United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R09-92/077
December 1991
SEPA Superfund
Record of Decision:
Sacramento Army Depot
(Operable Unit 3), CA
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NOTICE
The appendices listed in the index that are not found in this document have been removed at the request of
the issuing agency. They contain material which supplement but adds no further applicable information to
the content of the document All supplemental material is, however, contained in the administrative record
for this site.
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R09-92/077
3. Recipient's Accession No.
4. TWe and Subtitle
SUPERFUND RECORD OF DECISION
Sacramento Army Depot (Operable Unit 3), CA
Second Remedial Action - Subsequent to follow
5. Report Date
12/09/91
7. Author(»)
8. Performing Organization RepL No.
8. Performing Organization Name and Address
10. Project/Taak/Work Unit No.
11. Contract(O or Grant(G) No.
(G)
12. Sponsoring Organization Name snd Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
15. Supplementary Notes
PB93-964509
16. Abstract (Limit: 200 words)
The 485-acre Sacramento Army Depot (SAAD) is a U.S. Army support, service, and storage
facility located approximately 7 miles southeast of the City of Sacramento, California.
Land use in the area is predominantly commercial and light industrial, with residential
areas located mainly to the west. An estimated 56,000 people obtain water from a deep
aquifer that is not considered to be contaminated by the facility. However, some wells
in the surrounding area draw water from the upper aquifers. Past and present
activities conducted at SAAD include electro-optics equipment repair, the emergency
manufacture of parts, shelter repair, and metal treating. The primary waste-generating
activities included metal-plating and painting. In conjunction with these activities,
SAAD maintains several above- and below-ground storage tanks, some unlined lagoons and
burn pits, a battery disposal area, a firefighter training area, and a pesticide mixing
area. As a result of a late 1970's U.S. Army initiative, a 1981 onsite investigation
of SAAD revealed multiple chemical contamination from numerous sources within the
facility. Ground water remediation was addressed in a previous ROD. In the past,
Tank 2 was used as a waste solvent underground storage tank. In 1980, the tank was
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Sacramento Army Depot (Operable Unit 3), CA
Second Remedial Action - Subsequent to follow
Contaminated Medium: soil
Key Contaminants: VOCs (PCE, xylenes), other organics (PAHs, pesticides)
b. Identifiers/Open-Ended Terms
c. COSATt Field/Group
18. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
118
22. Price
(See ANSW38.18)
See Maffucff'ona on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R09-92/077
Sacramento Army Depot (Operable Unit 3), CA
Second Remedial Action - Subsequent to follow
Abstract (Continued)
emptied, and in 1986 the tank was removed. Sampling and analysis of the soil under and
around the tank showed that solvent contamination was confined to the soil well above
ground water level (aquifer). A 1989 ROD addressed contaminated ground water associated
with onsite burn pits. This ROD addresses the final remedial action for approximately
1,000 cubic yards of contaminated soil associated with Tank 2 (OU3). Future RODs will
address contamination occurring at the oxidation lagoons, the burn pits, the pesticide
mixing area, the battery disposal well, building 1320 leach field, and the firefighter
training area. The primary contaminants of concern affecting the soil are VOCs,
including PCE and xylenes; and other organics including PAHs and pesticides.
The selected remedial action for this site includes constructing and installing an onsite
soil vapor extraction system to remove VOCs from contaminated soil; dehumidifying the air
stream and treating the collected water vapor using UV/hydrogen peroxide; treating air
emissions using granular activated carbon and transporting the residual carbon offsite
for recycling and treatment; monitoring air emissions during the treatment process; and
sampling media after 6 months to determine compliance with clean-up standards. The
estimated present worth cost for this selected remedial action is $614,414. No O&M costs
are associated with this selected remedial action.
PERFORMANCE STANDARDS OR GOALS :
Chemical-specific soil clean-up levels are based on health-based criteria of reducing the
noncarcinogenic HI to approximately 1 and include 2-butanone (MEK) 1.2 mg/kg;
ethylbenzene 6 mg/kg; PCE 0.2 mg/kg; and total xylenes 23 mg/kg.
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SUPERFUND
RECORD OF DECISION
SACRAMENTO ARMY DEPOT
TANK 2
OPERABLE UNIT
SACRAMENTO,CALIFORNIA
September 25,1991
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RECORD OF DECISION
I. DECLARATION
SITE NAME AND LOCATION
Tank 2 Operable Unit
Sacramento Army Depot (SAAD)
8350 Fruitridge Road
Sacramento, California
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Tank 2 Operable Unit at
the SAAD facility in Sacramento, California, which was 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, to the extent practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP). This decision is based on the administrative record for this site,
which contains:
* The Tank 2 Operable Unit Feasibility Study (OUFS) which contains site
investigation data, the Public Health Evaluation, and an analysis of remedial
alternatives,
«• The Proposed Plan (PP), dated August 1991, which summarizes the preferred
cleanup alternative, compares the preferred alternative with several other
alternatives, and invites public participation,
» The Responsiveness Summary, which summarizes public comments on the
OUFS and the PP and includes the Army's response to comments.
The purpose of this Record of Decision (ROD) is to set forth the remedial action to be
conducted at SAAD to remedy soil contamination associated with the former Tank 2 waste
solvent storage tank. This is the second of several potential remedial actions addressing soil
and ground water contamination that may be conducted at SAAD. Subsequent ROD'-s will
address other potential threats posed by the site, both on and off site. A final ROD in a few
years will comprehensively address the entire SAAD facility.
The U.S. Environmental Protection Agency Region IX (EPA IX) and the State of California
[California EPA: Department of Toxic Substances Control (DTSC) and Central Valley
Regional Water Quality Control Board (CVRWQCB)] concur with the selected remedy.
E20-91-118 Page I of Pan I September 25, 1991
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ASSESSMENT OF THE SITE
Tank 2 was a 1000-gallon underground storage tank used by SAAD to store waste solvents
until approximately 1980. An investigation by the U.S. Army showed that soil around Tank 2
has been contaminated by volatile organic compounds (VOCs). The Tank 2 Operable Unit,
which contains the affected soil, is an area approximately 25 feet by 35 feet, and includes the
soil down to a depth of approximately 31 feet. The Tank 2 Operable Unit does not include
ground water. Analysis of soil samples from the Tank 2 Operable Unit, and comparison of the
soil contaminants with the types of contaminants present in ground water, indicates that Tank 2
is currently not a source of ground water contamination found at SAAD. The two VOCs most
often detected in soil at the Tank 2 Operable Unit are ethylbenzene and xylene. Other VOCs,
including tetrachloroethene and 2-butanone, were detected occasionally.
A baseline health risk assessment was conducted to evaluate the current and future risks posed
by the contamination at the Tank 2 area if no cleanup occurs. The health risk assessment
found that tetrachloroethene and 2-butanone pose the greatest potential threat to public health,
due to their toxicity and relatively high mobility in soil. Cleanup levels based on potential
health risks and on protection of ground water were then established for these two VOCs.
Cleanup levels were also established for ethylbenzene and xylene since they were found
consistently and at relatively high concentrations in samples from the Tank 2 Operable Unit.
The cleanup levels were determined based on additive risk and Applicable or Relevant and
Appropriate Requirements (ARARs).
Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action presented in this ROD, may present an imminent and
substantial endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The Army intends to clean up the Tank 2 Operable Unit so that the public is not exposed to
toxic chemicals from the site. This ROD addresses the principal threat at the Tank 2 site by
removing the contamination present in soil. Removal of contaminants in the soil will reduce
future migration of contamination from the soil to ground water beneath the site. The primary
risk to public health is the potential for future ground water contamination. The public is not
currently being exposed to contaminated soil at the Tank 2 Operable Unit since the entire area
is covered with asphalt and concrete.
E20-91-118 Page 2 of Pan 1 September 25, 1991
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The selected remedy for cleaning up the soil at the Tank 2 Operable Unit is composed of: in-
situ soil ventilation; air emissions control; and entrained (suspended) water treatment by the
existing on-site ultraviolet-hydrogen peroxide treatment plant. The selected remedy includes:
* Completing construction and installation of the soil ventilation system within the
next six months,
* Removing VOCs from the soil with a soil ventilation system that pulls air
through the contaminated soil, volatilizing contaminants and removing them
with the air-stream.
* De-humidifying the contaminated air-stream, which contains air, contaminants,
and vapor from the soil, by passing it through a moisture separator.
« Treating contaminated water from the moisture separator in the on-site treatment
plant that is part of the ongoing ground water remediation.
* Treating the contaminated air-stream, now containing significantly less water
but still carrying the contaminants, by passing it through a bed of granular
activated carbon. The contaminants in the air stream will be removed by
adsorbing onto the carbon bed. The treated air will be released to the
atmosphere and the carbon will be transported to a facility where the
contaminants are removed and treated,
* Meeting cleanup levels within approximately six months of system operation.
The soil will be sampled following remediation to verify that cleanup levels
have been met.
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 technologies, to the maximum extent practicable, and satisfies the statutory
preference for remedies that employ treatment that reduces toxicity, mobility, or volume as a
principal element. Because the remedial action will not leave hazardous residuals on-site
above health-based levels and will be completed after approximately six months of the
operation, the five-year review will not apply to this action.
E20-91-II8 Page 3 of Pan I September 25, 1991
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SENT BY: XEROX Telecopier 7017:12- 5-91 : 9:37AM : 9153884510- 415 744 1917!* 4
IT IS SO AGREE©:
FOR THE U.S. DEPARTMENT OF THE ARMY:
Date Lewis D. Walker
Deputy for Environmental, Safety, and
Occupational Health
Office of the Assistant Secretary of the Army
(I&L)
Date William Grundy
Colonel, SC
Commander, Sacramento Army Depot
FOR THE STATE OF CALIFORNIA ENVIRONMENTAL PROTECTION AGENCY:
Date Val F. Stehat ^^
Regional Administrator
Region 1
Department of Toxic Substances Control
Date William H. Crooks
Executive Officer
Central Valley Regional Water Quality Control
Board
T3Ot* TUTS. 11 G TJWVIft.AWl^BWtVS.1- UROTSCTTOW
Date Daniel W. McGovern
Regional Administrator
. United States Environmental Protection Agency,
Region IX
r»g« 4 or rin i
TOTOL P. 2
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IT IS SO AGREED:
FOR THE U.S. DEPARTMENT OF Tim ARMY:
Date Lewis D, Walker
Deputy fur Environmental, Safety, and
Occupational Health
Office of the Assistant Secretary of the Army
(I&L)
Date William Grundy
Colonel, SC
Commander, Sacramento Army Depot
FOR THE STATE OF CALIFORNIA ENVIRONMENTAL PROTECTION AGENCY:
Date Val F, Siebal
Regional Administrator
Region I
Department of Toxic Substances Control
Date William H. Crooks
Executive Officer
Centra! Valley Regional Water Duality Control
Hoard
FOR THE U.S. ENVIRONMENTAL PROTECTION AGENCY:
Tlntr. rianlf.1 W
Regional Administrator
United States Environmental Protection Agency,
Region IX
E2041-118 P.£C 4 of Ptit 1 iKpttnriiOf 21. IS81
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SENT BY.' XEROX Telecopier 7017:12- 5-91 : 9:36AM :
9163884519"
415 744 191?:* 2
IT IS SO AGREED;
FOR THE U.S. DEPARTMENT OF THE ARMY:
Date
Lewis D. Welkcr
Deputy for Environmental, Safety, and
Occupational Health
urncc 01 uie ASSI
(I&L)
ocurcuuy
uic nsmy
Date
William Gr
Colonel.il
Commander, Sacramento Army Depot
FOR THE STATE OF CALIFORNIA ENVIRONMENTAL PROTECTION AGENCY:
Date
Date
FOR THE U.S. ENVIRONMENTAL
Date
Val F. Siebal
ances Control
Vater Quality Control
.o"""^ ruiimnistrator
United States Environmental Protection Agency,
Region IX
E30-9U11S
Piya 4 of Pin t
September 25. 1991
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IT IS SO AGREED:
FOR THE U.S. DEPARTMENT OF THE ARMY:
Date Lewis D. Walker
Deputy for Environmental, Safety, and
Occupational Health
Office of the Assistant Secretary of the Army
(I&L)
Date William Grundy
Colonel, SC
Commander, Sacramento Army Depot
FOR THE STATE OF CALIFORNIA ENVIRONMENTAL PROTECTION AGENCY:
Date Val F. Siebal
Regional Administrator
Region 1
Department of Toxic Substances Control
Date William H. Crooks
Executive Officer
Central Valley Regional Water Quality Control
Board
FOR THE U.S. ENVIRONMENTAL PROTECTION AGENCY:
Date Daniel W. McGovem
Regional Administrator
United States Environmental Protection Agency,
Region IX
E20-91-118 Page 4 of Part I September 25, 1991
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RECORD OF DECISION
II. DECISION SUMMARY
SAAD -- TANK 2 OPERABLE UNIT
TABLE OF CONTENTS
Chapter
1 SITE NAME, LOCATION, AND DESCRIPTION 3
1.1 Location 3
1.2 Site Description 3
1.3 Demography 3
1.4 Land Use 4
1.5 Climatology 4
1.6 Regional Topography 4
1.7 Surface Water Hydrology 4
1.8 Geology 5
1.9 Hydrogeology 6
1.10 Natural Resources 6
2 SITE HISTORY AND ENFORCEMENT ACTIVITIES 6
3 HIGHLIGHTS OF COMMUNITY INVOLVEMENT 8
4 SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY 9
5 SUMMARY OF SITE CHARACTERISTICS 9
5.1 Contamination Sources 9
5.2 Evaluation of Primary Contaminants 10
5.3 Location of Contaminants and Potential Routes of Migration 11
6 SUMMARY OF SITE RISKS 11
6.1 Human Health Risks 11
6.1.1 Contaminants of Concern 12
6.1.2 Exposure Assessment 12
6.1.3 Summary of PHE Results 14
6.2 Environmental Evaluation 16
6.3 Cleanup Levels 16
6.3.1 Non-Carcinogens 16
6.3.2 Carcinogens 17
7 DESCRIPTON OF ALTERNATIVES 17
7.1 Alternative 1: No Action 18
7.2 Alternatives 2a, 2b, & 2c 19
7.3 Alternatives 3a, 3b and 3c 20
7.4 Alternative 4 20
7.5 Alternatives 21
7.6 Alternatives 6a and 6b 21
7.7 Alternatives 7a and 7b 21
7.8 Alternatives 21
8 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 22
8.1 Overall Protection of Human Health and the Environment 22
E20-9I-I18 Page 1 of Part II September IS, 1991
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8.2 Compliance with ARARs 23
8.3 Long-Term Effectiveness and Permanence 23
8.4 Reduction in Toxicity, Mobility, or Volume Through Treatment 23
8.5 Short-Term Effectiveness 24
8.6 Implementability 25
8.7 Cost 25
8.8 State Acceptance 26
8.9 Community Acceptance 26
9 SELECTED REMEDY 26
10 STATUTORY DETERMINATIONS 27
10.1 Protection of Human Health and Environment 28
10.2 Compliance with ARARS 2 8
10.3 Cost Effectiveness 29
10.4Utilization of Permanent Solutions and Alternative Treatment Technologies 29
10.5 Preference for Treatment as a Principal Element 29
11 DOCUMENTATION OF SIGNIFICANT CHANGES 29
FIGURES
1 Site Location Map
2 Site Map Tank 2 Operable Unit
3 Location of Soil Contamination, Plan View
4 Location of Soil Contamination, Cross Section
TABLES
1 Summary of Primary Contaminants
2 Definitions of Risk Terms
3 Baseline Exposure-Point Concentrations - Tank 2 Operable Unit
4 Carcinogenic Risks - Tank 2 Operable Unit
5 Non-Carcinogenic Risks - Tank 2 Operable Unit
6 Contaminant Concentrations & Cleanup Levels in Soil
7 Cost Estimate Summary, Selected Alternative: Soil Ventilation,
Carbon Adsorption Treatment of Vapor, UV/H202 Water Treatment
APPENDICES
A Analysis of ARARs
B Administrative Record Documents
E20-9I-118 Page 2 of Pan II September 25, 1991
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SACRAMENTO
SACRAMENTO
ARMY DEPOT
KLEINFELDER
PROJECT NO. 24-150028-A05
M -5
SITE LOCATION MAP
SACRAMENTO ARMY DEPOT
SACRAMENTO, CALIFORNIA
FIGURE
1
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(•nn)
I tnck = BOO fl.
KLEINFELDER
'ROJECT NO. 24-150028-A05
SITE LOCATION MAP
TANK 2 OPERABLE UNIT
SACRAMENTO ARMY DEPOT
SACRAMENTO, CALIFORNIA
FIGURE
2
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1 SITE NAME, LOCATION, AND DESCRIPTION
1.1 Location
The Tank 2 Operable Unit is part of the Sacramento Army Depot (SAAD) military facility
owned by the U.S. Army. The SAAD facility is located at 8350 Fruitridge Road in the City
and County of Sacramento, California. SAAD lies approximately seven miles southeast of
downtown Sacramento (Figure 1) and is bound by Fruitridge Road on the north, Florin-
Perkins Road on the east, Elder Creek Road on the south, and the Southern Pacific Railroad
tracks on the west. The SAAD facility encompasses an area of 485 acres.
The Tank 2 Operable Unit is located slightly northwest of the center of the SAAD facility,
approximately 10 feet south of Building 320 and 15 to 20 feet north of Attu Street. The
Operable Unit includes the area where Tank 2 was located prior to its removal and the soil that
appears to have been affected by leakage from Tank 2. The Tank 2 Operable Unit
encompasses approximately 875 square feet. A site map of the SAAD facility, showing the
location of Tank 2 with respect to other Operable Units and site features, is shown on
Figure 2.
1.2 Site Description
Past and present activities conducted at SAAD include electro-optics equipment repair, the
emergency manufacture of parts, shelter repair, metal plating and treatment, and painting.
The metal-plating and painting operations were the primary on-site waste generating activities.
Tank 2 was a 1000-gallon underground storage tank used to store waste solvents produced at
SAAD until 1980. Past and present surface and subsurface storage units and other structures
at the site include several underground and above ground storage tanks, unlined oxidation
lagoons and burn pits, a battery disposal area, areas where pesticides were mixed or pesticide
rinse water may have been discharged to the ground surface, and an area used for firefighter
training where flammable hydrocarbons were burned on the ground surface. Several of these
areas have released contaminants into the soil and/or ground water at SAAD and are being
investigated and cleaned up as separate Operable Units. The various areas where contaminants
have been found at SAAD are discussed in more detail in Section 2.
1.3 Demography
In 1987, there were 76 people living on the SAAD facility and 56,398 people living off-site
within two to three miles of SAAD. Data for the working populations on and around SAAD
E20-91-118 Page3ofP«rtII September 25, 1991
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in 1987 are not available. In 1984, 3,430 people worked on the SAAD facility and 20,710
people worked off-site within two to three miles of SAAD.
1.4 Land Use
SAAD is immediately surrounded on all sides by land currently zoned as commercial/light
industrial property. Within two to three miles of SAAD, the areas that are primarily low to
medium density residential are northwest, west and southwest of SAAD, while the areas south,
east, and north of SAAD are largely industrial.
1.5 Climatology
Climate at SAAD is classified as Mediterranean, hot summer (Kbppen System), with mean
temperatures of 30 to 40 degrees Fahrenheit in January and 90 to 100 degrees Fahrenheit in
July. Average relative humidity in January ranges from 80 to 90 percent, while in July it
ranges from 50 to 60 percent. Generally, 85 to 95 percent of the annual precipitation occurs
in winter. The mean annual precipitation at the site is estimated to be 17 inches, while the
estimated mean annual evaporation is estimated to be approximately 73 inches.
1.6 Regional Topography
SAAD is located in the Central Valley of California, a broad flat valley that lies between the
Sierra Nevada Mountains to the east and the Coast Ranges to the west. The youngest
sediments (up to 5 million years old) underlying SAAD were deposited by the American River
as its course meandered across the valley floor and, to a lesser extent, by Morrison Creek.
Consequently, the topography at the SAAD is relatively flat. The slope of the land surface is
approximately 0.13 percent to the west, with ground surface elevations ranging from 36 to 42
feet above mean sea level.
1.7 Surface Water Hydrology
SAAD is situated within the Morrison Creek drainage basin. Morrison Creek originally
flowed from east to west through the land now occupied by the SAAD facility. When SAAD
was constructed at its current location, the Army re-routed Morrison Creek so that it flowed
around the south side of the facility rather than through it. The floodplain for the re-routed
Morrison Creek extended approximately 1I2 mile north of the creek, onto the SAAD facility.
E20-91-II8 Pa «e 4 of Parti! September 25, 1991
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In 1958, 7,900 linear feet of flood-control dike was constructed along the re-routed portion of
Morrison Creek, and in 1986 the new channel was widened and deepened. The re-routed
portion of Morrison Creek is currently able to handle 100-year flood events, so SAAD is not
considered to be on the floodplain at this time. The old channel of Morrison Creek is
currently dry during most of the year. This channel bisects the facility from east to west and is
referred to as Old Morrison Creek.
Drainage of the SAAD facility is mainly overland flow to Morrison Creek and man-made
diversion structures. Morrison Creek also receives surface runoff from other industrial and
agricultural sites along the creek and permitted discharges from industries.
A study of the SAAD facility indicates that the only potential wetlands currently in existence
on the facility appear to be located approximately 1,000 feet southwest of Tank 2, along Old
Morrison Creek. No wetlands exist within the Tank 2 Operable Unit.
1.8 Geology
SAAD is located in the Great Valley of California, a broad asymmetric trough filled with a
thick assemblage of flat-lying marine and non-marine sediments. The most recent formations
deposited in the Great Valley are non-marine sediments derived from the Sierra Nevada
foothills and mountains on the west side of the valley and from the Coast Ranges on the east
side of the valley. The sediments are carried out of the mountains and deposited by a series of
large and small rivers. Sediments under SAAD have been largely derived from the Sierra
Nevada's, and have been deposited by the American River as it has meandered back and forth
across the valley floor.
The upper 250 feet of sediments under SAAD is comprised of interbedded sands, silts and
clays, with some coarse gravels underlying the north side of the facility at an approximate
depth of 40 feet. The identification of horizontal and vertical boundaries of formations is
extremely difficult in alluvial environments such as that encountered at SAAD. Older buried
stream channels exist at various locations and depths in the area. These streams have
deposited materials ranging in size from gravel down to clay as they meandered back and
forth. Multiple discontinuous hardpans (cemented clays), representing buried ancient soil
horizons, exist throughout the site.
E20-91-118 PageSofPartll September 25, 1991
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1.9 Hydrogeology
SAAD is underlain by a series of alluvial aquifers which provide water to residences,
industries, and agricultural properties in Sacramento County. The California Department of
Water Resources has divided the ground water in the area into two hydraulically isolated
sections, the superjacent (upper) series located from approximately 80 to 250 feet in depth
under the site and the subjacent (lower) series located deeper than approximately 250 feet
under the site. The primary water-producing aquifers are in the subjacent series, although
many wells in the surrounding area draw water from the superjacent series. Ground water
contamination under the SAAD facility has been found in three discrete, relatively thin, strata
located within the upper portion of the superjacent series, approximately 80 to 200 feet below
ground surface. Ground water contamination extends off site to the southwest of the SAAD
facility. The lateral extent of ground water contamination is currently being investigated, but
appears to extend approximately 1,000 feet southwest of SAAD. Industries and residences in
this area use City water from municipal wells located at least 3/4 mile from SAAD.
1.10 Natural Resources
Except for ground water, which is an extremely important resource throughout the Central
Valley, no other natural resources on the site are used.
2 SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Remedial Investigations conducted at SAAD are a part of the U.S. Army Installation
Restoration Program (IRP). The Army is the owner of the site and the lead agency for
implementing the environmental response actions.
In the late 1970's, the U.S. Army Depot Systems Command recommended that SAAD be
included in the Installation Restoration Program (IRP). Consequently, in 1978 and 1979, the
U.S. Army Toxic and Hazardous Materials Agency (USATHMA) conducted a review of
historical data to assess SAAD with regard to the use, storage, treatment, and disposal of toxic
and hazardous materials. USATHMA identified several areas of concern where further
investigation was warranted. In early 1981, the Army initiated an on-site investigation of soil
and ground water in the areas of concern identified by USATHMA, including the Oxidation
Lagoons, Burn Pits, Pesticide Mix Area, Morrison Creek and Old Morrison Creek. Tank 2
was not an identified area of concern at that time. Ground water samples collected during this
E20-91-118 Page 6 of Pan II September 25, 1991
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investigation indicated that VOCs were present in ground water under the southwest comer of
SAAD. Based on the location of the VOCs in ground water, the Burn Pits appeared to be one
of the main sources of ground water contamination in this area.
In late 1981, the CVRWQCB sampled off-site wells near the southwest corner of SAAD.
VOCs were reported in some of the wells closest to SAAD and the Army began working with
the CVRWQCB to assess the source and extent of ground water contamination. The U.S.
EPA and California Department of Health Services (DHS) subsequently became involved in
the investigation of contamination at SAAD and SAAD was placed on the National Priorities
List (NPL) effective August 21, 1987 (52 Fed. Reg. 27620; July 22, 1987). In December
1988, the U.S. Army, the U.S. EPA, and the State of California signed a Federal Facility
Agreement under CERCLA Section 120 agreeing to address the entire facility, including the
contaminated ground water and seven other areas of suspected contamination on the SAAD
facility:
* Tank 2
* Oxidation Lagoons
* Burn Pits
* Building 320 Leach Field
* Pesticide Mix Area
* Firefighter Training Area
* Battery Disposal Well
The FFA also calls for a rigorous RCRA Facility Assessment to identify specific Solid Waste
Management Units that need further characterization and cleanup. To expedite the
investigation and cleanup of the individual sites, the seven areas listed above and the on-site
ground water are each being treated as individual Operable Units. These seven Operable Units
are shown on Figure 2. Ground water was the first Operable Unit investigated, and is
currently being cleaned up under a ROD signed in 1989. Contaminated soil at the Tank 2
Operable Unit is scheduled to be cleaned up next, under the provisions of this ROD.
Tank 2 was a 1000-gallon underground storage tank used to store waste solvents produced at
SAAD. In 1980, Tank 2 was emptied, and in August 1986 it was removed. Upon removal,
Tank 2 showed signs of deterioration. The Army subsequently performed a Remedial
Investigation (RI) and Operable Unit Feasibility Study (OUFS) in accordance with the
requirements of the Federal Facility Agreement. The RI was performed to characterize the
extent of contamination at the Tank 2 Operable Unit. The field and laboratory work for the RI
was conducted in accordance with the Quality Assurance Project Plan (QAPP) and Field
E20-91-118 P«ge 7ofP»rt II September 25, 1991
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Sampling Plan (FSP) reviewed and approved by the regulatory agencies. The RI Report
concluded that VOCs were present in the soil around Tank 2, but that VOCs did not appear to
have migrated to ground water from this site. Therefore, the contaminants in the soil under
Tank 2 have not yet impacted ground water.
The OUFS identified alternatives for cleaning up the site. As part of the OUFS, the Army
prepared a baseline Public Health Evaluation (PHE) to estimate potential health and
environmental risks that could result if no action were taken at the site. The PHE indicated
that two of the VOCs present in the soil, tetrachloroethene and 2-butanone, could migrate to
ground water in the future and subsequently pose a significant risk to future on-site residents if
they were exposed to the ground water. Details of the PHE are summarized in Section 6.
3 HIGHLIGHTS OF COMMUNITY INVOLVEMENT
In June 1988, the Army prepared a Community Relations Plan. In August, 1991, the U.S.
•K
Army issued a Proposed Plan for the Tank 2 Operable Unit. The plan consists of an 11-page
fact sheet that was mailed to residents in the surrounding community. The plan describes the
site background, presents a summary of site contamination, discusses health risks, and
discusses cleanup levels and remedial alternatives. The plan also includes a list of individuals
who may be contacted for additional information, lists the addresses of the information
repositories, and announces the public comment period. The Army also placed an
advertisement in two local daily newspapers, The Sacramento Bee and the Sacramento Union,
for five days prior to the public comment to outline the preferred remedial alternative and to
announce the availability of the OUFS and PP, as part of the Administrative Record, for
review and comment. The SAAD Administrative Record was located at the following local
repositories: SAAD Visitor Control Center and the California State University, Sacramento,
•*
Library. The OUFS and PP were also available for public review at the Sacramento office of
DTSC and at EPA headquarters in San Francisco. ,/ . . , ; - .
-- J±. --• -1 ~ 7*- ;/ • J .'••-''
The public comment period was held from August 19 through September 18, 1991. A public
meeting to discuss the PP was held on August 20, 1991. Approximately 39 people, including
community members and representatives from the Army, USEPA, DTSC, and CVRWQCB
attended the public meeting. Six oral questions were received at the public meeting. No sets
of written comments were received during the public comment period.
E20-91-118 PagcSofPart II September 25, 1991
-------
Details of community involvement activities and responses to official public comments on the
PP are presented in the Responsiveness Summary, which is in Part III of this ROD.
4 SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY
Since the Army began investigating possible contamination at SAAD, eight Operable Units
have been identified that may require response (see Section 2, above). Four of the units, the
Oxidation Lagoons, Tank 2, the Burn Pits, and On-Site Ground Water, were recommended for
OUFS. The other four units will be addressed in the overall site Feasibility Study as the
important site characterization information becomes available.
The Ground Water OUFS was completed on May 19, 1989 and on-site ground water is
currently being remediated under a ROD signed September 29, 1989. The OUFS for Tank 2
was finished on August 2, 1991 and the OUFS for the Oxidation Lagoons was finished on
August 16, 1991. A ROD is expected to be completed for Oxidation Lagoons late in 1991.
The OUFS for Burn Pits is currently being conducted, and the ROD for the Burn Pits is
scheduled to be signed in 1992. Subsequent RODs will address other potential threats posed
by the site. Also, there will be a final ROD that will comprehensively address all of the
contaminated areas at SAAD.
The remedy selected in this ROD will address VOC contamination in soils at the Tank 2
Operable Unit. The principal threat at the Tank 2 Operable Unit is posed by several VOCs
present in the soil, including tetrachloroethene and 2-butanone. The primary risk posed by
VOCs in soil at Tank 2 is through ingestion of, or direct contact with, contaminated ground
water if the tetrachloroethene and 2-butanone currently present in soil are allowed to remain in
place where they could eventually migrate to ground water.
5 SUMMARY OF SITE CHARACTERISTICS
5.1 Contamination Sources
Within the Tank 2 Operable Unit, the 1000-gallon storage tank known as Tank 2 is the only
known source of contaminants. This underground tank reportedly stored waste solvents until
1980. Based on the condition of the tank when it was excavated in 1986, Tank 2 appears to
have deteriorated with age and began leaking waste solvents into the soil surrounding the tank
at some time before it was emptied in 1980.
E20-91-118 Page 9 of Pan II September 25, 1991
-------
5.2 Evaluation of Primary Contaminants
Sampling and analysis of soils at the Tank 2 Operable Unit indicate that VOCs, polycyclic
aromatic hydrocarbons (PAHs) and pesticides exist around the area where Tank 2 was located.
The volume of affected soil (soil with contaminants at concentrations above laboratory
detection limits) is approximately 1,000 cubic yards. Twenty-three chemicals were detected in
soil samples from the Tank 2 area. The two chemicals detected most frequently and at highest
concentrations around Tank 2 were ethylbenzene and xylene. Two other chemicals,
tetrachloroethene and 2-butanone, were detected in a smaller percentage of the samples
analyzed and at relatively low concentrations, but are of concern because they pose the greatest
risk to the public. The remaining 19 chemicals, with the exception of naphthalene, were
detected in less than four percent of the samples analyzed. The 19 chemicals detected are:
Chemical
Anthracene
Benzoic Acid
Benzo(a)anthracene
Benzo(g, h, i)pery lene
Chrysene
4,4'-DDE
4,4-DDT
Dibenzo(a,h)anthracene
Dieldrin
2,4-Dimethylphenol
Fluoranthene
Heptachlor epoxide
Ideno(l,2,3-cd)pyrene
2-Methylnaphthalene
4-Methyphenol
Naphthalene
Phenanthrene
Phenol
Pyrene
Percent of Times Detected"
0.9
0.9
0.9
1.9
1.9. .
1.4*
1.400
0.9.
1.9
3.7.
L4(x)
0.9
0.9
0.9
0.9
3.7
1.9
3.7
x =
Percent is calculated by dividing the number of times detected by the total number of
samples. The total number of samples is 105 to 108, unless percentage is marked with
an (x). Chemicals whose "percent detected" result is marked by an (x) were only
analyzed for in 74 samples.
See Footnote (+) above.
E20-9I-H8
Page 10 of Pan II
September 25, 1991
-------
A summary of the four primary organic chemicals described above, the percentage of times
each chemical was detected, the range of concentrations reported by the analytical laboratory,
the relative mobility of each chemical, and its classification as a carcinogen or non-carcinogen,
is presented in Table 1.
5.3 Location of Contaminants and Potential Routes of Migration
Most of the contaminants found at the Tank 2 Operable Unit are present in approximately 150
cubic yards of soil located in a circle that is 10 to 15 feet wide around the excavated tank and
extends from 9 to 15 feet below the ground surface. Figures 3 and 4 show the mapped
configuration of the contaminated soil in plan view and cross section, respectively. Although
soil samples were analyzed at depths up to 48 feet below ground surface, contaminants were
not found in soil more than 31 feet below ground surface. Therefore, it does not appear that
chemicals from the Tank 2 Operable Unit have migrated to ground water, which is
approximately 80 feet below ground water. Ground water downgradient of Tank 2 is
contaminated with several compounds not found in Tank 2 soils (trichloroethene, freon 113,
1,1,1-trichloroethane and chloroform), but the source of these compounds is currently
unknown. As noted in Section 2, contaminated ground water is being investigated and cleaned
up as a separate Operable Unit.
The entire ground surface above and around the Tank 2 area is currently covered with either
asphalt or concrete. The asphalt and concrete prevent on-site personnel or wildlife from
coming in direct contact with contaminated soil; therefore, there are currently no exposures to
the contaminated soil and there is no surface contaminant migration. The asphalt/concrete
surface also inhibits the infiltration of rainwater through the contaminated soil, thereby
reducing the potential for contaminants to be carried or pushed vertically downward through
the unsaturated soil (vadose zone) to ground water. Contaminants can migrate downward
through the vadose zone under the influence of gravity, spread laterally due to capillary forces,
or may move both vertically and laterally in the vapor phase, but other factors (such as
adsorption of the contaminants to soil or biodegradation of contaminants) may reduce the
movement of individual contaminants through the soil.
6 SUMMARY OF SITE RISKS
6.1 Human Health Risks
As part of the OUFS, the Army prepared a Baseline PHE. This PHE was carried out to
estimate, in the absence of remedial action (i.e., the No Action Alternative), the potential
E20-91-118 Page 11 of Part II September 25, 1991
-------
TABLE 1
SUMMARY OF PRIMARY CONTAMINANTS
TANK 2 OPERABLE UNIT
Chemical
KSHfel
2-Butanone
Ethylbenrene
Tetrachloroethene
Xylenes
Total Number
of Samples
Analyzed
^iISSl
105
105
105
105
Percent
of Times
Detected
4.8
13.3
5.7
21.0
Range of
Detected
Concentrations
;(ug/kg)
< 11 -15,000
<6- 2, 100,000
<6- 39,000
<5- 11,000,000
Relative
Mobility
In Soil
,: v £3|fv£ <
high
moderate
high
moderate
Toxicity
Characteristic
NC
NC
C, NC
NC
C - Carcinogen
NC - Non-carcinogen
ug/kg - micrograms per kilogram, which is equivalent to "parts per billion"
E20-91-118
September 25. 1991
-------
BUILDING #320
TANK 2
EXCAVATION
ATTU STREET
LEGEND
\\
APPROXIMATE EXTENT OF DETECTABLE
CONTAMINATION IN SOIL
APPROXIMATE EXTENT OF CONTAMINANTS AT
CONCENTRATIONS ABOVE CLEANUP GOALS
APPROXIMATE SCALE 1"= 10'
0 10 20
Scale in Feet
N S
I I CROSS SECTION LOCATION
Note: The extent of contamination is an estimate based on interpolating between discrete sample locations.
KLEINFELDER
PROJECT NO.
24-150028-A05
LOCATION OF SOIL CONTAMINATION
PLAN VIEW
TANK 2
SACRAMENTO ARMY DEPOT
SACRAMENTO, CALIFORNIA
FIGURE
-------
N Ground Surface
&
0
•£
Ground S _
sunace fe2!^C^S
xftx ^ TANK
'"^ EXCAV
- 5 TION
- 10 r/ — *
\.
^^
-20 /""
- 25 /
-30 ^ /
- 35
- 40
- 45
- 50
- 55
- 60
- 65
- 70
- 75
80
H N
2
A-
"v
) \
-Jj
• — •""
LEGEND
i / *~ N APPROXIMATE EXTENT OF DETECTABL
*-' \ CONTAMINATION IN SOIL
; s~*. APPROXIMATE EXTENT OF
I S \ CONTAMINANTS AT CONCENTRATIONS
^^ N ABOVE CLEANUP LEVELS
Tf APPROXIMATE LOCATION OF WATER
— TABLE IN 1991
APPROXIMATE SCALE: T = 10'
1
I-" P""-J^^-^»
E
1
02 10 20
Scale in Feet
NOTE: The extent of contamination is an estimate based on interpolating between discrete sample locations.
|d KLEIN FELDER
PROJECT NO. 24-1 50028-A05
LOCATION OF CONTAMINATION FIGURE
CROSS SECTION A
SACRAMENTO ARMY DEPOT H"
SACRAMENTO, CALIFORNIA
-------
future risks to human health by contaminants remaining in soil or leaching through soil,
migrating in ground water, or released to the air. Table 2 provides definitions of key risk
terms from the PHE that are used in this section of the ROD.
6.1.1 Contaminants of Concern
The risk assessment provides a list of contaminants based on the results of the RI that were
found above detection limits or above natural background levels. Twenty-three chemicals of
potential concern were identified in soil that appeared to originate at Tank 2. Of the 23
chemicals, four (ethylbenzene, xylene, tetrachloroethene, and 2-butanone) were detected at
concentrations higher than laboratory reporting limits. The remaining 19 compounds were
detected at concentrations below reporting limits but above instrument detection limits, and all
of the 19 chemicals, except naphthalene, were detected in less than four percent of the samples
collected and analyzed. To be conservative, the PHE estimated the risk posed by all 23
chemicals. However, the four chemicals listed above are the primary chemicals of concern
based on the estimated health risks and on the frequency of detection.
The toxicity characteristics of the four primary chemicals of concern are discussed below:
2-Butanone: 2-Butanone (methyl ethyl ketone) is classified as a non-carcinogen. It has
potential effects on the peripheral nervous system.
Ethylbenzene: a non-carcinogen that is toxic to the lung and central nervous system.
Subchronic and chronic exposures of laboratory animals to this compound cause liver and
kidney damage, as well as testicular toxicity. Teratogenicity of ethylbenzene has also been
indicated in rats.
Tetrachloroethene: classified as a group B2 carcinogen (a probable human carcinogen) based
on evidence that the chemical causes hepatocellular carcinoma (liver tumors) in mice.
Experiments with mice and rats indicate that tetrachloroethene is a teratogen and a
reproductive toxin. Tetrachloroethene may also cause non-carcinogenic health effects,
including liver, kidney and spleen toxicity.
Xylene: classified as a non-carcinogen. Xylene has been observed to cause hyperactivity and
decreased body weight in a chronic ingestion rat study.
6.1.2 Exposure Assessment
Since no exposure pathways to the contaminants present in the soil exist at this time, current
health risks were not evaluated.
E20-91-118 Page 12 of Part II September 25, 1991
-------
TABLE 2
DEFINITIONS OF RISK TERMS
Carcinogen: A substance that, with long term exposure, may increase the incidence of
cancer.
Chronic Daily Intake (CDI): The average amount of chemical in contact with an
individual on a daily basis over a substantial portion of a lifetime.
Chronic Exposure: A persistent, recurring, or long-term exposure. Chronic exposure
may result in health effects (such as cancer) that are delayed in onset, occurring long after
exposure ceased.
Exposure: The opportunity to receive a dose through direct contact with a chemical or
medium containing a chemical.
Exposure Assessment: The process of describing, for a population at risk, the amounts of
chemicals to which individuals are exposed, or the distribution of exposures within a
population, or the average exposure of an entire population.
Health Hazard Index (HHI): An EPA method used to assess the potential
noncarcinogenic risk. The ratio of the CDI to the chronic RfD (or other suitable toxicity
value for noncarcinogens) is calculated. If it is less than one, then the exposure represented
by the CDI is judged unlikely to produce an adverse noncarcinogenic effect. A cumulative,
endpoint-specific HHI can also be calculated to evaluate the risks posed by exposure to
more than one chemical by summing the CDI/RfD ratios for all the chemicals of interest
that exert a similar effect on a particular organ. This approach assumes that multiple
subthreshold exposures could result in an adverse effect on a particular organ and that the
magnitude of the adverse effect will be proportional to the sum of the ratios of the
subthreshold exposures. If the cumulative HHI is greater than one, then there my be
concern for public health risk.
Reference Dose (RfD): An estimate, with uncertainty spanning an order of magnitude, of
a daily exposure level for human population that is likely to be without an appreciable risk
of deleterious effects.
Risk: The nature and probability of occurrence of an unwanted, adverse effect on human
life, health, or on the environment.
Risk Assessment or Health Evaluation: The characterization of the potential adverse
effect on human life, health, or on the environment. According to the National Research
Council's Committee on the Institutional Means for Assessment of Health Risk, human
health risk assessment includes: (1) description on the potential adverse health effects based
on an evaluation of results of epidemiologic, clinical, toxicologic, and environmental
research; (2) extrapolation from those results to predict the types and estimate the extent of
health effect in humans under given conditions of exposure; (3) judgements as to the
number and characteristics of persons exposed at various intensities and durations; (4)
summary judgements on the existence and overall magnitude of the public-health program;
and (5) characterization of the uncertainties inherent in the process of inferring risk.
Slope Factor: A plausible upper-bound estimate (set at 95%) of the probability of a
response per unit intake of a chemical over a lifetime.
E20-91-118 September 25. 1991
-------
The SAAD facility is in an area zoned industrial and the Tank 2 area is occupied by industrial
operations at SAAD. Future residential use of the Tank 2 area is not expected. Most of the
area around SAAD is zoned industrial, although scattered residences exist around the perimeter
of the SAAD facility. To be conservative, the PHE assumed that the Tank 2 Operable Unit
could be re-zoned and developed as residential at some time in the future, and that the
asphalt/concrete covering the area would be removed. Based on these assumptions, two
important exposure scenarios, the Future On-Site Residents and the Future Off-Site Residents,
were developed to assess potential future risks posed by soil and ground water at the site. The
Future On-Site Residents represent the maximum exposed individual (MEI) under the scenario
that the SAAD facility is re-zoned and developed residential in the future. The Future Off-Site
Residents are also called the Average Exposed Individual (AEI), and represent potential risks
to off-site residents if the asphalt/concrete is removed, whether or not the SAAD facility
becomes residential in the future. For the Future On-Site Residents, four potential exposure
pathways were evaluated:
» Direct Dermal Contact with Soil
» Ingestion of Soil
» Drinking Shallow Ground Water
« Breathing Vapors From Shallow Ground Water
For the Future Off-Site Residents, only two potential exposure pathways were evaluated:
* Drinking Shallow Ground. Water
* Breathing Vapors From Shallow Ground Water
Estimates of chemical concentrations at the point of exposure were made as follows. For
exposures that involve direct contact with the soil, only chemicals found in the upper three feet
of soil were addressed. The exposure-point concentration for these chemicals was calculated
by taking the lesser of the following two numbers: the 95% upper confidence limit (UCL) of
the arithmetic mean for samples collected in the upper three feet; or the maximum
concentration reported in. a sample collected from the upper three feet. The exposure-point
soil concentrations for the four primary chemicals of concern are shown in Table 3.
For exposures that involve contact with ground water, the exposure-point concentrations for
the 23 chemicals detected at the site were calculated by 1) finding the 95% UCL of the
arithmetic mean concentration for each chemical based on soil samples collected down to a
depth of 47.5 feet and assuming that the chemical exists uniformly throughout the Tank 2 site
E20-91-118 Page 13of Part II September 25, 1991
-------
TABLE 3
ESTIMATED EXPOSURE-POINT CONCENTRATIONS®
TANK 2 OPERABLE UNIT
Chemical ';
2-Butanone
Ethylbenzene
Tetrachloroethene
Xylene
"-' " '- . ' Expos
On-site
Soil
NA+
NA
0.003
0.004
•"• ££
lire-Point Concentration (ppm)
On-site
Ground Water
16.0
0.99
0.29
28.0
Off-site
Ground Water
0.02
0.0015
0.0018
0.15
ppm: parts per million (equivalent to milligrams per kilogram soil or milligrams per liter of
water.
NA: Not applicable because the chemical was not detected in the upper three feet of soil.
Therefore, no exposure to the chemical via direct contact with soil is expected.
®: Assuming no site cleanup.
E20-91-118
September 25, 1991
-------
at that concentration, and then 2) estimating the amount of each chemical that could leach to
ground water from the area assuming no attenuation or degradation of the chemical. The
resulting estimated future ground water concentrations that could exist immediately under the
site were then used as the exposure-point ground water concentrations for the on-site resident.
The movement of chemicals in ground water to potential future off-site residents was then
modeled using a computer program to estimate the exposure-point ground water concentrations
for the off-site residents. On-site and off-site ground water exposure-point concentrations for
the four primary chemicals of concern are shown in Table 3.
The contaminant intake equations and values chosen for various intake parameters were
derived from the standard intake equations and data presented in EPA guidance documents.
Chronic daily intakes (GDIs), the amount of each chemical that could be inhaled, ingested, or
adsorbed, were estimated in the PHE. The estimated GDIs are shown on Tables 4 and 5. The
GDIs were then multiplied by chemical specific slope factors to calculate carcinogenic risk.
The slope factor represents the 95 % UCL value of the probability of a carcinogenic response
per unit intake of a contaminant over a lifetime (70 years for the analysis in the PHE). Slope
factors used in the PHE are presented in Table 4. To calculate the Health Hazard Index (HHI)
for non-carcinogenic risks, the GDIs were multiplied by chemical-specific Reference Dose
values. The Reference Dose values (RfD) for a substance represents a level of intake which is
unlikely to result in adverse non-carcinogenic health effects in individuals exposed for an
extended period of time (70 years for the analysis in the PHE). RfDs for the four primary
chemicals of concern are shown on Table 5.
6.1.3 Summary of PHE Results
The PHE estimated the potential carcinogenic and non-carcinogenic risks posed by each of the
23 chemicals of concern at the Tank 2 Operable Unit to both the Future On-Site and Future
Off-Site Residents. Carcinogenic risks were estimated by multiplying the GDI of each
contaminant by its slope factor. The carcinogenic risks for the four primary chemicals of
concern, expressed as the Potential Excess Cancer Risk, for each exposure pathway and each
chemical, are shown in Table 4. As a national goal, the EPA's target risk range is 10^ to
10"6, or one additional incidence of cancer per 10,000 people to one additional incidence of
cancer per 1,000,000 people. The aggregate (total) estimated carcinogenic risk from these
four chemicals due to the combined effects of all pathways is 4.5 excess cancers per 10,000
people for Future On-Site Residents and 2.9 excess cancers per 1,000,000 people for Future
E20-91-118 Page 14 of Part II September 25, 1991
-------
E20-9I-II8
TABLE 4
CARCINOGENIC RISKS
TANK 2 OPERABLE UNIT
September 25, 1991
Exposure
Pathway
Chemical
FUTURE ON-SITE RESIDENT^
Soil
Ingestion
Dermal
Contact
With Soil
Ground
Water
Ingestion
Inhalation
of Waterborne
Chemicals
Tetrachloro-
ethane
Tetrachloro-
ethane
Tetrachloro-
ethane
Tetrachloro-
ethane
GDI
(mg/kg-day)
', " '-"' ","*
4.5E-9
2.1E-8
8.3E-3
8.3E-3
GDI
adj. for
absorption
; . ' : ^ <
No
Yes
No
Yes
Slope Factor
(mg/kg-day)"1
Weight
of
Evidence
Slope
Factor
Source/Basis
,; ;f';\'-- ••"-•*-' J- > ,*.''?''* ;&:'*? "• - "•- -
- 'f ,.•-> •• - , (. , . ' •. -^v,V » ..., ;•; " '••' ' •.
5.1E-2
5.1E-2
5.1E-2
3.3E-3
B2
B2
B2
B2
FUTURE OFF-SITE RESIDENT , / , ^ : - -
, -.* J ' ^ I.--' ^ > '^
Ground Water
Ingestion
Inhalation
of Waterborne
Chemicals
Tetrachloro-
ethane
Tetrachloro-
ethane
5.3E-5
5.3E-5
No
Yes
5.1E-2
3.3E-3
B2
B2
IRIS +
IRIS +
IRIS +
IRIS +
':.' %«"• -.-.
IRIS +
IRIS +
Chemical
Specific
Risk
Total
Pathway
Risk
Vli:':^ V: .- .,
2.3E-10
1.1E-9
4.2E-4
2.7E-5
, s ,, --
2.7E-6
L7E-7
2.3E-10
1.1E-9
4.2E-4
2.7E-5
Total
Exposure
Risk
4.5E-4
> -
2.7E-6
1.7E-7
2.9E-6
^"These are proposed toxicity values, but have not been adopted yet.
*These risks represent potential excess cancer cases. A risk of l.OE-6 means that one person out of one million people exposed for a lifetime (70 years)
could potentially develop cancer as a result of the exposure.
-------
TABLE 5
NON-CARCINOGENIC RISKS
TANK 2 OPERABLE UNIT
Exposure
Pathway
Chemical
GDI
(mg/kg'day)
GDI
adj. for
absorption
RfD
(mg/kg-day)
RfD
.Source/Basis
Chemical
Specific
HHI
Total
Pathway
HHI
Total
Exposure
HHI
FOTlJREON-Sni^^ ^ « .'-'"'
Soil
Ingestion
Dermal
Contact
with
Soil
Ground
Water
Ingestion
Inhalation
of
Waterborne
Chemicals
2-Butanone
Ethylbenzene
Tetrachloroethene
Xylene
2-Butanone
Ethylbenzene
Tetrachlorothene
Xylene
2-Butanone
Ethylbenzene
Tetrachloroethene
Xylene
2-Butanone
Ethylbenzene
Tetrachloroethene
Xylene
NA
NA
4.5E-9
6.1E-9
NA
NA
2.1E-8
3.5E-10
4.6E-1
2.8E-2
8.3E-3
8.0E-1
4.6E-1
NI
8.3E-3
NI
NA
NA
No
No
NA
NA
Yes
Yes
No
No
No
No
No
NI
Yes
NI
NA
NA
l.OE-2
2.0E+0
NA
NA
l.OE-2
2.0E+0
5.0E-2
l.OE-1
l.OE-2
2.0E+0
9.0E-2
NI
4.0E-2
NI
NA
NA
1
1
1
1
1
1
1
1
1
1
2
NI
3
NI
NA
NA
4.5E-7
3.1E-9
NA
NA
2.1E-6
1.8E-10
9.1E+0
2.8E-1
8.3E-1
4.0E-1
5.1E+0
NI
2.1E-1
NI
4.5E-7
2.1E-6
10.6E+0
5.3E+0
15.9E+0
FUTUU^OF^SITERl^rDENT^^ f^^^- / v^^ ^l^rV)^^;^ " f',^ \ ; ;*,/
Ground
Water
Ingestion
Inhalation
of
Waterborne
Chemicals
2-Butanone
Ethylbenzene
Tetrachloroethene
Xylene
2-Butanone
Ethylbenzene
Tetrachloroethene
Xylene
5.8E-4
4.4E-5
5.3E-5
4.1E-3
5.8E-4
NI
5.3E-5
NI
No
No
No
No
No
NI
Yes
NI
5.0E-2
l.OE-1
l.OE-2
2.0E+0
9.0E-2
NI
4.0E-2
NI
1
1
1
1
2
NI
3
NI
1.1E-2
4.4E-4
5.3E-3
2.1E-3
6.3E-3
NI
1.3E-3
NI
1.9E-2
7.6E-3
2.7E-2
NA - Not appropriate because chemical does not exist in upper 3 feet of soil
NI - Not included because chemical is not an aliphatic. Therefore, by convention, it is not included in this exposure path.
1 - Supplied by EPA, Dr. Gerald Hiatt, personal communication.
2 - IRIS (Integrated Risk Information System)
3 - Derived in PHE
-------
Off-Site Residents. Thus, the baseline risk estimated for the Future On-Site Resident is
slightly higher than the target risk range. The baseline risk estimate for Future Off-Site
Residents is within the target risk range.
The non-carcinogenic risk posed by contaminants was estimated by computing the HHI for
each chemical in accordance with procedures established by EPA. An HHI of greater than 1.0
indicates a potential health threat. The non-carcinogenic risk posed by the four primary
chemicals of concern is shown on Table 5. The aggregate estimated HHI from these four
chemicals due to the combined effects of all pathways is 16.1 for the Future On-Site Resident
and is almost six orders of magnitude less than 1.0 for the Future Off-Site Resident.
Therefore, the baseline risk assessment indicates a potential non-carcinogenic health threat to
the Future On-Site Residents due to chemicals at the site, but no non-carcinogenic health threat
to the Future Off-Site Residents.
Health risk assessment provides a means of quantifying potential risks posed by chemicals
present in the environment. However, a great deal of uncertainty exists in the estimation
process. In addition to uncertainties common to the risk assessment process, sources of
uncertainty in the PHE conducted for the Tank 2 Operable Unit include:
Site Characterization — Chemicals may exist in localized "hotspots" where samples were not
collected or chemicals may exist at the site but may not have been detected by the selected
analytical methods. This could result in underestimations of risk.
Estimation of Exposure Point Concentrations -- These may be overestimated since (1)
chemicals reported as "non-detects" are assigned a value of half the detection limit for the
purpose of calculating site concentrations, and (2) the PHE assumes that chemical
concentrations in soil and ground water remain constant over the 70 year exposure period,
rather than decreasing as expected due to volatilization, degradation, and leaching. This could
result in overestimating the risk.
Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action selected in this ROD, may present an imminent and
substantial endangerment to public health, welfare, or the environment.
E20-91-118 Page 15 of Pan II September 25, 1991
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6.2 Environmental Evaluation
Ecological assessments, aquatic toxicity tests, stream evaluations, and terrestrial surveys were
not performed for the Tank 2 Operable Unit because the site is relatively small (875 square
feet), covered with asphalt/concrete, and located adjacent to industrial buildings and roadways.
Therefore, wildlife and surface water bodies are not expected to come in contact with
contaminated soil at the Tank 2 Operable Unit. There is no evidence of critical habitat,
endangered species, or wetlands within the Tank 2 Operable Unit.
The treatment of soil at Tank 2 is not expected to affect wildlife or wildlife habitat, since the
system installed will be located entirely in the industrial area next to Building 320 and no air
emissions of organic chemicals are expected during cleanup.
6.3 Cleanup Levels
Based on the results of the PHE, cleanup levels were established for each of the four primary
chemicals of concern. Since the PHE showed that health risks were highest for the Future On-
Site Residents, the cleanup levels were developed based on that scenario. Potential ground
water exposures represented the greatest risk to human health; therefore, cleanup levels were
developed by estimating the effects that contaminants left in the soil at concentrations below
cleanup levels would have on the ground water. The selected cleanup levels will reduce
contaminant levels in soil such that future ground water impacts will not affect human health
and will comply with Applicable or Relevant and Appropriate Requirements (ARARs). A
conservative computer model was used to estimate contaminant concentrations in leachate for
chemicals that could potentially migrate to ground water. Leachate concentrations of 2-
butanone and heptachlor epoxide could exceed state MCLs assuming that these contaminants
exist throughout the entire Tank 2 area. However, since 2-butanone was detected in only five
of 105 samples and heptachlor epoxide was detected in only one of 74 samples, actual leachate
concentrations are expected to meet ARARs. A list of ARARs is provided on Table A-l,
Appendix A. The cleanup levels are shown in Table 6, and are discussed below.
6.3.1 Non-Carcinogens
Of the four primary chemicals of concern, only 2-butanone and tetrachloroethene exceed the
acceptable HHI of 1.0. Cleanup levels were developed for both of these compounds. The
cleanup levels for 2-butanone and tetrachloroethene will result in a reduction in risk of 92%
E20-91-118 Page 16 of Pan II September 25, 1991
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TABLE 6
CONTAMINANT CONCENTRATIONS & CLEANUP LEVELS IN SOIL
Contaminants"1"
Average
Area
Levels
(ppm*)
Maximum
Area
Levels
(ppm*)
Cleanup
Levels
(ppm*)
Percent
Reduction
In Health
Risks
2-butanone
ethylbenzene
Total xylenes
tetrachloroethene
**
107
645
9
15
2,300
11,000
39
1.2
6
23
0.2
92
97
98
99
*ppm = Parts per million
** = This compound was not found frequently enough to calculate an area average.
To be conservative, the risk assessment assumed that the average level of this
compound is 18 ppm, which is higher than the maximum level that was
detected.
•f = Only contaminants with cleanup levels are included in this table.
E20-91-118 September 25, 1991
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and 99%, respectively. Ethylbenzene and xylenes, although individually below the HHI level
of concern, when considered together may contribute to the total risk at the site. These
compounds were the most frequently detected chemicals, and were present at relatively high
concentrations. Therefore, cleanup levels were developed for these compounds that represent
risk reductions of 97% for ethylbenzene and 98% for xylene.
6.3.2 Carcinogens
Of the four primary chemicals of concern, only tetrachloroethene is a carcinogen. The
proposed soil clean-up level, 0.2 mg/kg, would result in an estimated risk of approximately
4E-6 (four additional cases of cancer per one million people exposed). This represents a 99%
reduction in the level of risk estimated for the site.
7 DESCRIPTION OF ALTERNATIVES
An OUFS was conducted to develop and evaluate remedial alternatives for the Tank 2
Operable Unit. Seventy-five remedial alternatives were assembled from applicable remedial
technology process options and were initially evaluated for effectiveness, implementability,
and cost. Thirteen alternatives for cleaning up soil at Tank 2 passed this initial screening and
were then considered in detail by comparing them to the nine criteria required by the NCP.
In addition to the remedial alternatives, the NCP and CERCLA require that a no-action
alternative be considered at every site. The no-action alternative serves primarily as a point-
of-comparison for other alternatives. The fourteen alternatives evaluated were:
1) Alternative 1: No Action
2) Alternative 2a: Soil Ventilation, Air Emission Control by Thermal Vapor
Treatment, On-Site Entrained Water Treatment
3) Alternative 2b: Soil Ventilation, Air Emission Control by Gas Phase
Carbon Adsorption, On-Site Entrained Water Treatment
4) Alternative 2c: Soil Ventilation, Air Emission Control by Vapor
Recovery, On-Site Entrained Water Treatment
5) Alternative 3a: Soil Ventilation, Air Emission Control by Thermal Vapor
Treatment, Off-Site Entrained Water Treatment/Disposal
6) Alternative 3b: Soil Ventilation, Air Emission Control by Gas Phase
Carbon Adsorption, Off-Site Entrained Water
Treatment/Disposal
E20-91-118 Page 17ofPanII September 25. 1991
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7) Alternative 3c:
8) Alternative 4:
9) Alternative 5:
10) Alternative 6a:
11) Alternative 6b:
12) Alternative 7a:
13) Alternative 7b:
14) Alternative 8:
Soil Ventilation, Air Emission Control by Vapor
Recovery, Off-Site Entrained Water Treatment/Disposal
Excavation, Soil Washing, Activated Carbon Vapor
Treatment, Off-Site Liquid Treatment, Backfill
Excavation, Incineration, Backfill
Excavation, Low Temperature Desorption, Air Emission
Control by Gas Phase Carbon Adsorption, On-Site Water
Treatment, Backfill
Excavation, Low Temperature Desorption, Air Emissions
Control by Incineration, On-Site Water Treatment,
Backfill
Excavation, Low Temperature Desorption, Air Emission
Control by Gas Phase Carbon Adsorption, Off-Site Water
Treatment, Backfill
Excavation, Low Temperature Desorption, Air Emissions
Control by Incineration, Off-Site Water Treatment,
Backfill
Excavation, Surface Aerobic Biodegradation, Backfill
•2
Each alternative would be applied to remediate approximately 150 cubic yards (ydj) of soil
q
that contain the bulk of the contaminants detected at the site. The remaining 850 ydj of
affected soil contains contaminants at concentration that are already below cleanup levels. The
•3
location and configuration of the 150 ydj are described in Section 5.3. Each alternative is
expected to attain the treatment levels (cleanup levels) described in Section 6.3. Each
alternative can be implemented, subject to the difficulties and considerations described in
Section 8.6. The 14 alternatives are described in more detail in the following sections.
7.1 Alternative 1: No Action
Under this alternative, the Army would take no further action to control the source of
contamination. However, long-term monitoring of the site would be necessary to monitor
contaminant migration. Since periodic ground water monitoring is presently being conducted,
it is assumed that the current monitoring program would be continued under this alternative.
Because this alternative would result in contaminants remaining on site, CERCLA requires that
the site be reviewed every five years. If indicated by the review, remedial actions would be
implemented at that time to remove or treat the wastes. Estimated future upper-bound
E20-91-118
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September 25, 1991
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contaminant concentrations in ground water exceed State MCLs, which are ARARs for this
site (see Table A-l in Appendix A). Therefore, this alternative does not meet ARARs.
7.2 Alternatives 2a, 2b, & 2c
These three alternatives involve the use of a soil ventilation system (SVS), composed of
extraction wells and a vacuum pump/rotary blower, to extract hydrocarbon vapor from the
subsurface soil. The extracted vapor is then treated either by Thermal Vapor Treatment
(Alternative 2a), Gas Phase Adsorption (Alternative 2b), or Vapor Recovery/Condensation
(Alternative 2c). Entrained water, if any, will be treated in the existing on-site UV/H2O2
water treatment unit. Air sampling will be performed to evaluate the effectiveness of the
operation and compliance with the emissions requirements (a permit is not required for
Alternative 2b).
Extraction well sizing and the selection of a vacuum pump/blower will depend on the desired
soil ventilation rate. The results of treatability testing using a computer modeling approach
suggest that a soil ventilation rate of 200 cfm can accomplish site remediation over a period of
six months. For a 200 cubic feet per minute (cfm) SVS, the extraction system will be
comprised of two-inch wells screened from nine to 18 feet below grade.
The extracted vapor will be treated prior to discharge to the atmosphere. Treatment can be
accomplished in one of three ways:
Alternative 2a: Thermal Vapor Treatment - treatment will be accomplished by thermal
treatment such as catalytic oxidation, a catalyst-aided, low-temperature burning of organic
vapors. Typical destruction efficiencies are 90 to 99 percent.
Alternative 2b: Gas Phase Carbon Adsorption - treatment will be accomplished in an activated
carbon unit consisting of series of approximately 2000-pound carbon canisters connected in
parallel. The carbon will be changed out as necessary depending on contaminant loading, and
the loaded activated carbon will be shipped off site to a carbon regeneration facility where the
contaminants will be stripped. Typical organic destruction efficiencies are 90 percent.
Alternative 2c: Vapor Recovery - treatment will be accomplished in a refrigeration cycle
which turns the contaminants and the moisture in the vapors into a liquid. The condensed
E20-91-118 Page 19 of Pan II September 25. 1991
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liquid consists of a mixture of organics and water that will be treated in the on-site UV/H2O2
treatment plant.
Subsequent to treatment, the estimated upper-bound concentration of contaminants in ground
water are expected to be below State MCLs, which are ARARs for this site. (See Table A-l
in Appendix A. Other ARARs that will be met by Alternatives 2a, 2b, and 2c are presented
on Table A-2 in Appendix A.
7.3 Alternatives 3a, 3b and 3c
These three alternatives are the same as Alternatives 2a, 2b and 2c except that entrained water,
if any, will be collected in 55-gallon drums and transported off site for treatment at a facility
permitted to treat hazardous waste. ARARs that will be met by Alternatives 3a, 3b, and 3c are
shown on Table A-2 in Appendix A.
7.4 Alternative 4
Under this alternative, the contaminated soil would be excavated and washed on site.
Treatability testing conducted on soil from the site suggests the use of anionic surfactants as
soil washing reagents with a minimum reaction time of 30 minutes. Vapor treatment of
fugitive emissions during operations, if required, will be by activated carbon. Spent carbon
will be thermally regenerated or incinerated at a RCRA permitted facility. Wash liquid will be
transported off site for treatment at a facility permitted to treat hazardous waste. Soil sampling
will be conducted following treatment to ensure that soil cleanup levels have been met. The
treated soil will be returned to the site. ARARs that will be met by this alternative are
described on Table A-3 in Appendix A.
7.5 Alternatives
This alternative entails excavation and on-site treatment of contaminated soil in a circulating
bed combuster (CBC). A CBC uses high air velocity and circulating solids to create a
turbulent combustion zone for efficient destruction of organic constituents. Based on the
results of testing the incineration process on Tank 2 soil, a 36-inch-internal-diameter CBC unit
operating at 1600° F with a residence time of 30 minutes will be required to accomplish site
remediation. Air sampling will be performed on the exhaust gases to assess the organic
contaminant destruction efficiency and to verify compliance with emission requirements. Soil
sampling will be performed on the thermally treated soil to verify that cleanup levels have
E20-91-118 Page 20 of Part II September 25, 1991
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been met. The treated soil will then be returned to the site. ARARs that will be met by this
alternative are described in Table A-4 in Appendix A.
7.6 Alternatives 6a and 6b
These alternatives involve excavation and on-site treatment of contaminated soil in a low
temperature desorption (LTD) unit. The LTD unit includes an indirectly fired thermal
processor, a vapor recovery unit, and either a gas phase carbon adsorption unit (Alternative
6a) or an incinerator operating at 1600°F to 1800°F (Alternative 6b) for treatment of the non-
condensible fraction of the vapors. Treatability test results using the LTD process on soil from
Tank 2 suggest that a soil processing temperature of 350°F and a residence time of 46 minutes
will be sufficient to treat soil to meet the established cleanup levels (see Section 6.3). The
condensate from the vapor recovery unit will be treated at the existing on-site UV/H202
treatment plant. Spent carbon (Alternative 6a only) will be thermally regenerated or
incinerated at a RCRA permitted facility. Air sampling will be performed to assess
compliance with emissions requirements and soil sampling will be performed to confirm that
cleanup levels are met. Treated soil will be returned to the site. ARARs that will be met by
these alternatives are described on Table A-5 in Appendix A.
7.7 Alternatives 7a and 7b
These alternatives are identical to Alternatives 6a and 6b, respectively, except that the
condensate from the vapor recovery unit will be treated off site. The condensate will be
transported in 55-gallon drums to a facility permitted to treat hazardous waste. Treated soil
will be returned to the site. ARARs that will be met by these alternatives are described on
Table A-5 in Appendix A.
7.8 Alternative 8
This alternative involves excavation and on-site treatment of contaminated soil using surface
aerobic biodegradation. The excavated soil would be placed in a lined treatment cell with
dimensions of approximately 73 x 73 feet and spread to a depth of 12 inches or less. Periodic
tilling would be conducted to aerate the soil. Treatability testing conducted on soil from Tank
2 indicates that effective biodegradation of organic constituents to non-detectable levels can be
accomplished in two weeks by stimulating the indigenous bacteria with nutrients and moisture.
Soil sampling will be performed to assess whether cleanup levels have been met. Upon
verification of cleanup, the treated soil will be returned to the site.
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This alternative could be difficult to implement due to lack of space at the site. If the
treatment cell needs to be constructed away from Tank 2 due to the lack of space, it will be
located in an area where wildlife and wildlife habitat do not currently exist so that physical
effects on the environment are reduced. ARARs that will be met by this Alternative are
described on Table A-6 in Appendix A.
8 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The 14 remedial alternatives have been assessed using the nine evaluation criteria developed to
address CERCLA requirements. The nine criteria are:
Threshold Criteria
1). Overall Protection of Human Health and the Environment
2). Compliance with Applicable or Relevant and Appropriate Requirements
(ARARs)
Primary Balancing Criteria
3) Long-Term Effectiveness and Permanence
4). Reduction of Toxicity, Mobility, or Volume (TMV)
5). Short-Term Effectiveness
6). Implementability
7). Cost
Modifying Criteria
8). State Acceptance
9). Community Acceptance
The following sections compare the 14 remedial alternatives in terms of each of the nine
criteria.
8.1 Overall Protection of Human Health and the Environment
Alternative 1, No Action, would not provide adequate protection of human health and the
environment. It would allow contaminants to remain on site and potentially to migrate to
E20-91-I18 Page 22 of Pan II September 25, 1991
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ground water. The remaining 13 alternatives would meet the cleanup levels described in
Section 6.3, thereby reducing the estimated tofojjj carcinogenic risk posed by the site by more
than 90 percent to 4.5E-6 and reducing the estimated HHI to approximately 1.0.
8.2 Compliance with ARARs
Alternative 1 does not meet all of the ARARs, since potential ground water contamination does
not meet California MCLs (22 CCR, Article 5.5, Section 64444.5) or the non-degradation
policy (State Board Resolution No. 68-16), and since this alternative does not implement
measures to restore the Tank 2 site.
The remaining 13 remedial alternatives will meet the current Federal, State and local ARARs
identified during development of the OUFS (See Tables A-2 through A-6, Appendix A).
8.3 Long-Term Effectiveness and Permanence
This criterion addresses the ability of a remedy to maintain reliable protection of human health
and the environment over time once cleanup levels have been met. Alternative 1, No Action,
does not satisfy this criterion since no cleanup takes place. The remaining 13 alternatives
represent permanent remedies. Each alternative is expected to meet the established cleanup
levels and, in doing so, will provide long-term reliable protection of human health and the
environment.
8.4 Reduction in Toxicity, Mobility, or Volume Through Treatment
This criterion refers to the ability of a remedy to reduce the toxicity, mobility and volume of
the hazardous components present at the site. Alternative 1 does not reduce toxicity, mobility
or volume since no cleanup takes place. The remaining alternatives will remove contaminants
from the site, thereby satisfying the criteria for reducing the toxicity of the soil at the site.
Only three of the alternatives, Alternatives 2a, 5, and 6b provide for the complete on-site
destruction of contaminants. The remaining 10 alternatives do not meet the preference for
technologies that permanently destroy contaminants, since they involve the off-site
transportation of hazardous materials to permitted treatment facilities, or the potential for
uncontrolled air emissions of contaminants (Alternative 8 only).
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8.5 Short-Term Effectiveness
This criterion addresses the period of time needed to complete the remedy, and any adverse
impacts on human health and the environment that may be posed during the construction and
implementation, until cleanup levels are met. The period of time needed to complete the 14
alternatives are as follows:
Alternative 1 None
Alternatives 2a,2b,2c 6 months
Alternatives 3a,3b,3c 6 months
Alternative 4 6 months
Alternative 5 3 months
Alternatives 6a, 6b 3 months
Alternatives 7a, 7b 3 months
Alterative 8 3 months
Alternative 1 satisfies the preference for alternatives that minimize short-term adverse impacts
on human health and the environment, since the site is currently covered with asphalt/concrete
so that exposure pathways do not currently exist. The remaining 13 alternatives reduce the
potential future health risk to the public by reducing the potential for transport of contaminants
to ground water, however there are potential short-term exposures involved during the
construction and operation of the alternative technologies. During construction of each
alternative, workers could come in contact with contaminated soil. Workers will follow
OSHA guidelines for work on hazardous waste sites. Residents in the area surrounding SAAD
should not be exposed during construction except for the possible exception of slight increases
in dust, which will be controlled through the use of dust control technologies. Twelve of the
alternatives (all but Alternative 8) will have controlled air emissions so there is a potential for
exposure to on-site personnel and off-site residents. Air emission control devices that use
Thermal Vapor Control (Alternatives 2a & 3a) could potentially create dioxins. Additional
monitoring of air emissions would be required for these alternatives. A health risk assessment
(HRA) of the remedial alternatives indicates that the potential excess cancer risk to the MEI
due to the expected emissions is less than one in one million, and the HHI for the MEI is less
than 1.0. Health risks due to uncontrolled air emissions during soil aeration (Alternative 8)
are also expected to be less than one-in-one-million (carcinogenic risk) and less than 1.0 (non-
carcinogenic HHI).
Alternatives 3a, 3b, 3c, 4, 7a, and 7b also involve some short-term risk associated with the
transport of hazardous liquid waste off site to a permitted treatment facility.
E20-91-118 Pa»c 24 of Part II September 25, 1991
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8.6 Implementability
Implementability refers to the technical and administrative feasibility of a remedy, including
the availability of necessary materials and services. All of the alternatives can be implemented
at the site, however treatment units specified in Alternatives 2c, 3c, 5, 6a, 6b, 7a, and 7b (the
Vapor Recovery/Condensation Unit, the Incinerator, and the Low Temperature Desorption
Unit) are less readily available than those specified in the other alternatives. Thermal Vapor
Treatment of air emissions (Alternatives 2a and 3a) is currently an innovative technology and
may, therefore, be more difficult to implement than other established technologies.
Alternatives that require excavation of the contaminated soil (Alternatives 4, 5, 6a, 6b, 7a, 7b,
and 8) would be more difficult to implement because excavation will be complicated by the
presence of underground utilities in the area and the proximity of Building 320. Alternative 8
will also require more space than the other alternatives so that a treatment cell can be
constructed.
8.7 Cost
This criterion evaluates the capital and operation and maintenance (O&M) costs and present
worth of each alternative. These costs are as follows:
Present Capital O&M
Alternative Worth Cost Cost
Alternative 1 $ 0 $ 0 $0
Alternative 2a $ 482,515* $ 482,515* $0
Alternative 2b $ 614,414 $ 614,414 $0
Alternative 2c $ 763,182 $ 763,182 $0
Alternative 3a $ 482,791* $ 482,791* $0
Alternative 3b $ 614,690 $ 614,690 $0
Alternative 3c $ 766,145 $ 766,145 $0
Alternative 4 $ 666,348 $ 666,348 $0
Alternatives $ 2,507,494 $ 2,507,494 $0
Alternative 6a $ 764,223 $ 764,223 $0
Alternative 6b $ 770,849 $ 770,849 $0
Alternative 7a $ 768,251 $ 768,251 $0
Alternative 7b $ 774,876 $ 774,876 $0
Alternatives $ 701,116 $ 701,116 $0
*Does not include costs for monitoring potential dioxin emissions. These costs are not
currently known since the degree of stringency required is not known for this innovative
technology.
Since all of the alternatives require less than one year to complete, the estimated costs are
capital costs. No recurring O&M costs are expected. Alternative 1 is the least expensive and
E20-91-118 Page 25 of Part II September 25, 1991
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Alternative 5 is the most expensive remedy. The remaining 12 remedies have similar
estimated costs, falling in the range of $483,000 to $775,000.
8.8 State Acceptance
This criterion indicates whether, based on its review of the information, the State concurs
with, opposes or has no comment on the preferred alternative. The State of California has
concurred with the selected alternative for cleanup of the soil at the Tank 2 site.
8.9 Community Acceptance
This criterion indicates whether the public concurs with, opposes, or has no comment on the
preferred alternative. During the public meeting and comment period, the public requested
information on the types of sampling and analyses performed by the Army, the time frame for
remedial activity, the effects of rainfall, and the use of Superfund money. The public did not
comment on or indicate concerns about the preferred alternative. Part III of this ROD contains
the Responsiveness Summary from the public comment period and public meeting.
9 SELECTED REMEDY
Alternative 2b is the remedy selected for cleanup of the soil at the Tank 2 operable unit. This
alternative will involve the use of extraction wells and a vacuum pump/rotary blower to extract
hydrocarbon vapor from the subsurface soil. Extraction well sizing and the selection of the
vacuum/blower will depend on the desired soil ventilation rate. The results of treatability
testing suggest that a soil ventilation rate of 200 cfm can meet cleanup levels over a period of
six months. For a 200 cfm unit, the extraction system will be made up of two-inch PVC
wells, screened from nine to eighteen feet below grade. The number of extraction wells and
their configuration are unknown and will be defined during design tests. The extraction wells
will be connected to the vacuum pump/rotary blower with two-inch PVC pipe via an air/water
separator used to separate entrained water from the extracted vapor. The extracted vapor will
be treated by Gas Phase Adsorption, using an activated carbon unit consisting of series of
approximately 2000-pound carbon canisters connected in parallel. The carbon will be changed
out as necessary depending on contaminant loading, and the loaded activated carbon will be
shipped off site to a carbon regeneration facility where the contaminants will be stripped.
Typical organic destruction efficiencies are 90 percent. Entrained water, if any, will be
collected for treatment in the existing on-site UV/H2C>2 water treatment unit. Air sampling
E20-91-1I8 Page 26 of Pan II September 25. 1991
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will be performed to evaluate the effectiveness of the operation and compliance with the
emissions requirements. The treated air stream using carbon adsorption will comply with the
substantive requirements of the permit although the procedural requirements (such as paper
work) are not required because the Superfund action is conducted entirely on site. Upon
completion of the remedial action, confirmation sampling of the treated soil will be performed
to ascertain that cleanup levels have been met. Details of the confirmation sampling will be
presented in a future remedial action plan.
The itemized cost estimate for the selected alternative is shown in Table 7. Because the
remedy is expected to take six months, recurring operation and maintenance costs are not
expected. Therefore, Capital Cost equals the Present Worth of the Alternative.
The selected remedy is expected to meet performance standards, in the form of cleanup levels,
as described in Section 6.3. By meeting the cleanup levels for soil, public health and the
environment will be protected and all State and Federal ARARs, including Drinking Water
MCLs, should be met now and in the future. Estimated final risk levels, based on the cleanup
levels, are shown in Table 8.
Alternative 2b complies with ARARs and reduces the toxicity, mobility, and volume of the
contaminants in soil equally as well as the other alternatives. The short-term effectiveness of
Alternative 2b is the same or better than the remaining alternatives. Alternative 2b is easily
implemented, and is less costly than other alternatives that could be implemented easily at the
site.
The State of California concurs with the selected remedy.
10 STATUTORY DETERMINATIONS
The Army's primary responsibility at this NPL site is to undertake remedial actions that
achieve adequate protection of human health and the environment. Section 121 of CERCLA
establishes several statutory requirements and preferences. These specify that when complete,
the selected remedial action must comply with ARARs unless a statutory waiver is justified.
The selected remedy must also be cost-effective and utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the maximum extent practicable.
Finally, the statute expresses a preference for remedies that significantly reduce the volume,
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TABLE 7
COST ESTIMATE SUMMARY
SELECTED ALTERNATIVE:
SOIL VENTILATION, CARBON ADSORPTION TREATMENT OF VAPOR,
UV/H2O2 WATER TREATMENT
COST COMPONENT
NOTE
CONSTRUCTION
COSTS ($)
Soil Ventilation System
Electrical Power Hookup
Activated Carbon Vapor Treatment
Electricity
Soil Gas Sampling and Analysis
Post Remediation Soil Sampling
and Analysis
Water Transport
UV/H2O2 Water Treatment
A/E SVS Monitoring
Mobilization Bonds and Insurance (5%)
Workplan/Final Design
Permit Preparation
Site Specific Safety Plan
Sampling Plan
Design Quality Control Plan
Chemical Data Management Plan
Startup/Final Reports
Interim Progress Reports
CONSTRUCTION COST SUBTOTAL
Bid Contingency (15%)
Scope Contingency (15%)
CONSTRUCTION COST TOTAL
Services During Construction (6%)
TOTAL IMPLEMENTATION COST
Conceptual Engineering Design Cost (6%)
Document Review/Construction Observation
1
2
3
4
1
5*
6
7
2
8
2
2
2
2
2
2
2
2
9
9
9
10
59,333
5,000
131,000
2,700
included
23,430
200
20
12,662
11,717
24,864
7,778
14,084
10,680
11,409
29,439
14,210
43.382
401,908
60,286
60.286
522,481
31.349
553,830
33,230
27.355
TOTAL PROJECT COST
11
614.414
E20-91-118
September 25. 1991
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TABLE 7 (Continued)
COST ESTIMATE SUMMARY
SELECTED ALTERNATIVE:
SOIL VENTILATION, CARBON ADSORPTION TREATMENT OF VAPOR,
UV/H2O2 WATER TREATMENT
SELECTED ALTERNATIVE NOTES:
* Includes 10% markup for outside services
1. Based on Kleinfelder cost estimate 5/6/91
Includes well installation
Assumes 150 in-place cubic yards of soil to be remediated
200 SCFM system
4 month soil ventilation system operation includes soil gas sampling and analysis
2. Based on Kleinfelder Spec. No. 8976
3. Based on Kleinfelder cost estimate 7/10/91
Includes vapor cooling system
4. Electricity cost = $0.08163/KWH for four month duration
5. Based on Kleinfelder cost estimate 2/5/91
3 borings/6 samples
EPA 8240, 8270, TCLP volatiles, TCLP semi-volatiles
6. Based on SAAD estimate of transport costs
100 gallons water, 2 manhours/55 gallon drum = 4 hours
7. Based on SAAD estimate of tmt cost/gallon at tmt plant
100 gallons water, .2 cents/gallon
8. Based on 5 % of total construction cost
excluding permits, workplan, safety plan, sampling plan
chemical data management plan, design quality control plan,
and reports preparation
9 Based on percentage of construction costs
10 Assume 48 hours of construction observation to review sampling results,
remediation progress, weekly letter reports, and final summary report.
Review of final design, workplan, safety plan, sampling plan, chemical data
management plan, and design quality control plan.
11 Based on 1991 dollars
£20-91-118 September 26, 1991
-------
TABLE 8
ESTIMATED CARCINOGENIC AND NON-CARCINOGENIC RISKS AFTER REMEDIATION
TANK 2 OPERABLE UNIT
Exposure
Pathway
Chemical
WTuteON:SlTE RESIDENT <•
Soil
Ingestion
Dermal
Contact
with
Soil
Ground
Water
Ingestion
Inhalation
of
Waterborne
Chemicals
2-Butanone
Ethylbenzene
Tetrachloroethene
Xylene
2-Butanone
Ethylbenzene
Tetrachlorothene
Xylene
2-Butanone
Ethylbenzene
Tetrachloroethene
Xylene
2-Butanone
Ethylbenzene
Tetrachloroethene
Xylene
GDI
(mg/kg-day)
Chem. Spec.
Carcinogenic
Risk
; '-^f^^-^/;^
NA
NA
4.5E-9
6.1E-9
NA
NA
2.1E-8
3.5E-10
4.6E-1
2.8E-2
8.3E-3
8.0E-1
4.6E-1
NI
8.3E-3
NI
NC
NC
2.3E-12
NC
NC
NC
1.1E-11
NC
NC
NC
4.2E-6
NC
NC
NC
2.7E-7
NC
Pathway
Carcinogenic
Risk
Total
Carcinogenic
Risk
Chemical
Specific
HHI
Total
Pathway
HHI
Total
Exposure
HHI
f;;o\5^/f-^:|^;^:: v * *;.'f/X, X , . ' ,;
2.3E-12
1.1E-11
4.2E-6
2.7E-7
4.5E-6
NA
NA
4.5E-9
6.2E-11
NA
NA
2.1E-8
3.6E-12
7.3E-1
8.4E-3
8.3E-3
8.0E-3
4.1E-1
NI
2.1E-2
Nl
4.6E-9
2.1E-8
7.5E-1
4.3E-1
1.2
FUTURE OFF-SITE RESIDENT \ = ; ; ,
Ground
Water
Ingestion
Inhalation
of
Waterborne
Chemicals
2-Butanone
Ethylbenzene
Tetrachloroethene
Xylene
2-Butanone
Ethylbenzene
Tetrachloroethene
Xylene
5.8E-4
4.4E-5
5.3E-5
4.1E-3
5.8E-4
NI
5.3E-5
NI
NC
NC
2.7E-8
NC
NC
NC
1.7E-9
NC
2.7E-8
1.7E-9
2.9E-8
8.8E-4
1.3E-5
5.3E-5
4.2E-5
5.0E-4
NI
1.3E-5
NI
9.9E-4
5.1E-4
1.5E-3
N A - Not appropriate because chemical does not exist in upper 3 feet of soil
Nl - Not included because chemical is not an aliphatic. Therefore, by convention, it is not included in this exposure path.
NC - Not a Carcinogen
1 - Supplied by EPA, Dr. Gerald Hiatt, personal communication.
2 - IRIS (Integrated Risk Information System) 3 - Derived in PHE
-------
toxicity, or mobility of the hazardous waste. The following sections discuss how the selected
remedy meets the statutory requirements.
10.1 Protection of Human Health and the Environment
The selected remedy will remove contaminants from the soil so that the carcinogenic risk to
Future On-Site Residents (the most exposed individuals) will be reduced from 4.5E-4 to
4.5E-6. The non-carcinogenic HHI will be reduced to approximately 1. By removing the
contaminants from soil, no direct exposure to harmful concentrations in the soil or in the
ground water should occur now or in the future.
10.2 Compliance with ARARS
Section 121 of CERCLA provides that, except under certain narrow exemptions, remedial
actions shall comply with Federal and State laws that are applicable or relevant and appropriate
to the contaminants and circumstances of the site. The process by which potential ARARs are
identified, screened, and analyzed to determine if they actually are ARARs is described in
"CERCLA Compliance with Other Laws Manual" (EPA, 1988).
There are three general classes of ARARs:
1. Chemical Specific-for example, a drinking water "MCL" defines a maximum
acceptable concentration for drinking water;
2. Action Specific - for example, a landfill built to accept hazardous waste would have
to meet RCRA 264, Subpart N regulations and associated
requirements on design of the landfill;
3. Location Specific - for example, a hazardous waste landfill could not be built on a
flood plain.
The selected remedy complies with all ARARs and To Be Considered criteria (TBCs)
established for this site. The list of ARARs is contained in Appendix A. Table A-l provides a
comprehensive comparison of Federal, State, and local ARARs and TBCs to estimated
chemical concentrations derived in the baseline PHE. Tables A-2 through A-6 summarize
action-specific, chemical-specific, and site-specific ARARs for the remedial alternatives
evaluated. Key among these ARARs are the Safe Drinking Water Act chemical-specific MCLs
£20-91-118 Page 28 of Pan II September 25, 1991
-------
and the requirements under the Clean Air Act which relate to the emission standards. No
waivers are being invoked.
10.3 Cost Effectiveness
The selected alternative is cost-effective in mitigating the principal risk posed by the presence
of contaminants in soil that could migrate to ground water in the future. The estimated cost of
the selected alternative is $614,414, which is less than all of the remedial alternatives except
Alternative 1 (No Action) and Alternatives 2a and 3a. However, the costs of Alternatives 2a
and 3a may increase due to stringent requirements for monitoring dioxin emissions.
Alternative 1 is not acceptable since it does not protect human health and the environment.
Alternatives 2a and 3a may be difficult to implement since the treatment specified in these
alternatives is an innovative technology. Therefore, the estimated cost of the selected
alternative is reasonable considering the long-term protection of human health.
10.4 Utilization of Permanent Solutions and Alternative Treatment Technologies
The selected remedy represents the maximum extent to which permanent solutions and
treatment technologies can be utilized in a cost effective manner. Of those alternatives that are
protective of human health and the environment and comply with ARARs, the selected remedy
provides the best balance of trade-offs in terms of long-term effectiveness and permanence;
reduction in toxicity, mobility or volume achieved through treatment; short-term effectiveness;
implementability; and cost, and also considering the statutory preference for treatment as a
principal element and considering State and community acceptance.
10.5 Preference for Treatment as a Principal Element
The selected remedy satisfies the statutory preference for treatment as a principal element,
since it will remove contaminants from soil at the Tank 2 Operable Unit. Contaminants will
be transferred from the on-site soil to treatment canisters containing activated carbon. The
activated carbon will then be transported off site for treatment and/or recycling.
11 DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the Tank 2 Operable Unit was released for public comment in August
1991. The Proposed Plan identified Alternatives 2a, 2b, and 2c as the Preferred Alternatives,
E20-91-118 Page 29 of Part II September 25, 1991
-------
and stated that selection of one of these alternatives would be based on cost, contractor
recommendation, and public input. Based on these three factors, Alternative 2b is the selected
remedy for the Tank 2 Operable Unit. This does not represent a significant change from the
Proposed Plan, since the three alternatives only differ in how air emissions will be treated.
The Proposed Plan presented information on all three alternatives for treatment of the air
emissions and requested public input and comment on the three alternatives.
E20-91-118 P*gt 30 of Pan II September 25, 1991
-------
RECORD OF DECISION
III. RESPONSIVENESS SUMMARY
SAAD - TANK 2 OPERABLE UNIT
BACKGROUND ON COMMUNITY INVOLVEMENT
At various times since 1979, formal news releases have been issued by the SAAD Public
Affairs Office concerning contamination issues. The releases have provided the local media
and general public with information on the status of investigative and remedial efforts and
continuing action to protect public health and safety.
In October 1986, the Depot sent a news release to the media on the discovery of soil
contamination after removing Tank 2. The public did not express specific concerns about
contamination at the Tank 2 Operable Unit during the four-year period following the initial
press release. To date, public concerns about the contamination at SAAD have mainly focused
on (1) the potential for exposure to contaminated ground water that currently exists under the
southwest comer of SAAD and off-site to the south and west of SAAD, and (2) the effects that
contamination and remedial actions have on wildlife and wildlife habitat at the facility. These
two concerns apply to other Operable Units defined at SAAD, but are not applicable to the
Tank 2 Operable Unit since Tank 2 does not appear to have affected ground water at SAAD
(based on the results of soil and ground water sampling) and because the Tank 2 area is
industrial with no wildlife or wildlife habitat.
Contamination at the Tank 2 site is not expected to affect businesses in vicinity of the site,
residential property values, or traffic patterns during site cleanup since this Operable Unit is
located more than 1,000 feet from the nearest facility boundary and the selected remedy will
not significantly change the number of vehicles going to or from the Depot each day. The
public has expressed no concerns with these issues. If not remediated, contaminants at the
Tank 2 Operable Unit could pose a long-term health risk to future on-site residents. No short-
term or long-term human health or environmental risks should occur during or after
remediation of this site by the selected alternative, providing that on-site workers follow
standard OSHA guidelines for working with hazardous waste during remediation and dust
control measures are implemented during construction. The public has expressed no concerns
with short- or long-term health risks.
E20-91-118 Page 1 of Part III September 25, 1991
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OVERVIEW
Notice was placed in local community daily newspapers announcing the availability of the
Operable Unit Feasibility Study (OUFS) and Proposed Plan (PP) in the local information
repositories at the California State University Library and the SAAD Visitor Center. Public
review and comment was invited for a period of 30 days, from August 20 to September 19,
1991. No written comments were received.
A public information and comment meeting on the PP was held on August 20, 1991 at the
Army Reserve Center. The meeting was attended by 39 people, representing the public, the
Army, EPA, DTSC and RWQCB. During the public comment period and public meeting, the
public made no comments on the Army's preferred alternative for cleaning up the soil at the
Tank 2 Operable Unit. The public asked for clarification on several points of the plan during
the public meeting. The Army's preferred alternative for soil cleanup is composed of in-situ
soil ventilation with air emissions control and entrained (suspended) water treatment by
ultraviolet-hydrogen peroxide. Three alternatives for air emissions control were described to
the public:
1). Thermal Vapor Control
2). Gas Phase Carbon Adsorption
3). Vapor Recovery
The public did not express concerns or any preference for the type of air emissions control
employed, and the Army subsequently selected Gas Phase Carbon Adsorption based on
contractor recommendations and cost.
SUMMARY OF PUBLIC COMMENTS AND ARMY RESPONSES
The following questions were asked at the public meeting.
QUESTION #1:
Given some of the compounds that you have been looking for (polynuclear aromatics,
halocarbons), are you using GC method analysis for detection or how do you come up
with those levels? Was the analytical work done at SAAD? What does GCMS mean?
E20-91-118 Page2ofPan III September 25, 1991
-------
RESPONSE:
A variety of analytical methods have been used at the site, depending on the
compounds of interest. The methods used are:
GC/MS (Gas Chromatograph/Mass Spectrometer) - used for the analysis of
polynuclear aromatics, halocarbons, pesticides (including herbicides),
aromatic volatile organic compounds, semi-volatile organic compounds.
GC (Gas Chromatograph) - used for the analysis of volatile organic
compounds.
ICAP (Inductively Coupled Plasma Emission Spectroscopy) - used for the
analysis of most metals.
AA (Atomic Adsorption) - used for the analysis of selected metals such as
arsenic and mercury.
The analyses were performed by outside multi-state certified analytical laboratories to
ensure that the results were acceptable to the EPA and the State of California.
QUESTION #2:
How close are the contaminant levels to the naturally occurring levels found in the
ground?
RESPONSE:
The organic contaminants would not be found as naturally occurring because they are
man-made chemicals. No contaminant metals, which could be found as naturally
occurring at the site, were detected at the Tank 2 site.
QUESTION #3:
Are contaminants going down Morrison Creek?
E20-91-118 Page 3 of Pan III September 25, 1991
-------
RESPONSE:
Sampling in Morrison Creek indicates that contamination is not going off base to
Morrison Creek.
QUESTION #4:
What is the timeframe for remediation?
RESPONSE:
The Army hopes to award a remedial construction contract and sign a Record of
Decision this calendar year. The Remedial Action would then take place in 1992 and
would be completed in approximately six months.
QUESTION #5:
How is Superfund money involved in the cleanup of the site?
RESPONSE:
The Department of Defense is not eligible to use public Superfund money on cleanup
of its sites. The Department of Defense has a fund called the Defense Environment
Restoration Account, which is essentially the military equivalent of Superfund. PtfWie-
Superfund money is used to pay for EPA oversight costs.
QUESTION #6:
What effect will rain have on the distribution of contaminants? If the drought ends,
will rain carry contaminants to ground water?
RESPONSE:
The Tank 2 site is paved over with asphalt and concrete, which greatly reduces the
amount of rain water that can infiltrate through the soil in this area. Therefore, rainfall
E20-9I-H8 Page 4 of Pan III September 25, 1991
-------
will not have a large effect on the movement of contaminants at this site. There are
also 84 ground water monitoring wells on base and off base that are sampled quarterly
to detect contaminants that do reach ground water. Monitoring wells located
upgradient and downgradient of Tank 2 (ground water generally flows from upgradient
to downgradient) are used to assess whether contaminants from Tank 2 have impacted
ground water. The contaminants found in ground water downgradient of Tank 2 are
not the same as those found in the soil around Tank 2 . Soil samples were collected to
evaluate how far contaminants from Tank 2 have already traveled toward ground water.
At this time, it appears that contaminants have moved to a depth of 30 feet in one
location, but most of the contaminants have only moved to an approximate depth of 18
feet. Based on this information, ground water (which is 80 feet below ground surface)
does not appear to have been affected by the contaminants from Tank 2.
REMAINING CONCERNS
All public questions expressed during the public meeting were addressed by the Army. No
other concerns or questions were received during the public comment period.
E20-91-118 Page S of Pan III September 25, 1991
-------
RESPONSIVENESS SUMMARY
Attachment A
The Community Relations activities conducted at the Tank 2 Operable Unit on the SAAD
facility to date have included the following:
»• The Army issued a press release to local media describing the discovery of
contamination at the Tank 2 Operable Unit in October 1986.
>• The Army issued a Proposed Plan (PP) describing the preferred alternative for
soil cleanup at Tank 2 and soliciting public involvement on August 16, 1991.
The PP was mailed to contiguous property owners and numerous newspapers,
radio, and television stations. In addition to the Administrative Record, the PP
is available at the offices of the EPA, Region IX, and the DTSC in Sacramento,
California.
> The Army held a public meeting on August 20, 1991 at the U.S. Army Reserve
Center, 9376 Fruitridge Road in Sacramento, California. The meeting was
recorded by a court reporter and a written text of the meeting is available in the
Administrative Record.
> The Army opened a public comment period from August 19 to September 18,
1991. No written or oral comments were received during that time, except at
the public meeting on August 20 (see preceding item).
E20-91-118 Page 6 of Pan III September 25, 1991
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APPENDIX A
ANALYSIS OF ARARS
-------
E-Tk2-UbleA-l
TABLE A-l
TANK 2
COMPARISON OF CHEMICAL CONCENTRATION TO ARARS
' '' • Page I
Chemical
Anthracene
Benozoic Acid
Benzi>(i)anthracene
Benzo(gih,i)perylene
2-Buttnone(MEK)
Chrysene
4.4' -DDE
4-4'-DDT
Dibenzo(a,h)anlhracene
Dietdrin
2,4-DimeIhylphenol
Ethylbenzene
Fluoranlhene
HepUchlor epoxide
Indeno( 1 ,2,3-c,d)-pyrene
DTSC/EPA
MCLs1
(mg/1)
0.68/0.7
1X10-V2XI04
DfSC
AALs2
(rag/1)
0.02
2
0.02
2XIO-*
Proposed
RCRA
Action
Levels3
Water/Soil
(mg/l)/(mg/kg)
2/4000
.0001/2
.0001/2
2X10-6/.04
4/8000
4XIO-6/.08
Land Ban
Treatment
Standards4:
Wastewaler/
non-Wastewater
(mg/l)
f
O.OS/.75
0.05/0.053
Baseline
Cone.
in
Soil*
from PHE
(mg/ltg)
.041
.39
1.3
1.5
15
.3
.0018
.0038
1.5
.0078
.72
200
2.9
.0086
1.7
Proposed
Treatment
Cleanup
Level
(mg/kg)
1.2
6
Baseline'
GW'
(METN
Cone.
(mg/l)
I.6XI05
3.7XWZ
5.2X10-*
5.2X10*
16
8.2X10*
2.3XIO»
8.8X10-'
2.SXIO-*
2.5X10-'
9.3XI03
0.99
4.2XI04
2.1XIO-*-*-
6X10^
Bastfline
qK
AEl)
Cohc.
(mg/l)
RCRA Corrective Action Levels (proposed) are To Be Considered Criteria. Site Cleanup levels meet these criteria for water and soil.
4 ** Land Ban treatment standards for waste codes FOOI-F005. Site cleanup levels will meet both waste water and non-wastewater treatment standards. The wastewater standards
will be met at ground water. The non-wastewater standards will be met in soil after remediation. These standards are ARARs.
+ ** This estimated concentration is very conservative since it is based on an assumed uniform distribution of the contaminant. However, the contaminant was detected in only a few samples, so the actual concentration in ground
water will be much lower than this estimate and is expected to meet ARARs and TBCs - See Section 6.3.
-------
E-Tk2-UWeA-l
TABLE A-l (Continued)
TANK 2
COMPARISON OF CHEMICAL CONCENTRATION TO ARARS
Chemical
2-melhylnaphlhalene
4-Methylphenol
Niplhilene
Phenuithrene
ephenol
Pyrene
Tetrachtoroelhene (PCE)
Xylenes
DTSC/EPA
MCLs1
(mg/l)
.005/0.005
1.75/10
DTSC
AALs1
(mg/l)
0.02
0.02
0.02
0.007
2
Proposed
RCRA
Action
Levels3
Water/Soil
(mg/l)/(mg/kg)
20/50.000
.007/10
70/200.000
Land Bin
Treatment
Standards4:
Wastewater/
Non-wastewater
(mg/l)
0.079/0.05
0.05/0.15
Baseline
Cone.
in
Soil*
from PI IE
(mg/kg)
.32
.04
2.6
2.7
.067
2.4
18.7
1174
Proposed
Treatment
Cleanup
Level
(mg/kg)
0.2
23
Baseline
ow
MEI
Cone.
(mg/l)
IX6Xlfr3
4.5X10-3
.015
!XI(rJ
.026
3.5XIO-4
0.29
28
Baseline
GW
AEI
Cone.
(mg/l)
l.5Xlfr»
1.2XIO-7
2.3XIO-7
-------
E-Tk2uble-A-2
TABLE A-2
ARARs FOR SOIL VENTILATION SYSTEM
Page I
TVPE
suBMmriNo
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Action Specific
Depirtmenl of Toxic
Substances Control
(DTSC)
22 CCR, Article 20
22 CCR, Article 24
22 CCR, Article 25
22 CCR 66392
22 CCR Article 6
Requires preparation of » contingency
plan for the facility to minimize
hazards to human health and
environment from fire, explosion, or
release of hazardous waste to soil, air,
or water.
Applicable to hazardous waste
facilities that store containers of
hazardous waste.
Sets requirements for the design of
tanks used for the treatment or storage
of hazardous waste.
Permits by rule
Sets requirements for the generators of
hazardous waste.
The site specific Health and Safety Plan prepared by the
Contractor shall provide sufficient information mil
mitigation procedures for the protection of human health
during the SVS operation. SAAD's overall site Contingency
Plan will provide emergency procedures and other pertinent
information, as required by this regulation.
Waste generated during remedial activities will be considered
potentially hazardous. Examples for this alternative are spent
activated carbon or entrained water wastes which may require
management as per the requirements of this ARAR regarding
use and management of storage containers.
The quantity of hazardous wastes generated during remedial
activity is small and waste if any, will he stored in 55-gallon
drums. Therefore, this ARAR should not be applicable.
This alternative doe* not treat • hazardous waste (since the
soil is remediated in-iilu). A permil-by-nile process is not
utilized. Thus, this ARAR should not be applicable.
With regards to off-site disposal of entrained water, if any,
the Contractor may hive to comply with the requirements as
set forth by this ARAR regarding use of an EPA
identification number, hazardous waste manifest, and
recordlceeping.
-------
E-Tk2lable-A-2
TABLE A-2 (Cent.)
ARARs FOR SOIL VENTILATION SYSTEM
Pige2
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Chemical Specific
DTSC
DTSC/EPA
Site Specific
DTSC
40 CFR 264, Subpart G
22 CCR, Article 23
22 CCR, Article Section
66268.40 and
66268.41/40 CFR 268
40 CFR 261
22 CCR Article 11
22 CCR 66391
22 CCR 67103
22 CCR 67220
Sets requirements for closure and
post-closure of hazardous waste
management facilities.
» For disposal of waste to land, sets
treatment standards for RCRA and
Non-RCRA waste categories.
» Identification and listing of hazaidous
waste. Numerous compounds
detected at the Tank 2 site are listed as
potential hazardous wastes. These
regulations include specific testing
criteria for determining hazardous
waste characteristics.
» Hazardous waste facility permit -
contents of Part B of (he application.
» Site Security
Notice in Deed to Property required
for permitted disposal facilities.
The regulations set forth in this ARAR are applicable to
hazardous waste management facilities such as landfills and
surface impoundments. Operation of waste management
facility not anticipated. Thus, this ARAR should not be
applicable.
Waste are not being land disposed. Thus, this ARAR should
not be applicable.
Wastes generated during remedial activity will be considered
potentially hazardous. Examples for this alternative are spent
activated carbon or entrained water. Wastes will be managed
as hazardous waste unless shown not to be hazardous by
testing according to this ARAR.
» Under this alternative, • hazardous waste facility is not being
permitted. Thus this ARAR should not be applicable.
» The Contractor shall prevent the unknowing entry, and
minimize the possibility of unauthorized entry of, persons or
livestock in the area of the SVS operation.
» Since this alternative does not create a disposal facility, this
ARAR is aol applicable.
-------
E-Tk2lable-A-2
TABLE A-2 (Cent.)
ARARs FOR SOIL VENTILATION SYSTEM
Page 3
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Site/Action/Chemical
Specific
EPA
Safe Drinking Water Act
(SOWA) 42 USC300
40CFR14I
Drinking Water Standards, including
both enforceable MCLs.
Chemical Specific
DTSC
22 CCR, Article 5.5,
Section 64444.S
Sets maximum contaminant levels for
the primary drinking water
constituents.
Site/Action/
Chemical Specific
Regional Water Quality
Control Board (RWQCB)
Porter Cologne Water
Quality Control Act (CA
Water Code)
This Act coordinates regulatory
control over all activities that may
affect water quality.
» The following chemical specific regulatory requirements hive
been identified at the Tank 2 site:
Constituent
Ethylbenzene
Heplachlor epoxide
Tetrachloroethene
Xylenes
Max. Contaminant Level
0.7
0.0002
0.005
10
» The following chemical specific regulatory requirements have
been identified at the Tank 2 site:
Constituent
Efhylbenzene
Heplachlor epoxide
Tetrachloroethene
Xylenes
Max. Contaminant Level
mell
0.680
0.00001
0.005
1.750
» Refer to section 7.2.2.3 for details on compliance.
» This ARAR generally requires the protection of beneficial
uses of waters of the State. Specific requirements are
addressed in other ARAR's presented in this Table.
-------
E-Tk2(able-A-2
TABLE A-2 (Cent.)
ARARs FOR SOIL VENTILATION SYSTEM
Page 4
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTSflMPACTS
Site/Action/Chemical
Specific
Regional Wiler Quality
Control Board (RWQCB)
Site/Aclion/Chemical
Specific
RWQCB
CVRWQCB-R5. Water
Quality Control Plan
(Basin Plan)
Slate Board Resolution
No. 68-16
Proposition 65
Title 23, Chapter 15,
Discharges of Waste to
Land.
This plan is the vehicle by which the
CVRWQCB administers the CA
Water Code. This Act establishes the
responsibility of the RWQCB to
supervise cleanup efforts at spill sites
including approval of cleanup plans
and verification of final cleanup.
Non-degradation policy.
Safe Drinking Water and Toxic
Enforcement Act. This Act prohibits
(he discharge of known carcinogens
and reproductive toxins into a cource
of drinking water. The Act also
requires a clear warning of potential
significant exposures.
Chapter IS outlines requirements for
the design, construction, operation,
and closure of waste containment
facilities.
Contractor shall supply workplan and procedures to the
RWQCB for review and approval.
The contractor shall treat the soil to the required cleanup
levels stated in Section 3.6 such that residual constituents
will not degrade beneficial uses for ground water.
The contractor will comply health risks due to operation of
SVS by controlling air emissions, providing adequate site
security and appropriate aignage, and through
implementation of a site-specific worker Health and Safely
Plan.
A HRA will be conducted to estimate acceptable emission
levels. The HRA will be based on i one million cancer risk
an opposed to one in • hundred thousand cancer risk required
by Proposition 63.
The regulations in (his Chapter establish waste and site
classification and waste management requirements for waste
treatment storage, or disposal in landfills, surface
impoundments, waste piles, and land treatment facilities.
Since the SVS operation does not entail any of the above, this
ARAR should not be applicable.
-------
E-Tk2table-A-2
TABLE A-2 (Cont.)
ARARs FOR SOIL VENTILATION SYSTEM
PageS
TYPE
Site/ Action/Chemical
Specific
Site/ Action/Chemical
Specific
SUBMITTING
AGENCY ARAR DESCRIPTION
Environmental Protection NPDES »• Discharge of liquid streams to surface
Agency 40 CFR 122 waters.
(EPA)
Environmental Protection 40 CFR 264, Subpart F » Release from solid waste management
Agency units.
(EPA)
COMMENTSflMPACTS
* This alternative does not entail discharge of liquid streams to
surface waters, therefore this ARAR should not apply.
» This ARAR is applicable to owners or operators of facilities
that treat, store, or dispose of hazardous waste. It applies to
surface impoundments, waste piles, land treatment units, or
landfills. As the SVS operation does not entail any of the
above, this ARAR should not be applicable.
EPA
EPA and ARB
Land Ban
40 CFR 248
Clean Air Act
40 CFR 61
40 CFR Part SO el Seq.
!7CCR60204etSeq..
Land disposal restrictions for RCRA
and non-RCRA waste categories.
National Emissions Standards for
Hazardous Air PolluUnts.
Clean Air Act and Slate Air Pollution
Control Laws.
This ARAR Idenliftea hazardous wastes that are restricted
from land disposal. Since SVS does not entail land disposal,
this ARAR does not apply.
Air emissions from the remediation of the Tank 2 site would
primarily comprise of PCE, 2-butanone, eihylbenzene, and
xylenes which pursuant to Section 112 of (he Act ire not
designated as hazardous air pollutants. Therefore the ARAR
does not apply.
California lir pollution control taws are generally stricter and
therefore, cupercede the Federal Clean Air Act. Applicable
state/local air district air pollution control laws are discussed
below. Emission Sources are divided into Mobile and
Stationary Source*. Stationary Sources may be regulated as
new sources. Existing Sources, or granted a variance. New
Source emission standards are enforced by a permit system.
Administration and permits rests with the local air district.
-------
E-Tk2lable-A-2
TABLE A-2 (Cont.)
ARARs FOR SOIL VENTILATION SYSTEM
Page 6
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Action/Site Specific
Chemical Specific
Sacramento Metropolitan
Air Quality Management
District (SMAQMD)
SMAQMD
Rule 202, Section 301
New Source Review.
CA Health and Safety
Code. Section 41700
General guideline, if SVS operation
causes release of organic compounds
to the atmosphere, then a case-by-case
determination of public nuisance
potential should be performed to
verify compliance. Section 41700
states that discharges to air causing
injury, detriment, nuisance
annoyance; or endangers the comfort,
repose, health, or safety, or causes
injury or damage to business or
property is prohibited.
Reactive organic compounds will be emitted in excess of the
limit of 0 Ihs/day. This triggers the requirements for use of
BACT. Best Available Control Technology (BACT)- BACT
is defined as the maximum control device or technique which
it technologically feasible and cost effective. BACT is
generally thermal destruction for reactive organics.
To comply with this ARAR, carcinogens emitted by SVS
operation will require treatment prior to emission to the
atmosphere. Emissions from treatment processes will be
evaluated by the Contractor wjlh regards to public effects and
monitored and abated. A 10 criteria will be utilized.
Based on results of SVS pilot testing, a HRA wu conducted
to estimate the effect of carcinogens emitted on local
population. The results of HRA suggest health an excess
cancer risk of S.I x 10'* for tetrachloroelhane.
-------
E-Tk2lahle-A-2
TABLE A-2 (Cont.)
ARARs FOR SOIL VENTILATION SYSTEM
Page 7
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Chemical Specific
EPA
F.R. 5S(l45):30865July
27, 1990
Cleanup levels under RCRA
corrective actions.
The proposed RCRA Simple Action Levels for the following
chemical specific compounds identified at the Tank 2 site are
TBCs and are as follows:
Semi-Volatile Organic Compounds
Name Hazard Soil Water
Class Cone. Cone.
(mg/kg) (mg/kg)
Phenol
Name
5.0 E4
2.0 El
Peglicides/Dioxing
Hazard Soil Water Air
Class Cone. Cone. Cone.
(mg/kg) (mg/kg) pg/m*
DDE B2
DDT B2
Dieldrin B2
Heptichlor B2
epoxide
2 I.OE-4
2 I.OE-4 I.OE-2
4.0E-2 2.0E-« 2.0E-4
8.0E-2 4.0E-6 4.0E-4
-------
E-Tk2table-A-3
TABLE A-3
ARARs FOR EXCAVATION AND ON-SITE SOIL WASHING
P«gel
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Action Specific
Department of Toxic
Substances Control
(DTSC)
22 CCR. Article 20
22 CCR, Article 24
22 CCR. Article 25
22 CCR 66392
Requires preparation of • contingency
plan for the facility to minimize
hazards to human health and
environment from Tire, explosion, or
release of hazardous waste to soil, lir,
or water.
Applicable to hazardous waste
facilities that store containers of
hazardous waste.
Sets requirements for the design of
tanks used for the treatment or storage
of hazardous waste.
Permits by rule
The site specific Health and Safety Plan prepared by the
contractor should provide sufficient information and
mitigation procedures for the protection of human health
during the soil washing operation. SAAD's overall lite
Contingency Plan will provide emergency procedures and
other pertinent information, as required by this regulation.
Wastes generated during remedial activity will be considered
potentially hazardous. Examples for this alternative an soil
washing solution and (pent carbon which may require
managements as per the requirements of this ARAR
regarding use and management of storage containers.
Tanks used for storage of the aoil washing solution or its
components shall comply with the specific design and
containment requirements outlined in this ARAR. In
addition, the tank materials shall be compatible with the
solutions stored in them. Tank design and containment
information as well as monitoring and inspection plans will
be submitted by the Contractor for agency review and
approval.
The contractor shall review SAAD'a Part B Permit to ensure
that requirements of this ARAR for this process are met
under this permit. Where requirements are not met under the
Part B Permit, the operator shall submit for approval his plan
to meet these requirements.
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E-Tk2lable-A-3
TABLE A-3 (Cent.)
ARARs FOR EXCAVATION AND ON-SITE SOIL WASHING
Page 2
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Action Specific
Chemical Specific
Department of Toxic
Substances Control
(DTSC)
DTSC
22 CCR. Article 6
40 CFR 264. Subpart G
22 CCR, Article 23
Sets requirements for the generators of
hazardous waste.
Sets requirements for closure and
post-closure of hazardous waste
management facilities.
With regard to off-site disposal of soil washing liquid, (he
contractor shall comply with the requirements as set forth by
(his ARAR regarding the use of EPA identification number,
hazardous waste manifest, and recordkeeping.
The regulations set forth in this ARAR are applicable to
hazardous waste management facilities auch as landfills and
surface impoundments. Operations of waste management
facility is not anticipated. Thus, this ARAR should not be
applicable.
-------
E-Tk2table-A-3
TABLE A-3 (Cent.)
ARARs FOR EXCAVATION AND ON-SITE SOIL WASHING
Page 3
TYPE
SUBMITTING
AOENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Chemical Specific
DTSC/EPA
22 CCR, Article Section
66268.40 and
66268.41 MO CFR 268
For disposal of waste to land, sets
treatment standard.*! for RCRA and
Non-RCRA waste categories.
The history of Tank 2 indicates that the lank was used for
storage of waste solvents. The soil debris generated by
excavation would therefore be a FOOI-F005 waste.
Treatment Standards for reported soil constituent are:
FOOI - F005 Spent Solvents TCLP fmt/ll
Ethylbenzene 0.053
Telrachloroethene 0.05
Xylenea 0.15
2-Bulanone 0.75
Treatment standards for wutewater are:
FOOI - F005 Scent Solvents
2-Butanone
Ethylbenzene
Tetrachloroethene
Xylenes
Concentration (mg/l)
Wastewiten containing
snenl solvents
0.05
0.05
0.079
0.05
See Section 7.2.8.3 for details on compliance.
-------
E-Tk2e*ble-A-3
TABLE A-3 (Cont.)
ARARs FOR EXCAVATION AND ON-SITE SOIL WASHING
Pige4
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Chemical Specific
DTSC
40CFR26I
22 CCR. Article 11
Site Specific
DTSC
Site/Aclion^Chemicil
Specific
EPA
22 CCR 66391
22 CCR 67103
22 CCR 67220
Safe Drinking Water Act
(SDWA) 42 USC300
40CFRI4I
Identification and listing of hazardous
waste. Numerous compounds
delected at the Tank 2 site are listed as
hazardous wastes. These regulations
include specific testing criteria for
determining hazardous waste
characteristics.
Hazardous waste facility permit -
contents of Part B of the application.
Site Security
Notice in Deed to Properly required
for permitted disposal facilities.
Drinking Water Standards, including
both enforceable MCLs and MCLGs.
Wastes generated during remedial activity will be considered
potentially hazardous. Examples for this alternative are spent
activated carbon or wash liquid. Wastes will be managed as
hazardous waste unless shown not to be hazardous by testing
according to this ARAR.
»• Under this alternative, a hazardous waste facility is not being
permitted. This ARAR should not be applicable.
* The contractor ihall prevent the unknowing entry, and
minimize the possibility of unauthorized entry of, persons or
livestock in the area of the soil washing operation.
» Since this alternative doea not create a disposal facility, this
ARAR is not applicable.
» The following chemical specific regulatory requirements have
been identified at (he Tank 2 site:
Constituent
Ethylbenzene
Heptachlor epoxide
Tetrachloroelhene
Xylenes
Max. Contaminant Level
mg/l
0.7
0.0002
0.005
10
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B-Tk2lable-A-3
TABLE A-3 (Cent.)
ARARs FOR EXCAVATION AND ON-SITE SOIL WASHING
PageS
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Chemicil Specific
DTSC
Sile/AclionfChemicil
Specific
Regional Water Quality
Control Board (RWQCB)
22 CCR. Article 5.5,
Section 64444.5
Porter Cologne Water
Quality Control Act (CA
Water Code)
CVRWQCB-R5, Water
Quality Control Plan
(Basin Plan)
State Bond Resolution
No. 68-16
Sets maximum contaminant levels for
the primary drinking water
constituents.
This Act coordinates regulatory
control over all activities that may
affect water quality.
This plan is the vehicle by which the
CVRWQCB administers the CA
Water Code. This Act establishes the
responsibility of the RWQCB to
supervise cleanup efforts at spill tiles
including approval of cleanup plans
and verification of cleanup.
Non-degradation policy.
The following chemical specific regulatory requirements have
been identified at the Tank 2 site:
Constituent
Elhylbenxene
HepUchtor epoxide
Tetrmchloroelhene
Xylenes
Max. Contaminant Level
mg/l
0.680
0.00001
0.005
1.750
Refer to Section 7.2.8.3 for details on compliance.
This ARAR generally requires the protection of beneficial
uses of water* of the State. Specific requirements are
addressed in other ARAR's presented in this Table.
The contractor shall supply information required by this
ARAR in hit work plan and procedures. This information
shall be forwarded to the RWQCB for review and approval.
The contractor shall treat the soil to the required cleanup
levels dated in Section 3.6 such that residual constituents
will not degrade beneficial uses for ground water.
-------
E-Tk2uible-A-3
TABLE A-3 (Cont.)
ARARs FOR EXCAVATrON AND ON-SITE SOIL WASHING
Page 6
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Site/Action/Chemical
Specific
RWQCB
Proposition 65
Sile/Action/Chemical
Specific
EPA
Title 23, Chapter 15.
Discharges of Waste to
Und.
NPDES
40 CFR 122
40 CFR 2(54, Subp«rt F
Safe Drinking Water and Toxic
Enforcement Act. This Act prohibits
the discharge of known carcinogens
and reproductive toxins into a source
of drinking water. The Act also
requires a clear warning of potential
significant exposures.
Chapter 15 outlines requirements for
the design, construction, operation,
and closure of waste containment
facilities.
» Discharge of liquid streams to surface
waters.
» Release from solid waste management
units.
The contractor will comply by controlling air emissions,
providing adequate site security and appropriate signage, and
through implementation of a site-specific worker health and
ufety plan.
A HRA will be conducted to estimate acceptable emission
levels. The HRA will be based on a one in a million cancer
risk as opposed to a one in a hundred thousand cancer risk
required by Proposition 65.
The regulations in this Chapter establish waste and site
classification and waste management requirements for waste
treatment storage, or disposal in landfills, surface
impoundments, waste piles, and land treatment facilities.
Since the soil washing operation does not entail any of the
above, this ARAR should not be applicable.
This alternative does not entail discharge of liquid streams to
surface waters, therefore this ARAR should not apply.
This ARAR is applicable lo owners or operators of facilities
that treat, store, or dispose of hazardous waste. It applies to
surface impoundments, waste piles, land treatment unite, or
landfills. As the soil washing operation does not entail any
of the above, this ARAR should not be applicable.
-------
E-Tk2Uihle-A-3
TABLE A-3 (Cont.)
ARARs FOR EXCAVATION AND ON-SITE SOIL WASHING
Page?
TYPE
; Site/Aclion/Chemic«l
; Specific
SUBMITTING
AGENCY
Environmental Protection
Agency
(EPA)
ARAR
Land Ban
40 CFR 268
DESCRIPTION
» Land disposal restrictions for RCRA
and non-RCRA waste categories.
COMMENTS/IMPACTS
» Upon the effective date of May 8, 1992. soil generated by
excavation could be considered a non-waste water from a
multi-source leachate. A comparison of the reported
constituent values for treatment standards for F039 waste is
as follows:
Range of Detected Landban total
Chemical Concentrations Composition
(mg/kg) (mg/kg)
Anthracene
Bentoic Acid
Benm(a)anthracene
Benzo(g,h,i)perylene
2-BuUnone
Chrysene
4,4'-DDE
4.4--DDT
Dibenzo(a.h)anthracene
1 ,2-dichtoropropane
Dieldrin
2.4-Dimethylphenol
Ethylbenzene
Fluoranthene
Heplachlor epoxide
lndeno(l ,23,
-------
E-Tk2lanle-A-3
TABLE A-3 (Cont.)
ARARs FOR EXCAVATION AND ON-SITE SOIL WASHING
Page8
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTSflMPACTS
Chemical Specific
EPA
Clean Air Act
40CFR6I
40CFRPart SOelseq. 17
CCR 60204 et seq.
Action/Site Specific
Sacramento Metropolitan
Air Quality Management
District (SMAQMD)
Rule 202. Section 301
National Emissions Standards for
Hazardous Air Pollutants.
Clean Air Act and State Air Pollution
Control Laws.
New Source Review. The purpose of
this rule is to provide for the review
of new stationary air pollution sources
and to provide mechanisms by which
authorities to construct such sources
may he granted without interfering
with the attainment or maintenance of
ambient air quality standards.
> Air emissions from the remediation of the Tank 2 site would
primarily comprise of PCE, 2-bulanone. ethylbenzene, and
xylenes which pursuant to Section 112 of the Act are not
designated as hazardous air pollutants. Therefore, this
ARAR does not apply.
» California air pollution control laws ire generally stricter and
therefore, supercede the Federal Clean Air Act. Applicable
state/local air districts air pollution control laws are discussed
below. Emission Sources are divided into mobile and
stationary sources. Stationary sources may be regulated as
new sources, enisling sources, or may be granted • variance.
New source emission standards are enforced by • permit
system. Administration of permits rests with the local air
district.
» Reactive organic compounds will be emitted in excess of the
limit of 0 Ibs/day. This triggers requirement for use of
BACT. BACT is defined as the maximum control device or
technique which is technologically feasible and cost effective.
BACT could be either carbon adsorption or incineration for
the soil washing process.
-------
E-Tk2Uble-A-3
TABLE A-3 (Cent.)
ARARs FOR EXCAVATION AND ON-SITE SOIL WASHING
P«ge9
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Action/Site Specific
Sacramento Metropolitan
Air Quality Management
District (SMAQMD)
Rule 401
Ringelmann Chart
Site/Action/Chemical
Specific
SMAQMD
Rule 403
Fugitive Dust
Rule 404
Paniculate Miller
Atmospheric discharges from the aite from any source (other
thin uncombined water vapor) for a period of more than
three minutes in any one hour (hall not be as dark or darker
in shade u designation No. I on the Ringelmann Chart
published by the U.S. Bureau of Mines. Nor shall the
emissions be of such opacity u to obscure a human
observer's view, or register on * certified in-slack opacity
monitoring system at • level equal to or greater than
Ringelmann designation No. I.
Every reasonable precaution shall be taken not to cause or
allow the emissions of fugitive dust from being airborne
beyond the property line from which the emission originate.
Reasonable precautions (hall include, but are not limited to
applying asphalt, oil, water or suitable chemicals for the
control of dust on surfaces which can give rise to airborne
nutter. Other measures may be taken as approved by the Air
Pollution Control Officer.
No discharges shall be made to the atmosphere from any
sources particulate matter in excess of 0.23 grams per dry
standard cubic meter (0.1 grains per dry cubic foot).
-------
E-Tk2Uble-A-3
TABLE A-3 (Cent.)
ARARs FOR EXCAVATION AND ON-SITE SOIL WASHING
P.ge 10
TYPE
SUBMITTINO
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Site/Aclion/Chemical
Specific
SMAQMD
Rule 405
Dust and Condensed fumes.
No discharges into the atmosphere shall be made from any
source whatsoever of dust or condensed fumes in total
quantities exceeding the following:
ntoccn wraoHt «n> ALLOWAUJR DOCHAHOT
•Will F4U I
Mtl|kl Mlltf
t Kill HrllMUU
4IICMrf«l Irw ill
•«/«r
u« no .« i.t»
i>4 xn .11 t.it
in HO .H I.II
III WO .11 1.14
m i« .« t.u
III 40t .14 I.II
IM tn .n i.»
114 104 .44 I.M
M4 400 .M 4.4>
«t m i.4i -i.n
414 1000 1.04 • I.M
HI IIM I.II t.44
4M UOO 1.11 1.41
II? UM I.U !.»
414 1404. 1.44 1.41
N4 M04 1.44 1.44
IIM IWO 1.41. 4.11
IM4 1000 I.II 4.11
III! 1109 I.N' l.ll
1114 WOO 1.14 4.44
1041 4100 I.n 4.41
III! 4000 Ml 1.41
HOO 4100 l.ll . 4.41
Mil 4000 1.14 Ml
mi IIM Mr 1.44
till 1001 I.M 1.04
>W4 1104 ».«• 4.M
1114 1094 I.H l.ll
1444 4104 4.11 1.04
4NI 1001 I.H I.M
. 4111 tie* 4.41 I.IF
IKI 10004 4.11 14.4
4411 U004 4.11 ll.l
IH4 IU04 4.11 ll.l
till 14004 I.Of M.l
iin 14000 4.n 11.4
mi noo4 4.M ll.l.
IMM MOOO 4.11 U.I-
IIIII 40004 l.ll. U.l-
l»» 40000 4.14 M.1*
inn com l.ll
nut
WMI MOOt
icxllk praon.. b tt, ««*«, 7JB), ir 1. |Mr» I fraiM —lid pit hw e(
miK|. TH UN. 4lim> IM 'A' i»» ««4 At»w*> •«•*>* J.I1 K| h •*> h» *
i 4 n* te
-------
E-Tk2lahle-A-3
TABLE A-3 (Conl.)
ARARs FOR EXCAVATION AND ON-SITE SOIL WASHING
Pigell
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Action/Site Specific
SMAQMD
SMAQMD Rule 402 CA
Health and Safety Code,
Section 41700
General guideline, if (he mil wishing
operation causes release of
contaminants to the atmosphere, then
a case-by-case determination of public
nuisance potential should be
performed to verify compliance.
These ARARs state that discharges (o
air causing injury, detriment, nuisance
annoyance; or endanger the comfort,
repose, health, safety, or causes or
damage lo business or property is
prohibited.
To comply with Ihii ARAR, The contractor shall minimize
(he potential for emissions using BACT. A health risk
assessment has been conducted to evaluate the effect of
fugitive emission* on the receptors in the vicinity of the soil
washing unit. The results are included in the 'short term
effectiveness" criteria for this alternative.
-------
E-Tk2lable-A-3
TABLE A-3 (Cont.)
ARARs FOR EXCAVATION AND ON-SITE SOIL WASHING
Page 12
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Chemical Specific
EPA
F.R. 55(l45):30865July
27, 1990
Cleanup levels under RCRA
corrective actions.
The proposed RCRA Simple Action Levels for the following
chemical specific compounds identified it the Tank 2 site are
TBCs and ire as follows:
Semi-Volatile Organic Compounds
Name
Phenol
Hazard
CUa
D
Soil
Cone.
(mg/kg)
5.0 E4
Water
Cone.
(mg/kg)
2.0 El
Pesticldes/Dioxins
Name
DDE
DDT
Dieldrin
Heptachlor
epoxide
Hazard
Class
B2
B2
B2
B2
Soil
Cone.
(mg/kg)
2
2
4.0E-2
8.0E-2
Water
Cone,
(mg/kg)
l.OE-4
l.OE-4
2.0E-6
4.0E-6
Air
Cone.
pg/m'
I.OE-2
2.0E-4
4.0E-4
-------
E-Tk2l»ble-A-4
P«gel
TABLE A-4
ARARs FOR EXCAVATION AND ON-SITE INCINERATION
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Action Specific
California
Dept. of Health
Services (DHS)
22 CCR. Article 20
22 CCR. Article 24
22 CCR, Article 25
22 CCR 6(5392
Requires preparation of « contingency
plan for the facility to minimize
hazards to human health and
environment from fire, explosion, or
release of hazardous waste to soil, air,
or water.
Applicable to hazardous waste
facilities that store containers of
hazardous waste.
Sets requirements for the design of
tanks used for the treatment or storage
of hazardous waste.
Permits by rule
Action Specific
DHS
22 CCR. Article 30
Sets requirement* for operators of
incinerators at permitted and interim
status facilities.
The lite specific Health and Safely Plan prepared by the
contractor should provide sufficient information and
mitigation procedures for the protection of human health
during incineration operation. SAAD's overall site
Contingency Plan will provide emergency procedures and
other pertinent information, as required by this regulation.
The incineration operation does not entail on-«ite storage of
hazardous waste. Therefore, this ARAR should not be
applicable.
The incineration operation does not entail application or use
of tanks for soil decontamination.
The contractor (hall review SAAD'a current Part B Permit to
ensure that the requirements of this ARAR are met for this
process under this permit. Where the requirements of this
ARAR are not met for thii process under the current permit,
the operator shall submit for approval his plan to meet these
requirements.
The contractor will comply with the requirements set forth
by this ARAR with regards to waste analysis, operating
conditions, monitoring and inspection, and may be required
to demonstrate the effectiveness of the incineration process
through • trial bum. These requirements include destruction
and removal, efficiency of 99.99% for each constituent and
HCt emissions of no more than 4 Ibs/hr.
-------
E-Tk2lable-A-4
TABLE A-4 (Cont.)
ARARs FOR EXCAVATION AND ON-SITE INCINERATION
Page 2
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Chemical Specific
DTSC
DTSC/EPA
40CFR264. SubpartO
22 CCR, Article 23
40CFR26I
22 CCR, Article 11
22 CCR, Article Section
66268.40 and
66268.41 MO CFR 268
Sets requirements for closure and
post-closure of hazardous waste
management facilities.
Identification and listing of hazardous
waste.
For disposal of waste to land, Mis
treatment standards for RCRA and
Non-RCRA waste categories.
The regulations set forth in this ARAR are applicable to
hazardous waste management facilities such as landfills and
surface impoundments. Operation of a waste management
facility is not anticipated, Thus, this ARAR should not be
applicable.
The non-treated toil will be treated as a potential hazardous
waste and classified according to this ARAR. The treated
soil at the Tank 2 site is not considered a hazardous waste.
In addition, there ire no hazardous by-products of this
process.
The history of Tank 2 indicates that the lank was used for lh«
storage of waste solvents. The soil debris generated by
excavation would therefore be a FOOI-FOOS waste.
Treatment standards for reported soil constituents:
Site Specific
DTSC
22 CCR 66391
22 CCR 67103
Hazardous water facility permit
contents of Part B of the application.
Site Security
FOOI - FOOS Scent Solvents
Ethylbenzene
Telrachloroetheoe
Xylenes
2-BuUnone
TCLP(mgfl)
0.053
0.05
O.IS
0.75
See Section 7,2.9.3 for details on compliance.
Under this alternative, • hazardous wute facility it not being
permitted. This ARAR should not be applicable.
The contractor shall prevent the unknowing entry, and
minimize the possibility of, unauthorized entry of persons or
livestock in the area of incineration operation.
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E-Tk2lable-A-4
TABLE A-4 (Conl.)
ARARs FOR EXCAVATION AND ON-SITE INCINERATION
P«ge3
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Site Specific
Sile/Aclion/Chemical
Specific
DTSC
EPA
22 CCR 67220
Safe Drinking Witer Act
(SOWA) 42 USC300
40CFRI4I
Notice in Deed to Property required
for permitted disposal facilities.
Drinking Water Standards, including
both enforceable MCLs and MCLG.i.
Chemical Specific
DTSC
22 CCR, Article 5.5,
Section 64444.5
Sets maximum contaminant levels for
the primary drinking water
constituents.
Site/Action/Chemical
Specific
RWQCB
Porter Cologne Water
Quality Control Act (CA
Water Code)
This Act coordinates regulatory
control over all activities that may
affect water Quality.
» Since this alternative does not create a disposal facilities, this
ARAR is not applicable.
» The following chemical specific regulatory requirements have
been identified at the Tank 2 site:
Constituent
Elhylbenrene
HepUchlor epoxide
Tetrachloroefhene
Xylenes
Max. Contaminant Level
mg/l
0.7
0.0002
0.005
10
fr The following chemical specific regulatory requirements have
been identified at the Tank 2 site:
Constituent
Ethylbenzene
Heptachlor epoxide
Tetrachloroethene
Xylenes
Max. Contaminant Level
me/1
0.680
0.00001
0.005
1.750
Refer to Section 7.2.9.3 for details on compliance.
Thii ARAR generally requires the protection of beneficial
use* of water* of the Stale. Specific requirements are
addressed in other ARARs presented in this table.
-------
E-Tk2lable-A-4
TABLE A-4 (Cont.)
ARARs FOR EXCAVATION AND ON-SITE INCINERATION
Page 4
SUBMITTING
TYPE AGENCY
Site/Aclion/Chemical RWQCB
Specific
ARAR
CVRWQCB-R5, Water
Quality Control Plan
(Basin Plan)
DESCRIPTION
» This plan is the vehicle by which the
CVRWQCB administers the CA
Water Code. This Act establishes the
COMMENTS/IMPACTS
» The contractor shall coordinate site remedial activities with
the RWQCB and comply with other requirements as set forth
by this ARAR.
Sile/Action/Chemical
Specific
RWQCB
Sute Board Resolution
No. 68-16
Proposition 65
Site/ Action/Chemical
Specific
EPA
Title 23, Subchapter 15
Discharges of Waste to
Land.
responsibility of the RWQCB to
supervise cleanup efforts at spill sites
including approval of cleanup plans
and verification of cleanup.
Non-degradation policy.
Safe Drinking Water and Toxic
Enforcement Act. This act prohibits
the discharge of known carcinogens
and reproductive toxins into a source
of drinking water. This Act also
requires a clear warning of potential
significant exposures.
Subchapter 15 outlines requirements
for the design, construction,
operations, and closure of waste
containment facilities.
The contractor shall treat the soil to required cleanup levels
slated in Section 3.6 such that residual constituents will not
degrade beneficial uses for ground water.
Because (his alternative does not entail discharge of
contaminants into a source of drinking water, this ARAR is
not applicable. However, the contractor will minimize health
risks due to operation of incinerator by controlling air
emissions, providing adequate site security and appropriate
signage, and through implementation of a site-specific health
and safety plan.
A HRA will be conducted to estimate acceptable emission
levels. The HRA will be based on • one in a million cancer
risk an opposed to one in hundred thousand cancer risk as
required by Proposition 65.
The regulations in this Subchapter establish waste and site
classification and waste management requirements for waste
treatment, itorage, or disposal in landfills, surface
impoundments, waste piles, and land treatment facilities.
Since the incineration operation does not entail any of the
above, this ARAR should not be applicable.
-------
E-Tk2Uble-A-4
TABLE A-4 (Cant.)
ARARs FOR EXCAVATION AND ON-SITE INCINERATION
P«ge 5
TYPE
Site/ Action/Chemical
Specific
Site/ Action/Chemical
Specific
SUBMITTING
AGENCY ARAR
EPA NPDES
40CFRI22
Environment Protection 40 CFR 264, Suhpart F
Agency
(EPA)
DESCRIPTION
» Discharge nf liquid streams to surface
waters
» Release from solid waste management
units.
COMMENTS/IMPACTS
»• This alternative does not entail discharge of liquid streams to
surface waters, therefore this ARAR should not apply.
» This ARAR ii applicable to owners or operators of facilities
that treat, store, or dispose of hazardous waste. It applies to
surface impoundments waste piles, land treatment units, or
landfills. As the incineration operation does not entail any of
the above, this ARAR should not be applicable.
-------
E-Tk2lable-A-4
TABLE A-4 (Cont.)
ARARs FOR EXCAVATION AND ON-SITE INCINERATION
Page 6
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Site/Action/Chemicsl
Specific
EPA
Land Ban
40 CFR 268
Land disposal restrictions for RCRA
and non-RCRA waste categories.
» This ARAR identifies wastes that are restricted from land
disposal. Upon the effective date of May 8, 1992 soil
generated by excavation could be considered a non-waste
water from a multi-source leachate. A comparison of the
reported constituent values for treatment standards for F039
waste is as follows:
Range of Detected Landban tptal
Chemical Concentrations Composition
fig/Kg)
tmg/Kg>
Anthracene
Benzoic Acid
Benzo(a)anthncene
Benzo(glh,i)perylene
2-Butanone
Chrysene
4,4'-DDE
4,4--DDT
Dibenzo(i.h)inthncene
1,2-dichloroproptne
Dieldrin
2.4-Dimethylphenol
Elhylbenzene
Fluortnthene
Heptachlor epoxide
lndeno(l,23,-cd)pyrene
2-Melhylnophthatene
4-Methyphenol
Naphthalene
Phenonlhrene
Phenol
Pyrene
Tetrachloroelhene
Xylenes
.041
.39
1.3
.12-1.5
.027- IS
.05 - .3
.0018
.0038
I.S
.002
.003 - .0078
.17 -.72
.008-2100
.36 - 2.9
.0086
1.7
.32
.040
.21 - 26
.22-2.7
.035 - .067
.34 - 2.4
.003 - 39
.001-11000
4.0
—
8.2
1.5
36
8.2
.087
.087
8.2
18
0.13
14
6
8.2
.066
8.2
«
—
3.1
3.1
6.2
8.2
5.6
28
-------
E-Tk2lable-A-4
TABLE A-4 (Cent.)
ARARs FOR EXCAVATION AND ON-SITE INCINERATION
Page?
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Chemical Specific
EPA
Clean Air Act
40 CFR 61
40 CFR Part 50 el seq. 17
CCR 60204 el seq.
Nation*! Emissions Standards for
Hazardous Air Pollutants.
Clean Air Act and Slate Air Pollution
Control Laws.
> Air emissions from the remediation of the Tank 2 site would
primarily comprise of PCE, 2-hulinone, elhylbenzene, and
xylenes which pursuant to Section 112 of the Act are not
designated as hazardous air pollutants. Therefore, (his
ARAR does not apply.
»• California air pollution control laws are generally stricter and
therefore supercede the Federal Clean Air act. Applicable
stale/local air district pollution control laws are discussed
below. Emission sources are divided into mobile and
stationary sources. Stationary sources may be regulated is
new sources, existing sources, or may be granted a variance.
New source emission standards are enforced by a permit
system. Administration of permits rests with the local air
district.
-------
E-Tlc2lih!e-A-4
TABLE A-4 (Cent.)
ARARs FOR EXCAVATION AND ON-SITE INCINERATION
P«ge8
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Action/Site Specific
Sacramento Metropolitan
Air Quality Management
District (SMAQMD)
Rule 202, Section 301
Site/Aclion/Chemical
Specific
SMAQMD
Rule 401
Rule 403
Rule 404
New Source Review. The purpose of
this rule is to provide for the review
of new stationary air pollution sources
and to provide mechanisms by which
authorities to construct such sources
may be granted without interfering
with the attainment or maintenance of
ambient air quality standards.
Ringlemann Chart
Fugitive dust
Particulate Matter
The contractor shall comply with the requirements set by this
ARAR such as the use of BACT, the attainment of air quality
standards, and the possible preparation of I permit
application to construct and to operate the incineration unit.
Atmospheric discharges from the site from any source (other
thin uncombined water vapor) for • period of more than
three minutes in any one hour shall not be as dark or darker
in shade as designation No. I on the Ringelmann Chart
published by the U.S. Bureau of Mines. Nor shall the
emissions be of such opacity as to obscure a human
observer's view, or register on i certified in-sUck opacity
monitoring system at a level equal to or greater than
Ringelmann designation No. I.
Every reasonable precaution shall be taken not be cause or
allow the emissions of fugitive dust from being airborne
beyond the property line from which the emission originates
reasonable precautions shall include, but are not limited to
applying asphalt, oil, water or suitable chemicals for the
control of dust on surfaces which can give rise to airborne
matter. Other measures may be taken as approved by the Air
Pollution Control Officer.
No discharges shall be made to the atmosphere from any
source particulate matter in excess of 0.23 grams per dry
standard cubic meter (0.1 grains per dry cubic foot).
-------
E-TV2t«ble-A-4
TABLE A-4 (Cont.)
ARARs FOR EXCAVATION AND ON-SITE INCINERATION
Page 9
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Sile/Action/Chemicil
Specific
SMAQMD
Rule 405
Oust ind condensed fumes
» No discharges into the itmosphere thill be nude from «ny
source whatsoever of dust or condensed fumes in toul
quantities exceeding the following:
nacea mam *m AUOWAIU OOCHAIIOB
'rttlll fit*
..KM NIK
4l«tiurft4 frM all
.11
.11
M
.11
.11
.»
.n
.M
111 no
in IM
in no
III 40*
m IM
III WO
in no
no no
Ml MO
401 100 Ml
III 1000 I.M
III 1101 l.ll
IM 1109 l.ll
III ItOO l.ll
III IMO I.M
Ml 1000 I.M
IIM tMO l.ll
1111 not Ml
Illl IMO I.M l.ll
Illl ION l.ll I.M
Kit IMO I.M l.ll
Illl ION Ml l.ll
tMO IMO l.ll . I.M
Illl MO* I.M Ml
Mil IHO 1.41 I.M
lilt 1009 I.M I.M
1401 UN I.N I.M
I.M
I. II
I. II
I.M
I.M
I. II
I.H
.
•Ml
I.M
I.M
l.tl
Ml
l.ll
I.N
4.11
IIM
till
4011
. Illl
4111
HII
«IM
Illl
IIU
mi
HIM
Illll
tllll
Illll
Illll
Mill
4«Mt
Illll
•000 I.M l.ll
not l.ll I.M
MOO l.ll I.M
1100 4.40 l.ll
10009 l.ll II.0
ITOO l.ll 10,4
lion i.ii 10.1
IMM I.M ll.l
IMOO I.D ll.l
IOOM l.ll ll.l
loon 1.11 ll.l
40000 I.M U.I
MOM I.M ll.l
•0000 l.ll ll.l
10000 Ml ll.l
moo Ml ll.l'
fOOOO I.M U.«
Moot I.M IM
00000 1.11 lt.4
ooooo n.ii n.i
00000 10.11 ll.l
n.ii n.i
IIIMI 1
mill <
nun i
mill Mom it.n N.I
nun noooo it.n 11.1
MMM MOOOO IMI n.4
4omi noooo ii.it n.i
IIIIH loooooo n.« n.i
-------
B-Tk2lable-A-4
TABLE A-4 (Cent.)
ARARs FOR EXCAVATION AND ON-SITE INCINERATION
Page 10
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Site/Action/Chemical
Specific
SMAQMD
SMAQMD Rule 402 CA
Health and Safely Code,
Section 41700
General guideline, if the incineration
operation causes release of
contaminants to the atmosphere, then
• case-by-case determination of public
nuisance potential should be
performed to verify compliance.
These ARARs stale (hit discharges to
air causing injury, detriment, nuisance
annoyance: or endanger (he comfort,
repose, health, safety, or causes or
damage to business or property is
prohibited.
The contractor shall minimize the potential for emissions
through the use of BACT. A heillh risk assessment has been
conducted lo evaluate the effect of emissions on the receptors
in the vicinily of the incineration unit. The remits are
included under the "short term effectiveness" criteria for (his
alternative.
-------
E-Tk2lat>le-A-4
TABLE A-4 (Conl.)
ARARs FOR EXCAVATION AND ON-SITE INCINERATION
Page 11
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Chemical Specific
EPA
F.R. 55(l45):30865July
27, 1990
Cleanup levels under RCRA
corrective actions.
>• The proposed RCRA Simple Action Levels for the following
chemical specific compounds identified «t the Tank 2 site ire
TBCs and are as follows:
Semi-Volatile Organic Compounds
Name Hazard Soil Water
Class Cone. Cone.
(mg/kg) (mg/kg)
Phenol
Name
5.0 E4
2.0 El
Peglicideg/DioEi'ns
Hazard Soil Water
Clas« Cone. Cone.
(mg/kg) (mg/kg)
DDE 82
DDT B2
Dieldrin B2
Heptachlor B2
epoxide
Air
figlm'
2 I.OE-4 —•
2 I.OE-4 I.OE-2
4.0E-2 2.0E-6 2.0E-4
8.0E-2 4.0E-4 4.0E-4
-------
E-Tk2lable-A-5
Page I
TABLE A-5
ARARs FOR EXCAVATION AND LOW TEMPERATURE DESORPTION (LTD)
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Action Specific
Department of Toxic
Substances Control
(DTSC)
22 CCR, Article 20
22 CCR, Article 24
22 CCR. Article 25
22 CCR 66392
22 CCR. Article 6
Requires preparation of < contingency
plan for the facility to minimize
hazards to human health and
environment from fire, explosion, or
release of hazardous waste to soil, air,
or water.
Applicable to hazardous waste
facilities that store containers of
hazardous waste.
Sets requirements for the design of
tanks used for the treatment or storage
of hazardous waste.
Permits by rule
Sets requirements for the generators of
hazardous waste
The lite specific Health and Safety Plan prepared by the
contractor should provide sufficient information and
mitigation procedures for the protection of human health
during LTD operation. SAAD's overall site Contingency
Plan will provide emergency procedures and other pertinent
information, as required by this regulation.
Wastes generated during remedial activity will be considered
potentially hazardous. Examples for this alternative include
condensate and/or (pent carbon which may require
management per the requirements of this ARAR with regards
to use and management of storage containers.
The quantity of hazardous waste generated during remedial
activity will be small and waste will be collected in SS-gillon
drums. Because tanks are not utilized, this ARAR should not
be applicable.
The contractor shall review SAAD's current Part B Permit to
ensure that the requirements of this ARAR are met for this
process under this permit. Where the requirements of this
ARAR are not met for this process under the current permit,
the operator shall submit for approval his plan to meet these
requirements.
With regards to off-site disposal of the condensate, the
contractor will comply with the requirements as set forth by
this ARAR regarding the use of an EPA identification
number, hazardous waste manifest, and recordkeeping.
-------
E-Tk2laMe-A-5
TABLE A-S (Cent.)
ARAR.S FOR EXCAVATION AND LOW TEMPERATURE DESORPTION (LTD)
Page 2
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Action Specific
Chemical Specific
DTSC
DTSC
DTSC/EPA
22 CCR. Article 31
40 CFR 264, Subpart G
22 CCR, Article 23
22 CCR. Article Section
66268.40 and
66268.41/40 CFR 268
Sets requirements for operators/
owners of interim status facilities
utilizing thermal technologies for the
treatment of hazardous waste.
Sets requirements for closure and
post-closure of hazardous waste
management facilities.
For disposal of waste to land, set*
treatment standards for RCRA and
Non-RCRA waste categories.
The contractor will comply with the requirements set forth
by this ARAR with regards to waste analysis, operating
conditions, and monitoring and inspection.
The regulations set forth in this ARAR are applicable lo
hazardous waste management facilities such as landfills and
surface impoundments. Operation of • waste management
facility is not anticipated, Thus, this ARAR should not be
applicable.
The history of Tank 2 indicates that the tank was used for the
itorage of waste solvents. The soil debris generated by
excavation would therefore, be • FOOI-F005 waste.
Treatment standards for reported constituents are:
FOOI - F003 Spent Solvents TCLP fmyfl
Eihylbentene 0.053
Tetrachloroethene 0.05
Xylenes 0.15
2-BuUnone 0.75
See Section 7.2.10.3 for details on compliance.
-------
E-Tk2Uhle-A-5
TABLE A-5 (Cent.)
ARARs FOR EXCAVATION AND LOW TEMPERATURE DESORPTION (LTD)
Page 3
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Chemical Specific
DTSC
40CFR26I
22 CCR. Article 11
Site Specific
DTSC
Sile/Aclion/Chemical
Specific
EPA
22 CCR 6639 1
22 CCR 67 1 03
22 CCR 67220
Safe Drinking Water Act
(SDWA) 42 USC300
40CFRI4I
Identification and listing of hazardous
waste. Numerous compounds
delected at the Tank 2 site are listed as
hazardous wastes. These regulations
include specific testing criteria
determining hazardous waste
characteristics.
Hazardous water facility permit -
contents of Part B of (he application.
Site Security
Notice in Deed to Property required
for permitted disposal facilities.
Drinking Water Standards, including
both enforceable MCLs and MCLGs.
Wastes generated during remedial activity will be considered
potentially hazardous. Examples for this alternative are spent
carbon and/or condensate. Wastes will be managed as
hazardous waste unless shown not be hazardous by testing
according to this ARAR.
»• tinder the alternative, a hazardous waste facility is not being
permitted. Thus, this ARAR should not be applicable.
» The contractor ihatl prevent the unknowing entry, and
minimize the possibility of, unauthorized entry of persons or
livestock in the area of LTD operation.
» Since (his alternative does not create a disposal facility, (his
ARAR is not applicable.
» The following chemical specific regulatory requirement* have
been identified at (he Tank 2 site:
Constituent
Ethylbenzene
Heplachlor epoxide
Tetrachloroethene
Xylenes
Max. Contaminant Level
mg/l
0,7
0.0002
0.005
10
-------
E-Tk2lable-A-S
TABLE A-5 (Conl.)
ARARs FOR EXCAVATION AND LOW TEMPERATURE DESORPTION (LTD)
Page 4
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Chemical Specific
DTSC
22 CCR. Article 5.5,
Section 64444.5
Sets maximum contaminant levels for
(he primary drinking water
constituents.
•> The following chemical specific regulatory requirements have
been identified *t the Tank 2 site:
Constituent
Max. Contaminant Level
mg/l
Site/Action/
Chemical Specific
RWQCB
Porter Cologne Water
Quality Control Act (CA
Witer Code)
CVRWOCB-R5, Water
Quality Control Plan
(Basin Plan)
Slate Board Resolution
No. 68-16
This Act coordinates regulatory
control over all activities that may
affect water Quality.
This plan in the vehicle by which the
CVRWQCB administers the CA
Water Code. This Act establishes the
responsibility of the RWQCB to
supervise cleanup efforts at spill sites
including approval of cleanup plans
and verification of final cleanup.
Non-degradation policy.
Ethylbenzene
Heptachlor epoxide
Tetrachloroethene
Xylenes
0.680
0.00001
0.005
1.750
Refer to Section 7.2.10.3 for details on compliance.
This ARAR generally requires the protection of beneficial
uses of waters of the State. Specific requirements are
addressed in other ARARs presented in this table.
The contractor shall supply information required by this
ARAR in his workplan and procedures. This information
shall be forwarded to the RWCQB for review and approval.
The contractor shall treat the nil to require clean up levels
stated in Section 3.6 such that residual constituents will be
degrade beneficial uses for ground water.
-------
E-Tk2lable-A-5
TABLE A-5 (Cent.)
ARARs FOR EXCAVATION AND LOW TEMPERATURE DESORPTION (LTD)
P«geS
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Site/Aclion/Chemical
Specific
RWQCB
Proposition 65
Title 23. Chapter 15
Discharges of Waste (o
Land.
Safe Drinking Water Act and Toxic
Enforcement Act. This Act prohibits
the discharge of known carcinogens
and reproductive toxins into • source
of drinking water. The Act also
requires a clear warning of potential
significant exposures.
Chapter 15 outlines requirements for
the design, construction, operations,
and closure of waste containment
facilities.
The condensate generated during LTD operation will be
treated prior to discharge. Further, the contractor will
comply by controlling air emissions, providing adequate site
security and appropriate iignage, and through
implementation of cite specific health and safety plan.
A HRA will be conducted to acceptable emission levels. The
HRA will estimate one in • million cancer risk as opposed to
one in one thousand as suggested by Proposition 65.
The regulations in this Chapter establish waste and tile
classification and waste management requirements for waste
treatment, storage, or disposal in landfills, surface
impoundments, waste piles, and land treatment facilities.
Since the LTD operation does not entail any of the above,
this ARAR should not be applicable.
-------
E-Tk2lahle-A-3
TABLE A-5 (Cont.)
ARARs FOR EXCAVATION AND LOW TEMPERATURE DESORPTION (LTD)
Page 6
TYPE
Site/Action/Chemical
Specific
Site/ Action/Chemical
Specific
SUBMITTING
AGENCY
EPA
Environmental Protection
Agency
(EPA)
ARAR
NPDES
40CFR 122
40 CFR 264. Suhpart F
DESCRIPTION
» Discharge of liquid streams to surface
waters.
» Release from solid waste management
units.
COMMENTS/IMPACTS
» This alternative does not entail discharge of liquid streams to
surface waters, therefore this ARAR should not apply.
» This ARAR is applicable to owners or operators of facilities
that treat, store, or dispose of hazardous waste. It applies to
surface impoundments waste piles, land treatment units, or
landfills. As the LTD operation does not entail any of the
above, this ARAR should not be applicable.
-------
E-Tk2l«ble-A-5
TABLE A-5 (Cont.)
ARARs FOR EXCAVATION AND LOW TEMPERATURE DESORPTION (LTD)
P«ge 7
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Chemical Specific
EPA
Und Ban
40 CFR 268
Land disposal restrictions for RCRA
tnd non-RCRA waste categories.
This ARAR Identifies wastes lh«t ire restricted from land
disposal. Upon the effective date of May 8, 1992 soil
generated by excavation could be considered a non-waste
water from • multi-source (eachale. A comparison of the
reported constituents values for treatment standards for F039
waste is as follows:
Range of Delected
Chemical
Anthracene
Benzole Acid
Benzo(a)anthracene
Benzo(g,h.i)perylene
2-Butanone
Chrysene
4.4--DDE
4.4--DDT
Dibenzo(a,h)anthncene
1 ,2-ilichloropropane
Dieldrin
2,4-Dimethylphenol
Ethylbenzene
Fluoranlheno
Heptachlor epoxide
lndeno(l.23,-«d)pyrene
2-Methylnophthilene
4-Methylphenol
Naphthalene
Phenonlhrene
Phenol
Pyrene
Tetnchloroetheoe
Xylenes
Concentrations
(mg/kg)
.041
.39
1.3
.12-1.5
.027 - 1$
.05 - .3
.0018
.0038
1.5
.002
.003 - .0078
.17 -.72
.008-2100
.36-2.9
.0086
1.7
.32
.040
.21 - 26
.22 - 2.7
.035 - .067
.34 - 2.4
.003 - 39
.001-11000
Landban tola!
Composition
(mg/kg)
4.0
_
8.2
1.5
36
8.2
.087
.087
8.2
18
0.13
14
6
8.2
.066
8.2
-
-
3.1
3.1
6.2
8.2
5.6
28
-------
E-Tk2laMe-A-5
TABLE A-5 (Conl.)
ARARs FOR EXCAVATION AND LOW TEMPERATURE DESORPTION (LTD)
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Chemical Specific
EPA
EPA uid ARB
Clein Air Acl
40CFR6I
40 CFR Part 50 el seq.
17 CCR 60204 el seq.
Action/Site Specific
Sacramento MelropoliUn
Air Quality Management
District (SMAQMD)
Rule 202, Section 301
Site/Action/Chemical
Specific
SMAQMD
Rule 401
National Emission!! Standards for
Hazardous Air Pollutants.
Clean Air Acl and Slate Air Pollution
Control Laws.
New Source Review. The purpose of
this rule is to provide for (he review
of new stationary air pollution sources
and to provide mechanisms by which
authorities to construct such sources
may be granted without interfering
with the attainment or maintenance of
ambient air quality standards.
Ringlenunn Chart
» Air emissions from the remediation of Tank 2 site would
primarily compose of PCE, 2-butanone, ethylhenzene, and
xylenes which pursuant to Section 112 of the Act are not
designated as hazardous air pollutants. Therefore, this
ARAR does not apply.
» California air pollution control laws are generally stricter and
therefore supercede the federal Clean Air Act. Applicable
(tale/local air districts pollution control laws are discussed
below. Emission sources are Divided into mobile and
stationary sources. Stationary sources may be regulated as
new sources, existing sources, or may be granted a variance.
New source emission standards are enforced by a permit rests
with the local air districts.
» The contractor shall comply with the requirements set by this
ARAR such as the use of BACT, the attainment of air quality
standards, and the possible preparation of a permit
application to construct and lo operate the LTD unit.
Atmospheric ditchirgea from the lite form any source (other
than uncombined water vapor) for a period of more than
three minutes in any one hour shall not be as dark or darker
in shade as designation No. I on (he Ringlemann Chart
published by the U.S. Bureau of Mines. Nor shall the
emissions be of inch opacity as to obscure a human
observer's view, or register on a certified in-slack opacity
monitoring system at a level equal to or greater than
Ringlemann designation No. I.
-------
E-T1c2lable-A-5
TABLE A-5 (Conl.)
ARARs FOR EXCAVATION AND LOW TEMPERATURE DESORPTION (LTD)
P«ge9
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Site/Action/Chemical
Specific
SMAQMD
Rule 403
Fugitive dust
Rule 404
Participate Milter
Every reasonable precaution shall be Uken not to cause or
•How (he emissions of fugitive dust from being airborne
beyond the properly line from which the emission originates.
Reasonable precautions shall include, but are not limited
applying asphalt, oil, water or suitable chemicals for the
control of dust on surface which can give rise to airborne
matter. Other measures may be taken as approved by the Air
Pollution Control Officer.
No discharge* shall be made (o the atmosphere from any
source paniculate matter in excess of 0.23 grams per dry
standard cubic meter (0.1 grains per dry cubic fool).
-------
E-Tk2lable-A-5
TABLE A-5 (Conl.)
ARARs FOR EXCAVATION AND LOW TEMPERATURE DESORPTION (LTD)
Page 10
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Site/Aclion/Chemical
Specific
SMAQMD
Rule 405
Dust and condensed fumes
No discharges into (he atmosphere shall be made in any one
hour from any source whatsoever of dust or condensed fumes
in total quantities exceeding the following:
ntocEn WOOHT AND AILOWAUE DOCHAIOE
Mil* (lifrlMU
Ilictorfftl frw all
Hl>t« ft fr«c«lll
•HIM jlitMr*
r«r
•»I|M Mltl MMtcvtlU
Mr k«r «ltt*f l«f«rtt«U
IlKUrtt* lr«. Ill
MI»U ff tr«c«ll)
n/«r unr tinr ua*
UKr Iff* u/fr
IH
M
IM
40t
110
MO
MO
.11 I.M
.11 l.ll
,H l.ll
.11 I.M
.11 I.U
.11 l.ll
.It l.ll
.11 I.M
,M l.ll
no i.ii -l.ll
III 1000 I.M I.M
Ml 1100 l.ll I.M
•M 1400 I.U l.ll
m IMO i.ii MI
• II IMO I.M l.ll
Ml MOO I.M I.M
IIM IUO l.ll 4.11
IMI MOO l.ll l.ll
Illl IMO I.M l.ll
Ull 1000 l.ll I.M
IWI IMO I.N I.I)
llfl MOO t.ll 1.41
two lioo l.ll . l.ll
III) MOt I.M l.ll
mi iioo i.ii I.M
1111 rat i.n O.M
HOI IMO I.M I.M
III
IU
III
III
Ml
111
III
III
w
4M
MM MM I.M Ml
MI4 IMO 4.11 I.M
IMI MOO I.M I.M
. Illl KM 4.4t l.ll
4111 IICXX I.H ||.f
Mil UOM I.II ll.l
1144 14000 4.11 10.1
llfl UOM I.M ll.l
lid UOM 1.0 ll.l
mi nooo I.M n.i
IMM Km l.ll U.I
Illll *90M l.ll U.I
11111 KOOI I.M n.i •
tllll MOM l.ll U.I
11111 moi i.n 11.1
MMI MtM 1.41 U.I'
4tm Moog I.M ll.l
Illll BOOM I.M ll.l
MM M0009 1.17 N.I
IMI4I IOOOM ll.tl n.i
nun IOOOM ii.n 11.1
mill MOOOO ii.n n.i
mm MOOM 11.01 H.I
Itllll NOOM U.ll ll.l*
MMM MOOOI u.ii n.i
40ml MOOM U.ll D.I
4MIII 1000009 11.44 M.O
-------
E-Tk2lable-A-5
TABLE A-5 (Cont.)
ARARs FOR EXCAVATION AND LOW TEMPERATURE DESORPTION (LTD)
Page 11
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Action/Site Specific
SMAQMD
SMAQMD Rule 402 CA
Health and Safely Code,
Section 41700
General guideline, if (he LTD
operation causes release of
contaminants to the atmosphere, then
a case-by-case determination of public
nuisance potential should be
performed to verify compliance.
These ARARs state that discharges to
air causing injury, detriment, nuisance
annoyance; or endanger the comfort,
repose, health, safety, or causes or
damage to business or property is
prohibited.
To comply with this ARAR, the contractor shall minimize
the potential for emissions through the use of BACT. A
health risk assessment has been conducted to evaluate the
effect of emissions on the receptors in the vicinity of the
LTD unit. The results are included under the "short term
effectiveness' criteria for this alternative.
-------
E-Tk2lable-A-S
TABLE A-5 (Cont.)
ARARs FDR EXCAVATION AND LOW TEMPERATURE DESORPTION (LTD)
Page 12
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Chemical Specific
EPA
F.R. S5(l45):30865July
27, 1990
Cleanup levels under RCRA
corrective actions.
» The proposed RCRA Sample Action Levels for the following
chemical specific compounds identified at the Tank 2 site are
TBCs and are *s follows:
Semi-Volatile Organic Compounds
Name
Phenol
Name
Hazard Soil Water
Claa Cone. Cone.
(mg/kg) (mg/kg)
Hazard
Cla«
5.0 E4
Pesticides/Dioxiiu
Soil
2.0 El
DDE B2
DDT B2
Dieldrin B2
Heplachlor B2
epoxide
Water Air
Cone. Cone.
(mg/kg) (mg/kg) jjg/m>
2 I.OE-4 —
2 I.OE-4 I.OE-2
4.0E-2 2.0E-6 2.0E-4
8.0E-2 4.0E-6 4.0E-4
-------
e-71c2Uble-A4
Page!
TABLE A-6
ARARs FOR EXCAVATION AND SURFACE AEROBIC BIODEGRADATION
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Action Specific
Department of Toxic
Substances Control
(DTSC)
22 CCR, Article 20
22 CCR, Article 24
22 CCR, Article 25
22 CCR 66392
Action Specific
DTSC
22 CCR. Article 28
Requires preparation of a contingency
plan for the facility to minimize
hazards to human health and
environment from fire, explosion, or
release of hazardous waste to soil, air,
or water.
Applicable to hazardous waste
facilities that store containers of
hazardous waste.
Sets requirements for the design of
tanks used for the treatment or storage
of hazardous waste.
Permits by rule
Sets requirements for land treatment at
interim status facilities.
The site specific Health and Safety Plan prepared by the
contractor should provide sufficient information and
mitigation procedures for the protection of human health
during biodegradation operation. SAAD's overall site
Contingency Plan will provide emergency procedures and
other pertinent information, as required by this regulation.
The biodegradation operation does not entail on-site storage
of hazardous waste. Therefore, this ARAR should not be
applicable.
In this case, the biodegradation does not entail application or
use of tank* for soil decontamination. Thus, this ARAR
doe* not apply.
The contractor shall review SAAD's current Part B Permit to
ensure that the requirements of this ARAR are met for this
process under this permit. Where the requirements of this
ARAR are not met for this process under the current permit,
the operator shall submit for approval his plan to meet these
requirements.
The contractor shall design the treatment cell to control
runoff and minimize wind dispersion. The treatment celt
will be underlaid with a plastic liner to preclude
contamination of the surface toil and to prevent (he migration
of contamination to the vadose tone. Since the treatment
process will be conducted for one to two months, vadose
zone monitoring should not be required.
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E-tk2table-A-6
TABLE A-6 (Continued)
ARARs FOR EXCAVATION AND SURFACE AEROBIC BIODEGRADATION
Page 2
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Action Specific
DTSC
Chemical Specific
DTSC/EPA
22 CCR, Chapter 30
40 CFR 264, Subpirt G
22 CCR, Article 23
22 CCR .Article Section
66268.40 and
66268.41/40 CFR 268
40 CFR 261
22 CCR, Article 11
Sets requirements for liner
containment at land treatment
facilities.
Sets requirements Tor closure and
post-closure of hazardous waste
management facilities.
For disposal of waste to land, sets
treatment standards for RCRA and
Non-RCRA waste categories.
» Identification and listing of haiardous
waste. Numerous compounds
detected at the Tank 2 lite are listed as
hazardous wastes. These regulations
include specific testing criteria for
determining hazardous waste
characteristic*.
» Requires double LCRS containment if unsaturated zone
monitoring is impractical. The contractor will submit his
liner design to DTSC for review and approval.
* The regulations act forth in this ARAR are more applicable
to hazardous waste management facilities nich as landfills.
Since the operation of a waste management facility is not
anticipated, this ARAR should not be applicable.
» The history of the Tank 2 lite indicate* that the lank was
used for the storage of waste solvent*. The soil debris
generated by excavation would therefore be a FOOI-F005
waste. Treatment standards by reported soil constituents ire:
FOOI • F005 Spent Solvents
Ethylbenzem
Tetrachloroelhene
Xylenet
2-Butanone
TCLP imf/1)
O.OS
0.05
0.15
0.75
Refer to Section 7.2.14.3 for details on compliance.
The aoo-lreated (oil will be treated ai • potential hazardous
waste and classified according to this ARAR. The treated
toil ii not considered a hazardous waste. By-products (i.e.
run-off water) will be recycled in the biodegradation area
until treated.
-------
E-lk2table-A-«
TABLE A-6 (Continued)
ARARs FOR EXCAVATION AND SURFACE AEROBIC BIODEGRADATION
Page 3
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Site Specific
DTSC
Site/ Action/Chemical
Specific
EPA
Chemical Specific
DTSC
22 CCR 66391
22 CCR 67103
22 CCR 67220
Safe Drinking Water Act
(SOWA) 42 USC300
40CFRI4I
22 CCR, Article 5.5,
Section 64444.5
Hazardous water facility permit
contents of Part B of the application.
Site Security
Notice in Deed to Property required
for permitted disposal facilities.
Drinking Water Standards, including
both enforceable MCLs and MCLGs.
» Sets maximum contaminant levels for
the primary drinking water
constituents.
»• Under this alternative, a hazardous waste facility is not being
permitted. Thus, this ARAR should not be applicable.
» The contractor ihall prevent the unknowing entry, and
minimize the possibility of, unauthorized entry of persons or
livestock in the area of biodegradalion operation.
»• Since this alternative does not create a disposal facility, this
ARAR is not applicable.
» The following chemical specific regulatory requirements have
been identified at the Tank 2 site:
Constituent
Ethylbenzene
Heptachlor epoxide
Tetrtchloroelhene
Xylenes
Max. Contaminant Level
„ me/I
0.7
0.0002
0.005
10
The following chemical specific regulatory requirements have
been identified at the Tank 2 site:
Constituent
Ethylbenzene
Heptachlor epoxide
Tetrachloroethene
Xylenes
Max. Contaminant bevel
mg/l
0.680
0.00001
0.005
1.750
Refer to Section 7.2.14.) for details on compliance.
-------
n-lk2l«hle-A-«
TABLE A-6 (Con(inncd)
ARARs FOR EXCAVATION AND SURFACE AEROBIC BIODEGRADATION
Page 4
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Chemical Specific
Site/Action/Chemical
Specific
RWQCB
RWQCB
Sile/Aclion/Chcmicil
Specific
Site/Action/Chemical
Specific
RWQCB
RWQCB
Porter Cologne Water
Quality Control Act (CA
Water Code)
CVRWQCB-R5, Water
Quality Control Plan
(Basin Plan)
State Board Resolution
No. 68-16
Proposition 65
This Act coordinates regulatory
control over all activities that may
affect water quality.
This plan is the vehicle by which the
CVRWQCB administers the CA
Water Code. This Act establishes the
responsibility of the RWQCB to
supervise cleanup efforts at spill sites
including approval of cleanup plans
and verification of final cleanup.
Non-degradation policy.
Safe Drinking Water and Toxic
Enforcement Act. This Act prohibits
the discharge of known carcinogens
and reproductive toxins into • source
of drinking water. This Act also
requires a clear warning of potential
significant exposures.
»• This ARAR generally requires (he protection of beneficial
uses of waters of the Stile. Specific requirements are
addressed in other ARARs presented in this table.
» The contractor shall supply information required by this
ARAR in his work plan and procedures. This information
should he forwarded to the RWQCB for review and
approval.
» The contractor ihall treat the toil to the required cleanup
levels (Uted in Section 3.6 such (hat residual constituents
will be degrade beneficial uses for ground water.
fc The Contractor will comply by controlling air emissions,
providing adequate lite security and appropriate signage, and
through implementation of a site specific worker health and
safely plan.
A HRA will be conducted to estimate acceptable emission
levels. The HRA will be based on • one million cancer risk
required by Proposition 65.
-------
E-lk2fable-A-«
TABLE A-6 (Continued)
ARARs FOR EXCAVATION AND SURFACE AEROBIC BIODEGRADATION
PageS
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Site/Act ion/Chemical
Specific
RWQCB
Tide 23, Chapter 15
Discharges of Waste to
Land.
Site/ Action/Chemical
Specific
EPA
Environmental Protection
Agency
(EPA)
NPDES
40 CFR 122
40 CFR 264, Subpart F
and Subpart L
Chapter 15 outlines requirements for
the design, construction, operations,
and closure of waste containment
facilities.
Discharge of liquid streams to surface
waters
Release from solid waste management
units.
The operator of the biodegradation process shall construct a
treatment cell with • plastic liner to preclude migration of
contaminants to the vadose zone. The treatment cell would
be properly aloped to effectively manage surface run-on or
run-off for recycling into the treatment cell. In addition, the
ARAR requires the liner structures to contain the probable
maximum precipitation (which exceeds a 25 year storm
requirement of 40 CFR 264) and withstand a maximum
credible earthquake.
This alternative does not entail discharge of liquid streams to
surface waters, therefore this ARAR should not apply.
This ARAR is applicable to owners or operators of facilities
that treat, store, or dispose of hazardous waste. It applies to
surface impoundments waste piles, land treatment units, or
landfills. The biodegradation unit operator must comply
with the requirements of this ARAR. However, the state
requirements for waste piles are more stringent than the
Federal regulations. See Title 23, Chapter IS and Title 22
Division 4, Chapter 30.
-------
E-lk2lable-A-«
TABLE A-6 (Conllnued)
ARARs FOR EXCAVATION AND SURFACE AEROBIC BIODEGRADATION
Page 6
TYPE
SUBMITTING
AOENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Site/Action/Chemical
Specific
EPA
Land Bin
40 CFR 268
Land disposal restrictions for RCRA
and non-RCRA waste categories.
This ARAR identifies wastes that are restricted from land
disposal. Upon (he effective date of May 8, 1992, soil
generated by excavation could be considered a non-waste
water from a multi-source leachate. A comparison of (he
reported constituent values for treatment standards for F039
waste is as follows:
Range of Detected Landban total
Chemical Concentrations Composition
Anthracene
Benzoic Acid
Bento(a)anfhracene
Benzo(g,h,i)peryleM
2-Butanone
Chrysene
4.4--DDE
4.4--DDT
Dibenzo(a,h)anlhracene
1 ,2-dichloropropane
Dieldrin
2,4-Dimethylphenol
Elhylbenzene
Fluoranlhene
Heptachlor epoxide
lndeno(l ,23,
-------
E-tk2lihle-A-6
TABLE A-6 (Continued)
ARARs FOR EXCAVATION AND SURFACE AEROBIC BIODEGRADATION
Page?
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Chemical Specific
Chemical Specific
EPA
EPA and ARB
Clean Air Act
40CFR6I
Clean Air Act
40 CFR Part 50 el. seq.
17 CCR 60204 et.seq.
Action/Site Specific
Sacramento Metropolitan
Air Quality Management
District (SMAQMD)
Rule 202
National Emissions Standards for
Hazardous Air Pollutants.
Clean Air Act and Stale Air Pollution
Control Laws.
New Source Review. The purpose of
this rule is to provide for the review
of new stationary air pollution sources
and to provide mechanisms by which
authorities lo construct such sources
may be granted without interfering
with (he attainment or maintenance of
ambient air quality standards.
Air emission! from the remediation of Tank 2 site would
primarily comprise of PCE, 2-butanone, elhylbenzene, and
xylenes which pursuant to Section 112 of the Act are not
designated as hazardous air pollutants. Therefore, this
ARAR does not apply.
California air pollution control laws are generally stricter and
therefore supercede the Federal Clean Air Act. Applicable
state/local air districts air pollution control laws are discussed
below. Emission sources are divided into mobile and
stationary sources. Stationary sources may be regulated as
new sources, existing sources, or may be granted a variance.
New source emission standards enforced by a permit system.
Administration of permits rests with (he local air district.
Reactive organic compounds will be emitted in excess of (he
limit of 0 Ib/day. This triggers the requirement for use of
BACT. BACT is defined as the maximum technique or
control device which is technologically feasible and cost
effective. In this case, BACT could be covering (he
excavated soil which is being bioremcdiated.
-------
E-lk2(able-A-«
TABLE A-6 (Continued)
ARARs FOR EXCAVATION AND SURFACE AEROBIC BIODEGRADATION
PageS
TYPE
SUBMITTINO
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Action/Site Specific
SMAQMD
Rule 401
Ringtemann Chirt
Rule 403
Fugitive dusl
Rule 404
Paniculate Miller
Atmospheric discharge* from the site form my source (other
than uncombined wtter vapor) for • period of more than
three minutes in «ny one hour (hill not be as dirk or darker
in shide a* designation No. I on the Ringlenunn Chirt
published by the U.S. Bureau of Mines. Nor shall the
emissions be of such opacity as to obscure a human
observer's view, or register on a certified in-slack opicily
monitoring system it i level equal lo or greater than
Ringlemanndesignation No. I.
Every reasonable precaution shall be taken not lo cause or
allow the emissions of fugitive dusl from being airborne
beyond (he property line from which the emission originates.
Reasonable precautions shall include, but ire not limited
applying uphill, oil, water or suitable chemicals for the
control of dust on surface which can give rise to airborne
matter. Other measures may be taken as approved by the Air
Pollution Control Officer.
No discharge shall be made to the atmosphere from my
source pirticulile miller is excess of 0.23 grams per dry
standard cubic meter (0.1 grains per dry cubic foot).
-------
E-tk2(«ble-A-«
TADLE A-6 (Continued)
ARARs FOR EXCAVATION AND SURFACE AEROBIC BIODEGRADATION
Page 9
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Action/Site Specific
SMAQMD
Rule 405
Dust «nd condensed fumes
No discharges into (he atmosphere shall be nude in any one
hour from my source whatsoever of dust or condensed fumes
in total quantities exceeding the following:
MOCCa WOOHT AND /UXOWAILE MJCIIAIIOB
UtilM JHtkirtl
FrtMII r«w »llMt4 If
Ml|kl Mill MrltClUU
H' *** MlUr UftrtMtt
IlKhtrfM frM «1I
Hlfttl «f t'WMll
MUM Mill Mfllol
Hf IMW MtUr l.ll
lilt 4000 1,11 1.04
1041 4HO I.M I.I'
till 1000 1,11 I.It
not no) l.ll . Lit
III' WOO I.M I.I'
nil not i.i) '.«
lilt no* I.H I.N
MM not I.M I.M
HI UOO l.'ll
• M 1440 I.U
III 1100 1.41
III IMO I.N
101 tOOt I.M
IIM IMO l.ll
IIM mo i.ii
11*1 --•- - -•
Mil
IIM
IMI
. 4111
•III
1411
IW4
ml
•ID
•oil
inn
NMI
41411 IMOM
tom MOOM
IMM4 MOOOO
Illlll 400001
mill MOOM
mill loom
unit loom
MM)* MOQM
4NOII
4IUII
MO) i.n i.'i
KM 4.11 1.04
MOt 4.K I.M
tut 4.40 t.lf
10000 I.U II.*
urn i.ii
I4on
I40M
lion i.n
moo I.M
MOOO l.tl
400M I.H
MOO) I.N
MOM l.tl
nooo i.a
MOM 1.41
I.N
>.M ....
i.n M.4
N.II n.i
II.M 14.1
11.11 M.4
II.M H.I
U.ll
ii.n
11.11
II.M
. . 10.4
4,n it.i
I.M II.I
K:!
U.I'
U.I •
II.?'
U.I'-
IM
ll.Ji
19*9 •
IM'
»l.4
M.4
n.i
M.*
1H Mb *M *• 'A' m,mt •rt-rma,*m l.li K| ki* l
Thu• puna ii^iinti.iii>n niiii iij 1-1 • •
-------
B-lk2lihle-A-6
TABLE A-6 (Continued)
ARARs FOR EXCAVATION AND SURFACE AEROBIC BIODEGRADATION
Page 10
TYPE
SUBMITTINO
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Aclion/Site Specific
SMAQMD
Rule 402 CA Health and
Safety Code, Section
41700
General guideline. if (he
biodegradation operation causes
release of contaminants to the
atmosphere, (hen a case-by-case
determination of public nuisance
potential should be performed to
verify compliance. These ARARs
slate that discharges to air causing
injury, detriment, nuisance
annoyance; or endanger the comfort,
repose, health, safely, or causes or
damage to business or properly is
prohibited.
To comply with this ARAR, the contractor shall minimize
the potential for emissions through the use of BACT. A
health risk assessment has been conducted to evaluate the
effect of emissions on the receptors in the vicinity of the
biodegredation unit. The results are included under the
'short term effectiveness* criteria for this alternative.
-------
E-tk2lable-A-6
TABLE A-6 (Continued)
ARARs FOR EXCAVATION AND SURFACE AEROBIC BIODEGRADATION
Page 11
TYPE
SUBMITTING
AGENCY
ARAR
DESCRIPTION
COMMENTS/IMPACTS
Chemical Specific
EPA
F.R. 5S(l45):30g65)uly
27. 1990
Cleanup levels under RCRA
corrective actions.
The proposed RCRA Simple Action Levels for the following
chemical specific compounds identified it the Tank 2 site ire
TBCs ind are as follows:
Semi-Volalile Organic Compounds
Name Hazard Soil Water
Cl«ss Cope. Cone.
(rog/kg) (mg/kg)
Phenol D
5.0 E4
2.0 El
Peaticidea/Dioxins
Name Hazard
Clisa
DDE 82
DDT B2
Dieldrin B2
Heplachlor 62
epoxide
Soil
Cone.
(mgrttg)
2
2
4.0E-2
8.0E-2
Water
Cone.
(mgftg)
l.OE-4
I.OE-4
2.0E-*
4.0E-*
Air
Cone.
llg'n?
»•*
I.OE-2
2.0E-4
4.0E-4
-------
APPENDIX B
ADMINISTRATIVE RECORD DOCUMENTS
-------
ADMINISTRATIVE RECORD DOCUMENTS
SUBMITTAL DATE
1. Analytical Results Summary, Tank 2
Field Investigation
2. Potential California ARARs
3. Tank 2 Public Health Evaluation
4. Technology Screening Tables
5. Tank 2 Treatability Study/Additional
Treatability Testing Reports
6. Tank 2 Alternatives Public Health Evaluation
7. Tank 2 Public Health Evaluation of
the Soil Venting System
8. Mobility Assessment of Contaminants
at Tank 2 Site
9. Detailed Cost Estimates
10. Proposed Action Plan - Tank 2
August 2, 1991
August 2, 1991
Augusts, 1991
August 2, 1991
July 19, 1991
July 8, 1991
July 17, 1991
August 14, 1991
August 2, 1991
August 16, 1991
E20-91-118
September 25, 1991
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