assess the
adequacy of the technology. since maintenance of the treated
areas to prevent erosion and potential exposure of other treated
wastes would also be required, this remedy is not considered a
permanent solution.
Alternative 2, however, calls for placement of untreated
soils directly into a RCRA Subtitle C Hazardous Waste Landfill.
While a high degree of long-term effectiveness may be associated
with landfills (assuming proper operation and maintenance), in
the case of failure, the potential for exposure or migration of
the contaminants is greater than for the alternatives utilizing
both stabilization and placement in a land disposal unit.
Landfills are generally not considered permanent remedies since
the contaminated materials remain on-site, necessitating long-
term monitoring and maintenance. The uncertainties associated
with stabilization may make Alternative 4 comparable in long term
effectiveness to Alternative 2.
4. REDUCTION OF TOXICITY, MOBILITY, OR VOLUME THROUGH TREATMENT
This criterion assesses the degree to which hazardous
substances would be treated to permanentlY and significantly
reduce toxicity, mobility, or volume (TMV). This is accomplished
by analyzing the destruction of toxic contaminants, the reduction
of the total mass of toxic contaminants, the irreversible
reduction in contaminant mobility, or the reduction of total
volume of contaminated material.
Alternatives utilizing incineration (5 and 7) reduce the
volume, toxicity and mobility of the PAH- and TNT-contaminants.
Incineration has been shown to achieve a destruction and removal
efficiency for organics of greater than 99.99%. Because the
organic contaminants are essentially destroyed, incineration
would eliminate the toxicity, mobility, and volume of these
contaminants. Approximately 90% by weight of the soil mass put
into an incinerator is expected to remain following incineration.
Alternative 5 calls for incineration all of the TNT- and PAH-
contaminated soils and therefore achieves the greatest reduction
in TMV.
All of the alternatives which stabilize contaminated soils
(Alternatives 3, 4, 5, and 7) achieve reductions in either
toxicity, mobility, or volume of the stabilized contaminants.
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The degree of reduction in TMV, however, is uncertain since the
most effective technologies for the HEIP subsite would be
determined after completion of the necessary studies. The
physical-chemical changes to the inorganic contaminants as they
are bound into the matrix would reduce their ability to be
leached (i.e., they are immobilized). Additionally, these
changes may reduce the toxicity of metal contaminants, although
the degree to which this occurs is uncertain. Stabilization of
the TNT and PAHs would at least encapsulate the contaminants and
render the stabilized mass less permeable. The net result would
be a reductio~ in the mobility of these contaminants; the degree
to which this is achievable is unknown. The volume of soil
contaminants would not increase due to the addition of
stabilizing agents and water. However, the soil mass is expected
to increase from 5 to 60 percent.
5. SBORT-TERM EFFECTIVENESS
The short-term effectiveness criterion addresses the effects
of an alternative during the implementation phases through the
achievement of remedial action objectives. These include the
protection of workers and the community during construction and
implementation, possible environmental impacts resulting from
construction or implementation, and the amount of time necessary
to achieve the remedial action objectives.
The short-term risks associated with the excavation and land
disposal alternatives (2, 3, 5, and 7) include potential worker
exposure through inhalation, ingestion and dermal contact with
contaminants during excavation and handling of contaminated
materials and potential exposure of the public and the
environment to incineration stack emissions and fugitive dust.
These potential exposures could be effectively minimized and
controlled by the use of proper engineering controls (e.g, dust
suppressants and emission controls) and institutional controls
(restricting access to excavation, disposal and process areas).
Worker exposure would be minimized by requiring appropriate
personnel protection equipment and complying with OSHA
requirements and guidelines for hazardous waste site activities
including air monitoring.
The nature of the former NAD's activities raises some
specific health and safety concerns for the subsite. Ordnance
debris which may be encountered during subsite activities may
include unexploded ordnance (UXO). While no actual unexploded
ordnance has been found on the subsite, any ordnance debris
encountered must be handl~d as uxo to ensure adequate worker and
public safety. Appropriate precautions would be taken during
excavation and other subsite activities to prevent any accidental
encounter with Uxo. The USACE's Huntsville Division is currently
investigating the NAD for unexploded ordnance. Site work would
only be conducted after consultation with the Huntsville Division
and appropriate precautions have been taken to ensure the safety
of site workers.
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Because incineration is a complex industrial operation,
there is always the risk of accidents. Risks associated with the
incineration alternatives (5 and 7) would be minimized by
following proper operation, maintenance and safety procedures in
the operation and contingency plans.
Incineration of the soils contaminated with explosives is
not expected to present an unacceptable explosion hazard at the
known concentration levels in the subsite soils. Appropriate
Army safety reviews would be done to determine whether explosives
concentrations approach reactive limits. If so, additional
safety reviews would be done to approve soil processing
equipment, location and operations. In 1987, similar soils were
safely incinerated at the Cornhusker Army Ammunition Plant, near
Grand Island, Nebraska (approximately 40 miles north of
Hastings). These soils had higher concentrations of explosives
than the HElP soils. Soils with concentrations of up to 97,100
mg/kg TNT, 6380 mg/kg 2,4-DNT, 14,300 mg/kg RDX were safely
incinerated at that site.
potential environmental impacts associated with these site
activities include noise, possible dust emissions resulting from
excavation and handling of significant volumes of contaminated
soil, construction of disposal and process areas, implementation
of the treatment technologies, and air emissions during
incineration. Mitigation procedures would include phasing of
excavations and drainage rerouting along with sedimentation and
erosion control during both excavation and construction. The
temporary and permanent surface water diversions and changes in
topography resuiting from landfill construction would also ha7e
an environmental impact on the subsite. These actions, however,
should not cause significant detrimental or irreversible impacts.
Adverse effects on the nearby wetlands from site activities are
not expected. Any alteration in topography at the site would not
be expected to alter the volume or ultimate flow path of the
surface water run-off. During construction, sedimentation and
erosion controls would be implemented to minimize any negative
effects on the wetlands. The possibility that particulates may
be carried towards the wetlands is minimal since dust suppression
would be used to mitigate this potential hazard. Stack emission
controls would be utilized during incineration.
Since excavation of the soils is not required in
Alternative 4, the potential for worker and community exposure to
contaminants is much less than with the other alternatives.
Risks would further be reduced by dust emissions controls which
would be required during the injection of reagents and mixing
operations. Environmental impacts would be limited to potential
sedimentation and erosion caused by surface water diversions and
areas disturbed during implementation of the in-situ technology.
These impacts would readily be mitigated by implementing
appropriate controls and precautionary procedures, including air
emissions, sedimentation and erosion controls.
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All of the alternatives have similar short-term risks.
However, some difference exists between the alternatives with
respect to the length of time necessary to complete the cleanup.
The alternatives with longer remedial action periods would a~so
have longer periods of worker exposure to short-term risks. The
estimated remedial action periods for each alternative are:
Excavation-an-site Landfill
Excavation-Stabilization
In-situ Stabilization
Excavation-On-site Incineration
-Stabilization
7 Excavation-an-site Incineration
-Stabilization-On-site Landfill
2
3
4
5
2-1/2 to 4 years
3 years
3 years
3 to 4-1/2 years.
3-1/2 to 5 years
The remedial action period estimated for Alternative 7 is longer
than the remedial action period estimate for Alternative 5 to
account for the time needed for TNT- and PAH- stabilization
studies. If a different emergent destruction technology is
implemented for Alternative 7, the estimated remedial action
period could be longer.
6. IMPLEMENTABILITY
The implementability criterion addresses the technical and
administrative feasibility of implementing an alternative and the
availability of various services and materials required for
implementation. Technical feasibility encompasses the technical
difficulties and unknowns associated with the alternatives, the
reliability of the technologies, and monitoring requirements.
Administrative feasibility includes activities which must be
coordinated with other offices and agencies. Availability of
services and materials includes the availability of necessary
equipment and specialists, the ability to obtain competitive
bids, and the availability of remedial technologies. .
Implementation of the alternatives would involve
conventional construction technologies for the excavation of the
contaminated soil and construction of a landfill or disposal
cell. These activities, while labor intensive, are easily
implementable and the required materials are readily available.
The landfill or disposal cell would be relatively easy to
maintain. The integrity of the cap and liner systems would be
assessed by monitoring the amount of leachate production. Land
use and development restrictions would be necessary to ensure the
integrity of the cap. If the landfill components were to fail,
additional future remedial action may be necessary.
The use of a mobile incinerator to destroy organic
contaminants is a proven and reliable technology (Alternatives 5
and 7). operation and maintenance requirements for a mobile
incinerator are extensive and require fully trained personnel who
are normally provided by the incinerator owner/operator. All the
necessary technologies are readily available. However, the
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number of mobile incinerators is limited and the availability of
one at the time of implementation of the remedial action cannot
be predicted at this time.
stabilization is a proven technology for metals and should
be relatively easy to implement (Alternatives 3, 4, 5, and 7).
Studies would be required to determine the most effective
stabilizing agents for the subsite's inorganic contaminants.
Stabilization of the organics and explosives is not a proven
technology and more extensive testing would be necessary to
determine th~ most effective method for stabilizing these
contaminants. Alternatives 3, 4 and 7 utilize stabilization for
these contaminants.
Alternative 4 requires the injection of stabilizing agents
and water into the contaminated soils and mixing in place to the
depth of contamination. certain specialized equipment is
required (generally an injection device with either an auger and
mixing blades or a backhoe or bulldozer) and may have limited
availability. The scattered nature of the areas of contamination
adds further complexity to the implementation of this alternative
since materials must be stockpiled at each area and equipment
moved from area to area. Monitoring to determine the
effectiveness of this alternative may be more difficult to
implement than the monitoring for alternatives which contain the
treated or untreated contaminated materials in a disposal unit
specifically constructed to meet monitoring requirements
(landfill or disposal cell).
For the alternatives with on-site placement of treated or
untreated materials (2, 3, 5 and 7) various substantive
requirements must be met which would require a certain amount of
administrative coordination (e.g., coordination between EPA,
USACE and NDEC). Additionally, privately-owned land for the on-
site disposal cell or landfill must be purchased. These actions
are feasible.
Due to the similar number of uncertainties involved with
each of the excavation and stabilization alternatives (3, 4, 5,
and 7), the feasibility of implementation for these alternatives
appears to be comparable. Since no stabilization studies would
be required for Alternative 2, this alternative would be the
easiest to implement. Alternative 4 may be a little more
difficult to implement than the other alternatives due to the
specialized nature of required equipment. The incineration
alternatives (5 and 7) should be readily implementable but the
availability of mobile incinerator at the time of implementation
of the remedial action is uncertain.
7. COST
The cost evaluation of each alternative included capital
costs, annual operation and maintenance costs, and a present
worth analysis.
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The estimated present worth cost for each of the
alternatives are as follows:
2 - Excavation-On-site Landfill
3 - Excavation-Stabilization
4 - In-situ Stabilization
5 - Excavation-On-site Incineration
-Stabilization
7 - Excavation-On-site Incineration
-Stabilization-On-site Landfill
$ 9,000,000
$ 26,000,000
$ 30,000,000
$ 83,000,000
$ 45,000,000
capital and annual O&M costs are used to calculate estimated
present worth costs for each alternative. Annual O&M cost
estimates for all of the alternatives except Alternative 4 are
comparable ($73,000 to $86,000). Alternative 4 has an estimated
annual O&M cost of $467,000 as a result of the additional
monitoring required to assess the effectiveness of this remedy.
The capital and present worth costs for Alternative 7 have
been revised as discussed in Section VII. The revised costs
include $1,286,000 for temporary on-site storage. The provision
for temporary on-site storage and the associated costs are unique
to Alternative 7.
8. STATE ACCEPTANCE
This criterion assesses the technical and administrative
issues and concerns the state may have regarding the
alternatives.
NDEC concurs with the remedy selected in this ROD. A copy
of the concurrence letter from NDEC's Director to the Regional
Administrator of EPA Region VII is Attachment B to this ROD.
NDEC has been actively involved in the oversight of USACE's
investigations of the HEIP subsite. NDEC commented on the RI and
FS reports, participated in the public meeting and worked on the
proposed plan with EPA.
9. COMMUNITY ACCEPTANCE
This criterion assesses the issues and concerns of the
public regarding the alternatives.
Community acceptance is assessed in the attached
Responsiveness Summary. EPA is aware of no community opposition
to the components in the selected remedy. The Responsiveness
Summary provides a thorough review of and EPA's response to the
comments EPA received from the public regarding the remediation
of the surface soils. Very little public comment was received.
A few comments were received at the public meeting, none of which
expressed dissatisfaction with the preferred alternative.
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IX.
SELECTED ALTERNATIVE
Based on upon consideration of the requirements of CERCLA,
detailed analysis of alternatives and public comments, EPA has
selected Alternative 7 (Excavation - On-site Incineration -
Stabilization - On-site Landfill) as the response action for
surface soils at the HEIP subsite. .
The remedy will include excavation of all surface soils with
contaminant concentrations the exceeding cleanup goals (see Table
VI-1) established for the protection of human health and the
environment and discussed in section VI. The volume of soils to
be excavated is estimated to be 125,900 cubic yards.
The extent of contamination in the HEIP surface soils has
not been completely characterized. The contamination boundaries
(e.g., the lateral and vertical extent of the contamination) have
not been fully defined. The volumes and areas of contamination
discussed in Section V, are calculated from the contamination
boundaries identified in the remedial investigation. These
boundaries, and subsequently the corresponding volumes and areas
of contaminated soils, will be better defined through additional
soil sampling during the remedial design phase of the remedial
action.
Based on the type and concentrations of contaminants
present, the excavated surface soils will be either (1)
stabilized at a central location on the HEIP subsite by mixing
the soil with water and compounds that immobilize and/or
encapsulate the contaminants or (2) treated in an on-site
incinerator. The excavated soils will be segregated by
contaminant and contamination level prior to treatment.
Surface soils to be treated by on-site incineration will
include approximately 16,400 cubic yards of soil contaminated
with TNT or total cariinogenic PAHs exceeding the excess cancer
risk level of 1 x 10- for on-site residents. These soils have
concentrations which exceed the following levels:
660 mg/kg for TNT
1.8 mg/kg for PAHs
The TNT and PAH contaminants will be destroyed in the
incineration process. Operation of the incinerator will include
safety and emissions control equipment.
Incineration residue (ash) will be tested for residual
contamination. The contaminant-free incineration soil residue
(ash) will be replaced in excavated areas and supplemented with
clean backfill if necessary. The incineration soil residue
will then be covered with 12 to 18 inches of clean 80il.
Incineration residues containing metal contaminants will be
stabilized. Treatment residuals, including sludges from the
scrubber system and material from the electrostatic precipitator,
may require treatment prior to on- or off-site disposal.
76
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Surface soil contaminated with metals at levels exceeding
the cleanup goals (approximately 39,000 cubic yards) will be
stabilized. Since stabilization of metals is a proven
technology, only limited testing will be required to determine
the most effective method of stabilizing the HElP soils.
The remaining 70,500 cubic yards of soil will also be
stabilized. This portion of the excavated soils includes surface
soils contaminated with total carcinogenic PAHs, TNT, or both, at
concentrations exceeding the levels established fir the
protection of public health but below the 1 x 10- excess cancer
risk levels discussed above. Although stabilization is a proven
technology for metals, stabilization of organics is has not been
previously implemented as a remedy. Therefore, a variety of
tests will be necessary to determine the most effective method of
stabilizing these low-level TNT- and PAH-contaminated soils.
Stabilized soils and contaminated incinerator residues will
be placed in an on-site RCRA Subtitle C Hazardous Waste Landfill
and capped as required by RCRA regulations. Post-closure care
will include periodic inspections and maintenance of the landfill
and monitoring of the unsaturated soils below the landfill and
the ground water.
If stabilization is not effective for the low-level PAH- and
TNT- contaminated soils, the soils will be placed untreated into
the on-site RCRA Subtitle C Hazardous Waste Landfill. However,
if these soils fail to pass the TCLP or other RCRA characteristic
tests (ignitability, corrosivity and reactivity), and are
therefore RCRA c~aracteristic wastes, RCRA LDRs will prohibit the
placement of these untreated soils directly into the landfill.
Prior to placement, the appropriate BDAT (best demonstrated
available technology) treatment standard or soil and debris
variance level will be met through the application of an
alternative treatment technology to the soils. Parameters for
determining the effectiveness of stabilizing technologies' will be
addressed in the design of the planned treatability studies.
Under authority delegated to the USACE by the Department of
Defense (ooD) as a part of the Defense Environmental Restoration
Program (DERP), USACE is currently investigating two other areas
located on the former NAD (not associated with the HElP subsite
or the Hastings Ground Water Contamination site). These two
areas, referred to as the Explosives Disposal Area and the Yard
Dump Area, may contain soils with contaminants similar to those
at the HElP. Sampling and analysis may show that these soils
require treatment by incineration. If this proves to be the
case, the most cost-effective treatment method could be to
combine contaminated soils from these areas with soils to be
incinerated from the HEIP subsite for incineration concurrently
or sequentially. This approach will eliminate the high costs
associated. with setting up and demobilizing an incinerator more
than once, or allowing the unit to remain inactive on-site for an
extended period of time.
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A three year period will be allowed in which the USACE may
further investigate the Explosives Disposal and Yard Dump areas
(areas of possible contamination adjacent to the HEIP subsite).
During the three year period the US ACE may also investigate any
emerging destruction technologies which are currently under
development which may provide a contaminant destruction
efficiency comparable to that of incineration at lower cost.
Design and implementation for the remedial actions at the
HEIP (excavation, stabilization and construction of the landfill)
will begin soon after signature of this ROD. Upon excavation and
segregation, however, soils designated for incineration may be
temporarily stored on-site in a manner consistent with RCRA
requirements for temporary storage of hazardous wastes.
By the end of the three year period, the USACE must:
o
Determine if contaminated soils from the Explosives
Disposal and Yard Dump areas or other similarly
contaminated areas of the former Hastings Naval
Ammunitions Depot, will be treated along with the
subsite soils by a destruction technology. However, no
additional delay in the implementation of the remedy
set forth in this ROD will be allowed for investigation
of non-subsite areas of contamination.
o
Implement incineration or select an alternate emergent
destruction technology which is equally as effective as
incineration. If incineration is to be implementec"
the USACE must have completed the design on the
incineration portion of the remedy and must have begun
preparation for incineration. If another destruction
technology is chosen, the USACE will immediately
initiate its design. Implementation of an alternative
destruction technology will then begin in a timely
manner.
Design and implementation of the other components of the
remedy are not subject to the three year grace period and must be
initiated in a timely manner upon signature of this ROD. Any
fundamental changes to the remedy set forth in this ROD (i.e.,
utilization of an alternative destruction technology) would be
issued in a ROD amendment upon completion of the appropriate
public participation and documentation procedures specified in
Section 117 of CERCLA.
Additional institutional and technological requirements for
the remedy include: placement of a security fence around the
landfill; periodic site inspections and maintenance for the
lifetime of the disposal cell to monitor the effectiveness of the
remedy; ground water, leachate and unsaturated zone monitoring;
land purchases or easements for the construction of the landfill
and access roads will be obtained from private parties; land use
and development restrictions for the landfill to protect the
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integrity of the cap; possible installation and operation of a
water treatment facility for decontamination, process (including
scrubber) and leachate waters; and appropriate health and safety
precautions to protect the public and the site workers. "
Decontamination of trucks, mixing equipment and other site
equipment that have been in contact with contaminated soils will
be conducted prior to the equipment leaving the excavation and
disposal areas.
.
No contaminant-specific ARARs have been promulgated for the
remediation of contaminated soils. Most location-specific ARARs
do not apply'because the HEIP subsite is not in or near a
floodplain, wilderness area, historic site, or other protected
environment.
Action-specific ARARs exist for various components of the
remedy. For on-site remedial activities, only the substantive
requirements of ARARs must be met. The Final FS Report (USACE,
1990a) includes a description ARARs for components of the remedy
'taken from the alternatives analyzed in the FS. These ARARs
include:
o Resource Conservation and Resource Recovery Act (RCRA)
of 1976 as amended by the Hazardous and Solid Waste
Amendments (HSWA) of 1984 - identification of wastes,
treatment, destruction, storage, transport and disposal
requirements for solid wastes and RCRA listed and
characteristic hazardous wastes;
.
o Occupational Safety and
aspects of remediation, OSHA
workers, as stated in 40 CFR
compliance.
Health Act (OSHA) - during all
regulations for protection of
Section 300.38, will require
o Clean Water Act - Water treated by a water treatment
system located on-site and discharged to on-site surface
waters must meet the substantive requirements of this act.
o Clean Air Act - emissions from incineration, surface
impoundments, landfills, waste piles, and fugitive dust
emissions released during remedial activities may be subject
to the substantive requirements of this act.
o Nebraska Environmental Protection Act - includes rules
and regulations pertaining to solid waste management
facilities; hazardous waste treatment, storage and disposal
facilities; air pollution control including incineration and
excavation emissions; and discharge of pollutants from a
point source into any waters of Nebraska. The substantive
requirements of this act must be met for on-site activities.
TCLP testing of the HEIP soils will be required during the
design of the remedy to determine if the LDRs are ARARs for this
action. It is possible that some portion of the soils at the HEIP
subsite will not pass the TCLP test. Prior to placement, RCRA
79
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characteristic soils will be treated to the appropriate BDAT
standards or soil and debris variance levels prior to placement
in the on-site RCRA Subtitle C Hazardous Waste Landfill.
Performance standards for hazardous waste incinerators are
provided in the RCRA regulations. These regulations constitute
ARARs for hazardous waste incineration of explosives and PAHs.
It is anticipated that all thermal treatment options will attain
the identified applicable or relevant and appropriate thermal
treatment requirements.
The remedy will comply with LOR ARARs because this
alternative calls for application of the appropriate treatment
technology to the soils and incineration residues prior to place-
ment in the land disposal unit. The residue from the incinera-
tion process will then be tested to determine whether it exhibits
any RCRA hazardous characteristics. If RCRA characteristic
wastes are present in the soils or incineration residues, it is
anticipated that the appropriate BDAT treatment standard or soil
and debris treatability variance level will be met. However, if
stabilization of the PAH- and TNT-contaminated soils and
incineration residues is not effective and these standards are
not met, this remedy will not meet the LDR ARAR.
Construction and closure of the on-site RCRA Subtitle C
Hazardous Waste Landfill will be consistent with RCRA
regulations. If the soils to be stored at the HEIP subsite
exhibit any hazardous characteristic, the RCRA storage
requirements will be applicable to the storage option. It is
anticipated that storage ARARs will be attained by the remedy.
It is anticipated that other ARARS for the remedy, including
the Nebraska Regulation of Disposal Sites Statute, will be met.
The remedy meets LDRs by treating metals-contaminated soils
prior to placement in a land disposal unit. If, based on the
TCLP results, these soils are RCRA characteristic hazardous
wastes the treatment (stabilization) will address the
Treatability Variance levels for 'soil and debris contamination.
Stabilized metals will be tested with the TCLP prior to placement
in the on-site landfill. Incineration of soils with high levels
of TNT and PAHs will destroy the contaminants and placement of
residual "clean" ash will not invoke LDRs. However, soils
containing concentrations of eXPlosives agd PAHs which present a
health-based risk of between 10- and 10- have to be treated
prior to placement in the on-site landfill if they fail the TCLP
(i.e., concentrations of the contaminants in the leachate is
above regulatory levels).
It is anticipated that all the treatment technologies
selected for the characteristic hazardous wastes will meet the
treatability requirements of the LDR regulations. The remedy
calls for treatability studies and only those treatment
technologies which meet LDR requirements will be applied.
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The estimated time to complete the design and implement the
remedy is 3-1/2 years to 5 years. The time estimate is detailed
as follows:
18 - 26 months:
9 - 13 months:
9 - 12 months:
4 - 6
months:
1 - 2
months:
Additional soil sampling, testing of the
stabilization process, and engineering
design.
Site preparation, field testing of
stabilization process, and landfill
construction.
Excavation of contaminated soils,
incineration, stabilization, and
placement of stabilized soils in
landfill.
Construction of landfill cap.
Site closure.
If an alternate emergent destruction technology is selected, the
time estimate will change.
The present worth cost of the remedy is $45 million. A
summary of the costs is presented in Table IV-1. The capital
($44 million) and present worth costs for the remedy have been
revised from those published in the Proposed Plan (EPA, 1990).
The revised costs include $1,286,000 for temporary on-site
storage and $407,000 for treatment of decontamination water and
leachate. The provision for temporary on-site storage is unique
to the remedy. Detailed storage cost estimates were
provided in the Proposed Plan. These costs were not included in
the total capital and present worth costs in the Proposed Plan.
For the alternatives presented in the Final FS Report
(U5ACE, 1990a) (ROD Alternatives 1 through 6) it was assumed that
any decontamination water, leachate or process water will be
treated by one of the following three treatment systems: an on-
site mobile treatment unit; an on-site ground water treatment
unit (associated with the ground water operable unit for the
subsite); or an off-site treatment facility.
The cost estimates for this Proposed Plan's Preferred
Alternative (ROD Alternative 7) did not include costs for either
an on-site mobile treatment unit or an off-site treatment
facility because it was assumed that any wastewater generated
could be blended with the contaminated ground water which is
likely to be extracted concurrently to the soil remediation as
part of the ground water operable unit and treated in the full-
scale ground water treatment unit. The costs for an on-site
water treatment facility have been added to the cost estimates
for the remedy in order to be consistent with the cost
estimates for the other alternatives. The revised costs are
provided in detail in Appendix A to this ROD.
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TABLE IX - 1
cost Estimate Summary
Excavation - On-site Incineration-Stabilization - On-aite Landfi
CAPITAL COST
preparation/construction
Incineration
Fization/Stabilisation
Landfill Di8po8al
Surface water Diversion
Temporary storage
Decontamination Water'
Leachate Treatment
SUBTOTAL
Bonds' Insurance (3%)
Bid contingencies (15%)
scope contingencies (20%)
Investigation' Engineering
Design Costs (10%)
TOTAL
- CONSTRUCTION COSTS
Permitting and Legal (5%)
construction services (10%)
TOTAL CAPITAL COSTS
O&M COSTS
Landfill O'M and Ground water Monitoring
First Year After Remediation
Remaining Years
unit Cost contingencies (10 \)
Scope of contingencies (15%)
Administrative Costs(15\)
$113,880
11,000
17,000
17,000
TOTAL - O'M COSTS
First Year After Remediation
Remaining Years
$159,000
PRESENT WORTH COST
Base~ on 30-year Life and 5 percent Discount Rate
82
$2,867,000
',577,000
',729,000
2,293,000
133,000
1,285,000
407,000
$25,886,000
777,000
3,883,000
5,177,000
2,589,000
$38,312,000
1,916,000
3,831,000
$44,000,000
61,740
6,000
9,000
9,000
$86,000
$45,000,000
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x.
STATUTORY DETERM~NAT~ONS
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that achieve
adequate protection of human health and the environment. In
addition, section 121 of CERCLA establishes several other
statutory requirements. These specify that when complete, the
selected remedial action for this site must comply with the
applicable or relevant and appropriate environmental standards
established under Federal and state environmental protection laws
unless a statutory waiver is justified. The selected remedy also
must be cost-effective and utilize permanent solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. Finally, the
statute includes a preference for remedies that employ treatments
that permanently and significantly reduce the volume, toxicity or
mobility of hazardous wastes as their principal element. The
following sections discuss how the selected remedy meets these
statutory requirements.
Protection of Human Health and the Environment:
The selected remedy protects human health and the
environment by removing, destroying and/or stabilizing all
contaminants in the surface soils that exceed the health-based
standards (cleanup goals). The residual contamination in the
surface s01ls will pose no significant human health hazard. This
will be accomplished by the permanent dest~ction of the
contaminants in the soil which exceed a 10- potential excess
cancer risk. These surface soils pose two of the principal
threats at the subsite: potential human health hazards due to
ingestion or dermal exposure to soils with high concentrations of
TNT and PARs, and the potential for migration of soil
contaminants to the ground water. Stabilization of the metal-
contaminated soil and the soils_gontaini~i lower concentrations
of TNT and PAHs (between the 10 and 10 levels) and placement
in an on-site RCRA Subtitle C Hazardous Waste Landfill will also
reduce the potential for exposure to the site contaminants and
contaminant migration to the ground water.
Compliance with Applicable or Relevant and Appropriate
Requirements:
It is anticipated that the selected remedy will achieve the
provisions of every applicable, or relevant and appropriate
requirement (ARARs) for the protection of public health and the
environment. Requirement~ to be met prior to incineration of
soil include demonstration of destruction of 99.99% of the
targeted organic contaminants. In addition, the selected remedy
would meet all of the requirements of the Resource Conservation
and Recovery Act (including landfill construction and design
requirements, landfill closure requirements, land disposal
restrictions~ treatment standards and RCRA storage requirements),
the Clean Air Act, the Occupational Safety and Health Act, the
Nebraska Environmental Protection Act, Nebraska regulations
83
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pertaining to disposal sites, and the Nebraska Water Well
Contractor Licensing Act. Prior experience by EPA with similar
remedial activities elsewhere in Nebraska indicates that these
requirements are achievable.
Cost Effectiveness:
The selected remedy is cost-effective because it provides
the best balance among the evaluation criteria. It provides a
higher degree of overall protection than the less costly
alternatives. by utilizing proven technologies (incineration and
stabilization of metals) to address the surface soil's principal
threats; the potential health risk posed by high concentrations
of TNT and PAHs and the presence of metals in the surface soils,
and the potential for further contamination of the ground water.
A less costly technology (stabilization) will address the large
volume of soils with concentrations of TNT and PARs which
represent a lower potential public health risk. The selected
remedy maximizes the benefits of incineration by destroying only
the highly contaminated soils at approximately half the cost of
incinerating all of the explosive- and PAH-contaminated soils.
Therefore, the remedy selected remedy is the most cost-effective
alternative that is also highly protective.
Utilization of Permanent Solutions and Alternate Treatment
Technologies or Resource Recovery Technologies to the Maximum
Extent Practicable:
Section 121 of CERCLA requires the utilization of permanent
solutions and alternate treatment technologies or resource
recovery technologies to the maximum extent practicable. EPA
believes that the selected remedy represents the maximum extent
to which permanent solutions and treatment technologies can be
utilized in a cost-effective manner for this surface soils
operable unit at the Hastings East Industrial Park subsite. Of
those alternatives that are protective of human health and the
environment and comply with ARARs, EPA has determined that this
selected remedy provides the best balance of tradeoffs in terms
of long-term effectiveness and permanence, reduction in toxicity,
mobility and volume achieved through treatment, short-term
effectiveness, implementability, cost, consideration of the
statutory preference for treatment as a principal element, and
State and community acceptance.
While more expensive than some of the other alternatives,
the selected remedy provides a greater degree of permanence and
effectiveness than the Excavation - On-site Landfill Alternative
2 and the Excavation - Stabilization and In-situ Stabilization
Alternatives (3 and 4, respectively) by destroying the soils
representing the principal potential public health threat at the
subsite. The remedy further ensures the effectiveness of
stabilization by placing all stabilized materials in an on-site
RCRA Hazardous Waste Landfill. The remedy utilizes proven
technologies (incineration and stabilization of metals) to
address the principal subsite risks. Stabilization of the low
84
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level PAH- and TNT-contaminated soils is much less costly than
incineration of all of the organics-contaminated soils. Thus,
the remedy maximizes protectiveness and effectiveness for,
approximately half of the cost of the Excavation - On-site
Incineration - Stabilization Alternative 5.
Preference for Treatment &8 & principal Element:
By treating the soils containing high levels of PAH and TNT
contamination by incineration and by stabilizing the metals-
contaminated .soils and metals-contaminated treatment residuals
prior to placement in an on-site landfill, the remedy addresses
the principal threats at the subsite through the use of treatment
technologies. Therefore, the statutory preference for remedies
that employ treatment as a principal element is satisfied.
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XI.
DOCUMENTATION OP SIGNIPICANT CHANGES
The EPA released their proposed Plan for the HEIP subsite
for public comment in June 1990. The Proposed Plan identified
the Excavation - On-site Incineration - Stabilization - On-site
Landfill Alternative (ROD Alternative 7) as the preferred
alternative. The preferred alternative was a combination of
elements from several of the alternatives described in the Final
FS Report (USACE 1990a). Detailed cost estimates for the
preferred alternative were appended to the proposed Plan.
However, the detailed costs did not include the costs associated
with treatment of decontamination water. The capital and present
worth cost estimates also did not include the costs for temporary
on-site storage of the soils to be incinerated. Detailed cost
estimates including both temporary storage and treatment of
decontamination water are attached to this ROD. The cost
estimates for ROD Alternative 7 (the selected remedy) reflect the
addition these costs. The $43 million was the present worth cost
estimate in the Proposed plan for the preferred alternative. The
revised present worth cost estimate in this ROD is $45 million.
RCRA characteristic wastes may not be land disposed without
treatment under the RCRA LDR regulations. The LDRs were not
identified as an ARARs for the HEIP subsite in the proposed Plan.
All of the excavated HEIP soils will have to be tested for
ignitability, corrosivity, reactivity and toxicity
characteristics to determine whether the are RCRA characteristic
wastes. The method to be used to determine presence of the
toxicity characteristic, was promulgated by EPA in March of 1990
as part of the Toxicity Characteristics (TC) rule. At that time,
the TC rule became a potential ARAR for all RODs signed after
that date. The TC rule identified a new procedure, the TCLP, to
be used to test wastes for RCRA characteristic toxicity.
Formerly, the Extraction Procedures test, also known as the EP-
TOX, was used to determine the toxicity of a waste. The impact
of LDRs as ARARs is discussed in greater detail in sections VII -
IX of this ROD.
Conversations with USACE, since the development of the
proposed plan, have indicated that the U.S. Army Toxic and
Hazardous Materials Agency health and safety policies forbid the
use of solvent extraction for treatment of explosives
contaminated soils due to the known unacceptable explosive hazard
that results from concentrating and heating the explosive
contaminants during this process. Therefore, this alternative is
not an acceptable remedy for the surface soils operable unit and
is not discussed beyond the "Protectiveness of Human Health and
the Environment" criteria in section VIII.
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XII.
REFERENCES
Anderson, E., Browne, N., Duletsky, S., Warn, T. 1984.
Development of statistical Distributions of Ranges of
Standard Factors used in Exposure Assessments. Washington,
D.C.: U. S. Environmental Protection Agency, Office of
Health and Environmental Assessment.
.
ATSDR 1988a. Agency for Toxic Substances and Disease Registry.
Toxicological profile for lead (draft). Oak Ridge, TN: Oak
Ridge National Laboratories.
ATSDR 1988b. Agency for Toxic Substances and Disease Registry.
Toxicological profile for trichloroethylene (draft). Oak
Ridge, TN: Oak Ridge National Laboratories.
EPA 1990. U.S. Environmental Protection Agency. Proposed Plan
for Surface Soils Operable Unit, Hastings East Industrial
Park Subsite, Hastings, NE. Kansas City, KS: U.S.
Environmental Protection Agency, Region VII. June 1990.
EPA 1989a. U.S. Environmental Protection Agency. Health Effects
Assessment Summary Tables - Fourth Quarter FY 1989.
Washington D.C.: U.S. Environmental Protection Agency.
October 1989.
EPA 1989b. U.S. Environmental
Research and Development.
System. Wa~hington D.C.:
Agency.
Protection Agency. Office of
Integrated Risk Information
U.S. Environmental Protection
EPA 1989c. U.S. Environmental Protection Agency. Office of
Drinking Water. Trinitrotoluene Health Advisory.
Washington D.C.: U.S. Environmental Protection Agency.
January 1989. .
EPA 1987a. U.S. Environmental Protection Agency. Office of
Drinking Water. Tetrachloroethene Health Advisory.
Washington D.C.: U.S. Environmental Protection Agency.
January 1987.
EPA 1987b. U.S. Environmental Protection Agency. Superfund
Exposure Assessment Manual. Final Draft. Washington D.C.:
U.S. Environmental Protection Agency.
OSWER Directive 9285.51.
EPA 1986. U.S. Environmental Protection Agency.
Public Health Assessment Evaluation Manual.
D.C.: U.S. Environmental Protection Agency.
EPA/540/1-86/060.
Superfund
Washington
87
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Fish
and wildlife Service 1988. Letter from Jerry J. Brabander,
Nebraska State Supervisor, Endangered and Threatened Spe-
cies. Grand Island, NE: U. S. Department of Interior.
January 29, 1988.
Ryan, E.A., Hawkins, E.T., Magee., B., Santos, S.L. 1987.
Assessing Risk from Dermal Exposure at Hazardous Waste
Sites. Superfund '87: Proceedings of the 8th National
Conference (November 16-18, 1987, Washington D.C.). Silver
spring, MD: Hazardous Materials Control Research Institute.
Pages 1~6-168.
USACE 1990a. U. S. Army Corps of Engineers.
Study Report - Hastings East Industrial
volumes). Kansas City, MO: U. S. Army
Kansas City District. June 1990.
USACE 1990b. U. S. Army Corps of Engineers. Final Remedial
Investigation Report - Hastings East Industrial Park,
Hastings NE (3 volumes). Kansas City, MO: U. S. Army Corps
of Engineers, Kansas City District. August 1990.
Final Feasibility
Park, Hastings NE (2
Corps of Engineers,
USACE 1990c. U. S. Army Corps of Engineers. Final Ground Water
Modeling Report - Hastings East Industrial Park, Hastings
NE. Kansas City, MO: U. S. Army Corps of Engineers, Kansas
city District. August 1990.
USACE 1990d. U. S. Army Corps of Engineers. Interim Final
Baseline Risk Assessment Report - Hastings East Industrial
Park, Hastings NE. Kansas City, MO: U. S. Army Corps of
Engineers, Kansas City District. June 1990.
88
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SITE VICINITY MAP
i
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........IL TOI'j C;OUI'jTY
-CL.AYCOUNTY -
,
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-----
40......5 COUI'jTY
- - -.-
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----- -
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---- ----
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- --
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NUCIC0'. CS COUI'jTY-/-
- - --
HASTINCS
.
t
ill
,
NEBRASKA
ONt INCH tQUALS ...~~.O~IWATtlY . WILtS
~inurp 1
-------
ATTACHMENT A
. Detailed costs for the selected remedy (ROD Alternative 7:
Excavation - On-site Incineration - Stabilization - On-site.
Landfill) are summarized in the following tables. These costs
have been revised slightly since they were originally published
for the preferred alternative in the EPA proposed Plan in June
1990.
For all of the alternatives presented in the Final
Feasibility ~tudy, it was assumed that any decontamination
leachate, or process water would be treated by one of the
following three treatment systems:
water,
.
An on-site mobile treatment unit.
.
The on-site ground water treatment unit.
.
An off-site treatment facility.
The cost estimates for the preferred alternative in the EPA
Proposed Plan did not include costs for either an on-site mobile
treatment unit or an off-site treatment facility because it was
assumed that any wastewater generated could be blended with the
contaminated ground water being extracted concurrently to the
soil remediation (in the ground water operable unit) and treated
in the full-scale ground water treatment unit. For the ROD, EPA
specified that the preferred alternative (ROD Alternative 7)
would include a water treatment facility to treat any wastewater
produced during implementation of the preferred alternative.
Therefore, the costs associated with an on-site system have been
added to the cost estimate for the preferred alternative.
Assumptions used in preparing the cost estimate for on-site
treatment include the following:
Average maximum flow would be 2000 gallons per day.
system would be required for approximately 15
months.
Treatment system would be a full-service system from
an oxidationjUV photolysis subcontractor, and would
include the following components:
5000 gal tank for precipitation of solids and
metals
5000 gal tank for pH adjustment
Multi-media filter unit
oxidationjUV photolysis unit
2000 gal effluent tank
Potential for recirculation to pH adjustment
tank if high contaminant loading.
1
-------
Attachment A (continued)
Solids produced during treatment would be stabilized
with the contaminated surface soils, if appropriate.
.
Maximum loading would be 500 ppm total organic
carbon (TOC).
unit would operate 4 hours per day.
. Effluent would be discharged to an on-site tributary.
Effluent sampling would be conducted for organics,
metals, and explosives.
.
After adding the above two items to the cost estimate for
the preferred alternative, the total capital cost estimate is $44
million. The operation and maintenance costs would remain the
same, but the present worth value would increase to $45 million.
2
-------
wntlCs lAST lJrDUSnLU. 'AU.
'UTD.nD IUUAa SOlLS &1.T!1JtATIVE--ZSTlKATED OOIT&1. COSTS
EXCAVAnOIi 01 c:otrrAKlKATID SUklAC! SOlLS - Dts'n.UcnOll/
CHSIn STA1IILlUT1CH/OIISITZ UllDlILJ.
Attachment "A" (Can't.)
lTEH QtWmTt Inf1TS mrIT COST COST .
pu:p w nOli I exwS'n. DCTIOII
------------------------
ACQt11SInOll Of LUII) 7 ACU 3,600.00 15,000
CLlA!INC . GlUJIINC 7 ACU 3,'SO.00 15,000
ACCESS lOAD (20 f..t wtde)
II'nJKlNOUS 'AVEHZNT 2444 n '.06 20,000
lOAD IASI, CUDINC . CICHIACTIOII 3171 It 1.'0 .5,000
GlADINC . I!DIII(; 18OUlJ)!1S 733 It 1.74 1,000
I1CUkITt rIMer (6 foot ./barbed win) 3000 U 11.15 33 ,000
IUPPORT IUI~I"C 1 IA U,3OO.OO !S,OOO
DCA VA nOlI 01 eotrtAKIJlATED lOlL '6900 C'f 3.31 321,000
IAtlLINC nnoo C'f 2.0' 262,000
(3 aile r_d cdp, '4 c1 ...,,1)
COHSnUCTIOII SUPPORT UQ\111EKE1rI'S
AIR ttONlTORlHC 11 IfD '0,000.00 1,016.000
DUST SUPPllSSION 11 ttO 1,100.00 20,000
SOIL SAKPlINC , AKALYSIS
LAlOR 200 1m ,o.00 12,000
KrT J.l..S 350 IA 215.00 100,000
EXPLOSIVES 300 IJ. 42.5.00 12'.000
PAH. 250 IA 350.00 ",000
SBIPPI"C COOLERS 150 U 100.00 15,000
P1!! LIQUID STABILIZER ~OO C'f )0.00 ~,OOO
VESICL! DECOH STATION (laD4fill/iD~1Der.tor) 1 1.5 40,000.00 40,000
TEMPORARY VESICL! DECON STATION$ 20 IJ. 1,200.00 24,000
TEKPOPJ.R Y SOIL covn ($ ) 23000 SY 1.26 29,000
EXCAVATED A1IA lICLAKA1ION
NATIVE SOIL IACl111.L (~08p8eted) 91900 C'f 1.31 120,000
BORROY SOIL (201) 23000 C'f 11.00 ~3,OOO
TOPSOIL COVtR (6 1D~be.) 11 000 CY 13.55 149,000
CRADINC , SEEDING 659~~ SY 1.50 ",000
-------------
.lEPAlAnOll/COMSnUCTIOII IUJTOT&1. 2,16 7,000
OHSln INCINERATION
------.----------.-
ttOBILlZATIOII/SrruP/DEMOIILlZATION
Iin PIEPAAATION
CQtICUT! POUHDAnON
.1IrAJRlCATID BU1l.DINC
In1Lln lNSTALU.nON
UATn
IL!mlC1Tt
ftAJlS'OIKn 0500 rYA)
4-IMes PVC DUCT
ftDtW, u.s:r&UC2'JC»!
,wnOil AIm ITd1LI%.AnOli
---------------.-.--------
IPes lCALI nsnllc
PILOT nsnllc
KATD.1.ALS AID noasSIllc
ITAllUm lOlL UoKPLlNC . AlW.tl1S
TCLP ftST
'ITIICIJ. ftSTS
LoS 2, 2.JO , 000 . 00 2,~,OOO
2444 IT 21.00 68,000
1 U n,ISO.OO 14,000
400 U 2'.01 11,000
1 IA 23,100.00 24,000
400 U 23.67 _,000
20574 !ON 350.00 7,201,000
------------
UC1JIIUTlOI IUITCIT&1. _,577,000
,
I
115300
600
600
u
u
C'f
U
U
LAJlDnu. DUPOSAL
rwnCII AID ITdluu.nCII IUITCIT&1.
-----------------
IUlmING
DCAV4TION 01 UHPllLJ. AUA
'IH1 CaADINC 0' LAXDrILL fLOOR
CIOT!CB nsnllc 0' IAlTB KATElw.s
LAXD fl1.L Ll NIl
CLAY IACtlILL I' f.et, ca8p8cted)
24 D
102800 C'T
2"00 IT
so IA
24200 C'f
-3-
15,000.00 65,000
100,000.00 100,000
10.00 ',214,000
UO.oo 210,000
150.00 150,000
-----.-.----
',729,000
100.00 2,000
2.'4 241,000
0.67 1',000
100.00 5,000
20.40 .'4,000
-------
Attachment "A" (Con't.'
PUfEUED SUUAC! SOILS ALTDJU.TIVI--ESTlKU'ED WITAL COST'S (eClDtunaed)
"
ITEM QUABTITT UIf1 T'S UNIT COST COST e
UAl DmCTlON U:n:R 26300 n '.20 242,000
(10 ail liDer , dr.Laal. Det)
LUCBATE COWCTlON urn 26300 It 10.70 211,000
(10 ail liDer, dra1Dale .at , filear f.brie)
PUC!HEH'T , CcHPACTlON 0' 131360 CT 1.32 113,000
eotrrAKlIIATlD SOIL
UJmllLL KULTlu.m CAP
CLAY UTER (2 faet) 16300 CT 20.40 "3,000
1nrTBrr1 C GKlLUf! (10 ail), 26000 It 10.70 271,000
DUlMACE lET , lILm lAlllC
IAT1\'1 IOIL (11 iDdI..) 13300 CT 1.31 17,000
TOPSOIL (6 iDcbe.) 000 CT 13." '1,000
D05IOII eotmOL lAllIC , Ia:DIJIC 26600 It 1.10 2',000
:
IU1lACl VATO .lIMOn awnm.s 3000 U 10.30 31,000
(1 foot rid.)
LUCBATI COWCTION/lZA1 D!T!C'TIOII IA 2,270.00 2,000
LAND'ILL MONITORINC
MONITORINC Wt~ '20 U 120.00 12,000
(. veIl., 130 fe.t d..p)
L TS IHE:TIR S 12 IA l,UO.OO U,OOO
--------------
UNDllLL 111BTOT AI. 2,293,000
SURFACE WATER DlVE1SIOH
---.-------------------
KAJOR CALliER P~OJECTIU: LOA.DINC PUJrI'
'UI~IHC 109 AA1A
DCAVATION 1700 CT 3.31 6,000
IACJ.1ILL 2~000 CT 1.:)1 33,000
TOPSOIL COvrR (6 LDch..) 1800 CT 13." 24,000
CRADINC , SIEDINC 11000 CT 1. SO 17 ,000
CllLvrR'I'S 1 1.5 11,340.00 11,000
SUBSURFACE STORM DRAINS 1 1.5 3,750.00 4,000
KEDIUH CALliER PROJECTILl LOADINC PUJrI'
IUII.l)IHC 126 AREA
IACIF1LL lUOO CT 1.31 15,000
TOPSOIL COV£R (6 1DCh..) 1000 CY 13." 14,000
CRADINC , StIDINC 6000 IT I.S0 ',000
--.---------
IUllACI VATO DIVD.SIOII IUlTDTAL 133,000
TEHPORART STORACE
-----------------
lIT! PREPARATION
CL1A!INC. CIUIIINC, JTlIPPINC 14,720 IT 0.40 6.000
CIADINC 14,720 IT 3.00 44,000
lOADWAT GlAV!l IASI .00 Ct 53.00 42 ,000
10l.DWAT ASPIALT IU1'ACl 210 Ct 12.00 '6,000
IlCUl.ITT RNCE 2,'.0 U 14.15 42,000
UMDSWIJIC 1 U 1,000.00 1,000
IU11.DIIIC WE
4-DleB AlPIAL,. lUUltClJIC 680 CT 12.00 " ,000
12-IIICB CUVIL lASE 2,000 CT 53.00 106,000
CDllCUTI loonIes, aUKI' SlO CT 141.00 " .000
IU1~IJIC
nUL IU1~IIIC 54 ,000 If 7.'0 394,000
LICBT1I1C AIR> rucnICAL 54,000 If 2.15 122,000
MTnlAL UXDLINC
DCltVAT[ SOIL Inou ftU'n([trT' 16,400 CT 14.00 2.30,000
!AUL TO TUATKEHT UCILITY, DUHP 1,"'0 IA 75.00 UJ ,000
----..------
TIWOWT 'TaUCE IUlTOTAL 1,2U,OOO
-4-
-------
.1IYDRID suul.a SOILS AL1DJU.TlVI--UT1N.'IU CAPITAL COSTS (cOliUlauld)
ITni
Attachment "A" {(-c.. ~.)
"
DICOHTAKUlATlON VAM AND .WCBAT! 'ftU.'nmn'
--------------------------------------------
rvu. SDVItI OIlDI.TlOtl/UV .BOTOLtSlS
PUMPS
DlLU!M'r IAKPLDIC jJCP AlW.tSlS
OICA!l1CS
ItnI.1.S
DllDS IV!$
15
4
II)
..
..
..
..
',700.00
JOO . 00
JOO . 00
)is.oo
)45.00
)00
SOO
Soo
IUJTDTAL PIInU!D ALftlJlATlVE
II4S1WI.TD 1'UI.'tMEIn' IUITO'UL
101,000
2,000
90,000
110,000
104,000
------------
407,000
2J,U',ooo
IOImS AND lJISUUNC! (n)
lID CONT1NCtMCItS (151)
ICOPE CONT1NCtNCIES (201)
1JlVtSTlCATlON AND ENC111IEUIIC DESICN COSTS (101)
TOTAl - COtISnUCTIOH COSTS
'!RM1'M'lNC IJrD UCAl (51)
CONS7'P.:.JC'I'101i SERVICES (101)
. 777 ,000
S,8",ooO
J, 177 ,GOO
2,"9,000
------------
SI,312,ooO
1,916,000
3,831,000
'U ,000 .000 ..
TOTAl Cl.PITAl COSTS PRI1EU!D ALTERNATIVE
. Unl... otb.rvi.. iDd1cat.d. all COltl rOllDd.d to th. ...rl.t thOll.IDd dollar..
.. Valu. round.d to tbl D.ar..t 8111108 dollarl.
-5-
-------
WTINCS lAST lJIDUSnUL ,All
'WEntD IUUACE lOlLS ALTD.HATIVE--1STIKATID AHH1J1J. OPEUTIOtI &JfD MAlnElWla COSTS
EXCAVATIOti or eotrTAK1NATID IUthCE 1011.$ - DESnUCTIONI
OtISITI ITAJILIZATIOHIONSITI LANDfILL
AIIWAL COST
fIlST tW AnD AIDIUAL CDST
1TIM . qw.wnn UI1T1 anT CIDST IDDUTIOII IDA1nIC tWS
LAlDrlU. OPEUTIOH , MUJrnlWfCl.
UACtiT! IIHOVAL II II) 100.00 1.400 1,400
'YSTI)i Kt..ltrTU4JlCl II lID 100.00 1,400 1.400
DllNC AJrD CBlCl 12 II) 100.00 1,400 1,400
UlAU AMD USEEIIII1C 12 II) 100.00 1,400 1,400
ClOUIfD YAm db WS1'JVUTED ZOM! MDN1T'C1U1C.
1J.I0R 32 lID 480.00 U.J60 U,J60
(2 'EOPU. 4D/IIILL 01 LUlK!'TD I
, VEW , 12 LTSlHrTD.S. 21/n)
'SIPPINC ' IA 100.00 '00 '00
AJUJ. YS IS
,AH. " IA 300.00 10.100 10.100
EXPLOSIVES '6 V. 34~.00 12,420 12,420
HE'! Al.S 36 1A 360.00 12.960 12,960
ADDITIONAL HOIiITOUIiC lEQUIJ.DiIHTS. rUST tUl AJ'TD UKEDUTIOII,
1J.IOR 32 HD "0.00 15,360
(2 PEOP:..!, 41rP'1,::::":" .1R LTS1XE."":T'R,
4 WIu.5 , 12 LTSlHLTDS, 2X/n)
SBIPPING 6 1A
AKALYSIS
PAB.
EX P :..os 1 VES
HE'! Al.S
100.00
'00
36 1A
36 IA
36 U
300.00
)4~.OO
360.00
10.100
12,420
12.960
Attachment "A" (Con't.)
SUBTOTAL - ~" COSTS PRInnED ALTnJiATIVI
raST TLU Ann UliEDunON
lEKAIIIIHG TEARS
113.880
'1.740
VN1T COST COMTIHCEHCIES (101)
lCOP! CONT1MCENCIES (1)1)
~NIST1ATIVI COSTS (15%)
11 ,388
17 .0.2
17.082
'.174
'.261
'.261
.-.-.---.-.
-----------
TO'TAL - ~H COSTS PunnED ALTrMATIVE
ruST TU1 A.P'TIII UMEDUTIOII
I.IKAININC tUAS
8159.000 .
''',000 .
. 'allll..-d.cl CO UI aaarllc UoiuaDd .oUan.
-6-
-------
'""'
..., HASTlIIGS (AST INDUSTRiAl PARK
r:; PRESEIIT WORtH ANALTSIS--PR£f£RR£D SURfAC( SOILS AlTERNATIVES
0
u CAPITAL CLEANUP ANNUAl PRESENT ~IH .
'-" At TERlATlVE COST PERIOD 0&" COST eu
($) eYRS) ($)
~
.... PR£F(RRED AlT(RIATIV£ - £XCAVATION OF 144,000,000 44.000.000
r:; CONTAftIIAT(D SOil - D£STRUCTION/ONSIT£
III
a STABllllATION/ONSITE lAIIDflll
..c: FIRST rEAR I 1159,000 151.368
u RiMll11li Y(MS 29 $86,000 1.240.145
111
..., ----.. --------------
..., TOTAl 30 TOTAL $45.000.000
<
. Unl... otherwtse noted. .11 present worth total costs rounded to the nearest .1111on do1lan.
I
,.....
I
-------
1
Attacnment "B"
STATE
OF
NEBRASKA
li\:' A. ORR
GOVERNOR
DEPARTMENT or EN\1RONME"'TAL CONTROL
I DENNIS GRAMS
I DIRECTOR
Aug~st 28. 1990
.
.
Mr. Morris Kay.
Regiona' Ad~inis~rator
EPA Region VII
721 Minnesota Ave.
Kansas City. Kansas 66101
"ltA!JfI/:;
Dear M~-:--
U~O~ cor.side~a~~or. of the AdT.~n~s~~a~ive Reco~c and ~~e draf~ R~co~d 0&
J~:"s"c~ {PD:~. t~e Ne~ras~a Departmert of Environme~ta' Co~tro' (NDEC) CO~CM-S
with t,e Environme~ta' Protectior. Agency's remedy selection for the sw~face
so"s o~ t~e Has~~~gs Eas: ~~c~s~~ia1 (U,E!P) S~~sit€.
l~C~, \ ......
SE? u ~ 19Sa
iWONAl. ADMlitISJRATQ8
~::: ~nde~sta~cs that ~~e re~edy w~:: provide pe~mane;,t destruc~io~ o~
s~~~a:e sc"1s co~~a~ina~ec w~t~ h~~~ leve's 0& orga~ic che~ica's anc
s~a~"'"zat'o~ c~ ~e~a~s pos"~g a t~~e:~ ~c ~w~a~ ~ea'~~ a~d the e~vi:o~~e-~
:f p~ac~~ca~'e. so'ls co~ta~ina~ed w~tr. lo~ leve~s of o~Qa~ics w~'l be
s~a~"'zed. ~'e se'ec:e~ -e~e=y w'11 meet a'l state requ~~eme-ts.
N::: a~~-ec;a~es t~e o~~o-t~-~ty fo~ i~vo~ve~e~t ~~ t~€ ~e~e~y se'e:~"~-
~-ocess a-c :~A's cc:s~de~a~'on Of N~EC's inpJt t'rou~'c~t tr.'s invest~ga~~:-
N~:: cc-s'ce-s t,e deve'op~e~~ o~ t~is ~O~ ~o exe-~"fy a ~'g~ deg~ee o~
i~:e-age-cy cc~~e-a~"o~.
S'nce-e~y.
b~-
-
-~
Oe"1r,is Grar.-.s
DGllV/kv
~~C~DW[O
SEP 1 0 1990
,
SUPERfUND BRANCH
P. v. BOX 98911, LlSCOL~, NEBRASKA 61509-8912. PHOSE (.01) .71.1186
A" EQl'AL OPPORn'sm/AmRMAT1\[ ACTIO", EMPLOYER
-------
RESPONSIVENESS StJXKARY FOR TO
BASTINGS BAST INDUSTRIAL PARK SUBSITB,
BASTINGS GROtnm WATER CONTAMINATION SUPERPUND
HASTINGS, IlBBRABD
SITB
.
This Responsiveness Summary presents the responses of the
United states Environmental Protection Agency (EPA) to the
comments received during the public comment period conducted as
part of the remedy selection process for the Hastings East
Industrial Park Subsite of the Hastings Ground Water
Contamination Superfund site.
.
A.
OVERVIEW
The Hastings Ground Water Contamination Site is made up of
several subsites within and immediately east of the city of
Hastings, Nebraska. These subsites include the Colorado Avenue,
FAR-MAR-CO, Well Number 3, North Landfill, South Landfill, Second
Street and Hastings East Industrial Park (HEIP) Subsites. The
HEIP subsite is located east of Hastings on the western portion
of the former Hastings Naval Ammunition Depot (NAD).
In 1983, a city water well was taken out of service after
reports from the public of a foul smell and taste in the water.
As a result, the Nebraska Department of Health (NDOH), Nebraska
Department of Environmental Control (NDEC), and the EPA began
investigating ground water contamination in the area. Due to the
nature of the contaminants found in the ground water during this
investigation, the Hastings Ground Water Contamination site was
placed on the National Priorities List (NPL) in 1986.
Since the discovery of contamination in the Hastings ground
water in 1983, the city of Hastings has taken two municipal wells
out of service. Operators of Community & Municipal Services
(CMS) , Inc., a privately-owned water supply system which services
the Hastings East Industrial Park and Central Community College,
also took two of their three wells out of service due to ground
water contamination. Recent EPA testing indicates that the water
currently supplied by both the city of Hastings and the CMS
system is safe to drink.
In 1987, EPA published reports regarding the field
investigations conducted by BPA in the Hastings area from April
1985 to December 1986. These investigations focused on four
subsites: Colorado Avenue, FAR-MAR-CO, the North Landfill, and
the HEIP subsites. The studies identified the contamination
present in the soil, evalu~ted and defined potential source
areas, and identified potential pathways for contaminant
migration. Also in 1987, EPA published a ground water report
which presented the results of the ground water well sampling and
evaluated the extent of contamination of the area wide Hastings
site.
1
-------
On the basis of the EPA, NDOH and NDEC investigations of the
HEIP subsite, EPA and the U.S. Army Corps of Engineers (USACE)
have determined that the previous manufacture, use and disposal
of hazardous substances at the former NAD has given rise to the
actual release or threatened release of hazardous substances, and
that the actual or threatened release has contaminated and/or
could cause further contamination of soil, ground water and
surface water unless the release or threatened release is abated.
The USACE, on behalf of the Department of Defense (DOD), entered
into an interagency agreement (IAG) with EPA in June of 1986 to
undertake a remedial investigation of the HEIP subsite, address
the potential remedies and implement the appropriate response
action to protect public health and the environment.
USACE began the remedial investigation and development of
remedial alternatives for the HEIP in 1987. NDEC and EPA have
conducted oversight activities throughout the ongoing
investigation as required by the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act of
1986 (SARA). Results of USACE's studies are available in the
Final Remedial Investigation (RI) Report (USACE, September 1990),
the Final Feasibility Study (FS) Report (USACE, June 1990) and
Final Ground Water Modeling Report (USACE, September 1990).
These reports are available in the administrative record for
public review.
These investigations indicate that the surface soils
(approximately 0 to 10 feet in depth) at the HEIP subsite are
contaminated with explosives, polynuclear aromatic hydrocarbons
(PAHs) and met,ls. The surface soil contaminants of potentiul
concern to public health and the environment are:
trinitrotoluene (TNT), carcinogenic PARs, arsenic, cadmium, lead
and chromium. The first operable unit (i.e., cleanup phase) for
the HEIP subsite addresses this surface soil contamination.
In June of 1990, EPA published a Proposed Plan which
identified a preferred alternative for remediation of the HEIP
surface soils. This preferred alternative was subsequently
chosen as the selected remedy for the surface soils operable
unit. The major elements of the selected remedy are summarized
below. The remedy is described in greater detail in the
September 1990 Record of Decision (ROD) for the HEIP subsite
surface soils operable unit.
2
-------
The major components of the selected remedy are as follows:
1. Excavation of approximately 125,900 cubic yards of
contaminated soils.
2. Treatment dependent on type and concentration of contaminants.
- On-site incineration of approximately 16,400 cubic
yards of soils containing high levels of organic
contaminants.
4
- Stabilization of an estimated 39,000 cubic yards of
metal contaminated soils and placement in an on-site
RCRA hazardous waste landfill.
- Stabilization of the approximately 70,500 cubic yards
of soil with low levels of organic contamination, if
effective, and placement in an on-site RCRA hazardous
waste landfill. Should stabilization prove to be
ineffective due to the nature of the contaminants,
these soils will be placed directly in an on-site RCRA
Subtitle C hazardous waste landfill.
3. A period of three years will be allowed for USACE to study
similarly contaminated soils on the other portions of the
former NAD. At the end of this period, a determination will
be made whether to include these contaminated soils with the
HElP subsite soils to be treated with a destruction
technology. At the end of this period, the incineration
portion of the remedial action will begin.
If during this three year period, a less costly innovative
destruction technology with a destruction efficiency
comparable to incineration is developed, USACE may consider
its use in place of incineration. If such an alternative
innovative destruction technology is chosen, the design for
its implementation, in place of incineration, will begin at
the end of this period.
Design and implementation of the other components of the
remedy are not subject to the three year delay and will be
initiated in a timely manner upon signature of this ROD.
B.
BACltGROtJND OP COKKONITY INVOLVEMENT
The major concerns expressed by the community, city and
state officials during the remedial planning activities conducted
from 1985-1989 are presented in EPA's January 1990, Community
Relations Plan the Hastings Ground Water Contamination site.
These concerns focused on the distribution of information about
site activities, the cost of the investigation and future site
activities, water quality and quantity, the role of the EPA,
State of Nebraska, and potentially responsible parties (PRPs) in
3
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the activities at the site, and the economic impact of the
cleanup on present and future PRPs and on the city's economy.
On June 21, 1990, EPA made its Proposed Plan for the
remedial action for the Surface Soils Operable Unit of the
Hastings East Industrial Park Subsite publicly available. Notice
of the availability of the Proposed Plan and the administrative
record upon which EPA based its remedy selection was published in
the Hastings Tribune on June 19, 1990. This notice also
requested the public's comments on the Proposed Plan and
indicated the period during which public comments received by EPA
would be considered in the decision-making process. A public
meeting was held in Hastings, Nebraska on June 28, 1990 to
receive comments. A transcript was made of the public meeting
and copies of the transcript are available in administrative
record.
C.
SUMMARY OF COMMENTS RECBIVED DURING THE PUBLIC COMMENT PBRIOD
AND AGBNCY RESPONSBS
The public comment period on the Proposed Plan was held from
June 21 until July 20, 1990. Oral and written comments received
from the community during the public comment period are
summarized briefly below. The comments are organized by subject
matter into three categories: (I) public health/welfare
concerns; (II) technical questions/concerns regarding the
Proposed Plan; and (III) other concerns.
I.
Public Health/Welfare Concerns
1.
EPA received several comments noting that two of the
Community wells and two of the Municipal Services (CMS)
wells are no longer in use due to contamination and
expressed concern about what would happen if the third
well went out of service even temporarily or if other
sources of public water supplies become contaminated.
EPA Response: EPA appreciates public concern regarding
the safety of the water supply. CUrrently, the CMS and
public water supplies are safe for consumption.
However, should the CMS and public water supplies
become unsafe, EPA would direct the responsible parties
to take whatever response action is necessary in order
to protect public health and the environment. If
necessary, EPA would take the necessary actions itself.
The contaminated ground water at the HEIP subsite will
be addressed in a separate operable unit. CUrrent
ground water investigations are still underway. A ROD
will be prepared addressing remedial action for the
ground water upon completion of a Ground Water
Feasibility study Report, a Proposed Plan and the
appropriate public comment period.
4
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II.
..
.
III.
Technical Questions/Concerns Reqardinq the Proposed Plan
1.
EPA received one comment aSking whether a RCRA
Subtitle C hazardous waste landfill would be necessary
at the site if the soils to be placed in the landfill
do not exhibit the RCRA hazardous characteristic of
toxicity when the TCLP test is performed on the soils.
EPA Response: EPA has not desiqnated RCRA Subtitle C
landfill construction requirements as an applicable or
relevant and appropriate requirement for the selected
remedy. EPA expects that the TCLP test will reveal
that some of the soils in fact exhibit the
characteristic of toxicity. In either case, EPA would
still require the stabilized or treated soils to be
disposed in a RCRA subtitle C landfill in order to
enhance the permanence and protectiveness of the remedy
and to decrease the mobility of the wastes.
other Concerns
1.
EPA received one comment which noted that property
owners in the area of the HEIP had suffered a loss in
the value of the equity they have in their property as
a result of the contamination at the HEIP and the
designation of the HEIP as a Superfund subsite.
EPA Response: EPA sympathizes with the plight of
property owners who experience problems related to
buyer and lender uncertainty about potential Superfund
liability. Unfortunately, matters regarding the
valuation of private property are outside the scope of
EPA's authority and are generally state or local
issues.
2.
EPA received one comment which noted that there had
been many different EPA employees involved. at the site
as remedial project managers, and expressed concern
about the continuity of response activities at the
HEIP.
EPA Response: Although some staff turnover is
inevitable, EPA will continue to ensure that response
activities at the HEIP proceed smoothly and in a timely
manner. All EPA actions will be consistent with the
National Oil and Hazardous Substance Pollution
Contingency Plan (NCP).
3.
EPA received other comments addressing the boundaries
of the current investigations. Specifically, these
comments addressed the reasons for excluding the
Central Community College (CCC) from the HEIP subsite
since the buildings and land it occupies were the
administration complex for the former Hastings NAD.
These comments also addressed the extent to which
5
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investigations have been conducted beyond the subsite
boundaries to locate areas used as burn pits and
dumping areas during the naval operations at the former
NAD.
EEA ResDonse: Based on the investigations of the
former NAD, which included (but were not limited to)
inspection of the former NAD grounds, review of current
and historical aerial photographs, historical accounts
of NAD operations, analytical data and interviews with
former NAD employees and local residents, the HEIP
subsite was identified as a likely source for the
explosive contaminants in the ground water. The HEIP
subsite encompasses the majority of the production
buildings for the former NAD. This area was included
as a subsite of the Hastings Ground Water Contamination
Site due to the likelihood that the explosives
contamination in the inoperative CMS wells was a result
of production activities in this portion of the NAD.
The buildings and area occupied by CCC were primarily
used for administrative functions during the operation
of the former NAD. When the Hastings Ground Water
contamination site was placed on the NPL, there was no
indication of contaminated areas on the campus. As a
result, CCC was not included as a part of the HEIP
subsite.
The Defense Environmental Restoration Program (DERP) is
a congressionally mandated program provided for in the
1986 SARA amendments to CERCLA. DERP directs DOD to,
among other things, clean up contamination from
hazardous substances, pollutants and contaminants
resulting or remaining from DOD operations at current
and formerly owned defense sites. The USACE Kansas
City District, as agent for DOD, is conducting
investigations and will clean up environmental
contamination on the non-NPL portions (east of the HEIP
sUbsite) of the former NAD.
6
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