United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R09-92/084
September 1992
Superfund
Record of Decision:
Sacramento Army Depot
(Operable Unit 4), 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 supptement. but adds no further appIicabJe informatiOn to
the content of the document. All supptementai material is. however. c:ontained in the adrnirJis1ratiYe record
for this site. .
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50272-101
REPORT DOCUMENTATION .11. REPORT NO. I ~ 3. Recipienta Acc:ea8ion No.
PAGE EPA/ROD/R09-92/084
4. T1tJe and SUb11118 5. Report Dale
SUPERFUND RECORD OF DECISION 09/30/92
Sacramento Army Depot (Operable Unit 4), CA
6.
Third Remedial Action - Subsequent to follow
7. Author(a) 8. Perfonning Organization RepL No.
8. Perfonnlng OrgaInimtion Name and Add..... 10. ProjectlT..lIIWork Un~ No.
11. ContraCl(C) Of Grant(G) No.
(e)
(G)
12. Sponaorlng Or;animtion Name and Add..... 13. Type 01 Report & Period Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. Supple...ntaty NoIea
PB93-964510
16. Ab8Inct (UmII: 2110 .orela)
The 485-acre Sacramento Army Depot (SAAD) site is a military facility in Sacramento
County, California. Land use in the area is predominantly commercial and light
industrial, with wetlands in the vicinity of several oxidation lagoons. The estimated
56,398 people who live within 2 to 3 miles of the site use municipal water as their
drinking water supply. From 1950 to 1972, the lagoons received mostly industrial waste
water from metal plating processes and domestic wastewater. Domestic wastewater was
treated in the sewage treatment plant prior to discharge to the lagoons. Concentrated,
untreated rinse water generated by metal plating operations was diluted with large
volumes of water and then directed to the lagoons. Since the Army began investigating
possible contamination at SAAD, eight operable units have been identified that may
require remediation. This operable unit (OU4) consists of four lagoons, several
drainage ditches, and the neighboring Old Morrison Creek. As a result of a 1981
investigation by the Army and the state, VOCs were detected in ground water and
11 heavy metals up to concentrations of 10,900 mg/kg were found in the oxidation lagoon
pits. A 1989 ROD addressed OU1, the ground water, and a 1991 ROD addressed
(See Attached Page)
17. Documan' Anafy8i8 L De8cllptora
Record of Decision - Sacramento Army Depot (Operable Unit 4), CA
Third Remedial Action - Subsequent to follow
Contaminated Medium: soil
Key Contaminants: metals (arsenic, chromium, lead)
b. 1dentiII8nIOpan-Cnded Te,...
Co COSA TI FleldlGIOUP
18. Availability Statement '9. Security Claaa (This Report) 21. No. 01 pagea
None 76
20. Security Class (This Page) 22. Price
None
.18 2 2 (4-77/
cs- ANSI-Z38 )
SiNll2$tJvCtjonB on R41VlIfSS
(Formerly NTlS-35)
Department of Commerce
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EPA/ROD/R09-92/084
Sacramento Army Depot (Operable Unit 4), CA
Third Remedial Action - Subsequent to follow
Abstract (Continued)
contaminated soil at Tank 2. This ROD addresses OU4, the metal-contaminated soil at the
oxidation lagoons. Future OUs will address other potential risks posed by the site and a
final ROD will comprehensively address all contaminated areas at SAAD. The primary
contaminants of concern affecting the soil are metals, including arsenic, chromium, and
lead.
The selected. remedial action for this site includes excavating and treating approximately
15,500 cubic yards of contaminated soil onsite using soil washing; dewatering and then
backfilling the treated soil onsite in the excavation areas, and storing the rinsate
temporarily in onsite holding tanks for recycling; treating rinsate from the treatment
process using chemical precipitation, clarification/flocculation, and chemical
coagulation to remove metals, prior to discharge into the sanitary sewer; dewatering the
sludge containing the precipitated metals, and stabilizing this if necessary, followed by
disposal in a RCRA landfill or recovery at an offsite reclamation unit. The estimated
present worth cost for this remedial action is $5,020,000. There are no O&M costs
associated with this remedial action.
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific soil clean-up goals are based on PHE for the primary metals of concern
including arsenic 5 mg/kg; cadmium 40 mg/kg; and lead 174 mg/kg. A treatability variance
from LDR requirements is likely. Achievable treatment levels will be set by field pilot
tests employing the selected technology.
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,
SUPERFUND
RECORD OF DECISION:
SACRAMENTO ARMY DEPOT
OXIDATION LAGOONS
OPERABLE UNIT
SACRAMENTO, CALIFORNIA
September 15, 1992
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RECORD OF DECISION
I. DECLARATION
SITE NAME AND LOCATION
Oxidation Lagoons 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 Oxidation Lagoons
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). The basis for this decision is documented in the
administrative record for this site. which includes, among other documents:
.
The Oxidation Lagoons 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 April 1992, which summarizes the preferred
cleanup alternative. compares the preferred alternative with several other
alternatives. and invites public participation,
Summaries of public comments on the OUFS and the PP. including 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 Oxidation Lagoons.
This is the third of several potential remedial actions addressing soil and groundwater
contamination that may be conducted at SAAD. Subsequent RODs will address other potential
threats posed by the site, both on and off site. A final comprehensive ROD will address the
entire SAAD facility prior to SAAD's closure in 1997.
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.
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ASSESSMENT OF THE SITE
The Oxidation Lagoons Operable Unit includes four Oxidation Lagoons, the Drainage Ditches,
and a portion of Old Morrison Creek. An investigation by the U.S. Army showed that soils in
the Oxidation Lagoons Operable Unit have been contaminated by metals. Metals identified at
concentrations above background levels are antimony, arsenic, cadmium, chromium, cobalt,
copper, lead, mercury, nickel, silver, and zinc.
Contamination in the lagoons appears to extend laterally to the intermediate level of the berms
which surround each lagoon. The lateral extent of contamination in the Drainage Ditches is
approximately 6 feet wide, and the total length of the ditches. The lateral extent of
contamination in Old Morrison Creek is about 30 feet wide, and extends from approximately
50 feet east of the eastern Drainage Ditch to Caroline Drive. The vertical extent of
contamination is about 2 feet in the lagoons, and about 3 feet in the ditches and the creek.
The Oxidation Lagoons Operable Unit does not include groundwater. Comparison of soil
contaminants with the types of contaminants present in groundwater indicates that the
Oxidation Lagoons Unit is not currently a source of groundwater contamination found at
SAAD.
A baseline health risk assessment was conducted to evaluate the current and potential future
risks posed by the contamination at the Oxidation Lagoons Operable Unit if no cleanup occurs.
The health risk assessment found that arsenic, cadmium and lead pose the greatest potential
threat to human health, due to their toxicity and concentrations. Cleanup levels based on
potential health risks and on protection of groundwater were then established for arsenic,
cadmium and lead. The cleanup levels were determined based on additive risk and Applicable
or Relevant and Appropriate Requirements.
Actual or threatened released 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 SELECfED REMEDY
The Army intends to clean up the Oxidation L3goons Operable Unit so that the public is not
exposed to toxic chemicals from the site. This ROD addresses the principal threat at the
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September 15, 1992
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Oxidation Lagoons site by removing the contaminants present in the soil. Removal of
contaminants in the soil will reduce the potential for: future migration of contamination from
the soil to groundwater; public exposure to contamination from inhalation or ingestion of
fugitive dust containing contaminants; and public exposure to contamination due to direct
contact or ingestion of contaminated soil. These pathways represent the primary potential
present and future risks to public health. Inhalation or ingestion of fugitive dust by the nearest
off-site business and residence is presently a potential risk. Exposure to contamination due to
groundwater ingestion. or direct contact or ingestion of contaminated soil are potential future
risks.
The selected remedy for cleaning up the soil at the Oxidation Lagoons Operable Unit is
composed of: excavating contaminated soil; treating soil in an on-site washing unit; backfilling
the excavation with remediated soil; treating the soil-wash rinsate on site to precipitate metals;
and reclamation of metals from the de-watered sludge or off-site disposal of the sludge. The
selected remedy includes:
E27:92-13.DOC
.
Excavating soil that contains levels of arsenic. cadmium. and/or lead above
cleanup levels.
Removing metals from the soil by mixing it with a washing reagent for a
selected reaction time.
.
.
Sampling the washed soil to assess the effectiveness of the cleanup. Remediated
soil then will be used to backfill the excavation.
.
Treating the soil-wash rinsate on site using a chemical precipitant.
De-watering the sludge containing the precipitated metals on site. and disposing
of it at an off-site facility permitted to receive hazardous waste or recovering the
precipitated metals at an off-site metal reclamation unit. Although reclamation
of the sludge is preferred to off-site disposal. the decision will be based on the
cost. the concentration of metals in the sludge, the total quantity of sludge. and
the availability of a market for metals recycling.
.
.
Sampling the treated rinsate to assess its quality.
discharged to the sanitary sewer.
Completing the excavation and treatment within six to nine months after
contractor selection.
Treated rinsate will be
.
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September 15. 1992
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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 pennanent 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 to nine months of
operation, the five-year review will not apply to this action.
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September IS, 1992
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RECORD OF DECISION
OXIDATION LAGOONS
IT IS SO AGREED:
FOR THE U.S. DEPARTMENT OF THE ARMY:
Cj! )0/'12
Date
.....,
L.!5
Date
'S 'jf) c;---z
~r6~!J~
. Lewis D. Walker
Deputy for Environmental," Safety, and
Occupational Health
Office of the Assistant Secretary of the Anny
(IL&E)
\. ~//
U¥~~~ndY ,
Colonel, pD
Commander, Sacramento Army Depot
FOR THE STATE OF CALIFORNIA ENVIRONMENTAL PROTECTION AGENCY:
tj..- 3c - Cf<.'
Date
f7'""" ("
i I. \) --t'.- \~
v , i .' -':1- \.~.:) ,-r<:.-
Da\1d Wang .
Chief, Base Closure Branch
Department of Toxic Substances Control
California Environmental Protection Agency
(VJQsf!-&J!L
William H. Crooks
Executive Officer "
Central Valley Regional Water Quality Control
Board
q-36-91.
Date
FOR THE U.S. ENVIRONMENTAL PROTECTION AGENCY:
qr ~ 0 . '\ "-
Date
~ .
C - <...v \.U-
leI W. McGovern "'-
Regional Administrator
United States Environmental Protection Agency,
Region IX
EZ7:92-13.DOC
VenioD 3, Paac 5 of Part I
Scpc.embcc 15, 1992
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RECORD OF DECISION
n. DECISION SUMMARY
SAAD - OXIDATION LAGOONS OPERABLE UNIT
TABLE OF CONTENTS
ChaDter
1
SITE NAME, LOCATION, AND DESCRIPTION
1.1 Location
1.2 Site Description
1.3 Demography
1.4 Land Use
1.5 Climatology
1.6 Regional Topography
1.7 Surface Water Hydrology
1. 8 Geology
1.9 Hydrogeology
1.10 Natural Resources
1
1
1
2
2
2
2
3
3
4
4
5
2
3
SITE HISTORY AND ENFORCEMENT ACTIVITIES
HIGHLIGHTS OF COMMUNITY INVOLVEMENT
7
8
4
5
SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY
SUMMARY OF SITE CHARACTERISTICS
5.1 Contamination Sources
5.2 Evaluation of Primary Contaminants
5.3 Location of Contaminants and Potential Routes of Migration
8
8
9
11
12
12
12
12
14
16
18
19
19
6
SUMMARY OF SITE RISKS
6.1 Human Health Risks
6.1.1 Contaminants of Concern
6.1.2 Exposure Assessment
6.1.3 Summary of PRE Results
Environmental Evaluation
Cleanup Levels
6.3.1 Non-Carcinogens
6.3.2 Carcinogens
DESCRIPTION OF ALTERNATIVES
7.1 Alternative 1: No Action
7.2 Alternative 2: Excavation, On-Site Soil Washing, On-Site
Treatment of Wash Liquid, and Backfill
Alternative 3: Excavation, On-Site Soil Washing, Off-Site
Disposal of Wash Liquid, and Backfill
Alternative 4: Excavation. Stabilization, and Backfill
with Stabilized Soil
Alternative 5: Excavation. Stabilization, Backfill with
Stabilized Soil. and Cap
24
25
6.2
6.3
7
19
20
21
24
7.3
7.4
7.5
E27:92-13.DOC
September 15. 1992
. . .
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8 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 26
8.1 Criterion 1: Overall Protection of Human Health and the Environment 26
8.2 Criterion 2: Compliance with ARARs 27
8.3 Criterion 3: Long-Term Effectiveness and Permanence 27
8.4 Criterion 4: Reduction of Toxicity, Mobility, and Volume 28
Through Treatment
8.5 Criterion 5: Shon- Term Effectiveness 28
8.6 Criterion 6: Implementability 29
8.7 Criterion 7: Cost . 30
8.8 Criterion 8: State Acceptance 30
8.9 Criterion 9: Community Acceptance 30
..
9 SELEerED REMEDY 31
10 STATUTORY DETERMINATIONS 32
10.1 Protection of Human Health and Environment 33
10.2 Compliance with ARARs 33
10.3 Cost Effectiveness 33
10.4 Utilization of Permanent Solutions, 33
and Alternative Treatment and Resource Recovery Technologies
10.5 Preference for Treatment as a Principle Element 34
11 DOCUMENTATION OF SIGNIFICANT CHANGES 34
12 REFERENCES CITED 34
FIGURES
1
2
3
4
Site Location Map - Sacramento Army Depot
Site Location Map - Oxidation Lagoons Operable Unit
Horizontal Extent of Contamin2tion .
Vertical Extent of Contamination, Cross Sections A-A and B-B
TABLFS
1
2
3
4
5
6
7
Summary of Contaminants
Definitions of Risk Terms
Estimated Exposure Point Concentrations
Carcinogenic Risks
Non-Carcinogenic Risks
Contaminant Concentrations & Cleanup Levels in Soil
Selected Remedy Estimated Costs
E27:92-13.DOC
September 15, 1992
. - 4 ..
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APPENDICES
RECORD OF DECISION
ID. RESPONSIVENESS SUMMARY
SAAD - OXIDATION LAGOONS OPERABLE UNIT
A
B
Analysis of ARARs
Adnunistrative Record Documents
E27:92-13.DOC
September 15, 1992
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1
SITE NAME, LOCATION, AND DESCRIPTION
1.1
Location
,
The Oxidation Lagoons 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 Fruibidge Road, in
the City and County of Sacramento, California. SAAD lies approximately 7 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 facility encompasses an area of 485 acres.
The four Oxidation Lagoons, each covering approximately 0.5 to 0.75 acres, are located in the
southwest quadrant of the SAAD facility, north of the Bum Pits and east of Caroline Drive.
North of the lagoons are the Drainage Ditches and Old Morrison Creek. The Operable Unit
includes the four lagoons, the Drainages Ditches, and a portion of Old Morrison Creek. A site
map of the SAAD facility, showing the location of the Oxidation Lagoons Operable Unit with
respect to the 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 are Jikely the primary on-site waste generating
activities.
In addition to the Oxidation Lagoons, past and present surface and subsurface storage units and
other structures at the site include: several underground and above-ground storage tanks;
unlined bum 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 reportedly burned on the ground surface.
Several of these areas have released contaminants into the soil and/or groundwater at SAAD,
and are being investigated and cleaned up as separate Operable Units. Areas where
contaminants have been found at SAAD are discussed in more detail in Section 2.
E27:92-13.DOC
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Seplcmbcc IS, 1992
". .
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SACRAMENTO
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PROJECT NO.
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SITE LOCATION MAP
SACRAMENTO ARMY DEPOT
SACRAMENTO, CALIFORNIA
FIGURE
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SITE LOCATION MAP
OXIDATION LAGGONS OPERABLE UNIT
SACRAMENTO ARMY DEPOT
SACRAMENTO. CALIFORNIA
KLEINFELDER
PROJECT NO.
24-150028-A06
. . .-
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flGURE
2
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1.3
Demography
In 1987, 76 people were living on the SAAD facility, and 56,398 people were living off site,
within 2 to 3 miles of SAAD. Data for the working populations on and around SAAD in 1987
are not available. In 1984, 3,430 people worked on the SAAD facility and 20,710 worked off
site, within 2 to 3 miles of SAAD.
,
1.4
Land Use
SAAD is surrounded on all sides by land currently zoned as commercia1llight industrial
property. Within 2 to 3 miles of SAAD, the areas that are primarily low to medium density
residential are northwest, west, and southwest of the site. The areas south, east, and north of
SAAD are primarily industrial.
1.5
Climatology
Climate at SAAD is classified as 8 Mediterranean 8 , hot summer (Koppen System), with mean
temperatures of 30 to 40 degrees Fahrenheit in January, and 90 to 100 degrees in July.
Average relative humidity in January ranges from 80 to 90 percent, and from 50 to 60 percent
in July. Generally, 85 to 95 percent of the annual precipitation occurs in winter. The
estimated mean annual precipitation at the site is 17 inches, and the estimated mean
evaporation is 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 to the east and the Coast Ranges to the west. The youngest sediments (as old as
5 million years) 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 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.
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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, the Army re-routed Morrison Creek so that it flowed along the facility
boundary around the south side of the facility, rather than through it. The floodplain for the
re-routed Morrison Creek extended approximately half a mile north of the creek, onto the
SAAD facility. The creek discharges into two overflow basins of the Sacramento and
American Rivers, and ultimately empties into the Sacramento River.
In 1958, 7,900 linear feet of flood-control dikes were 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 capable of handling tOO-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 which are located along its course, and pennitted discharges from industries.
A study of the SAAD facility indicates that 0.52 acres of wetlands currently exist within the
Oxidation Lagoons Operable Unit, along Old Morrison Creek.
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
Nevadas, and have been deposited by the American River as it has meandered back and forth
across the valley floor.
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Sep\cmbcr IS. 1991
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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 formation 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.
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 groundwater in the area into two hydraulically isolated
sections, the supeIjacent (upper) series located form 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. Groundwater
contamination under the SAAD facility has been found in three discrete, relatively thin, strata
located within the upper portion of the supeIjacent series, approximately 80 to 200 feet below
ground surface. Groundwater contamination extends off site to the southwest of the SAAD
facility. The lateral extent of groundwater 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 groundwater, which is an extremely important resource throughout the Central
Valley, other natural resources on the site are minimal. The Army Corps of Engineers does
not consider the wetlands at SAAD to be high quality wetlands because they provide minimal
wetland functions and habitat values. The Army plans to restore the wetlands areas following
remediation by restoring the relict channel of Morrison Creek to its original grade and by
revegetating the impacted wetland areas with seed source material from areas of old Morrison
Creek that are currently jurisdictional wetlands. It is expected that there will be an overall
benefit to environmental quality by eliminating a source of contamination to species in the
area.
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2
SITE IDSTORY AND ENFORCEMENT ACI'IVlTIES
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 1970s, 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. USA THMA identified several areas of concern where furthel'
investigation was warranted.
In early 1981, the Army initiated an on-site investigation of soil and groundwater in the areas
of concern identified by USA THMA, including the Oxidation Lagoons, Bum Pits, Pesticide
Mix Area, Morrison Creek, and Old Morrison Creek. Groundwater samples collected during
this investigation indicated that volatile organic chemicals (VOCs) were present in groundwater
under the southwest corn€t'of SAAD. Based on the location of the VOCs in groundwater, the
Bum Pits appeared to be 'oJ;le of the main sources of groundwater contamination in this area.
The Oxidation Lagoons w~ie identified as an area contaminated with metals.
In late 1981, the Central Valley Regional Water Quality Control Board (CVRWQCB) sampled
off-site wells near the southwest comer of SAAD. VOCs were reported in some of the wells
closest to SAAD, and the:~y began working with the CVRWQCB to assess the source and
extent of groundwater contamination. The U.S. EPA and California Department of Hea1tb
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 (FF A) under CERCLA Section 120 agreeing to address the entire
facility, including the. contaminated groundwater and seven other areas of suspected
contamination on the SAAD facility:
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Version 3, Plge 5 o( Plr{ II
September IS, 1992
'. . .-
-------
.
.
.
.
Tank 2
Oxidation Lagoons
Bum Pits
Building 320 Leach Field
Pesticide Mix Area
Firefighter Training Area
Battery Disposal Well
.
.
.
11
The FFA also calls for a rigorous RCRA Facility Assessment to identify other specific Solid
Waste Management Units that need further characterization and cleanup. To eJtpedite
investigation and cleanup of the individual sites, the seven areas listed above and the on-site
groundwater are each being treated as individual Operable Units. These seven Operable Units
are shown on Figure 2. Groundwater 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 a ROD that was signed in
December 1991.
Built in 1950, the Oxidation Lagoons received most of the industrial and domestic wastewater
generated at SAAD until 1972. Domestic wastewater was treated in the sewage treatment
plant prior to discharge to the lagoons. Concentrated, untreated rinse water generated by
metal plating operations was diluted with large volumes of water and then directed to the
lagoons. Until 1968, this water was supplied by two on-site wells. In 1968, the wells were
abandoned and SAAD was connected to the City of Sacramento municipal water supply.
Currently, the four Oxidation Lagoons are not in use, and are dry. Vegetation is present in
three of the lagoons. The bottom of the southwest Oxidation Lagoon is void of vegetation,
apparently due to hardpan soil exposed at the surface.
As part of the IRP, the U.S. Army conducted additional soil assessments at the Oxidation
Lagoons in 1985, 1986 and 1990 through 1991. In 1991, the U.S. Army prepared a Remedial
InvestigationIFeasibility Study (RIIFS) workplan in accordance with the FFA. The RIfFS
evaluated the seven Operable Units. Based upon the RIfFS fIndings, four of these, including
the Oxidation Lagoons, were recommended for operable unit feasibility studies (OUFS).
The Oxidation Lagoons were recommended for an OUFS because: 1) heavy metals are present
in the near surface, and pose a threat for airborne migration or migration in surface water
runoff; and 2) the Toxic Pits Cleanup Act (fPCA) is an Applicable or Relevant and
E27:92-13.DOC
September IS. 1992
Version 3, Page 6 or Part n
. .
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Appropriate Requirement (ARAR). TPCA requires that surface impoundments be closed as
soon as feasible.
An OUFS for the Oxidation Lagoons was prepared in 1991, and was revised March 13, 1992.
As part of the OUFS, the Army prepared a baseline Public Health Evaluation (PHE) to
estimate potential health and environmental risks that could results if no action was taken at the
site. The PHE indicated potential cancer and non-cancer health effects to an on-site resident
from metals in Oxidation Lagoons soils. Details of the PHE are summarized in Section 6.
3
IDGHLIGHTS OF COMMUNITY INVOLVEMENT
In June 1988, the Army prepared a Community Relations Plan. In August, 1991, the U.S.
Army issued a Proposed Plan (PP) for the Oxidation Lagoons Operable Unit. The plan
consists of a 10-page fact sheet that was mailed to residents in the surrounding community.
The plan describes the site background, presents a summary of site contamination, and
discusses health risks, cleanup levels, and remedial alternatives. The plan also includes a list
of individuals who may be contacted for additional infonnation, lists the addresses of the
information repositories, and announces the public comment period. The Army also placed
notices in two local daily newspapers, the Sacramento Bee and the Sacramento Union, for five
days prior to the public comment period 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
the Department of Toxic Substances Control (DTSC) and at EP A headquarters in San
Francisco.
A public comment period was held from August 20 through Septe~ber 18, 1991. A public
meeting was held on August 20, 1991. Thirty-nine people, including community members and
representatives from the Army, U.S. EPA, DTSC, and CVRWQCB attended the public
meeting. Seven oral questions were received at the meeting. In April 1992, the U.S. Army
revised and reissued the PP for the Oxidation Lagoons Operable Unit in order to include
additional information on compliance with Land Disposal Regulations that are applicable to the
site. A second public comment period was held from May 9 through June 8, 1992. A second
public meeting was held on May 27, 1992. No written comments were received during either
public commentperiod.
E27:92-13.DOC
Version 3, Page 7 of Part D
September 15, 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 ill of this ROD.
In addition, the DTSC adopted a Negative Declaration fulfilling the requirements found under
the California Environmental Quality Act.
4
SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY
Since the Anny began investigating possible contamination at SAAD, eight Operable Units
have been identified that may require remediation (see Section 2, above). Four of the units,
the Oxidation Lagoons, Tank 2, the Bum Pits, and On-site Groundwater, were recommended
for OUPS. The other four units will be addressed in the overall site Feasibility Study as the
important site characterization information becomes available.
The Groundwater OUPS was completed on May 19, 1989, and on-site groundwater is
currently being remediated under a ROD signed on September 29, 1989. The OUPS for
Tank 2 was finalized on October I, 1991. A ROD for Tank 2 was signed in December 1991,
and remedial activities at Tank 2 are scheduled to begin in 1992. The OUFS for the Oxidation
Lagoons was finalized on March 13, 1992. The OUPS for the Bum Pits is scheduled to be
completed 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 metals contamination in soils at the Oxidation
Lagoons operable unit. These metals pose the principle risk through ingestion of, or contact
with, the contaminated soil.
5
SUMMARY OF SITE CHARACTERISTICS
5.1
Contamination Sources
Soil from the ground surface to depths of approximately 18 to 36 inches beneath the Oxidation
Lagoons Operable Unit (consisting of the four lagoons, the Drainage Ditches, and Old
Morrison Creek) contain 11 heavy metals at concentrations that exceed site background
concentrations. The source of these metals appears to be waste water that was discharged to
E27:92-13.DOC
Version 3, Page 8 ofPalt U
September IS, 1992
-------
the Oxidation Lagoons and, subsequently, to the three Drainage Ditches and Old Momson
Creek. Most of the waste water appears to have been generated by electroplating operations at
the Depot. These electroplating wastes are listed as FOO6 wastes under the Resource
Conservation and Recovery Act (RCRA) (40 CFR 261.31).
5.2
Evaluation of Primary Contaminants
,
Soil sample analytical results indicate that heavy metals are present in surficial soils of the
Oxidation Lagoons. Seventeen metals were detected in at least one sample of the Oxidation
Lagoons soils; each of these plus five additional metals were detected in at least one sample
from the Drainage Ditches and Old Morrison Creek. The estimated volume of affected soil at
the Oxidation Lagoons is approximately 12,000 in-place cubic yards (cy). The estimated
volume of affected soil at the Drainage Ditches and Old Morrison Creek is 3,500 in-place c:y.
The 22 metals detected are:
E27:92-13.DOC
Vel"5ion 3, Page 9 of Part II
September 15, 1m
-------
.-
Aluminum
Antimony
Arsenic
Barium
Beryllium
Boron
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Vanadium
Zinc
100
5
85
100
59
71
84
-(2)
100
100
100
77
100
3
8S
100
71
83
56
100
100
93
100
100
97
100
100
17
100
83
3
29
100
100
100
o
100
100
100
75
2S
(2)
100
100
100
(2)
100
(2)
(2)
2S
100
100
o
o
100
100
54
100
100
'0
63
100
100
(1) = Percent is calculated by dividing the number of times detected by the total number of
samples. The total number of samples ranges from 28 to 62 for Oxidation Lagoons,
and from 5 to 34 for Drainage Ditch~ and Old Morrison Creek.
(2) = Not analyzed
Many of these metals are naturally occurring in the soils at SAAD. Therefore, the area around
the Oxidation Lagoons Operable Unit was studied to establish the normal (background)
concentration of each metal. Eleven of the detected metals were identified above background
levels: antimony, arsenic, cadmium, chromium, cobalt, copper, lead, mercury, nickel, silver,
E27:92-13.DOC
Version 3, Page 10 of Part U
September IS, 1992
. .
-------
and zinc. A list of these metals, the percentage of times each was detected, the range of
concentrations reported by the analytical laboratory, the range of background concentrations,
the relative mobility of each metal, and its classification as a carcinogen or non-arcinogen,
are presented in Table 1.
5.3
Location of Contaminants and Potential Routes of Migration
The estimated lateral extent of contamination in the Oxidation Lagoons is shown on Figure 3.
The extent was estimated based upon the postulated maximum operating water levels in the
lagoons, as approximated from topographic surveys. Contamination appears to extend
laterally to the intermediate level of the berms which surround each lagoon. The lateral extent
of contamination in the Drainage Ditches is approximately 6 feet wide, and extends along the
total length of the ditches. The lateral extent of contamination in Old Morrison Creek is about
30 feet wide, and extends from approximately 50 feet east of the east Drainage Ditch to
Caroline Drive. Based upon soil sample analytical results, metals contamination in the lagoons
is concentrated in the upper 2 feet of soil (Figure 4). The vertical extent of contamination in
the Drainage Ditches and Old Morrison Creek is about 3 feet.
Since metals are present in surface soils, airborne migration could occur in windblown dust
Individuals on site could be exposed via inhalation of the dust, or by directly contacting
surface soil during outdoor activities. Individuals off site could be exposed to windblown
dust.
Groundwater, which is at a depth of about 80 feet beneath the unit, has not been affected by
metals from the Oxidation Lagoons. In the future, the metals could dissolve in infiltrating
rainwater and migrate downward to the underlying groundwater, and a resident or business
having a well downgradient of the unit could be exposed. However, contaminants have only
been detected in the top 18 to 36 inches of soil, which suggests that the potential for mobility
into groundwater is low. A numerical mobility assessment was performed to estimate future
movement of metals at the site. This assessment indicated that the contaminants will move
approximately 2 to 6 feet vertically downward over the next 100 years.
E27:92-13.DOC
Version 3, Page 11 of Part n
September 15, 1992
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TABLE 1
SUMMARY OF CONTAMINANTS
OXIDATION LAGOON OPERABLE UNIT
':':,;, ,:':
,!iiii!!',:I~,~~';~'!i!i!::'!:!!!ili!!i,ii!!!i!'!i'i!!!"i!,'i'!I~i~!:i,i!,:,!!!:!!!!'i'i"!:,!!,,~1..~1~(~~~j!'!!!ili"!!!:!!"!",!i'!i,!!!I"!!!:"!i!i!,,I!, ,!,,:,::,'C~d~": "",i.,
... .~:~:).m~:~~\.j{.~.:~::::::~{t:~;~r );r~:;~~~;~)}~~~jt~r' ;,;.:.:.:-;.: :';'. :.:.:.:.:.;.;" .. '::':;:':':':':':;:':'::::':":".. .
"ci6;;i~~~~e~
.',',""
""'>:.- ...
""""..",..',
..
....
....
,:': "'O~ldati~' , """Obn.l':d'inM"~.L,e..'.~.<'i,;,tc.;.;,.;hc';'.'l.':.'~,;,....':'..,;:',," .h'!;;'~~~:"
:.'!;;~~g~~;::!.; "IIIDVU ,-.i'ConCentfttiorii
. .. "'
."...","."':':.:.':'.. ".,.:':'::': .".'.':'::.':
. . '
......... ... ............
.. D~ri~g~:bithh~'&:; .
Old Morrison Creek: .
.. ' : ...,,'
: ,
<4-5.3 <4.2
I 1-40 2.2 - 4.6
<0.69-298 <0.68 - 6.8
20-320 28 - 38.9
< 10-23 8.5 - II. 3
12-297 14.8 - 24.1
4.4-135 5.1-11.3
<0.05~.42 <0.1-0.1
12-165 20.2 - 25.9
<0.23-14 <0.24
24.4-456 25.8 - 34.6
Antimony 62 34 5 3 <3.8-397
Arsenic 62 34 85 85 1.5-40
Cadmium 62 34 84 56 <0.53-1,960
Chromium 62 34 100 100 20-2,340
Cobalt 28 29 100 93 5.3-18.2
Copper 54 34 100 100 16.7-1,230
Lead 62 32 77 97 <5.3-1,460
Mercury 54 29 54 17 <0.1-3.46
Nickel S4 34 100 100 20-416
Silver 54 34 63 29 <0.22-54
linc 62 34 100 100 27.4-10,900
(1) mglkg "" milligrams per kilogram
(3) NC "" Non-carcinogen
(4) C "" Carcinogen
BMSl3-tablol
J
ReiatiVe'
Mobility. Toxicity
,. in Soil.. characteriutiOn
.
low
low
low
low
low
low
low
low
low
low
low
.
NC(3)
NC, C(4)
NC,C
NC
NC
NC
NC,C
NC
NC
NC
NC
March 31, 1992
-------
~ ;PPROXIMATE SCALE 1-.100'
N - 200
OLD i
; / ~/#.f/&-9$;;;;;!{ c To 100 Sew ~..:
_.:&/ / /?%~Clr
\ ~~/
\ d~~
\ ;t'*
\ J:~*
\ ------ DRAINAGE DITCHES 1 ~#~._-.....
~ z ,
\ J '
\ ~
\ ~
\ z
-..
,
~:':'-.'':I
t.
8
,
I
OXIDAiiON LAGOONS AREA
LEGEND
c:::=J LOCATION OF CONTAMINATION
EZZZJ LOCATION OF CONTA~.HNATION
EXCEEDING CLEANUP LEVELS
A'
+ CROSS SECTION LOCATION
A
A
I
"",----_J
[-~ K LEI /'\ F EL D E R
HORiZONTAL EXTENT 0;: CONTAMINATlON F,:;c~;
OXIDATlON LAGOOt{S OPERABLE UNIT
SACRAMENTO ARMY DEPOT
SACRAMENTO. CALIFORNIA
3
::;::~:~7 ....~
2':-' 50028-A06
-------
ijf 45
~
t;j 40
w
u.
~ 35
~
~ 30
>
~. 25
w
ijf 45
~
t;j 40
w
u.
~ 35
~
~ 30
>
~ 25
w
A
B
'." ,'.
. .
..., ..
..'" .
! .~
,". '." ,", ~ .{ ,", "
. . . . . .
.. ." . .
.. . ..
," .... .' ," " .. d' . .
'.... ,".,'.'"'' .'.:.
APPROXIMATE HORIZONTAL SCALE: 1-. 100'
APPROXIMATE VERTICAL SCALE: 1-.. 20'
o ~o
-
5 I ~ 100
.. ~'0 """,."""
SAAD13
HI
PROJECT NO.
FACING NORTH
A'
...
../.../:../ ,/ :(:.,,/:.7-
. t;
.".," .....{ ,;,/,,"':.;(':,,"".., ":/;",:,"'..{'..;..:".-(...:::';':., ":.;:",.:.:'",, " "".'
-....
FACING NORTH
B'
""",..,./.:::.-
. ..
. .
.......
.. .
LEGEND
1::::I}Wgj:] LOCATION OF CONTAMINATION
tr///~ LOCATION OF CONTAMINATION
EXCEEDING CLEANUP LEVELS
45 ~
40 tu
w
u.
35 ~
~
30 ~
>
25 ~
45 ~
40 tu
w
u.
35 ~
~
30 ~
>
25 ~
VERTICAL EXTENT OF CONTAMINATION FIGURE
CROSS SECTIONS A-A' & B-B'
OXIDATION LAGOONS OPERABLE UNIT 4
SACRAMENTO ARMY DEPOT
SACRAMENTO, CALIFORNIA
KLEIN FELDER
24-150028-A06
-------
6
SUMMARY OF SITE RISKS
6.1
Human Health Risks
As part of the OUFS, the Army prepared a baseline PHE. This PHE was prepared to
estimate, in the absence of remedial action (i.e., the 8No Action8 alternative), the potential
future risks to human health by contaminants remaining in soil or leaching through soil,
migrating in groundwater, or released to the air. Table 2 presents 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. Eleven metals of potential
concern were identified above background levels and appeared to originate from the Oxidation
Lagoons, Drainage Ditches, and Old Morrison Creek. The PHE estimated the risk posed by
all 11 metals. The following three metals are the primary chemicals of concern based on the
estimated health risks and on the frequency of detection:
Arsenic:
Classified as a Group A carcinogen (known human carcinogen)
Cadmiwn: Classified as a Group BI carcinogen (probable human carcinogen, limited human
data)
Lead:
classified as a Group B2 carcinogen (probable human carcinogen, no human data).
The most notable effect of lead exposure is decreased neurological development in
children.
6.1.2 Exposure Assessment
Four exposure points were considered for the PRE:
.
a hypothetical residence constructed on site at the Oxidation Lagoons following
closure of SAAD;
.
a hypothetical residence constructed on site at the Drainage Ditches and Old
Morrison Creek following closure of SAAD;
E27:92-13.DOC
Venion 3, Page 12 of Part n
September IS, 1992
-------
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 (HHl): An EPA method used to assess the potential
noncarcinogenic risk. The ratio of the CDI to the chronic RID (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
CDIIRfD 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 (RID): 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 judgemen~ 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.
EMS 13-0L T ABLE2
October 9. 1991
-------
.
the nearest off-site business downgradient from the Oxidation Lagoons operable
unit which has a well; and
.
the nearest off-site residence downgradient from the Oxidation Lagoons
operable unit which has a well.
The first two exposure scenarios were selected because SAAD is scheduled to close in the
future and the site could be re-zoned and used for residential development. Future residential
development is considered unlikely, but is a hea1th-conservation assumption. The latter two
exposure points presently exist. The approximate locations of the current off-site receptors are
shown on Figure 2.
Metals from the Oxidation Lagoons do not appear to have impacted groundwater quality to
date. For the PHE, however, the assumptions were made that: metals may migrate into the
underlying groundwater as components of leachate at some time in the future; metals present
in surface soils may enter the atmosphere in windblown dust; and individuals located on site
may directly contact soil. Thus, the following potential exposure pathways were considered:
soil ingestion, dermal absorption, drinking water ingestion, and inhalation of dust for on-site
individuals; and ingestion of drinking water and inhalation of dust for off-site individuals.
Metals detected in the top six inches of soil were assumed to pose a potential risk because the
concentrations are greatest near the soil surface. Analytical results for soil samples collected
within the four Oxidation Lagoons and along the Drainage Ditches and Old Morrison Creek
were used to calculate average and upper-bound concentrations for each of the metals found
above background concentrations. The calculated upperbound concentration for each metal is
the 95 % Upper Confidence Limit concentration, calculated by finding the arithmetic mean and
adding two times the standard deviation. Upper-bound soil concentrations were used for
calculating exposure point concentrations for direct contact with contaminated soil, and
inhalation of dust. Estimated exposure point concentrations of the three primary metals of
concern in soil and in fugitive dust are shown on Table 3.
Upper-bound groundwater exposure point concentrations were estimated based upon soil
concentrations, physical and chemical properties of the metals, physical characteristics of the
uppermost water-bearing zone, and net precipitation inf11tration at the site. Upper-bound metal
con~entrations in the contaminated soil were input to a vadose zone model to derive upper-
bound leachate concentrations. It was assumed that the source concentrations stayed constant
E27:92-13.DOC
Version 3. Page 13 of Part n
Sep1ember IS, 1992
-------
TABLE 3
ESTIMATED ESPOSURE-POINT CONCENTRATIONS(l)
OXIDATION LAGOONS OPERABLE UNIT
Chemical Oxidation Lagoon Resident(3) Off-site Business(3) Off-site Residence(3)
. ... .... ... ... ..
FUGITIVI!: DUST~.OXIDATION iAGOt)NOPERABLEl!Nrt.~~xpoSU~ POINT CO~CENi'RATION (mg/in3)(2) .
Arsenic 2.0x 10-7/2.Ox 10-7 1.lxlO-8/5.OxlO-lO 5.3xl0-9/2.6xlO-lO
Cadmium 1.0xIO's /1.9xl0-6 5.4xl0.7/4.8xl0-9 2.6x 10-7/2.4x 10-9
Lead 4.3xlO.6/9.1xl0.7 2.3xl0-7/2.3xl0.9 1. 1x 10.7 /1.2xl0-9
GROUND WATER- OXIDATION LAG0o.N OPERABLE UNiT. EXPOSURE POINT CONCE.i'rI1tAT10N (ppm)(4)
Arsenic 0.008/0.0023 1. Ox 10-9 /2.0xl0-10 < 1.Oxl0'tO / < 1.OxlO.lO
Cadmium 8.3/0.39 3.8x 1 0.3 /1.5xlO-3 <7.6xlO-4/ <3.OxlO-4
Lead 0.026/0.014 < 1.0xl0-1o / < 1.0xlO.lO < 1.OxlO-lO / < 1.OxlO-lO
DERMAL CONTACT, SOIL INGESTION . OXIDATION LAGOONS OPERABLE UNIT. EXPOSURKPOINT CONCENTRATION
(ppm)(4)
Arsenic 9/13 No Exposure No Exposure
Cadmium 449/122 No Exposure No Exposure
Lead 194/58 No Exposure No Exposure
(1)
(2)
(3)
(4)
Assuming no site cleanup.'
mgfni3: milligrams per cubic meter
The first number shown is the exposure-point concentration due to the Oxidation Lagoons. Thc second numbcr is the cxposurc-point conccntration duc to Old
Morrison Creek and the Drainagc Ditches.
ppm: parts per million (equivalcnt to milligrams pcr litcr in water or milligrams per kilogram in soil)
-------
over time (i.e., leaching of metals does not deplete the source). The calculated leachate
concentrations were then used to estimate the on-site upper-bound groundwater concentrations
directly beneath the lagoons, the Drainage Ditches, and Old Morrison Creek. These
groundwater concentrations were assumed to remain constant over a 7o-year exposure period.
A groundwater transport computer model was used to estimate upper-bound groundwater
exposure concentrations off site. Estimated upper-bound exposure point concentrations of the
three primary metals of concern in groundwater are shown on Table 3.
,
The contaminant intake equations and values chosen for various intake parameters were
derived from the standard intake equations and data presented in EP A guidance documents.
Chronic Daily Intake (CD!), the amount of each chemical that could be inhaled, ingested, or
adsorbed, were estimated in the PHE. The estimated CDIs are shown on Tables 4 and S. The
CDIs were then multiplied by chemical-specific slope factors (SF) to calculate carcinogenic
risk. The SF represents the 95 percent upper oonfidence limit (UCL) value of the probability
of a carcinogenic response per unit intake of a oontaminant over a lifetime (70 years for the
analysis in the PHE). SF values for arsenic and cadmium are presented in Table 4. No SF
has been established for lead. Therefore, lead is not included on Table 4.
.~~,~
To calculate the Health Hazard Index (HHI) for non-carcinogenic risks, the CDIs were
multiplied by chemical-specific Reference Dose (RID) values. The RID values for a substance
represent 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).
RIDs for the arsenic and cadmium are shown on Table S. U.S. EPA Health Criteria are not
available for lead at this ti~so lead is not included on Table 5.
6.1.3 Summary of PRE Results
The PRE estimated the potential non-carcinogenic and carcinogenic risks posed by each of the
11 metals of concern at the Oxidation Lagoons Operable Unit to Future On-site Residents, and
to the nearest Off-site Residence and Business. (Dose-response criteria are not available for
two of the metals, oobalt and lead. These metals were evaluated separately). .
Carcinogenic risks were estimated for arsenic and cadmium by multiplying the CDI of each
metal by its SF. The carcinogenic risks for arsenic and cadmium, expressed as the .potential
excess cancer risk", for each exposure pathway are shown on Table 4. As a National goal, the
EPA's target risk range is 10-4 to 10-6, or one additional incidence of cancer per 10,000
E27:92-13.DOC
Version 3, Page 14 of Part II
September IS, 1992
-------
TABLE 4
CARCINOGENIC RISKS
OXIDATION LAGOONS OPERABLE UNIT
.., ..CDt .1\. .,... . . . .
Exposure . CbI.:. . adj. for. 'Slope FaCtor
Pathway . C~emical. .\.:(ii1glk~~~~y.>.. ..::.:a.bs9.rptIo~i:...:J~g/kg~day)..
OXIDATION LAG66N.S:;~~IDE.~:;f:..:::::.:{.:.::
Soil Arsenic 1.3xlO-~
Ingestion Cadmium 6.8x10-
Dermal Arsenic 1.6xI0-~
Absorption Cadmium 7.9x10.
Ground Water Arsenic 2.3x10.i
Ingestion Cadmium 2.4x10.
Soil/Dust Arsenic S.7x10-~
Inhalation Cadmium 2.9xI0-
Weight..:... ,::::Slope
. of. .. Fattot .
E.vi~.eIic.~.:. ....S:()u.rce!J3asis .
...
...;. .... /'.. .>.;.:.::. ::.. ... ,","... ',.."' :.:.:.:.:.,..,..
... .. ... .. .
..-. ...... -,.
N 1.8x100 A NA~~~
N NA D
Y 1.8xlOo A (5)
Y NA D NA
N 1.8x100 A (3)
N NA D NA
Y l.SxlO-1 A ~~~
N 6.lxlOo BI
II
..
Cheriiica1 Total Total
.. SKecific . Pathway Ewosure
. isk2 Risk2 isk2
.. :
2.OxI0.5 2.OxlO-5
3.OxI0.6 3.OxlO-6
2.OxlO.4 2.0x 1 0-4 2.4xlO-4
9.OxlO.7 2.OxlO-5
2.OxlO.5
DRAINAGE DITCHES & OLD MORRISON CREEK RESIDENT
:
Soil Arsenic 2.OxlO.5 N 1.8xlOo A (3) 3.OxlO.5 3.OxlO-5
Ingestion Cadmium 1.9x10-4 N NA D NA NA
Dermal Arsenic 2.3xlO.~ Y 1.8xlOo A (5) 4.OxI0.6 4.0xI0.6
Absorption Cadmium 2.2x10. y NA D NA NA 1.2x 1 0-4
Ground Water Arsenic 6.6xIO.~ N 1.8x 1 00 A (3) 8.OxlO-S 8.0xlO.S
Ingestion Cadmium 1.1x10. N NA D NA NA
Soil/Dust Arsenic 5.9x10.~ y l.SxlO.1 A ~~~ 9.OxlO.7 3.9xI0.6
Inhalation Cadmium 5.5xlO. N 6.lxlOo BI 3.OxlO-6
g~
m
Group A chemicals are known human carcinogens; Group BI chemicgls are probable human carcinogens.
These risks represent potential excess cancer cases. A risk of 1.OxIO. 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.
U.S. EP A, 1990a
Not Applicable, contaminant is not a carcinogen via specified exposure pathway.
Derived from ingestion value by means of r~ute.to.tOute extrapolation.
U.S. EPA, 1990a. Published SF of 5.0xlO on absorbed dose basis converted to administered dose SF under assumption of 30
percent absorption.
=
=
=
=
=
=
-------
EMS 13.0L T ABLE4
TABLE 4 (Continued)
CARCINOGENIC RISKS
OXIDATION LAGOONS OPERABLE UNIT
,....., .
..CDi ....
.. .. CD! . adj. fot :..:...Slope Paetor
CheITiicar. :(mg/kg~day) .absorpti6.ri ..(rtig/kg-day)
. . . . "" "'" ." ,"..".. ,',','", ", . '. . ", '"
NEAREST OFF~SITEBUSIN.ESS:~UEtO:6X[DATtONLAG()()~S.
Ground Water Arsenic 1.0XlO-ll N 1.8xlOo
Ingestion Cadmium 3.9xlO-S N NA
Soil/Dust Arsenic 3.7xIO.IO Y 1.SxlOl
Inhalation Cadmium 1.8xIO-8 N 6.1x10o
...
..... .
Exposure
Pathway
'. ..
... ...
. Weipht ....:.. ~~~f:r. .
. ..E,Vj~~.rtf~... .. Source/Basis
..:.
..".,..,:,,,.,,..:,...
A
D
A
BI
(3)
NA
~~~
NEAREST OFF-SITE BUSINESS DUE TO DRAINAGE DITCHES & OLD MORRISON CREEK
Ground Water Arsenic 2.0xI0-12 N 1.8xlOo A (3)
Ingestion Cadmium 1.5xlO-5 N NA D NA
Soil/Dust Arsenic 1.7xlO-IIOI Y 1.5xlOl A (63)
Inhalation Cadmium 1.6x10. N 6.lxlOo Bl ( )
NEAREST OFF-SITE RESIDENT DUE TO OXIDATION LAGOONS
. .
Ground Water Arsenic <2.9x10-12 N 1.8x 1 00 A (3)
Ingestion Cadmium 2.2xlO-5 N NA D NA
Soil/Dust Arsenic l.SxlO-~ y l.SxlOl A ~~~
Inhalation Cadmium 7.4xl0- N 6.lxlOo Bl
. . . .
NEAREST OFF-SITE RESID~N1'DpE T()DRAINAGEDITCHES& OLD MORRlSO~~ImE~ .
Ground Water Arsenic <2.9xlO-12 N 1.8xl00 A (3)
Ingestion Cadmium 8.6xlO-6 N NA D NA
Soil/Dust Arsenic 7.3xI0-11 N l.SxlOl A
Inhalation " : Cadmium ?OxlO-lO N 6.1xlOo Bl
.
Group ~ chemicals are kno,,:,n human carcinogens; Gro\!PkBlf chemTccls are probable human carcInogens.
These risks represent potential excess cancer cases. A rlS 0 1.0xlO- 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.
U.S. EPA, 1990a
Not Applicable, contaminant is not a carcinogen via specified exposure pathway.
Derived from ingestion value by means of r~ute-to-route extrapolation.
U.S. EPA, 1990a. Published SF of 5.Oxl0 on absorbed dose basis converted to administered dose SF under assumption of 30
percent absorption.
H~
m
=
=
=
=
=
=
~~~
March 26, 1m
It
..
.Chen'1.idtl. Total Total
. s~ecific Pathway Eifosure
. isk2. Risk2 isk2
,
.......
2.0XlO-U 2.Ox10.11
NA 1.0x10.7
6.0XlO-9 1.0xIO- 7
1.Oxl0-7
5.Oxl0.12 5.0xlO.12
NA 1.0xl0.9
3.0xl0- 10 1. Ox 10-9
1.0xl0-9
<5.Ox1O-12 <5.0xl0.12
\,fA 5.0xI0.7
2.OxlO-8 5.Ox10-7
5.Ox10-7
< 5.Ox 10-12 < 5.0xlO-12
NA 5.0xI0.9
1. Ox 10-9 S.Oxl0-9
4.Ox1O-9
-------
people to one additional incidence of cancer per 1,000,000 people. The aggregate (total)
estimated carcinogenic risks from arsenic and cadmium due to the combined effects of all
pathways are:
.
Approximately 2.4 excess cancers per 10,000 people for Hypothetical Future
Oxidation Lagoons Residents;
.
Approximately one excess cancer per 10,000 people for Hypothetical Future
Drainage Ditches and Old Morrison Creek Residents;
.
Less than one excess cancer per one million people for off-site businesses and
off-site residents.
Thus, the baseline risk estimated for Future Oxidation Lagoon Residents is higher than the
target range. The baseline risks for the other exposure scenarios are within or less than the
target range.
The non-carcinogenic risks posed by contaminants were estimated by computing the HHI for
each chemical in accordance with procedures established by EPA. An HHI greater than 1.0
indicates a potential health threat. The non-carcinogenic risks posed by arsenic and cadmium
are shown on Table 5. The aggregate estimated HHIs from arsenic and cadmium due to the
combined effects of all pathways are:
.
5.8 for Future Oxidation Lagoons Residents;
.
2.1 for Future Drainage Ditches and Old Morrison Creek Residents;
.
Less than 1.0 for the Nearest Off-site Business and Nearest Off-site Resident.
For lead, which may cause decreased neurological development in children, the u.s. EPA has
developed a biokinetic model for evaluating lead exposures on a site-specific basis. Using the
model, potential blood lead levels in children can be calculated and then evaluated by
comparing them to the level which the U.S. EPA estimates will cause adverse effects in
children [10 micrograms per deciliter (ug/dl)] (U.S. EPA, 199Oc).
Based upon a calculated upper-bound surface soil lead concentration of 194 milligrams per
kilogram (equal to the 95 percent upper confidence limit of the mean), the geometric mean
blood level in children (0 to 6 years old) that reside at the Oxidation Lagoons would be 4.88
E27:92-13.DOC
Version 3. Page IS or Part D
Seplember IS, 1992
-------
TABLE 5
NON-CARCINOGENIC RISKS
OXIDATION LAGOONS OPERABLE UNIT
_E~~I
.a..ll~~~1~k~J!Ex;f~'
1.3xlO~ N 1.0XlO-~ (1) 1. Ox 10-2
6.8xlO N S.OxlO- (4) (1) 7.Oxl0.1
LOx 10-3
Dermal Arsenic 1.6xl0-~ Y 1. Ox 10-3 (3) 2.OxlO-3
Absorption Cadmium 7.9xl0- Y 3.OxlO-5 (3) 3.0
Ground Water Arsenic 2.3xlO-1 N 1.Oxl0~ (2) 9.Oxl0-2
Ingestion Cadmium 2.4xlO- N 5.0xl0 ~4) (1) 2.0
1. Ox 10-3
Arsenic 5.7XI0-~
Cadmium 2.9xlO-
7 .Ix 10-1
3.0
5.8
2.1
Soil Arsenic 2.0xlO~ N 1. Oxl O~ (2) 2.Oxl0-2
Ingestion Cadmium 1.9xlO N 5.0xlO 3(4) (1) 2.OxlO-l
1. Oxl 0-
Dermal Arsenic 2.3xI0-~ Y 1.0xl0-~ (3) 2.OxlO-3
Absorption Cadmium 2.2xlO- Y 3.0xlO- (3) 9.OxlO-1
Ground Water Arsenic 6.6xlO-~ N 1.0x10~ (2) 5.OxlO-2
Ingestion Cadmium 1.lxl0- N 5.Oxl0 3~4) (1) 1.0
... LOx 10-
"
Soil/Dust Arsenic 5.9x10-~
Inhalation Cadmium S.Sxl0-
(1) = U.S. EPA. 1990a
(2) .". U.S. EPA, 1990b
(3) = Derived from ingestion value by means of route-to-route extrapolation.
(4) = Frist value is RID for cadmium in water; second value is RID in food.
EMS 13.QUabloS
2.2xIO-l
9.OxlO-1
2.1
1.0
March 31. 1992
-------
EMSI3.0LtableS
TABLE 5 (Continued)
NON-CARCINOGENIC RISKS
OXIDATION LAGOONS OPERABLE UNIT
18
CDIChemical
Exposure CDl . adj. for. ..IHb . Rft).. . . . Specific
Pathway. Cheinicai (mg/kg-day)..: absorpti.orl::..::(riigjkg-day).:: Source/Basis ::\:.:\:::'.:fiHI.
NEAREST OFF.SI~ BUSINESSDUE.T~::OXIDATI~l'l:.:t~.GOONS .. .. ::...:::.. :.:.:. .
Ground Water Arsenic 1.0XlOS4 mg/kg 1.0xlO-~ (11) 1.0dO"68
Ingestion Cadmium 3.9x10" mg/kg 5.0xlO'i ( ) 3.0dO"
1.0xlO-
Soil/Dust Arsenic 3.7xlO-l0 mg/kg -- ""
Inhalation Cadmium 1.8xlO"8 mg/kg"" ""
NEAREST OFF-SITE BUSINESS DUE TO DRAINAGE DITCHES & OLD MORRISON CREEK
..
2.0xlO-f mg/kg 1.0xlO-~ (21)
1.5xl0" mg/kg 5.0xl0-3/ ( )
1. Oxl O'
--
--
3.0XI0-~
1.0xIO-
Ground Water
Ingestion
Arsenic
Cadmium
. .
Soil/Dust Arsenic 1.7xl0"~6 mg/kg --
Inhalation Cadmium 1.6xlO- mg/kg --
NEAREST OFF.SlTE RESIDENT DUE TOOXIDATIONLAGOONS
Ground Water Arsenic 2.9xlO.~2 mg/kg 1.0XI0-~
Ingestion Cadmium 2.2xlO" mg/kg i:g~~g:3(4)
a~
<3.0x10.~
2.0xlO-
--
..
--
..
n.-
.'
Arsenic 1.5XI0'~ mg/kg -- ""--
Cadmium 7.4x10. mg/kg -- --.-
. . . .: :.. ... :... ... .. . :. ...:. .. . ..:.. ..::. ..:. .::... ..:... ... . ..:. ./:.... .. . ..: . ...:: ...:. :.:..
NEARESrOF,F..&~~:~~ID~N'F~Q~:t.~:P~I,N~P~i:P!tS~E~}k.p~Pi1.'~HItRISONS~~~L:::.::::::);:::::..:::.:....
Ground Water Arsenic <2.9xlo-~2 mg/kg 1.OxIO-~ (2) <3.OxI0-~
Ingestion" 'Cadmium 8.6xIO. mg/kg 5.0xlO-3(.4) (1) 8.OxIO.
I 1.0xIO-
Soil/Dust
Inhalation
Soil/Dust
Inhalation
7.3xlO.llA
7.Oxl0.
--
mg/kg
mg/kg
Arsenic
Cadmium
--
-.
..
--
--
!!j
U.S. EP A. 1990a
U.S. EPA, 1990b
Derived from ingestion value by means of route-to.route extrapolation.
Frist value is RID for cadmium in water; second value is RID 10 food.
=
=
=
=
March 26, 1992
Total Total
Pathway Ex~osure
HHI HI
..
3.OxlO-6 3.0xlO-6
..
1. Ox 10-6
1. Ox 10-6
2.OxlO-6
2.0xIO.6
... ,
8.OxlO-7
8.0xIO-?
-------
ug/dl due to soil ingestion. Additionally, the blood lead level in 98.12 percent of the
population would be less than the suggested U.S. EPA criterion of 10 ugldl. These results
indicate that lead in surface soils at the Oxidation Lagoons Operable Unit is a low concern
with respect to human health.
Therefore, the baseline risk assessment indicates a potential non-carcinogenic health threat to
Hypothetical Future On-Site Residents due to the metals at the site, but no non-carcinogenic
health threat to the Nearest Off-Site Business or 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 Oxidation Lagoons 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 an underestimation of risk.
Estimation of Exposure Point Concentrations - These may be overestimated since (1)
chemicals reported as "non-detects" are assigned a value of one-half the detection limit for the
purpose of calculating site concentrations. and (2) the PRE assumes that chemical
concentrations in soil and groundwater remain constant over the 70-year exposure period,
rather than decreasing as expected due to 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.
6.2
Environmental Evaluation
The SAAD site is primarily a disturbed annual grassland ecosystem. No threatened plant or
animal species inhabit the site. Several sensitive species have been observed. including the
burrowing owl. black-shouldered kite, and American kestrel.
- E27:92-J3.DOC
Venion 3. Page 16 of Part II
Scp~mber 15, 1991
-------
Remediation activities at the Oxidation Lagoon Operable Unit will disrupt the existing habitat,
including riparian vegetation present on the perimeters of the lagoons. The riparian habitat
developed as a result of the wastewater formerly stored in the lagoons. In the opinion of a
retired California Fish and Game representative who investigated the site, the lagoons are only
a passage way for animals. except for ground squirrels. Ingestion of the squirrels by foxes and
great homed owls could result in their exposure to heavy metals. This could result in death
and deformity of young. and health problems for adults. Remediation, therefore, would favor
wildlife and appears to warrant disruption of the existing habitat.
A study of plants and soils was conducted at the Sacramento Army Depot on September 6,
1991. The objective of the study was to evaluate historically wet areas to determine if they fit
the criteria for jurisdictional wetlands, as regulated by Section 404 of the Clean Water Act.
The assessment was based on the Corps of Engineers' criteria for wetland delineation: hydric
soils. hydrophytic vegetation, and wetland hydrology.
The wetlands delineation indicated that Old Morrison Creek and a small bathtub-like feature
north of the Oxidation Lagoons display the hydric soils, hydrophytic plants. and hydrology
needed to qualify as jurisdictional wetlands. The total area of jurisdictional wetlands amounts
to approximately 0.52 acre. These seasonal wetlands are isolated from other waterbodies.
The Corps of Engineers has concluded that these wetlands are not high quality and provide
minimal wetland functions and habitat value. In addition, field surveys conducted at the time
of this study and on two other occasions, NovemberlDecember 1991 and April/May 1992,
indicated there are no threatened or endangered species inhabiting the area.
The following requirements are ARARs for all alternatives:
Section 404 of the Clean Water Act, 33 U.S.C. Section 1344, requires permits for the
discharge of dredged or fill material into waters of the United States. including wetlands. The
404(b) (1) regulations (40 CPR Part 230) and Executive Order 11990. .Protection of
Wetlands.. dated May 24. 1977, require Federal agencies to avoid adversely impacting
wetlands wherever possible. and to preserve the functional values of wetlands. The nationwide
permits (NWP) program, set forth in 33 CPR Part 330 and administered by the Army Corps of
Engineers. is designed to regulate with little. if any. delay or paperwork certain activities
having minimal impacts. The types of NWPs and conditions under which a permit is granted
are given in Appendix A to Part 330.
E27:92-13.DOC
Version 3, Page 17 or Part n
September IS, 1992
-------
Because the wetlands at SAAD exhibit low wetland functional values, the Army CotpS of
Engineers has determined that the proposed fill activities-replacement of excavated soil into
the wetlands area of the Oxidation Lagoons--would result in minimal adverse impacts and is
work of a nature specifically authorized under both NWPs 26 and 38. Although CERCLA
Sec. 121(e) provides that permits are not required for activities conducted entirely on-site, the
Army Corps of Engineers has determined that the replacement of the excavated soil is properly
authorized under the terms of NWP 26, 8Headwaters and Isolated Waters Discharges8. The
wetland area proposed to be impacted at SAAD qualifies as an 8isolated water8, defined as
non-tidal waters of the United States that are: (1) Not part of a surface tributary system to
interstate or navigable waters of the United States; and (2) Not adjacent to such tributary
waterbodies. Following remediation, the Army plans to restore the impacted wetland area by
regrading and revegetating, as described in Section 1.10.
6.3
Cleanup Levels
Based upon the results of the PHE, cleanup levels were established for the three primary
metals of concern: arsenic, cadmium, and lead.
Arsenic and cadmium are the primary metals of concern due to potential carcinogenic effects.
Arsenic poses a risk as a potential carcinogen via soil ingestion, dermal absorption, and
groundwater ingestion. Cadmium poses a risk as a potential carcinogen via dust inhalation.
Cadmium also poses a risk for noncarcinogenic effects via dermal absorption and groundwater
ingestion. Specific risk numbers were not developed in the PHE for lead. However, lead is a
metal of concern primarily because it poses risks as a reproductive toxin and can effect the
central nervous system in children.
One other metal assessed in the PRE, antimony poses a risk for noncarcinogenic effects via
groundwater ingestion. Antimony was only detected in 3 of 62 samples analyzed. Therefore.
it does not appear to exist throughout the site. However, the health risk assessment assumed
that antimony is present throughout the site at an upper-bound concentration of 28 mglkg.
This concentration is less than the Federally proposed action level of 30 mglkg. Exceeding the
proposed action level could indicate that further assessment is warranted. Since this proposed
action level is not exceeded and since antimony was detected in less than 5 percent of samples
analyzed, a specific cleanup level was not established. Some cleanup of antimony will be
achieved in the process of cleaning up other metals of concern.
E27:92-13.DOC
Version 3, Page 18 of Part II
SeptA:mbcr 15, 1991
-------
Specific soil cleanup levels for other metals found above background levels were not
developed. Based upon results of the PRE, the concentrations of these metals in soil do not
pose unacceptable health risks.
The selected cleanup levels will reduce contaminant levels in soil. A list of Comparative
Criteria is provided on Table A-I, Appendix A. The cleanup levels are shown in Table 6, and
are discussed below.
6.3.1 Non-Carcinogens
Of the three primary metals of concern, only cadmium exceeds the acceptable Inn of 1.0. A
cleanup level was developed for cadmium. Additionally, a cleanup level was established for
lead for the reasons described above. The cleanup levels will result in reductions of risk by 91
percent for cadmium, and by 10 percent for lead.
6.3.2 Carcinogens
Of the three primary metals of concern, arsenic and cadmium are carcinogens. The proposed
soil cleanup level for arsenic would result in a risk reduction of 50 percent. As stated above,
the proposed cleanup level for cadmium would result in a 91 percent risk reduction.
7
DESCRIPTION OF ALTERNATIVES
An OUPS was conducted to develop and evaluate remedial alternatives for the Oxidation
Lagoons Operable Unit. Fourteen remedial alternatives were assembled from applicable
remedial technology process options, and were initially evaluated for effectiveness,
institutional implementability, and cost. Five alternatives for cleaning up soil at the Oxidation
Lagoons passed this initial screening and were then considered in detail by comparing them to
the nine criteria required by the NCP. The remedial alternatives emphasize the use of
technologies which reduce toxicity, mobility, or volume of contaminants, and which provide a
permanent solution. 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 five alternatives evaluated are:
E27:92-13.DOC
Version 3, Page 19 of Part D
Scplcmber 15, 1992
. .
-------
TABLE 6
CONTAMINANT CONCENTRATIONS & CLEANUP LEVELS IN SOIL
Contaminants +
Average"
Area
Levels
(ppm*)
Maximum
Area
Levels
(ppm *)
Cleanup
Levels
(ppm *)
Percent
Reduction
In Health
Risks
Arsenic
Cadmium
Lead
13.0
449
194
40
1,960
1,460
5
40
174
50
91
10
**
=
Parts per million (total milligrams of contaminant per kilogram of soil)
Average levels were computed by summing the results for all samples from
the site and dividing by the total number of samples, and then adding tWo
standard deviations to estimate the highest reasonable average.
*ppm =
+
=
Only contaminants with cleanup levels are included in this table.
..
EMSI3-0Jd Table 6
October 9, 1991
. .
-------
.
Alternative 1: No Action
.
Alternative 2: Excavation, On-Site Soil Washing, On-Site Treatment of Wash
Liquid, and Backfill with Washed Soil
.
Alternative 3: Excavation, On-Site Soil Washing, Off-Site Disposal of Wash
Liquid, and Backfill with Washed Soil
.
Alternative 4: Excavation, Stabilization, and Backfill with Stabilized Soil
.
Alternative 5: Excavation, Stabilization, Backfill with Stabilized Soil, and Cap
Each alternative would be applied to remediate approximately 15,500 cy of soil that contain
the contaminants detected at the site at concentrations exceeding cleanup levels. The location
and configuration of the 15,500 cy are shown in Figures 3 and 4. 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. During
implementation of each alternative, controls will be exercised to reduce the disruption to
wildlife in the area, including removal of trees prior to nesting season to encourage nesting
activity in alternative l~ns. The five 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,~ng-term monitoring of the site would be necessary to monitor
contaminant migration. Sin:c:e periodic groundwater 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.
Based upon the health risk assessment, cadmium and arsenic left on site in present
concentrations pose potential threats to public health and the environment. Specifically, the
human health risks estimated for hypothetical future residents exceed levels normally
considered acceptable. Additionally, ingestion of squirrels by foxes and great-homed owls
E27:92-13.DOC
Venion 3. Page 20 of Part 0
September IS, 1992
-------
could result in ecological exposure to heavy metals. The wNo Action- alternative therefore
does not meet the threshold criteria of protectiveness of human health and the environment.
Alternatives which do not meet this first evaluation criterion are not acceptable remediation
alternatives and further evaluation is not necessary.
7.2 Alternative 2: Excavation, On-site Soil Washing, On-site Treatment of Wash Liquid,
and Backfill with Washed Soil
,
Alternative 2 consists of excavating contaminated soil and treating it in an on-site washing
unit. Soil samples would be collected from the excavation to assess whether contaminated soil
remains. Dust created while excavating would be controlled using water or foam sprays.
The washing unit would consist of a size segregation device, mix reactors, and a de-watering
device. Oversized soil particles would be segregated using wet screens to physically remove
contaminants from the larger size fraction. The segregated lower size fraction would be
transferred to mix reactors, where it would be mixed with a washing reagent. Based upon
treatability testing results, a combination of chelating agents and dilute acid solution witli a
minimum reaction time of 30 minutes would probably be used to meet the cleanup levels.
After the soil and washing reagent are mixed for a selected reaction time, the soiUreagent
slurry would be de-watered. De-watering would be accomplished using a centrifuge or
vacuum/pressure filters. The washed soil fraction would be recovered, and the rinsate would
be stored in holding tanks for recycling. Composite samples would be collected from the
washed soil to evaluate the effectiveness of the cleanup. Remediated soil would be replaced in
the excavation.
The soil wash rinsate would be treated on site using a chemical precipitant. Dissolved metals
would be converted to insoluble forms, and would be separated from the rinsate using a
clarifier. Flocculation and settling of the metals may be further enhanced by the addition of
chemical coagulants. The sludge containing precipitated metals would be de-watered on site
and disposed at an off-site facility permitted to receive hazardous waste. Stabilization of the
de-watered sludge may be required to minimize its leaching potential.
As an alternative, the precipitated metals could be recovered at an off-site metal reclamation
unit. The decision to use reclamation will depend upon the concentration of metals in the
E27:92-13.DOC
Version 3. Page 21 of Part n
September 15. 1991
. .
-------
sludge, the total amount of sludge, the cost, and the availability of a market for metals
recycling.
Samples of the treated rinsate would be analyzed to assess its quality. Treated rinsate would
be discharged to the sanitary sewer after demonstrating compliance with SAAD's sewer use
permit conditions.
,
Alternative 2 would be protective of human health and the environment. The protection is
achieved by removing metals from the soil. The heavy metals were estimated in the public
health evaluation to present an unacceptable risk to a hypothetical future resident and were
found in the environmental evaluation to be a potential risk to predators.
Soils would be excavated and then treated until sampling and analysis indicates that the
remaining unexcavated soil as well as the treated soil contain heavy metals at either the local
background levels or at the prescribed clean-up level. Clean-up levels, as presented in Section
6.3, are soil concentrations developed for three of the heavy metals which must be met in
order for the soil not to pose unacceptable risks to human health or the environment.
Alternative 2 will be conducted in full compliance with ARARs, as listed on Table A-2. U.S.
EPA has approved the State of California's application for RCRA authorization, effective
August 1, 1992. Therefore, all Federal RCRA regulations (40 CFR Parts 262 through 268)
cited as ARARs in Table A-2 are now superceded by the corresponding State RCRA
regulations. The site-specific ARARs are California Health and Safety Code Sections 25208.1
and 25208.4 and Sections 2580, 2582 and 2524 of Chapter 15, Title 23, California Code of
Regulations (CCR). These ARARs address closure requirements for surface impoundments.
The Health and Safety Codes (also known as the Toxic Pits Cleanup Act or TPCA) will be met
by achieving closure of these surface impoundments. The sections of 23 CCR will be met by
removing the old surface impoundment structures and contaminated geologic material. The
tenn .contaminated. used in the regulation has been defined for this project by the
development of cleanup levels. Also, because the SESOIL Modeling demonstrates that the
proposed soil cleanup and residual levels will not impact ground or surface waters, these soils
can be classified as 'Inert Waste' per California's Title 23 Chapter 15, Section 2524, CCR.
However, to confirm that the actual remediated and residual soils meet the 'Inert Waste'
classification, they will be sampled and analyzed (using the deionized water Waste Extraction
Test) to verify the SESOIL Modeling results.
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State Water Resources Control Board Resolution 68-16 (the Anti-Degradation Policy) has been
incorporated into the Water Quality Control Plan for the Central Valley Regional Water
Quality Control Board (Basin Plan). The CVRWQCB has indentified this as an ARAR for all
remedial alternatives. Compliance with this ARAR requires that the quality of the underlying
groundwater must be maintained following the implementation of the soil remedy.
Compliance with the soil cleanup levels set forth in Table 6 of this ROD, and with the closure
and sampling and analysis requirements specified in the preceding paragraph, will constitute
compliance with Resolution 68-16.
,
A number of action and chemical specific ARARs have been identified for this alternative.
The action specific ARARs will be achieved by the remediation contractor taking the necessary
actions to comply. Chemical specific ARARs will be met by designing the remediation system
for achieving the desired result and monitoring for compliance.
The soils at the Oxidation Lagoons contain both RCRA listed FOO6 waste and characteristic
hazardous waste (arsenic and mercury which exceed their toxic characteristic values).
Replacement of the excavated soil after treatment would require compliance with RCRA
ARARs for disposal of hazardous waste, including the land disposal restrictions. The RCRA
Land Disposal Restrictions (LDRs) are ARARs for all remedial alternatives.
Alternative 2 would comply with LDRs through either the treatment standards in 40 CPR
268.41 (now 22 CCR 66268.41) or a treatability variance under 40 CFR 268.44 (now 22 CCR
66268.44). Existing treatability study data do not conclusively demonstrate that the lDR
treatment standards can be attained. Thus, prior to full scale implementation of the soil
washing remedy, a pilot test will be conducted. If the pilot test shows that the treatment
standards (268.41) are not achievable, the alternative treatment levels shall apply through a
treatability variance under 268.44.
In complying with LDRs, the following items are -to be considered-:
- EPA's Superfund LDR Guide #6A, Superfund Publication 9347.3-Q6FS .
- OSWER Memo, Lowrance to Luftig, April 6, 1990.
As set forth in the Lowrance memo, Minimum Technology Requirements (MTRs) for land
disposal of RCRA restricted waste would not be triggered by placing the treated soil back into
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the excavated Oxidation Lagoons area as long as there is no lateral expansion of the original.
areas of contamination.
7.3 Alternative 3: Excavation, On-Site Soil Washing, Off-Site Disposal of Wash Liquid,
and Backfill
Alternative 3 consists of excavating contaminated soil and treating it in an on-site washing
unit. Alternative 3 is identical to Alternative 2, except that the rinsate generated during soil
washing operations would be treated off site.
Compliance with ARARs would be the same as described for Alternative 2 and as stated in
Table A-2, except that the wash water will be disposed off site. As noted on Table A-2, 40
CPR 403 is applicable for Alternative No.2 only since Alternative No.3 would not use
disposal to the regional P01W. Otherwise, Table A-2 applies to both alternatives.
The wash water would be subject to the same regulations as the heavy-metal containing sludge
which is produced for offsite disposal or recycling. The wash water will be analyzed to
determine the appropriate disposal methods and requirements.
7.4
Alternative 4: Excavation, Stabilization, and Backfill with Stabilized Soil
Alternative 4 consists of excavating and stabilizing contaminated soil. Stabilization would be
accomplished using pozzolanic-based additives, such as Portland cement. Pre-determined
quantities of cement, silicates, and water would be mixed and added to the soil. The mixture
would be homogenized in mix drums and allowed to cure. Alternative mixing and curing
procedures, including in-situ procedures, are feasible.
Stabilization depends on developing a suitable -mix design- or recipe for soil, cement, and
other additives. With a proper recipe, the heavy metals are immobilized in the soil mass to
meet leachability criteria. The leachability criteria, as measured by the Toxic Characteristic
Leaching Procedure (TCLP), is established at levels which are protective of human health and
the environment.
Compressive strength and permeability criteria are added to the engineering design to improve
the permanence of the remediation and reduce maintenance requirements. The soil mass, after
mixing in the additives, would be returned to the oxidation lagoons and backfilled in place.
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Verification testing would be used to ensure leachability and other criteria are being met at all
times.
The site-specific ARARs for Alternative 4 are the same as for other alternatives. Compliance
is also the same in that this remediation will close the surface impoundments. Closure will be
achieved via excavation and removal of surface impoundment structures and contaminated
geologic materials. The cleanup levels would guide excavation and the remaining,
unexcavated soil would not pose significant human health or environmental risks.
Stabilized soil would meet the criteria of an inert waste. Stabilized soil would not be
significantly leachable or pose other human health or environmental risks.
Action-specific and chemical specific ARARs will be achieved by design and contractor
adherence to the ARARs. Placement of the stabilized soil back into the oxidation lagoons will
not expand the area of contamination; therefore, minimum technology requirements for a
landfill are not applicable.
One requirement was found to be relevant and appropriate. Future site owners and operators
shall be notified of the ,&?Cistence of the stabilized soil mass. The Army shall develop a
notification procedure.
Table A-3 provides a list of ARARs for Alternative No.4.
7.5
Alternative 5: Excavation, Stabilization, Backfill with Stabilized Soil, and Cap
~.....
Alternative 5 consists of'-excavating and stabilizing contaminated soil. Alternative 5 is
identical to Alternative 4, except that the stabilized soil would be capped after it is returned to
the site. Alternative 5 would be selected if stabilized soil does not comply with leachability
criteria set for cadmium.
The cap would be approximately 5 feet thick, and would consist of vegetative and drainage
layers overlying a 40 millimeter-thick plastic liner and a clay layer. The cap would be sloped
at approximately 3 percent.
Alternative 5 would comply with the same ARARs as Alternative No.4 in the same manner as
described above. The higher leachability of cadmium is not expected to pose a significant
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human health or environmental risk. However, additional State of California regulations
would be applicable. These are 22 CCR 66264.301 (d) and (g) and 22 CCR 264.303 and 22
CCR 264.310. The feasibility study analysis provides sufficient demonstration that a liner is
not required for placement of the stabilized soil back into the oxidation lagoons.
8
.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The five remedial alternatives have been assessed using the nine evaluation criteria developed
to address CERCLA requirements. The nine criteria are:
Threshold Criteria
1)
2)
Overall Protection of Human Health and the Environment
Compliance with Applicable or R~levant and Appropriate Requirements
(ARARs)
Primary Balancing Criteria
3)
4)
5)
6)
7)
Long-Term Effectiveness and Permanence
Reduction of Toxicity, Mobility, or Volume (fMV)
Short-Term Effectiveness
Implementability
Cost
Modifying Criteria
8)
9)
State Acceptance
Community Acceptance
The following sections compare the five remedial alternatives in terms of each of the nine
criteria.
8.1
Overall Protection of Human Health and the Environment
This criterion assesses whether the alternative meets the statutory requirement for protection of
public health and the environment, and describes how risks posed through each potential
exposure pathway are eliminated, reduced, or controlled through treatment, or engineering or
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institutional controls. This criterion is based upon the findings of three other evaluation
criteria: .Compliance with ARARs8, .Long-Term Effectiveness and permanence8, and
8Short- Term Effectiveness 8 .
Each of the alternatives, except Alternative 1 (no action), would provide adequate protection
of human health and the environment. Potential risks due to groundwater ingestion and
inhalation of dust would be reduced to levels that are acceptable to the U.S. EPA and the
DTSC. Alternatives 2 through S would reduce risks by excavating contaminated soil.
Alternatives 2 and 3 treat the soil to an inert waste by washing out the contaminants.
Alternative 4 treats the soil to an inert waste by stabilization. Alternative S includes
stabilization of soil to levels that are protective of human health and the environment.
Risks temporarily posed due to the potential of increased dust inhalation exposure would be
reduced by controlling dust with water or foam sprays. Risks temporarily posed to workers
due to dermal exposure during excavation activities would be reduced by the use of protective
clothing. Additionally, workers would follow OSHA guidelines for working on an hazardous
waste site and ambient air quality would be monitored continuously.
8.2
Compliance with ARARs
Compliance with ARARs was not evaluated for Alternative No.1 since this alternative did not
meet the threshold requirement of protectiveness. Alternatives 2 through 5 were each found to
comply with ARARs. Compliance is achieved as discussed in Section 7 of this document. A
treatability variance from land disposal restrictions is likely to be required for alternatives 2
through S. The achievable treatment levels will be set by field pilot tests employing the
selected technology.
8.3
Long-Term Effectiveness and Permanence
The analysis of long-term effectiveness and permanence addresses the expected residual risk,
and the ability of a remedy to maintain reliable protection of human health and the
environment after the remedial objectives have been attained.
Alternatives 2, 3, 4, and 5 include excavation of the chemicals of concern present at
concentrations exceeding cleanup levels. Alternatives 2 and 3 include treating soil to
acceptable risk levels. Alternatives 4 and 5 include stabilization of the soil to reduce
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/,
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contaminant mobility. Each of these alternatives affords long-term effectiveness and
permanence. Alternatives 2 and 3 are more permanent than Alternatives 4 and 5, since the
contaminants would be removed from the site.
8.4
Reduction of Toxicity, Mobility, or Volume through Treatment
The analysis of this criterion addresses the anticipated performance of the treatment
technologies the remedy may employ. The analysis considers:
.
.
treatment process;
volume of hazardous material to be treated;
effectiveness in reducing toxicity, mobility, and volume of contaminant; and;
type of quantity of treatment residual.
.
.
Alternatives 2 and 3 would remove the contaminants from the site, which would effectively
reduce on-site mobility, toxicity, and volume. Alternatives 4 and 5 would decrease
contaminant mobility, which would result in a reduction in toxicity. However, Alternatives 4
and 5 would also increase the volume of contaminated material on site due to the addition of
cement or other stabilizers.
8.5
Short-Term Effectiveness
The analysis of short-term effectiveness addresses public health and environmental impacts
during the construction and implementation period. The period of time required to achieve
remediation objectives is also considered. The time required to complete the five alternatives
are as follows:
.
.
.
Alternative 1 - None
Alternative 2 - 6 to 9 months
Alternative 3 - 6 to 9 months
Alternative 4 - 3 months
Alternative 5 - 3 to 6 months
.
.
Alternative 1 is effective in the short term. The Oxidation Lagoons are secure, eliminating the
possibility of soil ingestion. The majority of the site is overgrown with vegetation, limiting
dust formation. Based upon absence of evidence of contaminant metals in soil below 3 feet or
in groundwater, downward migration of metals does not appear to be occurring.
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Alternatives 2, 3, 4, and 5 would slightly increase the potential for dust exposure during
construction activities. This could result in a short-term increase in human health risks. The
exposures would be controlled to acceptable levels and monitored.
8.6
Implementability
Implementability refers to the technical and administrative feasibility of performing the
remedial alternative. The analysis also considers the availability of necessary materials and
services. The following factors were considered:
.
.
.
t
t
t
Ability to construct the technology;
Reliability of the technology;
Ease of interfacing additional remedial technology;
Feasibility of monitoring;
Ability to obtain approvals from, and coordinate with, regulatory agencies;
Availability of treatment, storage, and disposal services; equipment and
specialists; and technologies.
Alternative 1 could be readily implemented. Alternative 4 could be readily implemented,
subject to preparation of a suitable mix design. Based upon results of the mix design
treatability studies, modifications would be required to develop a mix which would stabilize
the soil sufficiently to comply with ARARs. If an adequate mix design cannot be developed,
Alternative 5 could readily be implemented, subject to approval of the cap design.
Alternatives 2 and 3 rely on a process which has been proven in the laboratory and is believed
to be feasible. A pilot study will be conducted at the site to demonstrate the feasibility of the
process prior to full-scale implementation.
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8.7
Cost
This criterion evaluates the capital and operation and maintenance (O&M) costs, and present
worth of each alternative. The estimated costs as of August 1991 for each alternative were as
follows:
Present Capital O&.M
Alternative Worth ~ ~
Alternative 1 SO SO SO
Alternative 2 $5,020,000.00 $5,020,000.00 SO
Alternative 3 $4,556,000.00 $4,556,000.00 SO
Alternative 4 $2,574,000.00 $2,574,000.00 SO
Alternative 5 $3,800,000.00 $3,800,000.00 SO
Since all of the alternatives require less than one year to complete, the estimated costs are
capital costs. No recurring 0 & M costs are expected. These costs are estimates and actual
contractor bids may differ from the estimates. The contractor's bid for Alternative 2, the
selected remedy, is $8.9 million. The difference in cost is associated with more detailed
information presented by the contractor. The Army analyzed the contractor's cost estimate
and determined that it was fair and reasonable. It is anticipated that the contractor cost
estimate for the other alternatives would be similarly higher.
Alternative 1 is the least expensive. Alternatives 4 and 5 would cost 25 to 50 percent less than
Alternatives 2 and 3.
8.8
State Acceptance
The analysis of State acceptance addresses technical and administrative concerns of the U.S.
EPA, the DTSC, the SMAQMD, and the RWQCB relative to implementation of the remedial
alternative. The State of California has concurred with the selected alternative for the cleanup
of soil at the Oxidation Lagoons. The State of California Department of Toxic Substances
Control has adopted a Negative Declaration, pursuant to the California Environmental Quality
Act (CEQA).
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1-
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 two public comment periods, the public
requested infonnation on the results of the treatability testing, the use of Superfund money, the
effects of the cleanup on Depot wildlife, the applicability of bioremediatioD, the effects- of
rainfall, and the feasibility of achieving a lower cleanup level for lead in soil. The public did
not indicate concerns about the preferred alternative. Part ill of this ROD contains the
Responsiveness Summary from the public comment periods and public meeting.
9
SELECTED REMEDY
Alternative 2 is the remedy selected for the cleanup on the soil at the Oxidation Lagoons
Operative Unit. Tbe selection of this remedy was based upon the comparative analysis of
alternatives presented above, and provides the best balance of trade-offs with respect to the
nine evaluation criteria. The selected remedy consists of the following components:
.
excavating contaminated soil;
.
washing contaminated soil on-site to remove chemicals of concern;
.
replacing washed soil into the excavation;
.
treating soil-washing rinsate on-site;
.
disposing treated rinsate in the sanitary sewer;
.
treating and disposing of the de-watered residual sludge off-site; consisting of
stabilization and disposal in a RCRA landfill, or recovery of metals at an off-
site reclamation unit.
No air emissions are anticipated; dust would be controlled during excavation using water or
foam sprays.
The objective of the remedial action is to reduce the toxicity, mobility, and volume of
contaminants at the Oxidation Lagoons Operable Unit such that:
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.
remaining contaminant concentrations are in compliance with ARARs; and
.
human health and the environment are protected.
,
The selected remedy would cost more than the other alternatives which were considered;
however, it would meet the objectives of the remedial action most effectively. The total
estimated cost for the selected remedy is $5,020,000.00. The itemized cost estimate is
presented on Table 7. Because the remedy is expected to take six to nine months, recurring
operation and maintenance costs are not expected. Therefore, Capital Cost equals the Present
Worth of the alternative.
The selected remedy would provide short-term effectiveness, and is technically feasible. It
would provide better short-term effectiveness than Alternative 3, because the latter would
involve transporting hazardous rinsate off-site for treatment; this could temporarily increase
human health and environmental risks.
The selected remedy would provide long-term effectiveness by maintaining protection of
human health and the environment. The selected remedy would be more permanent than
Alternatives 4 and 5, because the contaminants would be removed from the site.
The selected remedy would reduce toxicity, mobility, and volume of the contaminant through
treatment more effectively than Alternatives 4 and 5. The latter two alternatives would
increase the volume of contaminated material due to the addition of a soil stabilizer.
The selected remedy is expected to comply with ARARs. A treatability variance may be
required in order to meet the Landban TCLP criterion. The ARARs for the selected remedy
are discussed in Table A-2.
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 remedy 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 or resource recovery technologies to the maximum extent practicable. Finally, the
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TABLE 7
SELECTED ALTERNATIVE COST SUMMARY
EXCAVATION, SOIL WASHING, ON.SITE TREATMENT
OF WASH LIQUID, BACKFILL
COST COMPONENT
NOTE
CONSTRUCTION
COSTS ($)
Pilot Scale Testing
Demolition
Electric Connection
Water Connection
Fences and Gates
Site Improvements
Hydroseeding
Site Restoration/Residuals Disposal
Earthwork
Excavation Verification SoiJ Sampling
Survey
Soil Washin~ System
Post Remediation Sampling/Analysis
Mobilization Bonds and Insurance (5%)
Site-Specific Safety Plan
Sampling Plan
Chemical Data Management Plan
Design Quality Control Plan
Final Design/Workplan
Soil Excavation Plan
Soil Treatment Plan
Soil Replacement Plan
Site Restoration Plan
Permit Requirements
Progress Reporting
1
2
3
3
4
4
5
6
7
8
9
10
11
12
13
13
13
13
13
13
13
13
13
13
13
CONSTRUCTION COST SUBTOTAL
Bid Contingency (15%)
Scope Contingency (15%)
14
14
CONSTRUCTION COST TOTAL
Services During Construction (6%)
TOTAL IMPLEMENTATION COST
14
Conceptual En~ineering Desi~n Cost (6%)
Document Review jConstructlon Observation
14
14
15
TOTAL PROJECT COST
EMS 13-QUable7
1
54,461
8,000
15,000
2,000
4,600
2,000
8,000
10,000
375,000
90,000
3,000
2,402,500
90,000
153,228
14,084
10,680
29,439
11,409
24,864
22,983
18,393
8,744
8,744
7,778
43.382
3,418,289
512,743
512.743
4,443,775
266.627
4,710,402
282,624
27.355
- 5.020.381
March 26, 1992
-------
ALTERNATIVE 2 NOTES:
1
2
Includes workplan preparation, sampling and analysis, soil washing tests, and repon
Includes trees and concrete valve boxes
3
Assumes electrical connection requires a transformer and the water connection a
tap to ground water treatment plant
Based on fence surrounding oxidation lagoons and staging area
4
5
6
Site improvements includes a barrier along nonh side of oxidation lagoons for laser
protection
Includes hydroseeding oxidation lagoons
Includes site restoration, water treated on-site and disposed of in sanitary sewer
Based on removing and replacing 15,500 in-place c.y. soil
7
8
Based on 66 surface samples analyzed for EPA 6010, Cd and Pb atomic adsorption,
QA/QC, report, 100% rush
9
10
Based on excavation verification survey
Soil washing system includes treatment sampling verification and wash liquid
treatment Based on 15,500 in-place c.y. soil @ SISSle.y.
11
Based on 66 3'-5' borings analyzed for EPA 6010, Cd and Pb atomic adsorption,
QA/QC, report, 100% rush
Based on 5% of construction costs excluding reports
12
13
Based on anticipated reports
Based on percentage of the construction costs
14
15
Based on 1991 dollars
EMS13-0Ltable7
March 26, 1992
2
. . .-
-------
statute expresses a preference for remedies that reduce toxicity, mobility, or volume of the
hazardous waste.
10.1
Protection of Human Health and Environment
The selected remedy would protect human health and the environment by removing the
contaminated material from the site. Risks posed by ingestion of contaminated soil and
groundwater would be eliminated. Risks posed by fugitive dust inhalation could be
temporarily increased during construction, but would be eliminated once the remediation is
accomplished. To reduce inhalation risks during construction, dust would be controlled with
water or foam sprays.
Because this remedy wilI not result in hazardous substances on site above health-based levels
(providing the variance for cadmium is granted; see Section 10.2, below), the S-year review
will not apply to this action.
10.2
Compliance with ARARs
The selected alternative complies with ARARs as listed in Table A-2. Detailed design and
pilot testing of the soil washing process has not yet been completed. When completed, the
design data will determine the exact method of compliance with certain regulations.
10.3
Cost Effectiveness
The selected remedy is cost-effective in mitigating the principle risks within a reasonable
period of time. The estimated cost of the selected alternative is $5,020,000, which is slightly
higher than the cost for Alternative 3 and about 25 to 50 percent higher than estimated costs
for Alternatives 4 and S. The no-action alternative is not acceptable since it does not protect
human health and the environment. Additionally, the selected remedy would be more effective
in protecting human health and the environment, and would be more permanent than
Alternatives 3, 4, and 5. Therefore, the estimated cost for the selected remedy is reasonable
considering these criteria.
10.4 Utilization of Permanent Solutions and Alternative Treatment Resource Recovery
Technologies
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The selected remedy represents the maximum extent to which permanent solutions and
treatment technologies can be used in a cost-effective manner at the Oxidation Lagoons
Operable Unit. Of those alternatives that are protective of human health and the environment,
and comply with ARARs, the selected remedy provides the best balance of ttadeoffs in terms
of:
.
Reduction of toxicity, mobility, and volume of contaminant through treatment:
Treatment would consist of washing soil, and adding precipitants to rinsate to
remove metals. Treatment of the soil and rinsate would reduce or eliminate the
risk to human health and the environment posed by the contaminants of
concern.
.
Long-term effectiveness and permanence: Metals, in residual sludge, would be
removed from the site, resulting in a permanent remedial solution. Resource
recovery technologies would be utilized, if economically practicable, to salvage
metals from the residual sludge.
10.5
Preference for Treatment as a Principle Element
The selected remedy sati.~,es the statutory preference for treatment as a principle element.
The principle threat to human health and the environment is heavy metal contamination in soil.
The selected remedy will reduce heavy metals concentrations through treatment, consisting of
soil washing. Heavy metals will be removed from soil-wash rinsate through treatment,
consisting of the addition of precipitants.
11
DOCUMENT A TI~ OF SIGNIFICANT CHANGES
There were no significant changes from the Proposed Plan issued in April 1992.
12
REFERENCES CITED
California Air Pollution Control Officers Association (CAPCOA), 1987, Toxics Air Pollutant
Source Assessment Manual for California Air Pollution Control Districts and Applicants for
Air Pollution Control District Permits; Interagency Working Group, CAPCOA, Cameron
Park, California.
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September IS, 1992
- . ..
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United States Environmental Protection Agency, 1986, Superfund Public Health Evaluation
Manual, EPA 540/1-86/060; U.S. Environmental Protection Agency, Office of Emergency
and Remedial Response, Washington, D.C.
, 1989, Risk Assessment Guidance for Superfund,
Human Health Risk Assessment, U.S. EPA Recommendations; U.S. Environmental Protection
Agency, Region IX, San Francisco, California.
,
, 19903, Integrated Risk Information System (IRIS);
U.S. Environmental Protection Agency, Washington, D.C.
, 1990b, Health Effects Assessment Summary Tables,
Third Quarter FY 1990; U.S. Environmental Protection Agency, Office of Solid Waste and
Emergency Response, Washington, D.C.
--------, 199Oc, User's Guide for Lead: a PC Software
Application of the UptakelBiokinetic Model, Version 0.40; U.S. Environmental Protection
Agency, Environmental Criteria and Assessment Office, Cincinnati, Ohio.
---------------------, 199Od, Policy Memorandum: .CERCLA Response
Activities and the Land Disposal Restrictions Program's Applicability at Plattsburgh Air Force
Base;" From Sylvia Lowrance, Director of Office of Solid Waste, April 6, 1990.
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APPENDIX A
ANALYSIS OF ARARs
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E2A:92-7.WKI
TABLE A-I
COMPARATIVE CRITERIA 1
iiii!ii:il~::'~::'C:~l' ..
;II~~ScJil..HR:,,!
"":"m' .... ....
[W. :mJi~lf~l~
.....
"~i"
I\~~~
Aluminum
Antimony
Arsenic
Barium
Beryllium
Boron
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Vanadium
Zinc
14,220
500 2.0
500 3.1
10,000 124
75 0.4
3.9
100 0.7
2,500 32
8,000 9.8
2,500 21
1,000 9.0
20 0.06
2,000 23
975
100
500 0.1
2,400 43
5,000 32
174
11.8
13.0
30
80
4,000
0.02
5
449.1
40
40
464.5
18.6
313.6
400
194
0.7
202.4
20
2,000
17.5
200
1,417.7
I Only soil concentration criteria are presenled since, based on the mobility assessment In Appendix J of the OUFS, sroundwater concentratioN are zero.
2 See SSFR 30798(JuIy27,199O).
, T1LC and S11.C valuel are let forlh In State of California resulatlonlln 22 CCR 66261.24. Under 22 CCR, a wllte eJhlblb the
characteriltics of toxicity, and is considered hazardoul, if it containl the listed chemical at a concentration which equals or esoced8lbTILC
or ie, using the Waste &tractlon Tesl (WBT). its concentration equaIJ or ClCCedS the S1LC.
4 Geometric mean background. If baseline concentrations or cleanup levels were above background, modeUlIIl'CIUlti \uMI lhowa that the
c:onc:entratlonsleft In loll will not Impact sroundwater.
S See Section 6.3.
Au,... U.l!19'l
-------
..
TABLE A-2
ALTERNATIVES 2 AND 3
APPUCABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARMs)
FOR EXCAVATION AND ON-SITE SOIL WASHING
Sep"mber 111, 1002
TYPE' : SUBMlmNa AGENCY ARAR :,"': .' DE9CRIPnON' ",' COMMENTsnMPACTS
Site Speclflo Reglona' Water Qual~ Callfllmla H & SC Seotlon 211208.1, - Requl..a cIoaure of a aurfaOllmpoundment - TIIla oode II appAoabla. Cloaure of tha.. aurfllOllmpoundmenta or that tha
Control Board (RWaCS) 211208.4, which oontalna huarclou. wa." and I. within a..a be ma. ..,. I. ..qulred b, law. Either cIoaure or a .a" a..a will be
1/2 mile upg.adlant from a polenllal eource of achieved under till. allarnatlwe.
drinking waler.
Action Speclflo Environmental Pro..otlon 40 Cf'A 282.10et aeq." - aeneralora who tr.al, atore, or dl,po.. of - TIIlaregUla1lon II appAoabla, The heavy metal, win be oonOlntral8d In a
Agency (EPA) huardou. wa.. a.. aubjtct to: aludge ..qulrlng management aa a huardoua wa.". TII. wa. liquid tDr
282.11 - huercloua w.... delermlnatlon Allemal"e 1 ma, be huardoua.
282.20 - manlttlllnl
282.12 - oblaln an PA 10 No.
2112.34 - accumulation 0' wa."
282.40(c),(d) - recordkHplng
Action Sp.clflo EPA 40 CFR 284.14 (a) (b) - Thla a.ctlon de.crib.a .eurtly 10 p_.nl - TIIla ..gulallon II ~Plloabla and the Contractor wtn Inotu. t,lO'tlalona In the
unknowlngenl", and mlnlmlz. unaulhorlzed Health and Sef8ly Ian and,-r Operatlona Plan to oonlrol.n .
enl".
Action Sp.clflo EPA 40 CFR 284.111 - TIIla a.ctIon apaoltlaa that an In,pactlon - TIll, ..guidon 18 ,:Ioabla. lctIecIul8d Inapaatlon, will be ouIIIn8d In the
aeh.dule be Implem.nted. oontractor'a Ope . Plan, and an In.pactlon log wtn be maintained on
.....
Action SpecHlo EPA 40 CFR 284.18 - Thl. .ectlon outline. minimum training In - TllII ..guidon 18 applloabla. Jlemecllatlon paraonnet will h- apPlOpriale
hu..doua wa." managem.nl and training.
.merg.ne, ...pon...
Action Sp.clflo EPA 40 CFR 284.31 - Thl. .ectlon ala8la that the taclllly .halt be - TIIe"JUIation 18 applloable. The taclRly'l a_~ncy "Ipon. plan ...
maintained and operal.d to mlnlml. an, out ta Iity opll8tlon protooolin tha IV.nt of are... of huardoua wa.".
unplanned auddln or non-aud.n re"aae of It la re"vant and approprla". the oontractor. Similar proloool win be
huardoua wa.". e.tabll.had In the oontraotor'. emergency "'ponae plan.
Action Speclflo EPA 40 CFR 284.U - Thl. ..ctlon .et. tDltti a 11.1 of ..qulred ..." - TIll. reguldon II apctlloabla. tha uf8ly of parlOnnel et tha taell"'. TIle
equlfment tDr .merg.ne, a88l.ta- and that oontractor wtllinolu thla equipment ona'" and In the oontractor', Hellth
mua b. on .... In the IVent of a tire, aplll, or and Sef8ty Plan.
equipment oontamlnatlon.
Action Sp.clflo EPA 40 CFR 2114031 - Thla aectlon reJUIre' "allno and prop.. - TIIla regulation Ie ap~n08bla. Routine "1IIng of equipment and maln"nanOl
maln"nanOl equipment. of the equipment wt be cIona II, tha oontractor 10 "'1118 proper ope.atlon In
an emergency.
Action Speclflo EPA 40 CFR 284.34 - Whlnlver a huardoul waa" la handled, an - TIIla regulation Ie applloabla. Contractor Ihall h- an alarm a,,"m.
pareonnel will have a_88 to an Internal alarm
aya..m.
Action Speclflo Departmant of Toxic 22 CCR 80284.112 - R.qul... p..p..allon of a oonttngenoy plan tDr - TIIla regulation II ..!want and applOprlat8. The oontI80t0r ~'rIIormlng
Subatanoaa Control the facility to mlnlmla huardato human health 'tablllzation lhaft dIVe~a oontInctl:nCYJ...M a,,,art 0' the .aldual
(DTSC) and environment from tire, .xploalon or Management Plan and a -ape 0 He and af8ly Plan tDr re.pona.to
re"a,e of huarcioul wa," to aoll, air or water. emergency ..18a..a.
Action Sp.clflo EPA 40 CFA 284.1111 - TIle ro" of the e_geno, _dln.tor (!C) II - TIIla regulation II applloabla. An EC willie aallgned who II
outlined. qualHlad and haa th8 author'" to oomm. ..IOU.OI'.
Action Specific EPA 40 CPR 284.80, - I!!merglncy prooadU"1 - outIln8cI. - The. regulatlilnl - applloabla. The oontrador will prepa.. an amergency
40 CfR 284.1110 reapon. plan.. a part of the HaaIth and Sef8ly Plan that Inoorporelea the
..qulrem.nla of thl. -ollon.
Action Speclflo EPA 40 CFR 284.114 - Sete requirement that oontrador wII propMy - TllII "Guidon II ap,""Ia. The eontracIIDI'a HuIth and 88taty Plan .hd
CR16:\ROD-OXV=R 16-4.WKl
Page 1 of'
-------
It
. '
. TYPE SUB..ITnNO AGENCY . AftAft.'::: ,.,DESCRIP110N '" '.",",.. ... .:COMMENTSIiMPAmll '.:..:.
..... . .. .,,'" ......
Aclion SPlcItIO EPA 40 CFR 284.111 - Contalnt,. muet blln good oondlllon Of tilt - TIIIt .-guidon It IIfIPIIa8b". The"""" u.d will be In good ....dlllon.
waa.. muet be managed In oompl18n08 with
IIIla.
Aclion 8plc",o OT8C 22 CCR 88284.112 - ContAlne" .hould bl u.d thet aN - TIIla IIgu1at!on It -=1Ia8b... The Chlmloal "Inagl",,", 'Ian/Rt.lclual.
oompatlb" with Iht oontlnta. "anall8mlnt Plan n .pao~ 8IIproprlata oolltAl"". tIIr an" huardoua
wa.. 1I.ldualhm Iht aoll wa.hlng prooa...
Aclion 8pecltlo OTSC" 22 CCR 88284.11S ..j - Thl. ..elion IIq~a plOpar managemlnt of - TIII8 =Ulatlon Itllflplloabll. Optn~ handllnl. tllnattrrlng and atonIOI
-:t: oontil",!! IncludiilS:PI"lng and handling 10 P- ulla will be outlined In 1M actor'. RI.ld.1 "ana"mlnt Plan.
a. "ot to caual a II a'l.
Aetlon Speclllo OT8C 22 CCR 88284.114 - W..Id" In.pactlon. of oontA""" Ia"qulrtd. - 11118 IIgulatlon 18 IIfIpllo8bll. The oontraotof wRt lnapeot""""WMId\'.
Adlon 8plc:lllo OT9C 22 CCR 88284.1711 (a) (1)) - Thl oontAlnl,. will h- a contaInmlnt a"a..m. - TIIla ..oulatlon .. 8IIplla8b18. Stolid drum. and other oontaIn8,.wIII h- a
oonWnmant .,..m a.outtlnad In tha R..ldual. "ana"mlnt Plan.
Action Sp.c",o OT8C 22 CCR 88284.118 - D.contamlnatlon or llmoval of huardoua - 11I'a .-gulllllon IIIIfIPIlo8llIl. The oontraCltOr wIII,,- and deoontamlnata
w..11 r..ld.. hm thl oo"tAln_nt a~a"m an oontAl",,. and wa.. ".ldue. ton tht ~m.nt .,..m et tht
mu.t bl oomplttl at cto.UII of thl tact Ity. oompl8tlCln of treatment of tht Oxidation Lagoon.
Action Sp.c:lllo OT8C 22 CCR 08284.182 - New tank ."..m ..Ion and Inatanatlon - 11IlalIOulatlon It IIfIJIIoabIl. The" waah~ plOoa.. wllllIwoIoM brlnolno
IIqulr.m.nt. a" outlined. tanka on a- tDr tII ment of 1M Ixoavated .. I. An, new""', will _t
tha atnIdural IIqulllmen18 of till. ..etIon.
Action SPlcltlO OTSC 22 CCR 08284.103 - Sloonda" oontalnmant and IqU~_nt tor - 11I1.IIOUIllllon It 8IIPIlo8llIl. The.. ayataml wII_t tilt .....dary
..cllon of r,"a... a""qulll tor all new oontaInrnent raqulrtmen18 a, outtIntd In thl O"'on Plan.
tank .,.lIm. un"" a varlanoa II grantld.
Action 9p.olllo EPA 40 CfR 284.104 - 11Ila ..clion d..crlbld gene,.1 op"attng - ThlallOu!ldlon It 8IIplla8b". The"1 wII be .,~ntd 10 handll tilt
r.qulrem.nl. tor tank. .,..m. oontalnlng huardou. wa..a aa .acribed In the oontractor'l p.rllttng Plan.
hazardoua waata Of othlr ma.r18la (trlatmlnt
r..glnta).
Action Sp.cltlo OTSC 12 CCRee284.11111 - Tank In.pactlon achedu18 and prooadUIII a" - 11Ila "gulatlon 18 1IfIc.loabll. The atablllatlon tank' wllbelnlpacnd
outlln.d. tIIllowing 1M. ~. They aN alao outlined In 1M oonnctor'l
"alth and Sat8ty 0 Plan.
Aclion SplcltlO EPA 40 CfR 284.tIl7 - 11111 ..clion d..crIb.. ctolU" and - Thla "gulatlon Ia 8IIPIlo8llIl. The oontraCllof wIII,,- and dloontamlna"
polt- ctoaure oa""qulrtmentl tDr ....... all tank., oqu't:"nt. and wadi "alduel at Iht oompllllDn of tIIatmlnt of
1M OIddatDn IJOOII" 8011.
Sit. Splc:lllO RWaC8 23 CC" 11112; 21124 - Thl. ,,~..tIon pnwldll CIIo.UII and - Thll"oulatlon laIlflP"b18. The oontraCllof wIIIl.0avat8 and ,,- tor
po.t- aure malnllnan08 IIqulllmen18 tor natm.nt naturalolOloglo material which II oontAmlnatad. The tIIated ...
aurfa08 Impoundment.. will b. an IMtt wa.. (par 8eotIon 11124) after atablllzatlon and win not "quill
dl.potalln . waata management unit.
TABLE A-2
ALTERNATIVES 2 AND 3
APPUCABLE OR RElEVANT AND APPROPRIATE REQUIREMENTS (ARAR.)
FOR EXCAVATION AND ON-SITE SOil WASHING
8epllmbtr tll, 1l1li1
CRt6:\ROD-OX'CR te-4.WlCt
'a" 10.1
-------
TYPE
Chamlcal Speclllc EPA
Actlon/Slta/
Chemical Speclllc
Chemical Speclllc EPA
Chemical Speclllc OTSC
SUBMlmNG AGENCY
EPA
..
TABLE A-2
ALTERNATIVES 2 AND 3
APPUCABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARMs)
FOR EXCAVATION AND ON-SITE SOIL WASHING
:.ARAft
40 CFR 288.41
40CFR 288.44
40 CFR 403
PropOlltlon 85 - Health and
8a18ly Code lectlonl 25248.8
and 25248.10
Chamlcal Speolllo Sac,amanto Metropolitan Rule 202, Section 301
Air Quailly Management
Olltrlct (SMAQMD)
CR16:\1l0D-OX'CR t6-4.WKt
. OESCRIP110N .
- Treatment atanclardl for land dllpo'" of
reltrlctld wal..
- P,ovldel fo' ane,nattia treatmant Itande,dl
whlre wal" cannot be trealed 80 the lpecHlld
leval.
- General Pretreatment Regulatlonl tor a.llllng
and new IOU,OI, of we.r pollution
- Thll Act p,ohlbltl knowing a.polu,ato a
carcinogen or reproducllveloxln. Thll Act allo
requl"l a clear warning of potenllalllgnlllcant
expo.ur...
- New Sou'OI RavIaw. The purpo.e of Ihl. Nle
II to provide for the !lvllw of new Ilationary all
pollullon louroel and to provide machanllm.
by which autho,ltll. to oonltlUct.uch IOU'OI.
may be granted without In.riartng with tha
attalnmant 0' maln.nanoa of ambllnt ai,
quality ltandard..
''''' 1 of 8
Sap.mbe, 111. 1l1li2
. COMMENTS MPACTS .
- Thlll'88ulatlon II appluOlllll, to 1M a.tInt "'at 1M pilot teat dlmonllnd81
thatlha following TClP 1Iv1'1 O8n be mat:
'~~l;::\\:::g .'fCtP:JilllIi'i'I':/tW;:,; 'WUtt'CtltiQOiYg,
Cadmium 0.088 "008
Chromium 1.2 FOO8
Lnd 0.81 "008
Nlckal 0.32 FOO8
Silva, 0.012 1"008
A,.anlo 1 0004
Marcury 0.2 000II
- "Iha pilot.." damonl1l8tl.1hat Iha aoI oannot llllra8I8d by aoI walhlng
to tha treatmant ltandard lpecltlad In 40 CFR 288.41, Iha a'" mattia
traatmant ltandardl al1alllllhid through a TraallbNIty Vwnoa un de, 288.44
lhewn below will apply:
c .tCU>'mli~) ..
Cadmium 0.2-2
Chromium 0.1-8
Nlcleal 0.8-1
Lead 0.1-1
Silvar NA
- Thl. ragulatlon II appHOlbIl 80 Ahmattta No. I. Tha contraclDr I"" meat
Iha requlramantl of th. a.lltlng _r UII pe,mlilluad to &MD. 0' Iha
contractor I"all obtain any parmltl fIom tIIa PQrw II __retanoa with Iha
app_al of POTW Pratrealmant Program. Permit. Ihan be obtalnad prior to
dllcharga of prat,aatad 8011 walh IIquldl tIIlha I.M' IAllamat~. 21.
Allaman.. No. I doel nollnolude dllcharga 80 tha PO'rW.
- Thll ragulatlon II applOlllIl. The oontractor wi! oomply by oontrolling
ai, amlillonl, provletlng adequate 1111 IICUrtly and applVpllate Ilgnlga,
anet through Impllmantatlon Of a 1111- lpaclflo _Iller Health and Sa181y
Plan.
- Tha Nle II applicable. 1M Nil 1II"ltIalthat 8ACT I"" III u.d wtl8n
PM10 amlllloni ara graatar than 0 Ib/day. 91n0e Ahmillva 2 and I win
a._d thll requirement 1M contractor I"" UII 8ACT. attain at, quality
I"nda,dl, and p,.pa,. a parmlt applloatlon tII parfo,m tha ltablllzallon
proOlII.
-------
. TYPE
Chamlcal Speclfto SMAQMD
Chamlcal Speclftc SMAQMD
Chamlcal Speolfto SMAQMD
Chamlcal Speclftc SMAQMD
CRI6:\ROD-OX'CR 16-4. WKI
SUBMlmNG AGENCY
TABLE A-2
Al TERNA nves 2 AND 3
APPUCABLE OR RElEVANT AND APPROPRIATE REQUIREMENTS (ARMs)
FOR EXCAVAll0N AND ON-SITE SOIL WASHING
.,"
., "RAR.'
P.
.. DESCRIP110N'
Rull 401
- Rlngllmann Chart
Rull 402
- Oana,aI guld8l1ne. It the .tablllzalion opa,allon
cau.a. ,al...a of contaminant. 10 the
alrno.p"r., then a ca.a-by-ca.a
de"rmlnallon 0' public nul..nce polanllal
.hould b. parfo,mad 10 va,1fV compliance.
Tha. ARAR. .ta.. thai dl.charge.", ai,
cau.lnglnlury, dalrlmenl, nul.anoa,
annoyance; 0' andanga, comtort, repo.a,
haa"h, .a18"', 0' cau.lng damaga '" bu.lne..
0' p,operty a,a prohlbllad.
Rull 403
- Fugll"a DUlt
Rull 404
- Partlcula. Matte,
Pa.,. 40fl
Sep.mbe'18,1"2
.. COMME
S MPACTS .
- Thl. rule I. atlplloabll. 'Almo.phe,1o dllcha,ge. from the 1111 from an,
IOU,ce foIhe, than unClOmblnad water Vatl0') tor a pe,lod of mo", than th,..
minute. In an, on. hou, .hall not ba .. dark or darkar In .hade a.
dealg.-lion No.1 on the Rlnglemann Chart pubU.hed by tha U.S. 8ureau of
Mine.. Nor .hallthe amlliion. ba of .uch opactty ..10 ob.cura a human
ob.arv.r'. view. or "'DII.r on acertlll8d In-.tad! opacity monlto,lng IYlllm
at a \awl.qua' to or g",aler than Rlnglemann d..lgnalion No. l' The
contracto, will be ",qulned to comply with thl. rule.
- Thl. rule I. applO8ll11 to both ahmatlva.. 111. oontralltor .haII minim_the
pollnllal tor .m'"bn. ullng8ACT. A health rI.1e a....lII8nl h.. been
conductad'" evalua" tha a!lact of fuD"wa aml.lIon. on the ",cepto" In the
vicinity of the atabllullon unit. Tha ra.ull. - Included In the '.hCHt-",m
arl8ctlvanall' ""arla to, thl. all8mallv.. The contraclor .han u. parlmet.,
monlto,lng to ¥8rIfV the .ueoallful dull conlrol mea.ure.. "the "'llowlng
valu.. a", '._ded, the contractor .hall .top dUII-ganeratad work and
undertaka a' acllon. nece...ry to allmlna" dull from 1r_lIIng 011 .1Ia:
? M8tiaf~tttr> ..... li~mS
A,..nlo 0.042
Cadmium 0.034
Coppar 35
Nlcka' 0..
Zino 311
Laad 1.11
- Thl. rule I. appRoabll, "I!very ....onabll p..08u11Dn .hat b. "a" not to
cau.a or allow the aml..bn. of fug~a dUll from being alrborna beyond the
p,operty Ana from which the .ml.lIon. orlglna". Raaeonable p,.caullon.
.haUlnclude, bul- not Imllad to atlPlyfnga.phall, 01, wall', 0' .ulllble
ctlaml0811 tor the control of du.1 0" 'Urfa08' whlctl can gwa rI.a to airborne
matter. Othar mea.u... may be "an a. atlP_ad b, tha A" Poftulbn
Control 0lIl081'. Tha contractor win be requl,ed 10 comply with thl. rule.
- Thl. rule II atlPRoabIl. 'No dll"" .haII.. m.de 10 the atme.phe",
from an, _ree. wtthlart!cu"" ma"'r In '.cell of 0.23 lI"m. pa, dry .
.tanderd cubic matar .1 1I,,1n. per dry cubic toot).' The oontractor win be
required to oomp" w thl. rule.
-------
TYPE
SUBMITnNG AGENCY
Ch.mlcal Speo",o SMAQMD
IV. ugul ,
,a
.,a
CRU:\ROD-OX'CR t6-4.WK1
TABLE A-2
ALTERNATIVES 2 AND 3
APPUCABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
FOR EXCAVATION AND ON-SITE SOIL WASHING
.. ARAR
DESCRIPT10N
Rull 405
- DUlt and cond.n_d Alma. NquINmanl..
- ThI.N" I. 8Ppllo8bll. No dlaohuoa. "*' the atmoep'*e
.han be made from any lOur08 what_r of duet or
condan..d fum..lnlotal quantnll. .x_dlngthe tollDwlrlll:
..,..
. ..
S.p.mber 15. 11102
COMMENTS MPAC S .
PROCESS WEIGHT AND ALLOWABLE DISCHARGE
Mull... dlo
-------
TYPE SUBMIT11NG AGENCY:
Slta Spaclfic Raglonal Walar Ouallty
Control Board (RWaCB)
Sita Spaclfic EPA
Action Spaclftc EPA
Action Spaclftc EPA
Action Spaclftc EPA
Action SpacHlc EPA
Action Sp.clfic EPA
Action Spacl1lc EPA
Action SpacHlc EPA
Action Sp.cHlc Dapartm.nl of Toxic
Sub,lance. Conlrol
(t)TSC)
Action SpacHlc EPA
Action Specific EPA
Action Sp.cIfIc EPA
Action Spaclflc DTSC
CR16:\ROD-OX'(:R 16-2.WKl
TABLE A-3
ALTERNATIVE 4
APPUCABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
FOR EXCAVATION AND LAND STABIUZATION
; ARAR'
. DESCRIPTION,
Call10mla H & SC Sactlon 25208.1, - R.qulr.. clo,uI. of a .urfacelmpoundmenl
25208.4. which conlllin. hazardou, wa.ta and I. within
112 mila upgradl8nl from a polantiallOur.,. 01
drinking walar.
40 CFR 284.12.
- Noll.,. r.qulr.d tor Irlln.llr of owna,.hlp.
40 CFR 284.14 (a) (b)
- Thl. .adlon ducrlba. ..curlty 10 pr.vant
unknowing anlry, and mlnlmlza unllulhorlz.d
anlry.
- Thl. ,adlon .pacHla, Ihal an In.padlon
,chadule be Implemanlad.
40 CFR 204.18
40 CFR 204.18
- Thl. ..ctlon oulll.... minimum trainIng In
hazardou. waatl. managemanl and
am.rgancy ra'pon...
- Thl. .actlon .Ia", Ihallha facility ,han be
malnl.ined and oparalad 10 minimize any
unplllnned .udd.n or non-.udden ralaa" of
hllzllrdou, Wa...
40 CFR 284.31
40 CFR 284.32
- Thl. .actlon ..1. forth a n.1 01 raqulrad .allty
aquipmenl for amargancy a..I,'anca and Ihat
mu.1 ba on ,Ita In lhe avanlof a fir.. .plll, or
.qulpmenl conlamlnlllion.
- Thl. .actlon raqulr., ...lIng and propar
malntananee of .qulpment.
40 CFR 284.33
40 CFR 284034
- Whan.var a hllzardou. wa,lIIl. handled. all
par80nll81 will hava ac.,..slo an Inlarnalalarm
,y.lllm.
- Raqul... praparallon 01 a contingency plan for
lhe facility 10 minimla hazard. 10 human haalth
and .nvlronm.nl from flra, axplo.lon, or
ralaa.a of hazardous wa... 10 ,oil, air or wal.r.
22 CCR 88284.52
40 CFR 284.55
- Tha rola of tha .margency _rdlnalor (EC) I.
oullinad.
- Emargancy pro08duraa ara oullln.d.
40 CFR 284.58,
40 CFR 204.1118
40 CFR 1M,114
- 881a raqulramanllhal oontractor will prop.'"
dl.po.. of 0' d.oonl8mlna.. equlpmenl
- New tank .y..m de.lgn and In.tallallon
requlramenl. - outlined.
22 CCR 88U..112
'a..10f4
Sap.mber 15, 1882
....
....
.,: COMM~NT9nMPACTS:...'
.......
- Thl. cod. ,. applicable. CIo,ure of the.. .1Irf'aoa Impound_nla or th.lthe
araa be made sa""s raqulrad by law. !lIher cIosura or a sa'" ar.a win ba
achlaved under thl. a""rnallile.
- ThI.raglllallon ,. nolappllcable. H_.r, II I. ralavant and apPl'I)prlal81o
nollfy fUlura own.,. or oparalor. of lhe .18 of the pru.n08 of stab iliad lOR.
- Thl. regillalion I. appncable and the Contractor will Include provl.lon. In the
Health and Sa"" Plan and,lor Op.rallon. Plan 10 conlrol.ntry.
- Thl. regulallon I. applicable. 8chedulld 1n.,.CIIIon. will... outlined In the
conlractor'. O,.rallon. Plan, and an 1n.,.ctIon log will bt malnl8lMd on
.Ita.
- Thl. ragulallon" applicable. Remedlallon I»8rlOnn.' will h- aPPlOprla..
tralnlnll.
- Tha ..gulatlon .. applicable. The lIeIIIIy'. emergency ra.pon. plan 08.'
out taellily oparallon prolooolln the tvenl of a ..Ia... of hazardou. wa...
III. r.18vanland approprla. tor III. oonlractor. Similar proloool win be
..tabll.hed In III. oonllactol'a emargency ...ponsa plan.
- Thlll.gulalion I. applicable tor the ....tyof paraonnel althe tacUlly. Th.
conlractor wllllnciudelhi. .qulprnanl on."" and In the conlractor'. Heallh
and Safety Plan.
- This ragulallon .. apfncable. Routine '''1Ino of .qulp_ntand meln.nanoa
0' the .qulpmenl wll be cion. by Ihe oonlractor 10 a....e proper op.rallon In
an am.rgency,
- Thl. regillalion I. applcable. Contractor .ha. h- an alarm .y...m.
- Thl. regulallon I. relevant and applOprlale. The oontracto, p.rto,mlng
.Iablltzallon shall davelop a oonllngency plan a. part of Ihe Ra.ldu.'
Managem.nl Plan and .18- .p.cHlc Heallh and Safety Plan tor r..pon..to
emarg.ncy relaa..a.
- Thl. ,egulallon ,. apptlolble, An I!C wlH be a..lgned who I.
qualHlad and haathe au1ho'lly 10 oommll re.our.,...
- Tha. regula.n. a.. applicable. The oontractor wit prapa.. an em.rgency
...pon. plan a. a part 0' lhe Health and Sataty Plan th.llnocrpof.le. the
requlramenta 0' 1111. .cllon.
- Thla ragulallon It applicable. The oontra"', HtaIIh and 8afIIy I'lan .hal
Inetude p_duraa thaI mutt be followed to deoonl8mln.. .qUlpment,
- Thl. regillallon It applicable. The.1 _.hlng pI'l)08.. wIIIlrwolv8 bringing
lank. on ."" fDr tr..\manl of the a._alad .011. Any new 18'" will _I
the atructurat raqulramenta of thlt . ctIon.
-------
TABLE A-3
ALTERNATIVE 4
APPUCABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
FOR EXCAVATION AND lAND STABIUZATION
TYPE' SUBMIT11NG 'AGENCY :- ARAR." "
Acllon Sp.clflc DTSC 22 CCR 88284.183
Acllon Sp.ciflc EPA 40 CFR 284. t 114
Acllon Sp.clflc DTSC 22 CCR 88284.1115
Acllon Sp.clflc EPA 40 CFR 284.1117
Sit. Sp.cHlc RwaCB 2' CCR 2882: 2824
Ch.mlcal Spaclftc EPA 40 CFR 288.41
. DESCRIPTION.
- S.cond.ry conteln_nt and .qulp_nt tor
dehtction of r.I..... ar. r.qulr.d tor all n.w
tank .y.l8me unl..e a variance Ie grant.d.
- Thl. ..ctlon d..crlb.d genaral op.ratlng
r.qulr.m.nt.tor tank. .y..m. containing
h8Z.rdou. wa.. or oth.r mel8rla'. (t,utm.nt
r.ag.nt.).
- Tank In.pactlon .ch.dule and procedur.. ar.
oullln.d.
- Thl. ..ctlon d..crlb.. clo.ur. and
po.t-clo.ur. car. requlr.m.nt.tor tank..
- Thl. r.ouiation provld.. clo.ur. and
po.t-clo.ur. maln.nance r.qulr.m.nt.tor
.urface Impoundm.nt..
- Tr.atm.nt .tandard.tor land dl.po.a' of
r..trlct.d wa...
S.p.mber 111. tll02
".
:'::'::';::::.:.:?;:: ';:::'"
",'y,',',','.'.,'''.','oV.,',
.'.i.COMMENTS MPACTS:'.:"
. ..',', ,
.....
'",:;;: ~~~:. {:~'" ': :;:'::,
u.. ...- ...
- Thl. regulation.. applicable. The tank .yetlm. will ","I the .oondary
contaln_nt requlrem.nt. .. outlln.d In the D..lgn Plan.
- Thl. regulation I. appftcable. The tank. will be ..Ign.d to handle the
huardou. w...... ..crIb.d In tha contr.ctor'. Op.r.tlno Plan.
- Thl. regulation .. applicable. The 8labllDIIon tanka will b. In.pactad
tollowlng tha.. r.qulr.m.nt.. TIIayar. at.o outtlned In tha oontractor'.
Health .nd Sataty/Op.ratlng Plan.
- TIll. regulation .. appftcable. The contractor .. remon and daoontamlna.
all tank.. aqulD-nl. and wa." re.ldu88 at the oomplellon of tr.atmanl of
tha Oxidation lagoon'. 8011.
- Thl. regulation .. app"cable. The contractor ...._ate and ,.- !Dr
tr.atm.nt naturatgeologlc malarial whlch'e oontamlna.d. The lIIatad 8011
will ba an In... wa.. (par Sactlon 2524) aftar .tablllzation and ..." nol require
d'.poulln . wa.. managemant unit.
- Th.. regulation .. apP'cable ..the .xtant thai the plllt "It cIa""'"ltrdIa
that tha tollwolng TClP leva.. 0811 be mlt:
.
~ii.tftijiiitNmm "TCtp.:'lii'll*m~}:I:i~ . W.a'" c...iiiotj.
Cadmium 0.088 "008
Chromium 8.2 "008
l.ad O.IU FOO8
Nickel 0.12 "008
SIIv.r 0.072 FOO8
A,..nlo II DOO4
M.rcury 0.2 DOO8
v
Acllon/SIt./
Ch.mlcal Spaclftc
EPA
40CFR 288.44
- Provl.. tor altamat". traatm.nt .Iandard. - "the pllol "It damon."... that tha aoI O8IInot b. tra.led by .01 _.hlng
where wa.. cannol be t'lIt.d" th. .paclftad 10 th.lreatm.nl .tandard .paclftad In 40 CFR 288.41, the alllma''''
lav.1. tr.atm.nl .tandud. ..tabU.had through a Treatability Vulan08 under 188.44
below wlft apply:
CRI6:\ROD-OX'CR 16-2. WKI
'8..10'4
Cadmium
Chromium
Nlckal
l.ad
Silver
0.2-2
0.8-8
0.11-1
0.1-1
NA
-------
. TYPE.
ChemIca' Specl1lc OTSC
SUBMlmNGAGENCY.:'
Chemical Specl1lc Sacramenlo MelropolMan
Air Oualily Managemenl
Ol.trlct (SMAQM )
Chemical Specific SMAOMO
Chemical Specl1lc SMAOMO
Ch.mlcal Specific SMAOMO
Ch.mlcal Speclfle SMAQMD
CRt6:\ROD-OX'Clll'-2. WKl
TABLE A-3
ALTERNATIVE 4
APPUCABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARMs)
FOR EXCAVATION AND lAND STABIUZATION
:.,:ARAR':
Propo.ltbn OS - H.allh and
Safely COM ..ctlon. 25240.8
and 25240.10
Ru" 202. S.ctlon 301
Rule 401
Ru" 402
Ru" 403
Ru" 404
.:..OESCRlPT10N. .'
- Thl. Act p,ohlblt. knowIng .xpo,u,. to a
carclnegen 0' r.productlve loxln. Thl. Act al.o
requlr.. a clear warning of polenllal .Ignlllcant
expo.ure..
- New Source R.vlew. Th. pu'po.e of Ihl. rule
I. 10 provide for Ih. ,evlewof n.w .Ialionary air
pollution .ourc.. and 10 prov'M mech.nl.m.
by which aulho,M... 10 con.truct .uch 8Ource.
may be granled wMhou1ln.rferlng wMh Ih.
atta'nmenlor maln.nance of amb"nl aIr
quaIMy.landard..
- Rlnglemann Chart
- Oen.ral gulMllne, If lhe .lablllzaUon operallon
cau... r.i.a.. of contaminant. to lhe
atmo.phere,lhen a c..e-by-c..e
d..rmlnation of public nul..nce polenllal
.hould b. p.rform.d 10 verify compliance.
Th... ARAR. .Ia. Ihal dl.charg.. to air
cau.lng Inlury. detrlmenl, nul.ance,
annoyance; or .ndanver comfort, ,.po..,
h.allh, ..fely, or C8ullng damlge to bu.lnall
or property Ire prohibited.
- "uglt~. Du.t
- PartlOll". Mattlr
'8ge . of4
'.p.mber 18, 'l1li2
.:;.::.:.:
- Thl. regulation ,. ac,pNcable. The contracto, win comply by controlling
Ilr .ml..lon., P'OY ding aMqual. .Ite ..curfty and applOp,lal. .Ignaga,
and Ihrough Imp" menlallon ot a .Ite- .peclflc work.r Heallh and Safely
Plan.
- Th. rule "appntab... The rule .pecltle. that 8ACT .haR b. u.d when
PM10 .ml..lon. a,. grealer than 0 Ib/day. Since Allemallv. 2 and 3 win
.xce.d Ihl. ,equl,.menl the oonlractor ."an u.. BACT, attain a', qualMy
.tandardl. and p..pa.. a permit appllcallon to p.rform the .tablllzalon
proce...
- Th'. rule "appRoable. 'Almo.pherlo d,.charge. fIom the .111 fIo," 8111'
8OU,ce (olh.r than uncomblnad wa., vapor) for a period of more than th...
mlnu.. In any on. hou, .han nol be a. dark 0' darke, In ahaM a.
M./gnliion No.1 on lhe Rlng"mann Chart publ/.hed by Ihe U.S. Bu..au of
Mine.. Nor .han the .ml..lon. b. of .uch opacity.. to ob.cur. a humin
ob..rv.r', view. or ..gl..r on acertlfl.d In-.lactl opacity monitoring .y..m
ala 1e..I.quallo or g'88I.r than Rlng"mann d"'gnallon No." The
oonlractor wm be required to comply with thl. rule.
- Thl. rule Ie applicable to both all.matlv... T11. oontraator .lIall minim" the
po.nlla' 10, .ml..ion. u.lno BACT. A health rI.k a....m.nl ha. be.n
conduct.d to ..alu.t. the .lf8ct of fugll~. .ml..lon. on the ..ceploll In the
vlclnMy of the .tabllzallon unit. Th. re.ull. are Included In th. '.hort-term
.flectlv.n...' crM.rla lor thl. all.mallv.. The oonbacto, .hall u. p.rlm.le,
monitoring to verify the .ueee..ful dull oontrol _a.u.... "\he IollowlnO
valu.. al. eX_Md, lhe oonbacto, .han .top du.t-g.n.retad work and
unMrtak. all action. n.08..a" to .nmlnal. dull from travenlng of! .Ite:
'''.W:;:::f'(:::::':tt:: 'jjOtin!
Ar..nlo 0.042
Cad,"lu", 0.034
Copp.r 35
Nlck.1 0.8
Zino 35
Lead 1.11
- T1II. rule Ie appn081118. '£V8ry reaeonab" p"08u11on .lIeII III tIIk.n not to
cau.. or lilow the .ml..lon. of fug"". du.1 from being a""om. beyond the
property line from which th. .ml.aIon. orlglnat.. A..8On.ble Pl'C8u1lon.
.haIlInCluM, 1Iu1 are not flmfl8d to applying a.phall, oil, wa"r, or .ulllble
ch.mlcal. tor the control of duato" 'Urfa08. which can gtia rI.. to alrborM
m.tter. OIh., _a.u... may be WI.n a. app_d by the Air Pollu1lon
Controf OftIoer". 11M oorrtraGtor wll be required to oo,"ply with thl. lUll.
- TIll. rule .. applloall". "No dleoharve. .lIal III made 10 the almo.phere
fro," any eource. W:£artloul8l8 "'Itter In ..08.. of 0.23 oram. per dry
.tandard oublo /ftat.r .1 oraln. p.r dry oublotoot).' The oonbactor will be
required 10 oomply thle rule.
-------
TABLE A-3
ALTERNATIVE 4
APPUCABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
FOR EXCAVATION AND lAND STABIUZATION
Septambel 15. 11102
. TYPE 5UBMIT11NG AGENCY ARAR " ', . ,. DESCRIP110N .. . .'. .COMMENT9J1MPACT9 .. :-.:.:
Chemical Specific SMAQMD Au" 405 - DUlt and conden..d rumel ,.qul,.m.ntl. - Thla rule 'a %pn08bla. No dlacha,g.,'nt!) till Itmo.ph.,.
ahall be ma fIom any 8OU,ce what_vII 0' duat or
cond.n..d rum.. In total quantlt181 exceeding the "'!lowing:
H'''' '.'.'.'.',', '''.PROCESS WE,QHT.AND'ALlOWABLE DISCHARGE,:',,:)'::':..
Man... dlodoo.o Mula.. dlodoo.o
nil obod 1111 ",lid nil obod I.. ",lid
p~ We IS III ponlevlall.n. '- Welshl porInla.. .n.
(0""" d-''' (a.o.... dlod....
per hour '-alpoloU~ per hour 1......1 potot..,
~ ..-.!
kalHr 1b1H. lralH. ..IH. Ira/H, ../H, Ira/H. ,,/H.
114 :gg :::~ t~ 3838 == 3.811 '.1U
138 3884 4.tt 0.04
180 350 0.88 1.23 4001 0000 4.28 8,38
182 400 0.81 1.34 4318 95oo UO 10.00
205 450 0.85 1.44 4545 10000 4085 10.0
227 500 0.70 1.54 8455 1 2000 4.7' 10.4
273 800 0.10 1.13 8354 14000 4.01 10.'
318 700 0.88 1.00 7273 111000 8.00 11.2
384 800 0.04 2.07 8182 18000 U3 11.5
400 000 1.01 2.22 8001 20000 11.38 11.'
455 1000 1.08 2.38 13838 30000 5.01 13.0
845 1200 1.21 2.88 18182 40000 8.32 13.0
838 1400 1.33 2.03 22727 110000 8.88 14.7
727 1800 1.45 3.10 27273 80000 8.011 111.3
818 1800 1.118 3.43 31818 70000 7.23 111.8
000 2000 1.88 3.88 38384 80000 7.411 18.4
1138 2500 1.01 4." 40000 00000 1.88 18.0
tt84 3000 2.111 4.72 454511 100000 7.88 17.3
11101 '500 2.38 11.10 00000 200000 1.27 20.4
1818 4000 2.118 11.54 138384 300000 10.2' 22.11
2045 4500 2.78 8.01 181818 400000 10.05 24.1
2273 8000 2.08 8.40 227273 800000 11.58 28.4
2500 8500 3.13 8.80 272727 800000 12.00 28.8
2727 8000 1.30 7.27 318182 700000 12.58 27.8
2055 8500 3.47 7.54 383838 .00000 12.01 28.4
3182 7000 3.04 8.00 400001 000000 13.32 20.3
340/1 7800 3.10 8.38 454848 100000o 13.84 30.0
0' 0'
-.... -.-
To ua. the lable ab_. taIIa Ih8 plO0811 _Ight p.r hour a. .uGh la "'ned
below. Th.n find thla flgu,. on the lab18, o~oa,," whlc:fllalh8 maximum
numb8f 01 kllo/l,ama or pounda at exmlam nanta which may be dlachargld
In~ thl atmoaphl,. In any on. hour. Aa an ..ample," 'A' haa a procell
which .mh contamlnantalnto the atmoaphl,. and which pro0811 181.. 3
houfl to complet., he wi" dltldelh8 .elehta," mata,Ie,.1n Ih8 .pedflo
~'Oc:lll,1n thlae..m~Ie, 7800, br3, g" nr a pro0811 ..llIhlper hour at
500 kg. The table. OWl that 'A may no dlacharge ,"011 than 3.13 kg In
an~aur during Ih8 procell, where the plO0811 weight per hour fa..
be en flJu..alnt he left hand coIumn,lh8 exaot MIght or crmMld
dllche.ge may be Interpolated. The oontraoto, will be requ d to comPIr
with thl. rull.
. . en.otlvl Auguat " 11102, all fad.,a! RCRA "/luratlon. (40 CFA Parle 282 thlOUgh 288) oiled In thl. tabla IN .upar08d.d by Ih8 OOfNlpOIIdlna .tate RCRA "aulatloll..
CRt4:\IlOD-OX'CR UI-2.WKt
'agl40f4
-------
. TYPE.. SUBMITllNG AGENCY
Site Speclflo Regional Water Quality
Control Board (RWQCS)
Site Splclflo EPA
Action Speclfto EPA
Action SplCIftO EPA
Action Splclflc EPA
Action Speclfto EPA
Action SplCIftO EPA
ActIon Speclfto EPA
Action Speclfto EPA
Action Speolflo DeClrtmlnt of Toxlo
Su .ta~. Control
(DTSC)
Action Spaclflc EPA
Action Spaclfto EPA
Action SplCIftO EPA
Action 8paclfto DT80
CRt6:\ROD-OX'(:R t6-,.WXt
TABLE A-4
. AL TERNA T1VE 5
APPUCABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
FOR EXCAVATION, STABIUZATION, AND CAPPING
.::ARAR.:
.. DESCRIPllON
..
California H & 8C Sactlon 25208.1, - Rlqulre. clo.ura of a .urfacalmpoundmant
25208.4. which contllin. hazardou. wa.. and I. withIn
1/2 mile upgradiont from a potentlalllOur08 of
drinking wlltar.
40 CFR 284.12"
- NotlO8 required for tran."r of owna"hlp.
40 CFR 284.14 (I) (b)
- Thl. .actlon ducrlba. .curlty to prl"anl
unknowing Intry, Ind mlnlmtza unluthorlzad
entry.
- Thl. .ectlon .paclfte. thai an In.pacllon
.chedu. be Imp.mlntad.
40 CFR 284.111
40 CFR 284.18
- Thl. aacllon ouiline. minimum Iralnlna In
hazardou. wa.. managemanl and
amergency rl.pon.e.
- Thl. .Icllon .Ia..lhal thl facility .h.1I be
maintained and oparatad 10 mlnlmla Iny
unplanned .uddln or non-.uddln ral...a of
huardoul wa...
40 CFR 284.11
40 CFR 284.12
- Thl. .ecllon .11. 'clfth all.t of raqulrad ....ty
aqulpmenl tor amlrgancy a..l.tance and Ihat
mU.1 ba on .Ita In the I"anl 01 a lira, .plll, or
equipment contamination.
- TIll. .ecllon Nqulra. I8.tI"g a"d propar
maln."anca olaqulpment.
40 CFR 284.11
40 CFR 284.14
- Whenever a hazardou. wa.. ,. hand.d. ad
pareo"nel will hava acca..10 a" I"tama' alarm
.y..m.
- Raqulre. preparallon of a contlngenoy plan tor
lhe facility 10 mlnlmla hazard. 10 human haalth
and environment from 111e, e.plo.lon, or
relea.a 01 hazardou. wa.. 10 .011. air or wat.,.
22 CCR 88284.112
40 CFR 284.115
- The role of "'a amargency coordlnalor (EC) I.
oulllnld.
- Emaraenoy pro08dura. aN outllnad.
40 CFR 284.118,
40 CFR 284.188
40 CFR 284.114
- Sat. Nqulramanl that contractor win propally
dl.po.e 01 or daconlamlna. aqulpment.
- Seta Nqulremenla for hazardoua wa'"
dl.poul fadlltle. including Nqunmenla tor:
- .umyplll(.118)
- po.l-elo.ure _N and u- of property
(.117)
- po.l-elo.u.. plan (.118)
- daad ra.lrletion (.11a)
- OIrtttlCIItIon of oomplit!Drl err polt-eroIU..
OlIN (.110)
12 CCR H284.11. -110
'.' 0'.
Sep.mber 111.1"2
..
...
'<:~:~;:{:::~;/~::~:::'C() U ME NTan UP ACTS :;-: :::..:;.;:;.;:.:;:.:.:;:.;; ':;;.. ';:;,.;:. ..
...
..
.. ..
- Thl. cod. I. .ppllcabll. CIo.UN of tha.1 aurfaOl'mpoundmanta or thll the
area be made .a18.. raqulrad by law. Elthar cto.UN or a aa18 aNa will ba
achlavld undlr thl. alllrnatlita.
- Thla Ngulallon II not appllc:abll. "-r..11 Nlevant end apPlOPrIat8lo
nollfy 1I.oluN owna,. or oparatol' o1tha .111 o1tha pra."08 of lOll, and that
OIIpplng ha. ocoUrNd.
- TIll. NIlUlallon I. appneabll and tha Contractor wIIIlnelude plOYllbnl In tha
Health and Sa18ly Plan and~r Oparatlon. Plan 10 controlanlry.
- TIll. Nllulatlon I. appn_ble. lohadulad In.pactlon. will be outIInad In "'a
contraclor'a Oparallon, Plan, and an In.pactlon loa will ba maintained on
all8.
- Thll raoulaIIorIll appncable. Ramedlatlon p_net will hava approprla.
Iralnlnll.
- TIIa Ngulatlon II appncable. The fadl1ty', ._rgancy N.pon- plan call.
out facility oparallon proDco"n the avanl of a Nlaa.a 01 huardou. wa...
Similar proloool will ba a.labll.had In tha contractor'l amaraanoy N.pon-
plan.
- ThI.Naulation II applicable tor h utatyo1 pa,aonMi 11th "ellty. The
conlractor will Include Ihl. aqulpment on." and In the contraclor'. Haalth
and S.18ly Plan.
- Thla NgUIat!n .. applloablt. Routtnaltttln, of .qu"'IMftt end rnaIMInanOl of
the aqulpmant wHl bI done by the contractor to a..u.. "lapar oparatlon In
an amargency.
- Thill NgUIatlon II appnOlble. The oontraolor ahall h_enalarm a,..m.
- Thl. Naulatlon II not appROIIbll but II N.."ant end approprlala. The
contraclor partormlna .tablllzalion ahall develop a contlnoancy plan a. pa" of
the lIa.ldua' Managemant Plan and ....- 'paclllo Health and Sa18ty Plan tor
N.pon. 10 amaraancy Nlaa.a..
- Thl. Ngulallon II appROIbli. An ec will ba a'llollld who III qUlllllld end
ha. the authority 10 commit Naourca..
- Tha. NgUlalbn. - applloable. The contractor will pNP- enamergenoy
N.pon. plan a.. part of the HaaIIh and 8afaty Plan thallnoorpOlIlt8. the
Nqulramanl' ofthl. .clbn.
- TIll. Ngu1at\on II appllOllbli. The contractor'l Healll! and 88tlty ,Ian .hall
Include p_duNa that mult ba tollowad 10 deconlamlnl. aqulpmant.
- The NOUIatlon. - N\avant end app"",'" due III higher mob8ly rrfllMvy
metal. "the.'" II not malntalnad. A .umyplat wII ba fIIad III cto'UN. A
~.t-cIo'UN plan will ba aubmMld. A notation on the dMd will be made
WIthin eo dap of the OIItIftOltlon of CIIo.UN. A OIr1IRoatIon of polt-cto.u..
- will ba p..p...d end propal1y .ubmllt8d.
-------
TABLE A-4
ALTERNATIVE 5
APPUCABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARMs)
FOR EXCAVATION, STABIUZATlON, AND CAPPING
TYPE SUBMITTING AGENCY ':;. " "ARAR":'" ..
Action Spaclftc DTSC 22 CCR 88284.1112
Action Spaclftc DTSC 22 CCR 11112114.1113
Action Spaclfic EPA 40 CFR 2114.1114
Action Spaclftc OTSC 22 CCA 11112114.1115
Action Spaclftc EPA 40 CFA 284.1117
Action Spaclftc DTSC 22 CCA 88284.301 (d)
Action Spaclftc DTSC 22 CCR 811284.301 (g)
Action Spaclftc OTSC 22 CCR 8112114.303
Action Spaclftc DTSC 22 CCR 882114.310
Slta Spaclfic RWQCB 23 CCR 25112: 2824
Chamlcal Spaclftc EPA 40 CFR 288.41
,'.'..
:: DESCRIPT10N:'
- New tank .y...m dulgn and In.l&lIallon
raqulramanl. ara oullined.
- Sacondery canlalnmani and aqulpmani 'or
da18clion 01 ralae.a. ara raqulrad 'or ell naw
tank .y.tom. unl... a variance I. grentad.
- Thl. .actlon deecrlbad ganerel oparatlng
raqulramant. for tank. 'V.18m. containing
huardou. wa.. or olhar ma.rlal. ("..tmant
raaganl.).
- Tank In.pactlon achadu" and proeadu..a a..
outllnad.
- Thl. .actlon da.crfba. clo.ura and
po.t-clo.ure cara raqulr.manl. 'or tank..
- Oa.lgn and oparallng ..qulram.nt. 'or landfill..
- Oa.lgn and oparallng raqulramanl. of landfill..
- Monitoring and In.pactlon 0' capping.
CIo.ura and po.t-clo'u" ca.. ..quI..mant.
'or landfill..
- Thl. regulallon provlda. clo.ura and
po.l-clo.ure malntonanee raqulramant. for
.urfaea Impoundm.nt..
- Traalmant .Ianclard. 'or 'and dl.po..1 0'
...Irlctad wa...
CJU6:\ROD-OX'CR 16-3. WKI
'aOllo'.
S.p" mbar 18, 1102
COMMENfS MPACTS:,,:
... . ....,
.;'.,..'.,. :.",',':: .
. ,
- Thl. 18gulallon ,. appllcab". The 8011 wa.hl"" plDca" wIIIlrwolva brtnglng
tank. on .'" 'or traalmanl 0' the ,xOjivatad '011. AnV new tank. will ma.t the
.Iructural requlramanl. of thl. .cllon.
- Thl. regulation Ia appROjib... The tank 'V..m. win -t the .condery
oonlalnmani 18qulremani. a. outHn.d In tha Oaelgn Plan.
- Thl. regulallon ,. appRcab". The tank. win ba de.lgnad to hand" tha
huardou. wa.", a. de.crfbad In tha conlractor'. Op.rallng Plan.
- Thl. regulation .. apC'cab... The ltabl1zatlon tank. will be In.pactad
blloWlng the. requ ramanl.. They are al.o outlined In the oontractor'.
Health and Satalv/Oparallng Plan.
- Thl. ..gulatlon .. appRcab". The oonInIctDr will ..move and dacontamlnato
all tanka, aqulpmanl, and wa." ...Idu.. at the comp..tbn of traatmant of
the Oxldallon Lagoon'. 8011.
- Thl. ..gulatlon I. ..levant and applOprla" to thl. oIo.u... The 80R
.Iablltzallon and capping win pravant the mlgrallon of h8l8rdou. oon81t1u8nt8
InD the groundwa.r or .urfaca wa.r or .urroundlng 8OH.. An axampllon I.
not ralavant or applDprtat., "-var the ..ctor. fo ba oon.lda..d. H.tod In
S.ctlon (d) 1-8. a.. ..levant and ha" baan con.lelared.
- Thl. .actlon II relevant and apPlDprlata. Storm Nnofl wi! be "'-Old by
the contractor during Raid op.ratlon..
- Thl. regulallon ,. relevant and applDprfata. Th. _r .,,,,,,, wlR ba
In.pactad b:r; the contractor a. outlined In the contractor. Oparallnll Plan 'or
uniformity. amaga, and Impartactlona.
- Thl. regulation II relevant and applDprfata. The oap wIR be da"gned and
oon.lructad to maat requlramant. 0' (a) 1-7. I'o.t- cIo.u.. care
requlrament. that will ba outlined In the pOIl-oIo.ure cara plan wHl be mat.
- Thl. regulation .. appHcab". The oonInIctDr wIIIa._ata and remova for
tr..tmant naturalg.ologlc matertal which I. contamlnatod. The treated .011
will ba ratumad to lhe oxldallon lagoon. which will b. managad a. par tha
.ub"anl"" requl..m.nt. o. a wa... managament unit.
- Thll regulation II applcablaLIo tha axtant thai the pRot talldemon.trata.
that the bllowtrlg TClP lava" can be "'at:
,COlliltlt...nt,,:{,:~:n :,:';,;:TCLP'IiiiaM :,:,,: Wa.li.CateilOrY
Cadmium 0.088 1'008
Chromium 8.2 FOO8
Lead 0.81 1'000
Nlcka' 0.32 1'008
81"'ar 0.072 FOOO
A..anlo 8 0004
Marcury 0.1 0008
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TYPE
Actlon/Sijel
Chemical Sp.clfio
Chemical Sp.clfio DTSC
SUBMITTING AGENCY
EPA
Chemical Sp.olfto Sacramento Metropolitan
Air Qualijy M.naoement
Ol.trld (SMAQMO)
Chemical Sp.clftc SMAOMD
Chemical Sp.clftc SMAOMD
Chemical Sp.clflo SMAQMO
CR16:\ROD-OX'CR 16-'- WK1
TABLE A-4
ALTERNATIVE 5
APPUCABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
FOR EXCAVATION, STABIUZATlON, AND CAPPING
ARAR
. DESCRIPTION
40CFR 288.44
- Provide. tor alternatwe treetment .tanclard.
where wa.1I cannot be treated 10 the .p.clfied
level.
PropoaRlon 85 - Health and
S.,.ty Code .ection. 25248.8
and 252411.10
Sap"mber 111, 111112
"COMMENTS MPACTS'
- Thl. rellulatlon I. appllcabll "It I. demon.tart8d that the eon cannot be
II the pilot ,"t demon.tra..a that the eoll cannot be treated by aoll wa.hlnll
to the treatment .tandard .p.clfled In 40 CFR 288.41, the a"'matwe beatment
.tanclard. e.tabll.hed through a TreatabllltyVarlanoe under fell.44 .hown
below wUlapply:
,t}co".tltiM"t~}, \tCL"'liiiilli.'
Cadmium 0.2-2
Chromium 0.11-8
Nickel 0.11-1
Lead 0.1-3
Silver NA
- Thl. Act prohibit. knowlnge.po.ure to a - Thl. regulation I. aC'PUcabll. The contractor wfn comply by controlllnll
cerclnogen or reproductIVe to.ln. Thl. Act al.o air emlnlon., prov ding adequate .... ..curlty and applVprlate .Ionaga,
require. a clear warnlno 01 potentlal.ionificant and through Impllrnenlatlon 0' a ....- .p.clftc worker H.alth and Sale",
e.po.ure.. Plan.
Rull 202, Section 301
- New Source Review. The purpo.e 01 thl. rule
I. to provide lor the review 01 new .tatlonary air
pollulion .ource. and to provide machanl.m.
by which authorltln to con.truct .uch aourcea
may be grentad without Inllrlerlng with the
altalnmant or malnllnance 0' ambllnt air
quality .tandard..
- Rlnglamann Chart
Rull 401
Rull 402
- Oenerailluidellna," the .tebUlzaton operation
ceu.e. relea.e of conteminenl. to the
elme.phare, than a ce.e-by-ea.e
dellrmln.tlon 0' public nul.nce potential
.hould be performed to verify compliance.
The.. ARAR. .ta" that dl.charga.1o air
cau.lng Injury, detrlmant, nul.anOl,
annoyance; or endangar comtort, rapo.e,
health, .a..ty, 0' cau.lng damaga 10 bu.l",a.
or property are p,ohlbltad.
Rull 403
- I'ualt~e Du.t
Ita..' of4
- The rule Ie appUcabll. The rule .peolfle. that BACT .hd be u.d when
PMtO emlilione are llreate, than 0 Ib/day. Since Altematlve 2 and 3 wilt
e.ceed thl. requl..ment tha contractor .han u.e BACT, attain air quality
.tanclard., and p..p... a pa,mlt application 10 perform the llabllluton
procen,
- Thl. rule I. appllc8bll, .Atmo.pha,1o dl.chargaa tom the a'" tom any
eourca (other than unoomblnad wa", va:r.0r) tor a period 0' more than th...
mlnu... In anyone hour .han not be a. ark or darker In .hade ..
de.lgnatlon No.1 on the Rlnallmann Chart publl.had by the U.S. BUr88u 0'
Mlna.. No, .han the emlnlone be of auch opacity a. to ob.cure a human
ob.erver'. view, or ..gl...r on acertlfled In-.tade opacity monllorlng.y..m
at a leve'equa' to or greate, than Rlngllmann de.lgnaton No. ,. The
contractor wfll be ..qulred to comply with thl. rule.
- Thle rule I. appllcabll. The contractor .ha. minim" the potential tilt
emlnlon. u.lna BACT. A health rI.k anellment ha. been oonducted 10
evatuate the efled of fualtwe emlilion. on the reDlptoraln the vicinity of the
.tablUzatlon unit. Tho ...ult. a.. Inctuded In tha ..hort-term oflecllve",aa.
criteria 10, thla allamatn. The contractor .han u. porlmete' monllorlng to
verify the aUCOle.fIIl dull control maa.ure.. "tIte tollowlna valu.. are
oxceeded, the contractor .hall.lop dull-flono,ated work and undertako an
actlone neoeaaary to ellmlnato du.t tom travelllnfl off alta:
~.....t,,))t'\t~t ..'. !iiiiiil'
ArMnlo 0.042
Cadmium 0.034
Coppe, 35
Nlcko' 0.11
Zlno 311
Lead 1.11
- Thl. rule la apploabll. 'Eftry r88aonabll pre08utlon thai be tabn not to
cauao 0' allow the omlllklna of fIIgltlilo dul1 tom being alrbome beyond the
property line tom whlcll the emlllion. orlalna". Reaeonable precaution.
ehallindude, but - not Im"'d to applvlnga.phalt. 01, wa"', or .ulllble
ahemlO8la tilt the control of dul10n aurfa08' which O8n 1118 rI8e to aIIboma
m."',. Oth., moa.ure. may be taIIO" aa applVV8d by trle AIr Pollution
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TABLE A-4
ALTERNATIVE 5
APPUCABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
FOR EXCAVATION, STABIUZATlON, AND CAPPING
8epllmbel 18. '"2
If
TYPE.
SUBMIT1lNG AGENCY
. .
':ARAR"
'''''' ...
.: DESCRIPTION'.'..':.::::
...
...
'. COMMENTS MPACTS
..
Chamlcal Spaclfto SMAQMD Rule 404 - Partlcula" Mattar - Thla rule la applicable. 'No dllhcaroaa IhaW ba mada to !ha atmolpha,.
tom any 10ur~1 wfth iart,cu,a.. mattal In al(~11 of 0.23 oraml p.r d~
Itanelald cublo matal .1 Olalna pal dry cublo foot)." Tha contractol w n be
,.qulrad 10 comply wit !hll rule.
Chamlcal Spaolfto SMAQMD Rule 405 - DUll and condan.d fum.. raqulramanll. - Thll rule fa appncable. No dlacharo.. Into the atmolpha,.
Ihall be mada tom any 80urce what_IIal of dUlt 01
condan.d fum..'" Iolal quanlltlea axceadlngtha tDfIowIng:
.... 'PROCESS::WEtOHT.ANO:ALLoWAoLEOISCHAROE'''.: .:.,
",... ..... ',,',',
lit....... 4kU,. lItuim..4i1dw,.
n" .!brlll ,.. ooM nt.t IbM 101 IOtid
'.j ~; Proceu Welthl porthl....- Proceu Wel.hl """"'''.-
.' (....... 4....,001 (........ 4....,001
! per hour 1_.lpo8ticl per hour Ir.." po8ti cI
..-I pr"""'l
..~ 111, 11.11.1. IrnlN, !h1N. IrnlN. !h1N. IrnlN. !h/lol,
114 250 O:~ T.~ 35311 8000 :1.85 8.70
138 300 0.81 1.12 3854 1500 4.11 8.04
158 350 0.88 1.21 4081 8000 4.25 0.38
182 400 0.81 1.34 431. 8500 4.40 10.00
205 450 0.811 1.44 4545 10000 4.15 10.0
227 800 0.70 1.54 8455 12000 4.73 10.4
273 800 0.78 1.73 8384 14000 4.81 10.1
318 700 0.18 1.80 7273 15000 8.08 11.2
384 lOG 0.84 2.07 .,82 18000 5.23 11.5
408 800 1.01 2.22 8081 20000 1.38 11.8
455 1000 1.08 2.31 13538 30000 11.81 13.0
045 1200 1.21 2.111 Ilt82 40000 8.32 13.8
838 1400 1.33 2.83 22727 80000 8.81 f4.7
727 1800 1.45 3.18 27273 80000 1.85 15.1
Itl 1800 1.51 3043 31818 70000 7.23 111.8
808 2000 1.011 3.118 38304 80000 7.45 18.4
1138 2500 1.81 4.21 40808 80000 7.111 111.8
1184 3000 2.15 4.72 45455 100000 7.88 17.3
1581 3800 UI 8.18 80808 200000 8.27 20.4
1818 4000 2.58 8.84 138384 300000 10.23 22.8
2045 4500 2.78 '.07 181818 400000 10.85 24.1
2273 8000 2.88 8.48 2272n 500000 11.55 25.4
2500 8500 U3 1.88 272727 1100000 12.08 t8.8
2727 8000 3.SO 7.27 318182 700000 12.55 27.8
2855 8500 3.47 7.84 383838 100000 12.81 28.4
3182 7000 3." '.00 408081 800000 13,32 28.3
3408 7500 3.10 8.38 454545 100000o 13." 30.0
or or
"'0'" "'0'"
To ula the table ab_. talla Ih8 procell _llIht plI hour a. .uch Ie dafln8d
balow. Than IInd !hll IIgu,. on thatable, o~oall8 which IIIh8 m...lmum
numbar of kiiooram. or poundl of oontam anla which may ba dracharoad
Intolha almoapha,. In any ona hour. A. an a.ample. ""A" hal a procel.
which amlla oonlaminanllinlo tha almo.pha" and which procal. "a. 3
houl8 10 oomplela. ha win d~a Ih8 ~hl 01 all ma..rlala In the lpaclflo
roca.a,1n !hll all8m~Ie, 7500, bt 3, II ~ a plO0811 _IOhl par hour of
500 lei. Thatable a owa!hat"A may n dltCh"ga mOil than 3.13 kg In
an~our durln81ha plOceli. whe,. !he plO0811 waloht par hou, 18l1a
be an IIluM.1nt lia left hand ODlumn, the a..ct _IOhl or !:'mltlad
dllchaloa ma, bllnl8rpo1ated. The oon1ractor win ba ,.qu ad to oomp"
with !hI. rule.
CRU:\ROD-OXCR U-'.WKt
"aoa 4 0'4
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