United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R09-93/087
March 1993
£EPA Superfund
Record of Decision:
Sacramento Army Depot, CA
-------
50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO. 2.
EPA/ROD/RO 9-93/087
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Sacramento Army Depot, CA
Fourth Remedial Action
7. Author(s)
9. Performing Organization Nam* and Address
12. Sponsoring Organization Nam* and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. Recipient's Accession No.
5. Report Date
03/29/93
6.
8. Performing Organization R»pt. No.
1 0 Project Taskwork Unit No.
1 1 . Contract(C) or Grant(G) No.
(C)
(G)
1 3. Type of Report & Period Covered
800/800
14.
15. Supplementary Notes
PB94-964521
16. Abstract (Limit: 200 words)
The Sacramento Army Depot site is part of a 485-acre military facility, located in the
Sacramento, California. Onsite operations include electro-optics equipment repair, the
emergency manufacture of parts, shelter repair, metal plating and treatment, and
painting operations. Approximately 3,000 people are employed at the site; however,
there are no longer any residents at the Sacramento Army Depot (SAAD) facility. Land
use is the area is predominantly commercial and light industrial, with some residential
areas located two to three miles west of the site. Morrison Creek originally flowed
from east to west through the land now occupied by the SAAD facility, but was later
re-routed to flow outside the southern boundary of the site. The creek discharges into
two overflow basins of the Sacramento and American Rivers, and ultimately empties into
the Sacramento River. Ground water contamination at the site appears to extend
approximately 1,000 feet southwest of the site; however, most industries and residences
in the area use Sacramento City water from municipal wells located at least three '
quarters of a mile from the SAAD. In 1981, as part of the Army's Installation
Restoration Program (IRP) , the U.S. Army initiated an onsite investigation that
revealed VOC-contaminated ground water in the southwest corner of the site. Based on
the location of the VOCs in the ground water, two burn pits appeared to be the main
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Sacramento Army Depot, CA
Fourth Remedial Action
Contaminated Media: soil, debris
Key Contaminants: VOCs (PCE, TCE, toluene, xylenes) , metals (arsenic,
b. Identlfiers/Open-Ended Terms
c. COSATI Field/Group
16. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None .
chromium, lead)
21. No. of Pages
90
22. Price
(SeeANSI-Z39.18)
S«* Instructions on Ravens
OPTIONAL FORM 272 (4-77)
- leriy NTIS-35)
rtment of Commerce
(Formerly NTIS-35)
bepartn ' • • -
-------
EPA/ROD/R09-93/087
Sacramento Army Depot, CA
Fourth Remedial Action
Abstract (Continued)
sources of this contamination. Constructed in the late 1950s, the Burn Pits served
intermittently as incineration pits until 1966. Materials that reportedly were buried
and/or burned in the Burn Pits include plating shop wastes, oil and grease, batteries, and
uncontaminated construction debris. The 21-foot deep Burn Pits occupy approximately 2
acres in the southwest corner of the SAAD, and are currently filled to the ground surface
with soil and debris. The extent of soil contamination has been determined to extend as
far as sixty feet laterally from the pits, to varying depths of 0 to 86 feet outside the
Pits. Three RODs signed in 1989, 1991, and 1992 addressed the VOC-contaminated ground
water, the VOC-contaminated soil in the Tank 2 area, and the heavy metal-contaminated soil
in the oxidation lagoons at the SAAD, respectively. This ROD addresses a final remedy for
the contaminated soil and debris in the Burn Pits, as OU5. Future RODs will address four
other OUs at the SAAD. The primary contaminants of concern affecting the soil and debris
are VOCs, including PCE, TCE, toluene, and xylenes; and metals, including arsenic,
chromium, and lead.
The selected remedial action for this site includes ventilating all soil to remove VOCs,
and applying a soil sealant annually to control dust; treating 247,900 yd^ of soil using a
soil vapor extraction (SVE) treatment system to remove VOCs from the soil, and extracting
vapor through an air/water separator and routing the water to the existing onsite ground
water treatment plant; transporting the spent carbon adsorption canisters offsite for
disposal or recycling; conducting air sampling at the wellheads to evaluate the
effectiveness of the SVE system and identify vadose zone hot spots; using particulate air
filters on extraction wells located in the area of the Burn Pits, and disposing of any
spent filters at an offsite hazardous waste facility; excavating the soil that contains
non-volatile contaminants from the Burn Pits; removing containers and other debris from
the Burn Pits, crushing some of the onsite debris for use as an aggregate in the
solidification/fixation process, and transporting the remaining debris offsite for
treatment, recycling, or disposal; treating the excavated soil onsite using cement-based
stabilization; backfilling the excavated areas with solidified soil and debris, and
covering the backfill with a layer of clean soil; and implementing institutional controls,
including deed and land use restrictions. The estimated present worth cost for this
remedial action is $2,811,000.
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific soil cleanup goals are based on RCRA TCLP levels, and include arsenic 5
mg/1; cadmium 1 mg/1; chromium 5 mg/1; and lead 5 mg/1. Additionally, the SVE system will
reduce TCE, PCE, and 1,2-DCE soil concentrations to 5 ug/kg or less; and soil gas
concentrations will be reduced to 5 ug/kg or less.
-------
SUPERFUND
RECORD OF DECISION:
Sacramento Army Depot
Burn Pits
Operable Unit
Sacramento, California
February 26,1993
-------
RECORD OF DECISION
I. DECLARATION
SITE NAME AND LOCATION
Bum Pits Operable Unit
Sacramento Army Depot (SAAD)
8350 Fruitridge Road
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Burn Pits 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
(CERQLA), as amended by the Superfund Amendments and Reauthorization Act of 1986
(SARA), and, to the extent practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP). This decision is documented in the administrative record for this
site, which contains, among other documents:
» The Burn Pits Operable Unit Feasibility Study (OUFS) which contains site
investigation data, the Public Health Evaluation, and an analysis of remedial
alternatives;
• The Proposed Plan (PP), dated August 1992, which summarizes the preferred
cleanup alternative, compares the preferred alternative with several other
alternatives, and invites public participation; and
• Summaries of public comments on the OUFS and the PP, including the Army's
response to comments (as Part TO of this ROD).
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 Bum Pits. This is the
fourth of several remedial actions addressing soil and groundwater contamination that may be
conducted, or are currently being conducted at SAAD. Subsequent RODs will address other
potential threats posed by conditions at SAAD, both on and off site. A final comprehensive
ROD will address the entire facility prior to SAAD's closure in 1997.
ER33-I(1993) Put I, Page ii 24-1S0029-A41
-------
The U.S. Environmental Protection Agency, Region IX (EPA) and the State of California
[California EPA: Department of Toxic Substances Control (DTSC) and the Central Valley
Regional Water Quality Control Board (CVRWQCB)] concur with the selected remedy.
ASSESSMENT OF THE SITE
The Burn Pits Operable Unit consists of two pits containing soils and debris to a depth of 21
feet, and soils from depths of 0 to 86 feet outside the pits, extending as far as 60 feet laterally
from the pits. The two pits have been designated "Unit 1*. The remainder of the Burn Pits
Operable Unit has been designated "Unit 2" through "Unit 5*. The Bum Pits Operable Unit
does not include groundwater. Although groundwater beneath a portion of SAAD has been
impacted by volatile organic chemicals, it is currently being remediated as a separate Operable
Unit.
An investigation by the Army showed that soils in the Burn Pits Operable Unit have been
contaminated by semi-volatile and volatile organic chemicals, metals, polychlorinated
biphenyls (PCBs), and dioxins and furans. Organic chemicals detected most often in site soils
were ethylbenzene, di-n-butylphthalate, tetrachloroethene (PCE), toluene, 1,2-dichloroethene
(1,2-DCE),. trichloroethene (TCE), and xylenes. Two PCBs were detected, Arochlor 1254
and Arochlor 1260. Twelve metals were detected at concentrations exceeding background:
antimony, arsenic, boron, cadmium, chromium (including chromium m and chromium VI),
copper, lead, manganese, mercury, molybdenum, silver, and zinc.
Volatile organics contamination appears to extend vertically to the total depth of groundwater,
and is a primary source of groundwater contamination. However, the vertical extent of semi-
volatiles, metals, PCBs and dioxins/furans appears to be confined to Unit 1, no deeper man
about 21 feet, and is limited laterally to the pits area. Volatile organic chemicals have been
detected throughout the Bum Pits Operable Unit, in Units 1 through 5.
A baseline health risk assessment was conducted to evaluate the current and potential future
risks posed by the contamination at the Bum Pits Operable Unit if no cleanup is performed.
The health risk assessment found that arsenic, cadmium, chromium (chromium m and
chromium VI), lead, TCE, PCE, and 1,2-DCE pose potential risks to human health, due to
their toxicities and concentrations. For the purpose of reducing potential health risks and
protecting groundwater, four Remedial Action Objectives (RAOs) were identified which target
these contaminants. The RAOs were developed on the basis of Applicable or Relevant and
Appropriate Requirements, and To-Be-Considered criteria.
ER33-K1993) Part I, Page ui 24-150029-A41
-------
Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action presented in mis Record of Decision, may present an
imminent and substantial endangerment to the public health, welfare, or the environment
DESCRIPTION OF THE SELECTED REMEDY
In. order to expedite the assessment and remediation processes at SAAD, the Army and
participating regulatory agencies agreed to treat individual areas where hazardous materials
have been used, stored, or disposed of as separate Operable Units. The Burn Pits Operable
TJnitis the fourth Operable Unit for which a ROD has been prepared.
The Army intends to clean up the Bum Pits Operable Unit so mat the public is not exposed to
toxic chemicals from the site. This ROD addresses the principal threat at the Burn Pits site by
removing volatile contaminants and stabilizing non-volatile contaminants present in the soil.
Removal and stabilization of contaminants in the soil will reduce the potential for.
• migration of contamination from soil to groundwater, and
• public exposure to contamination via inhalation of dust, direct contact with, or
ingestion of, contaminated soil.
Each of these pathways represent primary potential future risks to public health.
The selected remedy for cleaning up the soil at the Burn Pits Operable Unit consists of:
• ventilating the entire Bum Pits Operable Unit soils to remove VOCs using
extraction wells and a vacuum pump/rotary blower,
• treating extracted vapor using carbon adsorption;
• treating entrained water in the on-site water treatment plant;
• sampling air emissions to verify that volatile organic chemicals have been
removed prior to venting to the atmosphere;
• sampling ventilated soils following treatment to assess whether treatment has
been effective;
• excavating Unit 1 soils which contain non-volatile contaminants;
• sampling the excavation bottom and sidewalls to verify that contaminated soil
has been removed;
• stabilizing the excavated soils using a cement-silica mixture;
» • backfilling the excavation with stabilized soil; and
ER3J-H1993) Pirt I, Page iv 24-1S0029-A41
-------
• implementing institutional controls in the form of a deed restriction and notice,
to prohibit future disturbance of the g**hiii*ed soil mass.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies with Federal
and State requirements that are legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. This remedy utilizes permanent solutions and alternative
treatment technologies to the maximum extent practicable, and satisfies the statutory
preference for remedies that employ treatment that reduces the toxicity, mobility or volume as
a principal element The remedial action will remove volatile contaminants from the site, will
immobilize non-volatile contaminants through stabilization treatment, and will be completed
within approximately IS months. Since solidification of the non-volatile contaminants results
in hazardous substances remaining at the Burn Pits above levels which allow for unlimited use
and unrestricted exposure, the solidification component of mis action shall be reviewed,
pursuant to CERCLA 121(c) and the NCP 300.430 (f) (4) Qi), within five years after its
initiation.
ER33-1(1993) Parti, Page v 24-150029-A41
-------
BURN PITS
RECORD OF DECISION
IT IS SO AGREED:
FOR THE U.S. DEPARTMENT OF THE ARMY:
Date Lewis D. Walker
Deputy for Environmental, Safety, and Occupational Health
Office of the Assistant Secretary of the Army (IL&E)
Date William Grundy
Colonel, OD
Commander, Sacramento Army Depot
FOR THE STATE OF CALIFORNIA ENVIRONMENTAL PROTECTION AGENCY:
Date David Wang
Chief, Base Closure Branch
Department of Toxic Substances Control
California Environmental Protection Agency
Date William H. Crooks
Executive Officer
Central Valley Regional Water Quality Control Board
FOR THE U.S. ENVIRONMENTAL PROTECTION AGENCY:
Date
Regional Administrator
United States Environmental Protection Agency, Region K
ER33-K1993) Part I, Page vi 24-150029-A41
-------
BURN PITS
RECORD OF DECISION
IT IS SO AGREED:
FOR THE U.S. DEPARTMENT OF THE ARMY:
Date -*- Lewis D. Walker
Deputy for Environmental, Safety, and Occupational Health
Office of the Assistant Secretary of the Army (IL&E)
~ _
Date William Grndy /
Colonel, OD
Commander, Sacramento Army Depot
FOR THE STATE OF CALIFORNIA ENVIRONMENTAL PROTECTION AGENCY:
&~J
Date David Wang
Chief, Base Closure Branch
Department of Toxic Substances Control
California Environmental Protection Agency
Date William H. Crooks
Executive Officer
Central Valley Regional Water Quality Control Board
FOR THE U.S. ENVIRONMENTAL PROTECTION AGENCY:
Date
Regional Administrator
United States Environmental Protection Agency, Region DC
ER33-1(1993) Part I, Page vi 24-1S0029-A41
-------
RECORD OF DECISION
SAAD-BURN PITS OPERABLE UNIT
TABLE OF CONTENTS
H. DECISION SUMMARY
Chapter Page
1 SITE NAME, LOCATION, AND DESCRIPTION 1
1.1 Location 1
1.2 Site Description 1
1.3 Demography 1
1.4 Land Use 2
1.5 Climatology 2
1.6 Regional Topography 2
1.7 Surface Water Hydrology 2
1.8 Geology 3
1.9 Hydrogeology 4
1.10 Natural Resources 4
2 SITE HISTORY AND ENFORCEMENT ACTIVITIES 4
3 HIGHLIGHTS OF COMMUNITY INVOLVEMENT 6
4 SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY 7
5 SUMMARY OF SITE CHARACTERISTICS 8
5.1 Contamination Sources 8
5.2 Evaluation of Primary Contaminants 8
5.3 Location of Contaminants and Potential Routes of Migration 9
6 SUMMARY OF SITE RISKS 9
6.1 Human Health Risks 9
6.1.1 Contaminants of Concern 10
6.1.2 Exposure Assessment 10
6.1.3 Summary of PHE Results . 13
6.2 Environmental Evaluation 16
6.3 Threat to Groundwater 17
6.4 Remedial Action Objectives • 17
7 DESCRIPTION OF ALTERNATIVES 18
7.1 Alternative 1 No Action ' 19
7.2 Alternative 2 Capping of the Entire Bum Pits Operable Unit 20
7.3 Alternative 3 In-situ Soil Ventilation of the Entire Burn Pits Operable Unit;
Controls to limit Surface Soil Exposure 21
7.4 Alternative 4 In-situ Soil Ventilation or the Entire Burn Pits Operable Unit;
Capping of Unit 1 23
7.5 Alternative 5 In-situ Soil Ventilation of the Entire Burn Pits Operable Unit;
Excavation of Unit 1; Soil Washing of Excavated Soil; Backfilling 24
ER33-1(1993) Part I, Page vii 24-150029-A41
-------
7.6 Alternative 6 In-ritu Soil Ventilation of the Entire Bum Pits Operable Unit;
Excavation of Unit 1; Stabilization of Excavated Soil; Backfilling 26
& SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 28
8.1 Criterion 1 Overall Protection of Human Health and the Environment 29
8.2 Criterion 2 Compliance with ARARs 29
8.3 Criterion 3 Long-term Effectiveness and Permanence 30
8.4 Criterion 4 Reduction of Toxicity, Mobility, or Volume through Treatment 30
8.5 Criterion 5 Short-term Effectiveness 31
8.6 Criterion 6 Implementability 32
8.7 Criterion 7 Cost 33
8.8 Criterion 8 State Acceptance 33
8.9 Criterion 9 Community Acceptance 33
9 -^BT.ffk -i KII REMEDY 34
9.1 Components of the Remedy 34
9.2 Cleanup Standards 34
9.3 Cost Information 34
10 STATUTORY DETERMINATIONS 35
10.1 Protection of Human Health and the Environment 35
10.2 Compliance with ARARs 35
10.3 Cost Effectiveness 35
10.4 Utilization of Permanent Solutions, and Alternative Treatment and Resource
Recovery Technologies 36
IQ.5 Preference for Treatment as a Principal Element 36
CITED 36
FIGURES
I Site Location Map - Sacramento Army Depot
Z Site Map - Burn Pits Operable Unit
3 Approximate Extent of Organic Compounds, Units 1 and 2; 0 to 21 feet
4 Approximate Extent of Organic Compounds, Unit 3; 21 to 41 feet
5 Approximate Extent of Organic Compounds, Unit 4; 41 to 61 feet
6 Approximate Extent of Organic Compounds, Unit 5; 61 to 86 feet
7 Cross Section location Map
8 North-South Contaminant Distribution Cross Section
9 West-East Contaminant Distribution Cross Section
10 Site Vicinity Map Showing Potential Exposure Points
TABLES
I Summary of Primary Contaminants
Z Definitions of Risk Terms
3 Estimated Total Carcinogenic Risks for Each of the Primary Carcinogens
4- Estimated Total Hazard Indices for Each of the Primary Non-carcinogenic
Contaminants
5 Summary of Comparison of Remedial Alternatives
6 Selected Alternative Cost Summary
ER33-I
-------
APPENDICES
A Analysis of ARARs
B Administrative Record Documents
m. RESPONSIVENESS SUMMARY
Chapter Page
1 BACKGROUND ON COMMUNITY INVOLVEMENT 1
2 OVERVIEW 2
3 SUMMARY OF PUBLIC COMMENTS AND ARMY RESPONSES 2
4 RESPONSIVENESS SUMMARY 6
ER33-K1993) Ptrtl.Pigeix 24-150029-A41
-------
I SHE NAME, LOCATION, AND DESCRIPTION
I.I Location
The Bora Pits Operable Unit is part of the Sacramento Army Depot (SAAD) military facility
owned by the U.S. Army. The SAAD facility is located at 8350 Fruitridge Road, in the City
and County of Sacramento, California. SAAD lies approximately 7 mile southeast of
downtown Sacramento (Figure 1), and is bound by Fruitridge Road on the north, Florin-
Pedtins 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 Bum Pits Operable Unit occupies approximately two acres in the southwest portion of
SAAD. The Operable Unit consists of two rectangular trenches (North and South Pits)
containing soils and debris to a depth of 21 feet, and soils outside the trenches to a depth of 86
feet within about 60 feet of the Burn Pits. A site map of the SAAD facility, showing the
location, of the Burn Pits Operable Unit with respect to the other Operable Units and site
fixtures, is shown on Figure 2.
L2 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 likely the primary on-site waste generating
activities.
In addition to the Bum Pits, past and present disposal and storage areas and structures at the
ate include: several underground and above-ground storage tanks; unlined wastewater lagoons;
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.
L3 Demography
In 1987, 76 people were living on the SAAD facility; 56,398 people were living off site,
within 2 to 3 miles of SAAD. Currently, there are no residents on the SAAD facility.
ER33-K1993) Part II, Page 1 24-150029-A41
-------
Sacramento
Army Depot
APPROXIMATE SCALE: 1"« 21£ MBes
0 21/2 S
1
Scale in Miles .
KLEINFELDER
DATE PRODUCED: 5/12/92J DATE REVISED: 2/8/93
PROJECT NO. 24-150028-A07
SITE VICINITY MAP
SACRAMENTO ARMY DEPOT
SACRAMENTO, CALIFORNIA
FIGURE
1
-------
«PPRQDOM«TESCAL£:1-.10(Xr
too 1000
e an.
ScatoinFMt
........ srrE BOUNDARY
" i 1 BUILDINGS/STRUCTURES
KLEINFELDER
PROJECT NO.
24-150028-A07
SITE LOCATION MAP
FOR BURN PITS
SACRAMENTO ARMY DEPOT
SACRAMENTO, CALIFORNIA
FIGURE
-------
In 1984, there were 20,710 people working off site, within 2 to 3 miles of SAAD. There are
approximately 3,000 people currently working on the SAAD facility. Due to base closure, the
number of employees is expected to decrease to approximately 100 by the end of 1994.
1.4 Land Use
SAAD is surrounded on all sides by land currently zoned as commercial/light 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
the SAAD are primarily industrial.
1.5 Climatology
Climate at SAAD is classified as "Mediterranean", 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, and the
majority of the evaporation occurs in the summer. 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.
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 Oat 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
ER33-K1993) P«t II, Ptge 2 24-150029-A41
-------
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 100-year flood events, so the Bum
Pits 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 permitted discharges from industries.
A study of the SAAD facility indicates that the only potential wetlands at the facility are
located within the Oxidation Lagoons Operable Unit, along Old Morrison Creek,
approximately 800 feet north of the Burn Pits. There are no wetlands in or adjacent to the
Burn Pits that would be impacted by this ROD.
1.8 Geology
SAAD is located in the Great Valley of California, a broad asymmetric trough filled with a
thick assemblage of flat-lying marine and non-marine sediments. The most recent formations
deposited in the Great Valley are non-marine sediments derived from the Sierra Nevada
foothills and mountains on the west side of the valley and from the Coast Ranges on the east
side of the valley. The sediments are carried out of the mountains and deposited by a series of
large and small rivers. Sediments under SAAD have been largely derived from the Sierra
Nevada, and have been deposited by the American River as it has meandered across the valley
floor.
The upper 250 feet of sediments under SAAD are comprised of interbedded sands, silts, and
days, 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 geologic
formations is extremely difficult in alluvial deposits, such as those underlying SAAD. Older
buried stream channels exist at various locations and depths in the area. These streams have
deposited materials ranging in size from gravel to clay as they meandered across the area.
Multiple discontinuous hardpans (cemented clays), representing ancient soil horizons, exist
throughout the site.
ER33-1(1993) Part II, Page 3 24-150029-A41
-------
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 water-bearing sediments in the area into two hydraulically
isolated sections: the superjacent (upper) series, at depths of about 80 to 250 feet beneath the
site; and, the subjacent (lower) series, at depths below about 2SO feet The primary water-
producing aquifers are in the subjacent series, although many wells in the area surrounding the
site draw water from the superjacent series.
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 mis area use
Sacramento City water from municipal wells located at least three quarters of a mile from
SAAD. However, there may be some private wells in the area using groundwater.
1.10 Natural Resources
Except for groundwater, which is an extremely important resource throughout the Central
Valley, no other natural resources on the site are used.
2 SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Remedial Investigations conducted at SAAD are a part of the U.S Army Installation
Restoration Program (IRP). The Army owns the site and is the lead agency for implementing
the environmental response actions.
In the late 1970's, the U.S. Army Depot Systems Command recommended that SAAD be
included in the IRP. Consequently, in 1978 and 1979, the U.S. Army Toxic and Hazardous
Materials Agency (USATHMA) conducted a review of historical data to assess SAAD with
regard to the use, storage, treatment, and disposal of toxic and hazardous materials.
USATHMA identified several areas of concern where further investigations were warranted.
In early 1981, the Army initiated an on-site investigation of soil and groundwater in the areas
of concern identified by the USATHMA, including the Burn Pits, Oxidation Lagoons,
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 corner of SAAD. Based on the location of the
ER33-1(1993) Part II, Page 4 24-150029-A41
-------
VOCs in groundwater, the Burn Pits appeared to be one of the main sources of groundwater
contamination in this area.
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 Army began working with the CVRWQCB to assess the source and
extent of groundwater contamination. The EPA and the California Department of Health
Services subsequently became involved in the investigation of contamination at SAAD, and
SAAD was placed on die National Priorities List (NPL), effective August 21, 1987 (52 Fed.
Reg. 27620; July 22, 1987).
la December 1988, the Army, the EPA, and the State of California signed a Federal Facility
Agreement (FFA) under CERCLA Section 120, agreeing to address the entire facility,
including the contaminated groundwater and seven areas of suspected contamination on the
SAAD facility:
Tank2
Oxidation Lagoons
Bum Pits
Building 320 Leach Field
Pesticide Mix Area
Firefighter Training Area
• Battery Disposal Well
The FFA also calls for a RCRA Facility Assessment to identify other specific Solid Waste
Management Units that need further characterization and cleanup. To expedite investigation
and cleanup of the individual sites, three areas listed above and the on-site/off-site groundwater
are each being treated as individual Operable Units. The remaining areas are being addressed
under the installation-wide RI/FS. These seven areas are shown on Figure 2. Groundwater
and the saturated zone immediately above the water table was the first Operable Unit
investigated, and is currently being cleaned up under a Record of Decision (ROD) which was
signed in 1989. Contaminated soil at the Tank 2 Operable Unit is scheduled to be cleaned up
next, under a ROD that was signed in December 1991. A ROD for the Oxidation Lagoons
was signed in September 1992, and this area will be cleaned up in 1994.
Constructed in the late 1950's, the Burn Pits served intermittently as incineration pits until
1966. Materials that were reportedly buried and/or burned in the Bum Pits include plating
shop wastes, oil and grease, batteries, and uncontaminated construction debris. Currently the
Burn, Pits are filled to the ground surface with soil and debris.
ER33-KI993) Part n, Page 5 24-150029-A41
-------
As part of the IRP, the U.S. Army conducted additional soil assessments at the Bum Pits in
1985 through 1987, and 1990 through 1992. In 1991, the Army prepared a Remedial
Investigation/Feasibility Study (RI/FS) workplan in accordance with the FFA. The RI/FS
evaluated the seven Operable Units. Based upon die RI/FS findings, four of these, including
the Burn Pits were recommended for Operable Unit feasibility studies (OUFS).
The Burn Pits were recommended for an OUFS because heavy metals, VOCs and semi-volatile
organic chemicals are present in the near surface, and pose a potential threat via direct contact,
airborne migration, or migration through soil to groundwater.
An OUFS for the Bum Pits was prepared in May 1992. As part of the OUFS, the Army
prepared a baseline Public Health Evaluation (PHE) to estimate potential health and
environmental risks mat could result if no action was taken at the site. The PHE indicated
potential cancer and non-cancer health effects to a future on-site business, an off-site resident,
and a future on-site recreation user from metals, VOCs, polychlorinated biphenyls (PCBs), and
dioxins/furans in Burn Pits soil. Details of the PHE are summarized in Section 6.
3 HIGHLIGHTS OF COMMUNITY INVOLVEMENT
In May, 1992, the Army prepared a new Community Relations Plan. In August, 1992, the
Army issued a Proposed Plan (PP) for the Burn Pits Operable Unit. The plan consists of a 12-
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,
remedial action objectives, and remediation alternatives. The plan also includes a list of
individuals who may be contacted for additional information, lists the addresses of the
information repositories, and announces the public comment period. The Army also placed a
notice in a local daily newspaper, the Sacramento Bee, for five days prior to the public
comment period to outline the preferred remediation 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 Center, the California State University, Sacramento, Library, and the George
Sim Community Center. The OUFS and PP were also available for public review at the
Sacramento office of the DTSC and at EPA headquarters in San Francisco.
A public comment period was held from August 3 through September 1, 1992. A public
meeting was held on August 13, 1992. Thirty-four people, including community members and
representatives from the Army, EPA, DTSC, and CVRWQCB attended the public meeting.
ER33-K1993) P«tII,P«ge6 24-150029-A41
-------
Eleven oral questions/comments were received at the meeting. No written comments were
received during the public comment period.
Details of community involvement activities and responses to official public comments on the
PP are presented in the Responsiveness Summary, which is Part in of this ROD.
4 SCOPE AND ROLE OF OPERABLE UNIT WTTHIN SITE STRATEGY
Since the Army began investigating possible contamination at SAAD, eight Operable Units
have been identified that may require remediation (see Section 2, preceding). Four of the
units, the Bum Pits, the Oxidation Lagoons, Tank 2, and On-site Groundwater, were
recommended for OUFS'.
The Groundwater OUFS was completed in May 1989, and an operable unit ROD addressing
volatile organic compounds (VOCs) in groundwater was signed in September 1989; The
OUFS for Tank 2 was finalized in October 1991, and an operable unit ROD addressing VOCs
in soil was signed in December 1991. The OUFS for the Oxidation Lagoons was finalized in
March 1992, and an operable unit ROD addressing heavy metals in soil was signed .in
September 1992. The additional four OUs will be addressed in a comprehensive site
Feasibility Study and ROD, after important site characterization information becomes
available.
The existing southwest comer groundwater VOC plume is currently being "captured" (i-*-. it
is being refrained from further migration) by the on-site groundwater extraction and treatment
system selected in the 1989 groundwater ROD. The groundwater cleanup standards are federal
and State drinking water standards, called maximum contaminant levels (MCLs).
The Burn Pits cleanup will address two different types of soil contamination: (1) VOCs, which
are considered the primary source of groundwater contamination, and (2) heavy metals which
based on the remedial investigation, are not considered a threat to groundwater.
Following completion of the Bum Pits soil cleanup, the pump and treatment system will
continue to operate until the remaining VOC contamination in the aquifer has been cleaned up
to MCLs.
ER33-K1993) Put II, Page 7 24-1S0029-A41
-------
5 SUMMARY OF SITE CHARACTERISTICS
5.1 Contamination Sources
In order to better define contaminant concentrations and distribution for the purpose of
evaluating health risks and developing remediation plans, the Army divided the Burn Pits
Operable Unit into five units. VOC concentrations and distribution were used as the bases for
assigning the unit divisions. The units are:
• Unit 1: North and South Pits; depths of 0 to 21 feet
• Unit 2: Outside Bum Pits; depths of 0 to 21 feet
• Unit 3: Outside Burn Pits; depths of 21 to 41 feet
• Unit 4: Outside Burn Pits; depths of 41 to 61 feet
• Unit 5: Outside Bum Pits; depths of 61 to 86 feet.
Soils in each of the units contain volatile and semi-volatile organic chemicals. Soils in Unit 1
also contain 12 metals at concentrations exceeding background, PCBs, and dioxins/furans.
Additionally, groundwater beneath the site contains VOCs. However, as described in
preceding sections of mis ROD, groundwater, including the saturated zone, is being
remediated-as a unique Operable Unit. Under the existing Groundwater Treatment ROD, the
affected groundwater is being extracted and treated using ultraviolet/chemical oxidation. The
extraction wells were located to treat the contaminant plume as well as to act as a barrier to
contain offsite flow of contaminated groundwater. The medium targeted for remediation of
the Burn Pits is soil. This will remove the primary source of groundwater contamination,
which is critical to the overall remediation of groundwater.
The source of the contaminants at the Burn Pits Operable Unit appears to be disposal and
incineration of materials containing metals, volatile and semi-volatile organic chemicals, and
PCBs.
5.2 Evaluation of Primary Contaminants
The organic compounds detected most often were ethylbenzene, di-n-butylphthalate,
tetrachloroethene (PCE), toluene, 1,2-dichloroethene (1,2-DCE), trichloroethene (TCE), and
xylenes. Twelve metals have been detected at concentrations exceeding background:
antimony, arsenic, boron, cadmium, chromium (including chromium VI and chromium ID),
copper, lead, manganese, mercury, molybdenum, silver, and zinc. Metals appear to be
confined to Unit 1 soils. A summary of contaminants detected at the Bum Pits Operable Unit
ER33-1(1993) Put II, Page 8 24-150029-A41
-------
is presented on Table 1. All RI data have been validated and die quality is acceptable to
support the recommendations made in this ROD.
The total volume of soil in the Burn Pits Operable Unit is approximately 247,900 cubic yards.
Of mis volume, 16,900 cubic yards of material are located within the two Bum Pits and
primarily are contaminated with volatile chemicals and metals. Approximately 231,000 cubic
yards of soil are located outside of the two Burn Pits, and are contaminated primarily with
volatile organic chemicals. PCBs and dioxins/furans have been detected in Unit 1 soils but are
not considered primary contaminants of concern because of the low levels found.
5.3 Location of Contaminants and Potential Routes of Migration
The estimated lateral extents of contamination for each of the five investigation Units are
shown, on Figures 3 through 6. Cross sections showing the extent of contamination in each
Unit are presented on Figures 7 through 9. The vertical extent of VOC contamination appears
to extend to the total depth of groundwater, about 86 feet. The vertical extent of metals,
PCBs, and dioxins/furans appears to be no deeper than about 21 feet.
The presence of metals, PCBs, and dioxins/furans in soils is limited laterally to the area of
Unit 1, i.e., within the two Bum Pits. VOCs have been detected in soils throughout the Bum
Pits Operable Unit, as far as about 120 feet north and 20 feet west of the North Pit, and 60
feet, south and west of the South Pit Contamination does not appear to extend eastward
beyond the Burn Pits.
Since contaminants are present in surface soils, airborne migration off site could occur in
windblown dust Individuals on site could be exposed via inhalation of dust, or by direct
c"n*yt or ingestion of soils.
€ SUMMARY OF SITE RISKS
6.1 Human Health Risks
As part of the OUFS, the Army prepared a baseline Public Health Evaluation (PHE). This
PHE was prepared to estimate, in the absence of remedial action (i.e., the "No Action"
alternative), the potential future risks to human health if contaminants remained in soil or
leached through soil, migrated to groundwater, or entered the atmosphere. Table 2 presents
definitions of key risk terms from the PHE that are used in this section of the ROD.
ER33-I(1993) Part II, Page 9 24-150029-A41
-------
TABLE 1
SUMMARV OF PRIMARY CONTAMINANTS
CHEMICAL
MioutNct of ocncn
MANOCOrOCIECICO
coHCCNiMinm
HANOI OF IAMPIE QUAN
f!TAHONUMI14
Bum m» OUl ••ttO'om*
BUBH mo oreftAME UNIT
lui»»«««o01 UoO.ll UnO.ll U««l 1 U»I4 I Uno,»
•ACK-
OKOUNtl
1UHN Pill Off RMHI UMT
T^tXl I
1 tfc.4 T U«»
ORGAN £8
TetHBO
llflOT
NO-1,4001
•>.*•«•
«•*-*»
^
«-,".»»».
AVEAAOOj CONOENT1U1KMI* froOol
_U_
»•
1.0
HC
."»«
•n UOLOT cooainMi
_t»_
ih
TT
*
#
"HO"
-NO"
EomWMono ^
'P«.
NO -10.001
i - 11.000
_»J_
_!!_
NC
~NC"
HflOO
1 - 11,000
4K10>
* - ".o*»
-.»».
_»•_
_»•_
^1
Jh
_"B
1,1-DICMOftMflhtAO
HBO!
I.I - II.SOC
• - 11.000
-00
too
1F.O
lilllcMMOOtHIIO
IOT4I
» - 11.0
-I»_
•"0*
"«'
-51^
,««-«»
No DM
MO- 1.000
100 -.JOO
»»-««»
Mo DM
IM
H.OM
. '»««.
"»»
"^
»I4.»
MO
MOPM
HQOrt.
..•Mt
3t
^^
MI DM1
'«*»..
T.9.S-
:SoS:
Ho DM
Tftr
•MTo£
l,M.4-tCOOoox.«
METALS '•'
Ajti^^MM
Anoj*
IW10
*» t
.
MO-T.
-144
xmoamtAitoM- v_/*ot
SI
110.0
ft
is
H
tMR»
NO -1
NO - *
0 « - II
»*
00
NC
4.0
III
nifiio
NO -4.4
1.44-10
1 44 - 10
41
01
NO '
NC
o
56
0»
MIBM
(KM
"*•**
OIO-4
11.0
NC
NC
*••.
•SSL
000.0
NO-
"ft"
"HO~
s:
MO
NO
04.1
|4.»- 4t.f
0.1-10
10.
dt
MC
^E
«f««.
"o-M"
NO-10.401
*"-»
»»*^»
«««
. w
*»••
II - 4J 4
0.14 - 14 4
O.t4 -
MO
r.4
100.0
MO
N0
MO
MO
XI
•4-1.144
NO-.4
4-44I
01 i *
0.1
Mt
•H
404 r
5
MO
cuv
, .
IWM
KO
0,01 - 0.0
ft«-0.l
HC
004
Bo
«f4l
NO-»7
NO
NO
11- *
,*•>
NC
1.1
•HIM
NO - I4.»
Oil - t!4
ow-i
OM
0.1
NO
NO
fie
a
1.1
».• - 4.4H
14.* - 4?.4
OM-t
NO HolO«lOO>
•at- OM 44»OCl kK C<0« III OWMOIlkOM •) 00 44I»*M4.4
•OMO ff'\ 00 44M»lM
(C/'| 00 <•««•••
l«^«l«Qi»n»u»antlrK«.->in«IM(i«i»liln<»»«l.».f.4-ICOOnil 4»Af >«
UMO A- f 01 ON OMB FOl
-------
PP-14
IPP-15
NORTH
BURN PIT
PP-13
PP-2
PP-12
APPROXIMATE
BURN PIT LOCATIONS
PP-11
SOUTH
BURN
PP.16
PP-6
PP.8
LEGEND
KLEINFELDER 1990/91 BORINGS
KLEINFELDER 1986 BORINGS
WOODWARD-CLYDE
1985 BORINGS
MONITORING WELL MW-5
EXTENT OF ORGANIC
COMPOUNDS, UNIT 1
EXTENT OF ORGANIC
COMPOUNDS, UNIT 2
APPROXIMATE SCALE: 1* » 60'
10
"~"1
•»ft Cft
Scale in Feel
MW-5 Monitoring Wei Shown lor Location Reference Rectangular Coocdtoates lor MW-5 are: 308.912.32 (eel north 2.171.611.73 feet east
NP= NORTH PIT BORING
SP • SOUTH PIT BORING
PP . PERIMETER PIT BORING
KLEINFELDER
DATE PRODUCED: 6/15/92 | DATE REVISED: 2/8/93
PROJECT MO. 24-150028-A07
APPROXIMATE EXTENT OF ORGANIC
COMPOUNDS, UNITS 1 & 2; 0-21 FEET
BURN PITS OPERABLE UNIT
SACRAMENTO ARMY DEPOT
SACRAMENTO, CALIFORNIA
FIGURE
SAAtWO-IWOOT W7-OT
-------
NORTH
BURN PIT
PP-12
. Xf-. s «. s -> "• S. -S. 0* Sw s v K
^^::^^^¥>«v, •
PP.3
IPP-15
PP-16
PP-6
APPROXIMATE
BURN PIT
LOCATIONS
SOUTH V^-^^^
BURN PIT
LEGEND
PP-8
APPROXIMATE SCALE: r . 60'
10
KLEINFELDER1990/91 BORINGS o 30
MONITORING WELL MW-5 *& '
Hfl EXTENT OF ORGANIC MW'5 Monitoring Wed Shown tor location Reference Rectangular Coordinates lor MW-5 are: 306.912.32 leal north 2.171.61173 feel east
60 Sca-einFeo, 12°
•^ COMPOUNDS
NP° NORTH PIT BORING
SP n SOUTH PIT BORING
PP » PERIMETER PIT BORING
SAAC»0-IMI02»-M)7-04
KLEINFELDER
DATE PRODUCED: 1 /15/92JPATE REVISED: 2/8/93
PROJECT NO. 24-150028-A07
APPROXIMATE EXTENT OF ORGANIC
COMPOUNDS, UNIT 3; 21 TO 41 FEET
BURN PITS OPERABLE UNIT
SACRAMENTO ARMY DEPOT
SACRAMENTO, CALIFORNIA
FIGURE
-------
NORTH
BURN PIT
APPROXIMATE
BURN PIT LOCATIONS
SOUTH
BURN PIT
)PP-15
_J
.PP-16
LEGEND
APPROXIMATE SCALE: T - 60'
10
KLEINFELDER 1991 BORINGS
30
60 ScaleinFee, 12°
MONITORING WELL MW-5
EXTENT OF ORGANIC
COMPOUNDS
PP = PERIMETER PIT BORING
MW-5 Monitoring Wei Shown (or Locaftm Reference Rectangular CoocrtnaWs lor MW-5 are: 30S.912.32 (eel north 2.171.611.73 (eel easl
KLEINFELDER
DATE PRODUCED: 1/15/92 | DATE REVISED: 2/8/93
PROJECT NO. 24-150028-A07
APPROXIMATE EXTENT OF ORGANIC
COMPOUNDS, UNIT 4; 41 TO 61 FEET
BURN PITS OPERABLE UNIT
SACRAMENTO ARMY DEPOT
SACRAMENTO, CALIFORNIA
FIGURE
-------
NORTH
BURN PIT
APPROXIMATE
BURN PIT LOCATIONS
SOUTH
BURN PIT
LEGEND
KLEINFELDER 1991 BORINGS
IPP-15
kPP-16
APPROXIMATE SCALE: f » 60'
10
30
60 Scale In Feel t20
MONITORING WELL MW-5
j EXTENT OF ORGANIC
COMPOUNDS
PP . PERIMETER PIT BORING
MW-5 Monitoring Wed Shown lor Location Reference Rectangular Coor Jnates lor MW-S are: 306.912.32 leet north 2.171.611.73 teat east
KLEINFELDER
DATE PRODUCED: 1/15/92 |PATE REVISED: 2/8/93
PROJECT NO. 24-150028-A07
APPROXIMATE EXTENT OF ORGANIC
COMPOUNDS, UNIT 5; 61 TO 86 FEET
BURN PITS OPERABLE UNIT
SACRAMENTO ARMY DEPOT
SACRAMENTO, CALIFORNIA
FIGURE
-------
r >- N
NORTH
BURN PIT
APPROXIMATE
BURN PIT LOCATIONS
PP-3
PP-15
PP-6
PP-8
KLEINFELDER 1990/91 BORINGS
KLEINFELDER 1986 BORINGS
MONITORING WELL MW-5
WOODWARD-CLYDE
1985 BORINGS
APPROXIMATE SCALE: 1' . 60'
10
30
60
Scale In Feel
MW-5 Monitoring Well Shown lor Location Reference Rectangular Coordinates lor MW-5 are: 306.912.32 leel north 2.17l.611.73leelea»l
12°
NP. NORTH PIT BORING
SP . SOUTH PIT BORING
PP - PERIMETER PIT BORING
KLEINFELDER
DATE PRODUCED: 1 /15/92 j DATE REVISED: 2/6/93
PROJECT NO. 24-150028-A07
CROSS SECTION LOCATION MAP
BURN PITS OPERABLE UNIT
SACRAMENTO ARMY DEPOT
SACRAMENTO, CALIFORNIA
FIGURE
SAAUM-I900M-CI3-OS
-------
LEGEND
p~^ APPROXIMATE AREA
L - J OF CONTAMINATION
T GROUND WATER
#w#*
&S&&
mm.
FrTTV1^
I * « » » » y»4 *".
h~^\<^^,
I /;\\N^"«v .
: - o\\
I? -: i^r-'<- ?^. „
I f -. SN> S^-. ^ s •• ^ %v-.
Iv > **,\ "w ,s^ ^ ,
r;>X"\ «#..*,
I -KK^ ,^^
^^ ^^^M^^*:*.^*^*
! '>:^::^'^-r \ "^^
',-* ^?v" %r\\» :>\
„ ^nv^-^v^Xi
; v>. % ? * \Sil " ^ W** \» » 15-^
, >» % > v\ ^ -;^V*5 ^'" "w & \™ <\»*- •
' -. "• ;*" >o.*X \ ;^ «A \«-Nvt > ^AV
SOUTH
BURN PIT
'V1-* k... \*Se^% fXNfr?*^ *?
i[ *w •f#^ **fr •wM ^iw •fm*'*tfM£i(N*' ^y^
\ ' ^ <•$.«% J\ '>\ ;^ „ -. %;.,. •* A i; . % f •>
-•0
10
20
30
40
ui
u.
50 u]
Q
60
70
60
90
APPROXIMATE
HORIZONTAL SCALE: V = 601
0 30 GO
Scale In Feel
8AAJMCHWOW A07-0?
KLEINFELDER
DATE PRODUCED: 1/7/92 | DATE REVISED: 2/8/93
PROJECT NO. 24-150028-A07
NORTH-SOUTH CONTAMINANT
DISTRIBUTION CROSS SECTION
BURN PITS OPERABLE UNIT
SACRAMENTO ARMY DEPOT
SACRAMENTO. CALIFORNIA
FIGURE
8
-------
w
LEGEND
GROUND SURFACE
i'v * S \
•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.'.•.•..•.•.•.•.' 'XNX/CWOCVXXNX^
•:•.-.•.•.•.•.•.•.•.•.•.•.-.•. •.•.•.•.•.•.•.•.•.•.!
•x>;x;x>/-:-x^x:::>x-::::x.';{
.•.•.•.•.•.•.•.•.•.•,•.•.'.•.•.•.•.•.'.'.'.•.'.'. 'i
i
uNni;V; ^V:^XV:::\
y!^\ ;.. ^r >.w.:^??vl
,- ;n> x - ~, - - , , uiiupvr " ^ s;::, ^v *• w\^ ::
:^ -, :^ - , -{ " y:P\ ; , Y >',^ ^3<*.l
i o^o !s ^ t*^ >; , * ^-f ^V^<->^r>^\ ^^:-^>-:;^y:^|
rS-r \ fV ^'' "r - *-; .;• vr^3>:;v;^r\;^vll!
i.'.-s'1"..'^ .".' "Li _i_ J^, isi _l !_:.__::,„ _i £. j_; Sii~l> v» Ji ii., i &. *i.si_ ^. ^.^s a
APPROXIMATE AREA
M- OF CONTAMINATION
T GROUND WATER
s% % s-- •,
10
APPROXIMATE
HORIZONTAL SCALE: 1'
30 60
Scale In Feet
120
KLEINFELDER
DATE PRODUCED: 1 /15/921 DATE REVISED: 2/8/93
PROJECT NO.
24-150028-A07
w
20
30
40
E
50
ui
Q
60
70
BO
WEST-EAST CONTAMINANT FIGURE
DISTRIBUTION CROSS SECTION
BURN PITS OPERABLE UNIT Q
SACRAMENTO ARMY DEPOT
SACRAMENTO, CALIFORNIA
SAAOOO-1SOOM-M7-W
-------
TABLE2
DEFINITIONS OF RISK TERMS
Carcinogen: A substance that, with long term exposure, may increase the incidence
of cancer.
Chrome Daily Intake (CDI): The average amount of chemical in contact with an
individual on a daily basis over a substantial portion of a lifetime.
Chronic Exposure: A persistent, recurring, or long-term exposure. Chronic
exposure may result in health effects (such as cancer) that are delayed in onset,
occurring long after exposure ceased.
Exposure: The opportunity to receive a dose through direct contact with a chemical
or medium containing a chemical.
Exposure Assessment: The process of describing, for a population at risk, the
amounts of chemicals to which individuals are exposed, or the distribution of
exposures within a population, or the average exposure of an entire population.
Health Hazard Index (HHI): An EPA method used to assess the potential
noncartinogenic risk. The ratio of the CDI to the chronic RfD (or other suitable
toxicity value for noncarcinogens) is calculated. If it is less than one, then the
exposure represented by the CDI is judged unlikely to produce an adverse
noncarcinogenic effect A cumulative, endpoint-specffic HHI can also be calculated
to evaluate the risks posed by exposure to more than one chemical by summing the
CDI/RfD ratios for all the chemicals of interest that exert a similar effect on a
particular organ. This approach assumes that multiple subthreshold exposures could
result in an adverse effect on a particular organ and that the magnitude of the
adverse effect will be proportional to the sum of the ratios of the subthreshold
exposures. If the cumulative HHI is greater than one, then there may be concern for
" ; health risk.
Reference Dose (RfD): An estimate, with uncertainty spanning an order of
magnitude, of a daily exposure level for human population that is likely to be
"**• a appreciable nsk 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) judgments as to the number of characteristics of
persons exposed at various intensities and durations; (4) summary judgments 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.
ER33-I3(1993) 24-150029-A41
-------
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. Twelve metals above
background levels, seven semi-volatile and volatile organic chemicals, two PCBs, and
dioxins/furans were identified in Bum Pits soils. The PHE estimated the risk posed by each of
these metals or chemicals. Based upon the estimated health risks, and detection frequencies,
the following metals and chemicals were identified as targets for remedial action:
METALS
Arsenic: Classified as a Group A carcinogen by ingestion and inhalation (known human
carcinogen).
Cadmium: Classified as a Group Bl carcinogen by inhalation (probable human carcinogen,
limited human data).
Chromium III: Non-carcinogenic; inhalation is associated with nasal mucosa atrophy.
Chromium VI: Classified as a Group A carcinogen by inhalation.
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.
VOLATILE ORGANIC CHEMICALS
1,2-Dichloroethene: Non-carcinogenic; inhalation is associated with CNS depression.
Tetrachloroethene: Classified as a Group B2 carcinogen (probable human carcinogen,
combination of sufficient evidence in animals and inadequate or no evidence in humans).
Trichloroethene: Classified as a Group B2 carcinogen.
6.1.2 Exposure Assessment
Seven exposure points were considered for the PHE:
• The current depot resident: a residence for the base Commander is located 600
feet east-southeast of the Burn Pits. In the past, occupants have been assigned
on 2- to 3-year rotations, so no one family lives at the residence for more than 3
years. Currently no one lives at the residence.
• Current depot employees: depot employees work at several locations in the
vicinity. For the PHE, the nearest depot employees were considered to be those
about 600. feet northeast of the Bum Pits, since this location is more often
downwind than other worker areas.
ER33-K1993) Part II, Page 10 24-150029-A41
-------
• Future on-site recreational user: a portion of SAAD is being evaluated for
Natural Resources Restoration. Future users could include hikers, picnickers,
and people playing.
• Future on-site workers: the area is zoned light industrial, and potential new
business built on die Bum Pits could include indoor and outdoor workers.
• Current and future off-site residents: the nearest off-site resident is located about
1,800 feet southwest of the Bum Pits, and does not have a well. No future
residents, other than this one, are expected due to the industrial zoning.
• Current and future off-site business with a well: the nearest off-site business
with a well is located about 1,100 feet southwest of the Bum Pits. Since city
water is provided to the area, future businesses with wells are not anticipated.
• Current and future off-site business without a well: the nearest current off-site
business is located about 600 feet west of the burn pits. This business is as
close to the Bum Pits as an off-site business can be.
Additionally, one worst-case exposure point was requested by the EPA for inclusion as a point
of comparison: future on-site resident with a well. This exposure point is highly unlikely,
since the area is zoned industrial, is surrounded by industries, and has access to municipal
water. Locations of potential exposure points are shown on Figure 10.
Since site groundwater has been impacted by VOCs from the Bum Pits, the assumption was
made that, in the absence of remediation, contaminants presently in the Bum Pits soil will
continue to migrate to groundwater. Other assumptions for the PHE were: contaminants in
site soils may eater the atmosphere as windblown dust, and individuals on site may contact or
ingest soil. Thus, the following exposure pathways were considered:
For on-site individuals:
• dust inhalation;
• soil vapor inhalation;
• groundwater vapor inhalation;
• dermal absorption from soil;
• soil ingestion;
• groundwater ingestion; and
• dermal absorption from groundwater,
ER33-I(1993) Part II, Page 11 24-1S0029-A41
-------
LJLJ
Fire Fighting
Training Area
Battery Disposal Well
O
on
ELDER
CREEK
ROAD
D
LEGEND
APPROXIMATE SCALE in FEET: V - 600'
0 100 300 600
1300
—•••—•—• Site Boundary
Buildings / Structures
On-Depot Resident (currently vacant)
Depot Worker
Future On-Site Recreational User
Future On-Site Business
Off-Site Residential
Off-Site Business with a Well
Off-Site Business without a Well
KLEINFELDER
PROJECT NO.
24-150028-A07
SITE VICINITY MAP
SHOWING POTENTIAL EXPOSURE POINTS
SACRAMENTO ARMY DEPOT
SACRAMENTO, CALIFORNIA
FIGURE
10
-------
For off-site individuals:
• dust inhalation;
• groundwater vapor inhalation;
• groundwater ingestion; and
• dermal absorption from groundwater.
Soil sample analytical results were used to calculate average and upper-bound concentrations of
chemicals found at the Burn Pits Operable Unit. The calculated upper-bound concentration for
each chemical is the 95 percent upper confidence limit (UCL) concentration, calculated by
finding the mean and adding twice the standard deviation. The 95 percent UCL concentrations
for chemicals found at the Bum Pits are presented on Table 1. Upper-bound chemical
concentrations were used for calculating exposure point concentrations for each of the
exposure pathways listed above.
Exposure point concentrations for each exposure pathway were based upon the following:
• Dust inhalation, dermal absorption from soil, and soil ingestion -.For a current
SAAD resident and employee, average concentrations of contaminants in
surface soil (0 to 1 foot) covering the two Bum Pits were used as exposure point
concentrations. Future on-site, and future and current off-site exposure
concentrations were calculated based upon the 95 percent UCL concentrations in
Unit 1 soils (0 to 20 feet within the two Burn Pits).
• Soil vapor inhalation - Potential soil vapor concentrations were calculated based
upon the 95 percent UCL concentrations of VOCs in Unit 1 soil samples.
• Groundwater vapor inhalation, ingestion, and dermal absorption - The potential
contribution of contaminants to groundwater from the vadose zone, and the
maximum average exposure concentrations in groundwater were estimated using
two computer models. The upper-bound chemical concentrations in the soil,
which were assumed to remain constant over time, were input to a vadose zone
model (SESOIL) to derive upper-bound leachate concentrations. These
calculated leachate concentrations were then input to a transport model
(AT123D) to estimate contaminant migration in groundwater to off-site
exposure points. The modeling results were used to calculate the maximum
average exposure point concentration for off-site receptors with wells, assuming
a 30-year exposure for residents and a 25-year exposure for businesses. The on-
site residential exposure-point concentrations for groundwater were estimated by
using 30-year leachate concentrations as input to AT123D. Groundwater vapor
concentrations were calculated using Henry's Law Constant.
ER33-1(1993) Ptitn,P*gel2 24-150029-A41
-------
The equations used to estimate contaminant intake and the values chosen for various intake
parameters were derived from standard intake equations presented in EPA's guidance
documents for conducting health risk assessments. Chronic Daily Intake (GDI), the amount of
each chemical that could be inhaled, ingested, or absorbed, was estimated for VOCs, metals,
PCBs, and dioxins/furans.
The GDIs were then multiplied by chemical-specific slope factors (SF) to calculate
carcinogenic risk. The SF represents the 95 percent UCL value of the probability of a
carcinogenic response per unit intake of a contaminant over the exposure period (25 years and
30 years for the business and resident, respectively). Standard SF values approved by EPA
were used for each of the chemicals, except lead, found at the Burn Pits. A SF has not been
established for lead.
To calculate the Health Hazard Index (HHQ for non-carcinogenic risks, the GDIs were divided
by chemical-specific Reference Dose (RfD) values. The RfD 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 (25 and 30 years for the business and
resident, respectively). RfDs were available for each of die metals and chemicals, except lead.
EPA Health Criteria are not available for lead at this time.
Several RfDs and SFs were derived by extrapolation, because the toxicity values were not
available. This was done for chemicals that may have systemic effects which could occur if
the chemical was absorbed at the point of exposure. In most cases, oral toxicity values were
used to derive toxicity values for inhalation or dermal absorption. These extrapolations were
performed by first expressing the oral toxicity value as an absorbed dose (i.e. by multiplying
the oral toxicity value by the estimated fraction of the chemical that is absorbed orally).
Dermal toxicity values were derived directly from the absorbed doses. Toxicity values for
inhalation were derived by dividing the absorbed dose by the fraction of the chemical that is
absorbed following inhalation.
6.1.3 Summary of PHE Results
The PHE estimated the potential non-carcinogenic and carcinogenic risks posed by each of the
chemicals of concern at the Bum Pits Operable Unit to individuals at current and potential
future exposure points. Dose-response criteria are not available for lead, so it was evaluated
separately.
ER33-1(1993) Part n, Page 13 24-150029-A41
-------
The primary carcinogenic chemicals of concern at the Burn Pits Operable Unit were identified
based on die PHE as follows: TCE, PCE, arsenic, cadmium, chromium VI, and lead. The
calculated carcinogenic risks from TCE, PCE, and metals at each exposure point are
summarized in Table 3.
Neither the PCBs nor the dioxins/furans were identified as primary chemicals of concern
because of the low levels detected, which were below regulated levels and within the
acceptable risk range. PCBs were detected in the soil at concentrations less than 1 ppm, below
levels requiring remedial action. See "Guidance on Remedial Actions for Superfund Sites with
PCS Contamination', OSWER Directive No. 9355.4-01. Dioxins/furans were detected in the
soil at concentrations less than 1 ppb. The EPA Diootin Disposal Advisory Group had
indicated that no remediation is warranted when dioxin/furan levels are less than 1 ppb for
residential areas or less than 20 ppb for industrial or non-residential areas. See "General
Approach Used By the Dioxin Disposal Advisory Group (DDAG) Regarding
Pentachlorophenol Waste (also PCBs)*, November IS 1988.
As a National goal, the EPA's target risk range is 10"4 to 10~*>, or one incidence of cancer per
10,000 people to one additional incidence of cancer per 1,000,000 people. The total estimated
carcinogenic risks from each of the carcinogenic chemicals due to the combined effects of all
pathways are approximately:
• less than one excess cancer per 1,000,000 people for Current Depot Employees;
• less than one excess cancer per 1,000,000 people for Current Depot (3-year)
Resident;
• one excess cancer per 100,000 people for Future Qn-site Recreational Users;
• three excess cancers per 100,000 people for Future On-site Workers;
• one excess cancer per 100,000 people for Current and Future Off-site Residents;
• less than one excess cancer per 1,000,000 people for Current and Future Off-
site Businesses with Wells;
• less than one excess cancer per 1,000,000 people for Current and Future Off-
site Businesses without Wells; and
• one excess cancer per 10,000 people for Future On-site Residents.
Thus, the baseline risks estimated for Future On-site Recreational Users, Future On-site
Workers, Current and Future Off-site Residents, and Future On-site Residents are within the
target risk range, but greater than 10~°.
ER33-K1993) Part U, Ptge 14 24-150029-A41
-------
TABLE 3
ESTIMATED TOTAL CARCINOGENIC RISKS FOR EACH OF THE PRIMARY CARCINOGENS
BURN PITS OPERABLE UNIT
CHEMICAL
Trichloroethene
Tetrachloroethene
Arochlor 1254
Arochlorl260
Arsenic
Cadmium
Chromium VI
Lead
TOTAL
•:'' '••••• -;•;.;•• ;••-•••.• ^.: TOTAL CARCINbGENIC RISK -t:^^^
PRIMARY EXPOSURE POINT
Current Depot
Resident
(3-year)
3.1E-11
3.2E-12
NC
NC
2.3E-09
1.1E-08
8.0E-09
NC
2E-08
Current
Depot
Employee
2.9E-10
3.1E-11
NC
NC
6.5E-09
1.0E-07
5.7E-08
NC
2E-07
Future
On- Site
Recreational
User
2.9E-09
3.5E-09
1.1E-06
3.4E-07
:;; o.oE-08
8.5E-07
7.5E-07
NC
1E-05
Future
On-Stte
Worker
7.1E-09
7.4E-09
2.6E-08
7.8E-07
1.8E-05
3.9E-08
3.4E-OB
NC
' ''• ''!Xy 3E-05
Current ft Future
Off-Site
Resident
7.1E-06
2.8E-06
NC
NC
1.4E-08
1.5E-08
1.3E-09
NC
IE-OS
Current & Future
OK- Site
Business
with well
5.7E-08
8.2E-08
NC
NC
1.7E-08
1.9E-08
1.7E-08
NC
2E-07
Current ft Future
Off-Site
Business
without well
6.2E-14
4.0E-14
NC
NC
8.6E-08
8.4E-08
8.4E-08
NC
3E-07
TOTAL
CARC. RISK
WORST-CASE*
Future
On- Site
Resident
With Well
2.4E-05
8.3E-06
7.8E-06
2.4E-06
8.3E-05
6.SE-06
S.BE-06
NC
IE- 04
•: Worst-case exposure not considered likely, but Is Included as a point-of-reference at the request of EPA, Region IX
NC: Not calculated, slope factor not available for applicable exposure routes.
14-IMOM-A4I
-------
As discussed in Section 6.1.2 of this ROD, the Future On-rite Residents scenario is highly
unlikely. Therefore, the most exposed individual is likely to be the Future On-site Worker.
The risks to this individual are attributable primarily to ingestion of arsenic, inhalation of dust
containing arsenic, cadmium, and chromium VI, and absorption of Arochlor 12S4 through
direct contact with soil.
Other individuals potentially exposed to a risk greater man 10"° would be the Future On-site
Recreational User and the Current and Future Off-site Residents. Risks to the Recreational
User are attributable primarily to ingestion of arsenic in soil. Risks to Off-site Residents are
primarily from inhalation of ICE and PCE vapors from groundwater while showering.
For non-carcinogenic risks, an Hffl greater than 1.0 indicates a potential health threat. The
total estimated HHTs from each of the contaminants due to the combined effects of all the
pathways are shown on Table 4. Total HHIs for the Future On-site Worker and the Future
On-site Resident with a well exceed 1.0, with index values of 4.2 for the former and 9.5 for
the latter.
An RfD value was not available for lead, and therefore lead was not included in the HHI
calculation. However, for lead, which may cause decreased neurological development in
children younger than 6 years, the 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. The results can then be evaluated by comparing them to the level which the
EPA estimates will cause adverse affects in children [10 micrograms per deciliter (ug/dl) for 0-
to 6-year-old children , U.S. EPA, 1990].
Potential non-carcinogenic health effects from exposure to lead in soil at the Bum Pits were
estimated by EPA for the exposure points most likely to include 0- to- 6-year-old children:
Current On-site Residents and Future On-site Recreational Users or Residents. As a
conservative assumption, the model for children was used.
Under current conditions, the Current On-site Resident's exposure to lead in the Burn Pits
would result in an average blood lead concentration in children of 4.1 pg/dl. Considering a
range of blood lead levels, an estimated 99.5 percent of children at this exposure point would
have blood lead concentrations less than the recommended 10 jig/dl limit
The risk to the Future On-site Recreational User or Future On-site Resident from lead
exposure was estimated using the 95 percent UCL lead concentration, which is 506.9 mg/kg.
At mis concentration, potential exposure to lead in the Bum Pits would result in an average
ER33-1(X993) Part n, Page 15 24-1S0029-A41
-------
TABLE 4
ESTIMATED TOTAL HAZARD INDICES FOR EACH OF THE PRMARY NON-CARCINOGENIC CONTAMINANTS
BURN PITS OPERABLE UNIT
: CHEMICAL
TdUMtt
XytanM
TiteMonxBxnt
1.2-OfcMt»M0wn»(d«)
TckMNorMtom
Dt-N-BuMpMlwM*
Affl^MMV
Amok
Baron
Ccdmkm
ChrontonM
CtvnrtumVt
COMMT
L«ri
MMHWIM.
KMfowy
I^^«|M^MMMM
MOTymiBjvwvn
Sftrar
Zhw
TOTAL
•- . V: :' / • v •'• '•'• ' : -'•• '." ?.v : ; :' TOTAL HAZARD INDEX-'- ' •• • ' f " V ;' I? ' v^l'-'^ '-:-';
PRIMARY EXPOSURE POINT
On-Dcpot
Ttra-Yw
fwwOM'lt
0.4 E-M
0.0 E+M
2.SE-07
NC
O.OE400
1.1 E-M
NC
0.0 E+M
2.0 E-M
1.1 E-M
1.1 E-M
0.0 E-M
4.0 E-02
•lOE-M
NC
O.OE-fM
1JE-M
0.0 E-M
1.1 E-OT
t.»E-M
• E-aa
On-D«pot
Wwk«
2.0E-07
0.1 E-M
7.4E-07
NC
1.3 E-M
2.4 E-M
NC
2.tE-04
1.1 E-M
2.1 E-M
0.2 E-M
0.4 E-<»
0.0 E-M
1.0 E-OT
NC
2.1 E-M
07 E-M
1.ZE-07
2.0 E-M
1.0 E-M
0E-02
Futur*
On-SK*
R*cr«ritoMl
UMf
1.0 E-M
1.4 E-M
1.4 E-M
NC
0.0 E-M
1.0 E-M
1.0 E-M
0.0 E-0>
S.0E-02
1.1E-04
1.1 E-01
0.0E-01
7.0E-02
4.0 E-M
NO
2^ E-M
0.0E-04
0.0 E-M
1.0 E-M
0.2 E-M
0E-01
Firtura
On-Sto
Wtelnr
0.0 E-M
4.0 E-M
1.0 E-M
NC
3.0 E-M
0.0 E-M
3.4 E-M
1.2 E-01
0.4 E-M
2.3 E-M
2.1 E-01
;*3iE+00
4^ E-01
0.0 E-M
NC
1.0 E-01
1.0 E-M
0.7 E-M
3.0 E-M
1.1 E-m
4E4-00
OB-Slto
ftotldtnt
1.0E-11
2.1 E-OS
1.0 E-M
NC
0.0 E-01
0.2E-02
NC
1.0 E-M
0.4E-07
3.0 E-M
1.2 E-M
1.1 E-02
1.3 E-M
8.0 E-M
NO
2.0 E-M
1.TE-OT
1.0 E-M
2.0 E-OT
T.3 E-OT
10 E-01
Ofl-Sto
BMhMM
wNhwtd
2.3 E- 11
ME-OT
0.TE-OT
NC
1.0 E-M
3.4 E-M
NC
2.4 E-M
07 E-OT
10 E-M
1.0 E-M
1.0 E-M
2.0 E-M
0.0 E-M
NC
4.0 E-M
2.0 E-OT
2.0 E-M
3.0 E-OT
1.1 E-M
2 E-02
Off-Sib
Bu»lim»
without w«l
1.1 E-10
ME- 10
1.2 E-M
NC
0.0 E-10
1.TE-M
NC
1.2 E-M
4.0 E-M
2.0 E-M
0.0 E-M
7.0 E-02
1.0E-OJ
4.4 E-OT
NC
2.2 E-M
1.3 E-M
1.2 E-OT
1.0 E-M
0.8 E-M
OE-M
• TOTALS
MQ/NQ-OAV
WORST CASE*
Fuh»»
On-Ste
•^•l«0Wrf
nwovfn
VWhW««
1.3 E-M
4.3 E-M
T.0E-M
NC
''itie+wv"y-'
2.1 E-01
1.3 E-M
4.0 E-01
10 E-01
0.1 E-M
7.4 E-01
•;?a$$ij$$'&$\ff"
•^4«E*»:^r;-
0.0 E-01
3.4E-02
NC
1.7 E-01
0.0 E-M
3.0 E-M
1.3 E-M
4.4 E-02
: »E+M
TOTAL M.
FOR
SEVEN
PRIMARY
. EXPOSURE
POINTS
' ONLY
0.0
0.0
0.0
NC
0.0
0.1
0.0
0.2
0.1
0.0
0.3
A'V'.*' .''M
0.0
o.m
NC
0.1
0.0
0.0
0.0
0.02
NC: NotCakufaML EMtwwpoMicprtfMy dtMtnatapplytoMtcxiKMui^potnior RIOnol«v«lhkbl»«Of chwnlod
E3a.02-10.WK1
24-150020-A41
-------
blood lead concentration in children of 12.2 Mg/dl. An estimated 32 percent of children at this
exposure point would have blood lead concentrations less than die recommended limit.
In summary, the baseline risk assessment indicates a potential non-carcinogenic health threat to
the Future On-site Worker, the Future On-site Recreational User, and the Future On-site
Resident (an unlikely scenario) from contaminants at the site. The risk to a Future On-site
Worker is primarily from inhalation of dust containing chromium m. The risk to a Future
Qnrsite Recreational User is from exposure to lead. Although a Future On-site Resident would
be at risk for non-carcinogenic health effects, this scenario is unlikely to occur, and was not a
factor in developing cleanup objectives.
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 Bum Pits Operable Unit include:
• Site Characterization - Chemicals may exist in localized "hot spots", 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 "not detected" are assigned a value of half the
detection limit for the purpose of calculating site concentrations; and (2) the
PHE assumes that chemical concentrations in soil and groundwater remain
constant over the 25- and 30-year exposure periods, 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 is primarily a disturbed annual grassland ecosystem. No threatened plant or
animal species inhabit the site. The Burn Pits are located in a grassland area, and a landscaped
area is located east of the site. Several bird species have been observed at the site, and
fackrahbits and gophers inhabit the grassland area. No wetlands or vernal pools have been
identLied in the Bum Pits area.
ER33-I(I993) Part II, Page 16 24-150029-A41
-------
In summary, significant ecological resources have not been found in the Bum Pits Operable
Unit The area may be disrupted as a consequence of excavation activities during remediation,
but significant habitat disruption is not anticipated.
6.3 Threat to Groundwater
Soil data from the remedial investigation indicates that the VOC contamination at the Bum Pits
is the primary source of groundwater contamination at SAAD, but mat the non-volatile
constituents (heavy metals, PCBs, dioxins, and furans) are not a threat to groundwater.
Because the VOCs have impacted groundwater quality, the Burn Pits are subject to California
Code of Regulations Title 23, Chapter 15, Section 2S10(g), which provides for groundwater
monitoring of discharges at closed waste managements units as for corrective action if water
quality impairment is found. However, section 2Sll(d) exempts cleanup actions taken by
public agencies from Chapter IS requirements, provided mat die VOCs removed by soil vapor
extraction are disposed of at an appropriate off-site facility. The existing groundwater
monitoring program and remediation under the Groundwater ROD, in conjunction with the
implementation of VOC soil remediation under this ROD, will satisfy the monitoring and
corrective action requirements of Chapter 15.
Remedial investigation data showed that total metals in the Burn Pits Unit 1 soils are above
background soil concentrations. However, groundwater and soils outside Unit 1 have not been
impacted, indicating that the metals are relatively immobile and do not pose a threat to
groundwater quality. To further verify this conclusion, the Army conducted deionized water
waste extraction tests (DI-WET) on soil samples from Unit 1, in accordance with the Central
Valley Regional Water Quality Control Board's water quality site assessment (WQSA)
procedures. The results confirmed that the potential leachate from Unit 1 would not pose a
threat to groundwater.
6.4 Remedial Action Objectives
Based upon the results of the PHE and the objective of reducing the potential for migration of
contaminants to groundwater, the Army, EPA and the State developed remedial action
objectives (RAOs) for contaminants at the site. Specific RAOs were developed for those
contaminants identified as being primarily responsible for the assessed health risks: arsenic,
cadmium, chromium, lead, 1,2-DCE, TCE, and PCE. Specific RAOs were not developed for
PCBs or dioxins/furans because the low levels found at the site do not warrant remediation
(see Section 6.1.3). However, when remediation alternatives were evaluated, preference was
ER33-1(1993) P«tII,P«gel7 24-150029-A41
-------
given to the alternatives which would reduce potential risks posed by these chemicals. The
objective of the remedial action is to clean up the soil so that public health is protected and
contaminants present above background levels are reduced so that there is no migration to
groundwater. Any residual VOC contamination reaching groundwater will be cleaned up by
the existing groundwater extraction and treatment system.
The four RAOs are:
• To reduce the potential for inhaling arsenic, cadmium, and chromium in dust to
an acceptable risk level (1.0 E-6 for carcinogens or HI = 1.0 for
noncarcinogens) by reducing either the metals concentrations in soil or the
amount of potential dust by 75 percent. Maximum residual concentrations in
soil would be: arsenic 7.3 mg/kg (background concentration), cadmium 88
mg/kg, total chromium 112 mg/kg, and chromium VI 16 mg/kg. These
concentrations were estimated using the acceptable risk levels and chemical
intake equations for industrial exposures.
• To reduce the potential for ingesting arsenic in soil so that risk is reduced to
background level, by either reducing the concentration of arsenic to the
background level (7.3 mg/kg) or reducing the amount of soil which can be
ingested by 81 percent.
• To reduce migration of VOCs to groundwater above the groundwater cleanup
levels (drinking water standards) established in the existing Groundwater ROD.
TCE, 1,2-DCE, and PCE concentration must be reduced by 98 percent, 96
percent, and 92 percent respectively. These reductions correspond to soil
concentrations of 5 ug/kg or less and soil gas concentrations of 5 ppb or less.
• To reduce lead concentrations in soil to 174 parts per million or less, which is
the concentration that is recommended by DTSC of the Cal EPA for lead
exposures to children, ages 1-6 years. This requires reducing lead
concentrations in soil or reducing the potential for ingestion of soil containing
lead by 92 percent.
7 DESCRIPTION OF ALTERNATIVES
An OUFS was conducted to develop remediation alternatives for the Burn Pits Operable Unit.
Forty-seven remediation alternatives were assembled from applicable remediation technology
options, and were initially evaluated for effectiveness, institutional implementability, and cost.
Six alternatives for remediating soil at the Bum Pits passed the initial screening, and were then
evaluated by comparing them to the nine criteria required by the National Oil and Hazardous
substances Pollution Contingency Plan (NCP). The remediation alternatives emphasize the use
of technologies which reduce toxicity, mobility, or volume (TMV) of contaminants, and which
ER33-K1993) Pmrt II, Page 18 24-150029-A41
-------
provide a permanent solution. In addition to the remediation 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 six
alternatives evaluated are:
Alternative 1: No Action
Alternative 2: Capping of entire Bum Pits Operable Unit
Alternative 3: In-situ soil ventilation of the entire Burn Pits Operable Unit; controls to limit
surface soils exposures
Alternative 4: In-situ soil ventilation of the Entire Burn Pits Operable Unit; capping of Unit 1
Alternative 5: In-situ soil ventilation of the entire Bum Pits Operable Unit; excavation of Unit
1; soil washing of excavated soil; backfilling with treated soil
Alternative 6: In-situ soil ventilation of the entire Bum Pits Operable Unit; excavation of Unit
1; Stabilisation of excavated soil; backfilling with stabilised soil
Each alternative would be applied to remediate approximately 247,900 cubic yards (cy) of soil:
16,900 cy are located within the two Burn Pits and contain volatile and semi-volatile organic
chemicals, metals, PCBs, and dioxins/furans; 231,000 cy are located outside the Bum Pits and
contain volatile and semi-volatile organic chemicals.
The Burn Pits contain RCRA characteristic wastes, based on toxicity, including the metals
arsenic, cadmium, chromium, lead, and the VOCs 1,2-DCE, TCE, and PCE. Although the
Bum Pits would be considered a RCRA landfill if they were in use today, the pits have not
been used for waste treatment and disposal since 1966, prior to the effective date of RCRA.
Therefore, the only applicable RCRA requirements are those triggered by the action-specific
components of the various alternatives, as described below. However, for alternatives which
include a RCRA-type cap, RCRA closure requirements have been determined to be relevant
and appropriate. Because the state of California's RCRA program has now been authorized to
operate in lieu of the federal RCRA program, the RCRA ARARs for the Bum Pits ROD are
state RCRA regulations.
7.1 Alternative 1: No Action
Under this alternative, the Army would take no further action to control the source of
contamination. However, volatile organics would continue to contaminate the groundwater.
Therefore, because the No Action alternative does not pass the threshold criterion of
protectiveness, no further evaluation of ARARs or detailed assessment is required.
ER33-1(1993) Put U, Page 19 24-1S0029-A41
-------
7.2 Alternative 2: Capping of the Entire Bum Pits Operable Unit
Alternative 2 consists of covering the entire Bum Pits Operable Unit to inhibit exposure to
surface soils and to impede infiltration of rainfall or runoff into the contaminated soil. The
cap would be designed as a surface water collection and removal system. From top to bottom,
it would consist of a cover, a drainage zone, a flexible membrane liner (FML), and a
secondary clay liner.
The cover would consist of a 2-foot thick soil layer with vegetation. Under the cover, the
drainage zone would consist of a one-foot thick layer of granular material, such as gravel.
This granular layer would allow water to drain from the soil/vegetation layer, and would also
inhibit burrowing animals from damaging the FML. Water drained from this layer would be
collected in perimeter ditches and transported via an underground culvert or PVC piping to
Morrison Creek. Under the granular material, a 2-inch thick sand bed would help protect the
underlying FML. The FML would be about 30 milliliters thick. Beneath the FML, a 2-foot
thick, day liner would further impede infiltration from the surface. The clay liner would be
compacted to reduce its permeability to 1 X 10-7 centimeters per second or slower. The cap
would be constructed with a slope of 3 to 5 percent to promote drainage away from it into
perimeter ditches.
Overall protection of human health was evaluated based on the ability of the cap to prevent
surface exposures to metals and reduce VOC concentrations in leachate. A cap would act as a
thick barrier to nearly eliminate all contact with the surface soil. Exposures would occur only
if the cap was inadvertently disturbed, for example, through excavation of the soil. Fate and
transport modeling indicates that TCE and PCE concentrations will be reduced by 73% and
90%, respectively, by capping using a typical cap design. A cap is expected to meet the
protectiveness of human health criterion by reducing risk to within the EPA's 10"4 to 10~*>
target risk range.
Capping wfll reduce health risks to on-site and off-site receptors due to dermal contact,
inhalation, and/or ingestion of metals, dioxins, furans, and PCBs in soil and fugitive dust
Periodic maintenance of the cap would be required to ensure its integrity. Following
completion of the remedial action and prior to any sale or other transfer of the portion of
SAAD property where the Burn Pits Operable Unit is located, the Army would record a land
use restriction as an institutional control to prohibit future disturbance of the hazardous
substances remaining in the soil, in accordance with California Health and Safety Code
ER33-I(l»3) P«tn.Pige20 24-150029-A41
-------
§ 25230. In addition, the Army would provide notice of this restriction in any purchase,
lease, or rental agreements relating to that portion of the property.
Since the contaminated soil and debris will be allowed to remain in-place under this
alternative, capping does not provide long-term control of human exposure to volatile organic
compounds in groundwater at levels that may be harmful. Vapor phase vadose zone
monitoring, to detect leaching from the capped area would be required.
ARARs
ARARs for Alternative 2 are listed on Table A-l in Appendix A. Capping can be performed
in compliance with ARARs.
Under Alternative 2, the wastes would be left in place and covered with a cap that meets
RCRA specifications. Long-term monitoring and maintenance would be conducted to ensure
the effectiveness of the cap. Although not applicable, RCRA closure requirements for cap
design specifications, long-term monitoring and maintenance would be relevant and
appropriate.
Because the VOCs have impacted groundwater quality, the Burn Pits are subject to California
Code of Regulations Title 23, Chapter 15, Section 2510(g) monitoring and corrective action
requirements are applicable; see Section 6.3. Section 2581 final cover requirements for
landfill closure would also be applicable for Alternative 2.
7.3 Alternative 3: In-situ Soil Ventilation of the Entire Burn Pits Operable Unit; Controls to
Limit Surface Soils Exposures
Alternative 3 consists of using soil ventilation to extract volatile organic chemicals from the
subsurface. A soil sealant would be applied annually to control dust, and site access would be
limited to reduce the potential for soil ingestion, dermal absorption, and inhalation.
Soil Vapor Extraction fSVE> (Alternatives 3. 4. S. and 6)
The SVE system consists of: a) air extraction wells, b) a vacuum pump/rotary blower, and c) a
system of carbon adsorption canisters (CACs).
The pump/rotary blower pulls a vacuum at the extraction wells thus mobilizing the
contaminated soil gas in the soil pore spaces. Air sampling at the well heads will be
ER33-1(1993) P«rtII,P»ge21 24-150029-A41
-------
performed periodically to evaluate the effectiveness of the SVE system and to identify vadose
zone hot spots.
The extracted contaminated air will be routed through CACs to capture the VOC contaminants
for treatment The CAC exhaust will be monitored to assess compliance with air emission
standards, and the treated air will be discharge to the atmosphere. Carbon treatment of vapors
typically achieves an organic removal efficiency of 90 percent Multiple CACs in series will
be used, if necessary, to meet the Sacramento Metropolitan Air Quality Management District
(SMAQMD) air discharge requirements. The spent CACs will be transported off-site for
disposal or recycling.
All extracted vapor will be routed through an air/water separator to separate entrained water,
and through a paniculate air filter prior to routing through the CACs. The entrained water
will be routed for treatment to the existing on-site groundwater treatment plant
Because the Bum Pits (Unit 1) contain heavy metals, PCBs, dioxins and furans, paniculate air
filters capable of removing such contaminants adsorbed onto paniculate matter from Unit 1
will be used on Unit 1 wells. Based on remedial investigation data, PCBs, dioxins or furans
are not major contaminants of concern. However, the filters are included as a
safety/contingency component so that these particulates and chemicals, if any, do not reach the
pump and emissions control equipment (the CACs). The spent HEPA filters will be disposed
of at an off-site facility as hazardous waste.
Also, because the mixture of soil and debris in Unit 1 is highly permeable, Unit 1 may be
temporarily covered during ventilation to reduce the potential for air channeling.
For Unit 1, treatability study results indicate that a ventilation rate of 200 cubic feet per
minute (cfm) could accomplish remediation. For Units 2 thru 5, higher ventilation rates, a
minimum of 500 cfm, are required.
Implementation of soil venting at Units 1 through 5 will reduce risk to human health from
TCE, PCE, and 1,2-DCE via ingestion, absorption, or inhalation of vapors from ground water
to meet RAO No. 3.
ER33-K1993) Part 0, Page 22 24-150029-A41
-------
Controls to Limit Surface Soil Exposures
A soil sealant will be applied to the surface of Unit 1 to control dust The sealant would
penetrate and stabilize the surface soil, and would resist natural erosion. The sealant would be
re-applied annually.
Maintenance of dust control and use restrictions to Unit 1 will protect human health by
preventing dermal exposure to soil, inhalation of fugitive dust, and ingestion of soil that
contains metals, PCBs, and dioxins/furans. These controls are expected to achieve'the
exposure reductions required by RAO Nos. 1 and 2. RAO No. 4 would be achieved through
dust control and limiting of site access. Following completion of the remedial action and prior
to any sale or other transfer of the portion of SAAD property where the Bum Pits Operable
Unit is located, the Army would record a land use restriction as an institutional control to
prohibit future disturbance of the hazardous substances remaining in the soil, in accordance
with California Health and Safety Code § 25230. In addition, the Army would provide notice
of this restriction in any purchase, lease, or rental agreements relating to that portion of the
property.
ARARs
ARARs for Alternative 3 are listed on Table A-2 in Appendix A. Soil ventilation with dust
control can be performed in compliance with ARARs.
RCRA tank requirements are applicable to the activated carbon unit used for the treatment of
vapors from the SVE system. The carbon units and HEPA filters will be disposed of at an
appropriate off-site facility.
7.4 Alternative 4: In-situ Soil Ventilation of the Entire Burn Pits Operable Unit; Capping of
Unitl
Alternative 4 combines the cap component of Alternative 2 with the soil ventilation component
of Alternative 3. The cap would be designed as a barrier to limit exposure to surface soils, but
not to limit water infiltration, since mobile contaminants would have been removed by
ventilation.
Cap
The cap would consist of a one- to two-foot thick layer of compacted soil. Vegetation would
be planted on the cap to impede erosion and increase soil stability. The vegetative root zone
ER33-1(1993) Put II, Page 23 24-1S0029-A41
-------
would increase the capacity of the cap to hold water, thereby decreasing infiltration. The cap
would be constructed with a slope of about 3 to 5 percent to direct runoff away from it. On-
going maintenance would be required, including visual inspections and repairs.
This alternative meets the RAOs. RAO Nos. 1, 2, and 4 are met by the protective barrier cap.
RAO No. 3 is met by reducing the total mass of volatile contaminants in the subsurface to non-
detectable levels.
The debris in the Bum Pits will remain under mis alternative. However, the cap will reduce
rain, water infiltration and provide a measure of reduction in the threat of a chemical release
and migration to groundwater. Vapor phase vadose zone monitoring will be used to monitor
potential unknown releases from the debris.
Following completion of the remedial action and prior to any sale or other transfer of the
portion of SAAD property where the Burn Pits Operable Unit is located, the Army would
record a land use restriction as an institutional control to prohibit future disturbance of the
hazardous substances remaining in the soil, in accordance with California Health and Safety
Code § 25230. In addition, the Army would provide notice of this restriction in any purchase,
lease, or rental agreements relating to that portion of the property.
ARARs
ARARs for Alternative No. 4 are listed in Table A-3. Soil ventilation with capping can be
implemented in compliance with ARARs.
RCRA tank requirements are applicable to the activated carbon unit, as described for
Alternative 3. RCRA landfill closure requirements are relevant and appropriate. Unlike
Alternative 2, the Alternative 4 cap is designed to limit surface exposure but not water
infiltration, since the VOCs would be removed by SVE. Only limited long-term maintenance
and monitoring would be required. Therefore, RCRA closure requirements for a hybrid-
landfill closure would be relevant and appropriate.
7.5 Alternative 5: In-situ Soil Ventilation of the Entire Bum Pits Operable Unit; Excavation
of Unit 1; Soil Washing of Excavated Soil; and Backfilling with Treated Soil
Alternative 5 consists of using soil ventilation to remove VOCs from Units 1 through 5,
excavating soil contaminated with metals from Unit 1, washing the soil to remove the metals,
ER33-1(1993) Part II, Page 24 24-150029-A41
-------
and replacing die washed soil in the excavation. Soil ventilation would be conducted as
previously described for Alternative 3.
Soil Washing
During soil excavation, dust would be controlled using water or foam sprays. At the time of
excavation for soil washing, solid debris will be segregated from the soil. Hazardous debris
will be separated from the general non-hazardous debris. Non-hazardous debris will be
washed using physical abrasion, water, and/or pressurized water. The residues from the
washing will be treated along with other water during the soil washing process.
Hazardous debris will be treated at the BDAT standards for hazardous debris, using physical
extraction or chemical extraction technologies. Residuals will be managed according to
requirements either by discharge to the sewer, by inclusion of the residual in the soil washing
process, or by shipping the residual offsite to a facility that can apply BDAT treatment for the
constituents in the residual. All debris after treatment will be disposed of offsite.
The soil washing unit would consist of a size segregation device, mix reactors, and a de-
watering device. Oversized soil particles will be segregated, using wet screens to physically
remove contaminants from the larger-sized fraction. The segregated, lower-sized fraction
would be combined with a washing reagent in a mix reactor. Based upon treatability testing
results, a dilute acid solution would likely be used. Composited samples of the washed soil
would be chemically analyzed to assess whether cleanup has been successful. The clean soil
would then be used as backfill in the excavation.
After washing, the wash liquid would be treated on site using a chemical precipitant, and the
treated water would be disposed in a sanitary sewer. Dissolved metals would be converted to
insoluble forms, and would be separated from the rinseate using a clarifier. The sludge
containing precipitated metals would be de-watered on site, and disposed at an off-site facility
permitted to accept hazardous waste. Stabilization of the de-watered sludge may be required
to minimize its leaching potential. As an alternative, the precipitated metals may be recovered
at an off-site metal reclamation unit. The decision to use reclamation will depend upon the
concentration of metals in the sludge, the total amount of sludge, the cost, and the availability
of a market for metals recycling.
Implementation of this alternative would protect both human health and the environment. Soil
ventilation will reduce risk posed by volatile organics that could be inhaled, ingested, or
absorbed from soil and groundwater. Estimated removal of these constituents meets RAO No.
ER33-1(1993) Put H, Page 25 24-150029-A41
-------
3. Soil washing would be performed to reduce risk to human health by inhalation, dermal
contact, or ingestion of metals found in Unit 1. To meet RAO Nos. 1 and 2 the soil washing
will need to remove metals to the following residual concentrations:
Metal
Cadmium
Total Chromium
Chromium (VI)
Arsenic
Lead
Residual Concentration
88mg/kg
112mg/kg
16mg/kg
7.3mg/kg (background)
174mg/kg
ARARs
ARARs for Alternative No. 5 are listed in Table A-4 in Appendix A. Soil ventilation and soil
washing can be implemented in compliance with ARARs.
RCRA land disposal restrictions (LDRs) treatment standards are applicable for replacement of
excavated soil containing RCRA characteristic waste. Testing indicates that the washed soil
would achieve the LDR leachability limits.
RCRA tank requirements are applicable for the activated carbon vessel used for SVE vapor
treatment. RCRA container requirements are applicable for the containers used to store and
wash excavated soil.
7.6 Alternative 6: In-situ Soil Ventilation of the Entire Burn Pits Operable Unit; Excavation
of Unit 1, Stabilization of Excavated Soil, and Backfilling with Stabilized Soil
Under mis alternative, two technologies will be utilised.
The first part of the remedy utilizes soil vapor extraction (SVE) to extract VOCs from the bum
pits and vadose zone soils in order to curtail VOC migration to groundwater, as discussed for
Alternative 3.
The second part of the remedy consists of solidification of relatively immobile contaminants
(heavy metals, PCBs, and dioxins/furans) within the bum pits (Unit 1) in order to reduce their
bioavailability (reduce potential future exposure via direct dermal contact, ingestion or
ER33-1(1993)
Part n. Page 26
24-150029-A41
-------
inhalation of fugitive dust). Because of their relative immobility, these non-volatile
contaminants are not considered a threat to groundwater. Although PCBs, and dioxins/furans
are not considered primary contaminants of concern, solidification will also immobilize those
contaminants.
Solidification
The objective of the bum pits soil solidification (stabilization) is to reduce potential future risk
to human health by reducing exposure via dermal contact and/or ingestion of contaminated site
soils, or inhalation of contaminated dust.
Stabilization will be accomplished by excavating contaminated soil from Unit 1 and mixing it
with the appropriate pre-determined quantities of cement, silicates, and water. The stabilized
soil will then be loaded into dump trucks, replaced in the excavation, and spread and
compacted by bulldozers. A layer of clean soil will cover the solidified mass.
Excavation will also remove containers and other debris which may be buried in the Bum pits.
Some of the debris may be crushed and used as aggregate in the stabilization. Other debris
will be transported off-site for treatment, recycling, or disposal.
Testing has shown that the excavated soil meets the "inert waste* classification as defined by
§2524 of Chapter IS, Tide 23 CCR. No additional requirements (such as a cap, post-closure
monitoring, or long-term maintenance) will be needed.
Following completion of the remedial action and prior to any sale or oner transfer of the
portion of SAAD property where the Bum Pits Operable Unit is located, the Army would
record a land use restriction as an institutional control to prohibit future disturbance of the
hazardous substances remaining in the soil, in accordance with California Health and Safety
Code § 25230. In addition, the Army would provide notice of this restriction in any purchase,
lease, or rental agreements relating to that portion of the property.
ER33-1(1993) Part n, P»ge 27 24-150029-A41
-------
ARARs
The ARARs for Alternative #6 are listed in Table A-5. The major ARARs for the SVE
portion of the remedy include:
a) 22 CCR 66264.192-199, RCRA tank standards for owners and operators of
hazardous waste treatment, storage, and disposal facilities applicable to carbon
adsorption canisters,
b) 22 CCR 66262.34 RCRA storage time restrictions. This requirement applies to
spent HEP A filters and CACs,
c) SMAQMD Rule 202, Sec. 301 requires the use of best available control
technology (BACT) when reactive organic emissions are greater than 0 Ibs/day,
d) SMAQMD Rule 402, requires the use of risk assessment to set emissions
standards (a 1CH health risk criteria will be used) when BACT is not sufficiently
protective.
The major ARARs for the solidification portion of this remedy include:
a) 22 CCR 66268.41 Land Disposal Restriction Treatment Standards (expressed as
concentrations in waste extract) applicable for on-site land disposal of stabilized
RCRA characteristic waste,
b) 22 CR 66264.192-199 RCRA tank requirements applicable for the cement
mixing tanks,
c) SMAQMD Rule 403 Applicable requirement that regulates operations which
periodically may cause fugitive dust emissions into the atmosphere.
8 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The six remediation alternatives were assessed using the nine evaluation criteria developed to
address CERCLA requirements. The nine criteria are:
ER33-K1993) Part H, Page 28 24-150029-A41
-------
Threshold Criteria
1) Overall Protection of Human Health and the Environment
2) Compliance with ARARs
Primary Balancing Criteria
3) Long-term Effectiveness and Permanence
4) Reduction of Toxicity, Mobility, or Volume through treatment
5) Short-term Effectiveness
6) Implementability
7) Cost
Modifying Criteria
8) State Acceptance
9) Community Acceptance
The following sections compare the six remediation alternatives in terms of each of the nine
criteria. The comparisons are summarized on Table 5.
8.1 Criterion 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
institutional controls.
Each of the alternatives except Alternative 1 (No-action) would provide protection of human
health and the environment. Risks are expected to be reduced to acceptable levels.
8.2 Criterion 2: Compliance with ARARs
The ARARs evaluations are presented on Tables A-l through A-5 in Appendix A. •
Compliance with ARARs was not evaluated for Alternative No. 1 since this alternative did not
meet the threshold criterion of protectiveness.
Alternative 2 capping would not eliminate the threat to groundwater because VOCs would be
expected to continue migrating to groundwater.
ER33-1(1993) Put II, P«ge 29 24-150029-A41
-------
Tables
Summary Comparison of Remedial Alternatives, Burn Pits Operable Unit
ALTERNATIVE
SELECTION CRITERIA
OVERALL
pROTEC-
TTVENESS
COMPLIANCE
WTTHARARs
LONG-TERM
EFFECnVENESS
PERMANENCE
REDUCTION
OFTMV
SHORT-TERM
EFFECnVENESS
IMPLEMEN-
TABILrrY
ESTIMATED
COST
feet not protect
NotAppfoMe,
fo only »
boot* long-term
XMS not redact
no
Effective, i
• carnally
expotedlo
chamois m toil of
OU.
Easily
mplemqgible
SO
Unto I-5
TOtCCtlblBDtt
Conipbei wiib
ARARt.
dp would Bttd to
Coaaawrf
a pits and could
Bdefiorate and
Doniotndnce
uuiiycr
botwBre
aobjEty.
Mtptady
zposvBi
nd/ortet
afly
S1.200JKIO
thefiane-VOa
Sofl \faungofUniu
l-SDua/Acecu
Caoooki
beallhadlhe
ARARsiftoU
CQD&OUed.
ofdust
COOBOtt
needed Lad toe
mobility tad
volume of voUnk
Ittnouy Cuec&ve
lue lo limited
vncot aponsct.
$304.000
Coalmen of
CaOBtCtis Oty OUfl
vithiKfaepiBiiKl
no&olnduccs
aobffiiyofmeuli,
m no reductKB p
Ibeiozicinrar
volume oft
txponrcd
tod RICISG OQDlflUS
Sofl VcotiB^ of Units
l-5(otttire Bom Pits
OU), CipUaitl.
F^uJbbb BUDJO
betbhodtbe
Coopfits wtdt
ARARs.
forVOaCip
vowd ocod to be
could detsiontc
mobfliiy,iad
volume of VOO.
DocfMiedace
tozinty or volume
of metals. Tlee^i
wfll father reduce
mobility nd (be
potential for
eipocuiulooccBC
Effective, win
reduce potrnlhl
cxpuiUfti tonfl
asuy
$306,000
BkOOwOnfiJ 01 VtpOT
performed ID
proucuvcDCB*
Sofl \feamig of Una
FroMl
betkhadte
Caoipbcswitfa
ARARs.
\tatiDsprovidei
voasoa
nidung • cxpccto
to provide
Reduca tozicit);
Btobi&(yt tod
volume ofVOQ
Poceattilfar&Bt
examio&Dun
nooBonBg woAcr
EUV be difficult
Pilot tot required.
$13^03,000
unscneful
WUi DC
Sou TCSoBg of Units
Proiecis hiHMfl
TCOllQf DtOVMCS
ucnniptBl itflicdy
forVOCi.
expected to provide
Reduces totieitjr
ladmoinfityof
VOQndmetak.
Pottoul for oosf
exctvationofUait
L DM control ad
monitoring, worker
Puny easy to
S2.va.ooo
Excavated soil
reruns screeoAj.
for mettb tad
dioxtts/funos.
airemissiao
mooioringwinbe
performed.
TMV .ToiicttY. McbiHty. \bhsne.
-------
Alternative 3 will meet ARARs if soil exposure controls are implemented annually. The
remaining alternatives, 4 through 6, would meet ARARs. Pilot testing will be conducted prior
to soil washing (Alternative 5) to select a wash reagent capable of removing metals to levels
required for compliance with ARARs.
8.3 Criterion 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 completion of the remedial action.
Alternative 1, No Action, would not provide a long-term or permanent solution. The
magnitude of health risks associated with this alternative are estimated in the baseline health
risk assessment. The remaining alternatives would provide better long-term effectiveness and
permanence than No-Action. The long-term effectiveness and permanence of Alternatives 5
and 6 would be better than those of Alternatives 2, 3, and 4 because they involve excavation of
the material in the Burn Pits. Based on previous investigations, containers of unknown
chemicals may be present in the Burn Pits. These containers could deteriorate with time and
release their contents. Alternatives 5 and 6 would provide means for removing containerized
waste, if any, and disposing of it at a permitted facility.
8.4 Criterion 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, or volume (TMV) of contaminants;
and
• type and quantity of treatment residual.
Alternative 2, Capping of the Operable Unit, does not involve a treatment process. Mobility
of the contaminants would be reduced, but the toxicity and volume would not be affected.
Alternative 3, Soil Ventilation with Surface Dust Control, involves removal of organics from
the soil using soil ventilation, thus reducing the TMV of the volatile organics in soil. In
addition, treatment of surface soils through the annual application of soil sealant will reduce
ER33-1(1993) Part II, Page 30 24-I50029-A41
-------
the mobility of metals. Treatment residual from the process includes entrained water from the
soil ventilation process. The entrained water will be further treated in the existing on-site
water treatment plant
Alternative 4, In-situ Soil Ventilation and Capping, is similar to Alternative 3, with the
exception that capping is used instead of applying a soil sealant. Mobility of metals is
similarly reduced with capping; however, capping does not involve treatment and toxicity and
volume would not be reduced.
Alternative 5 involves several treatment processes including soil ventilation for removal of
volatile organics; debris decontamination to reduce the toxicity of the debris and volume of
contaminants; and a soil washing to remove metals from the soil. The wash liquid will be
further treated on-site using a chemical precipitant to remove metals from the wash liquid, thus
reducing the volume of treatment residual to be disposed of. This will reduce the toxicity of
the wash water and allow the treated wash water to be disposed of in the sanitary sewer.
Alternative 6, In-situ Soil Ventilation, Excavation, Stabilization, and Backfilling, involves
treatment by soil ventilation to reduce the toxicity and volume of volatile compounds,
stabilization of the soil to immobilize non-volatile contaminants, and treatment of the
contaminated debris to reduce its toxicity.
8.5 Criterion 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 six alternatives
are as follows:
• Alternative 1 - None
• Alternative 2 - 6 months
• Alternative 3-10 months
• Alternative 4-15 months
• Alternative 5-24 months
• Alternative 6-15 months
Alternative 1 provides short-term effectiveness, since the Bum Pits are secure on SAAD, are
located in an area not used by workers or the current on-site resident, and do not present a
ER33-I(1993) Put II, Page 31 24-150029-A41
-------
current health risk. Alternative 2 would slightly increase short-term exposures due to dust
formation during cap construction, but mis could be controlled. Alternatives 3 through 6
would slightly increase short-term exposure by increasing the potential for dust and organic
vapors during installation of extraction wells. A contingency plan would be developed to limit
vapor emissions. Alternatives 5 and 6 have the greatest potentials for increased short-term
exposures because soil would be excavated. However, these short-term risks and exposures
will be monitored and controlled to acceptable levels through air monitoring and dust controls.
8.6 Criterion 6: Implementability
Implementability refers to the technical and administrative feasibility of performing the
remediation alternative. The analysis also considers the availability of necessary materials and
services. The following factors were considered:
• ability to construct the technology;
• reliability of the technology;
• ease of interfacing additional remediation technology;
• feasibility of monitoring;
• * ability to obtain approvals from, and coordinate with, regulatory agencies; and
• availability of treatment, storage, and disposal services; equipment and
specialists; and technologies.
Alternatives 1 through 4 and 6 could be readily implemented. The implementability of
Alternative 5 is poor for several reasons. Experienced contractors with quality equipment are
generally not available; prices can be high and scheduling contractors is difficult. Soil
washing is being used at the Oxidation Lagoons, where contamination is restricted to the top
few feet of soil. At the Oxidation Lagoons, there is no debris and metals are the only known
contaminants. In contrast, the soils to be washed at Bum Pits extend to approximately a 20
foot depth, are more variable, and are filled with debris which would need to be removed prior
to soil washing. Pilot testing would be required to select a reagent and washing time which
would meet objectives. Pilot testing could indicate the washing process is not effective.
Alternative 6 relies on a process (soil stabilization) which is proven at the bench-scale level,
and has been implemented at other sites. However, handling the debris during excavation
creates some uncertainties for both Alternatives 5 and 6, because the nature of the debris is not
completely known and therefore, there are unknown potential hazards from the debris.
ER33-1(1993) Part II, Page 32 24-150029-A41
-------
8.7 Criterion 7: Cost
This criterion evaluates the capital and operation and maintenance (O&M) costs, and present
worth of each alternative. The estimated costs for each alternative are as follows:
Alternative
Alternative 1
Alternative 2
Alternatives
Alternative 4
Alternatives
Alternative 6
Present Worth
$0
$1,200,000
$304,000
$306,000
$13,203,000
$2,811,000
Capital Cost
$0
$296,000
$289,000
$298,000
$13,203,000
$2,811,000
O&M Cost
$0
$904,000
$15,000
$8,000
$0
$0
O&M costs for Alternative 2 are for cap maintenance and groundwater monitoring for 30
years. O&M costs for Alternatives 3 and 4 are for annual dust control and cover maintenance,
respectively, for 30 years. These costs are estimates; actual contractor bids may differ from
me estimate.
Alternative 1 would be the least expensive. The estimated costs for Alternatives 3 and 4 are
similar, and are about one-eighth the estimated costs for Alternative 6. Alternative 5 would be
the most expensive, exceeding Alternative 6 estimated costs by over 400 percent.
8.8 Criterion 8: State Acceptance
The State of California has concurred with the selected alternative for the cleanup of soil at the
Bum Pits Operable Unit.
8.9 Criterion 9: Community Acceptance
This criterion indicates whether the public concurs with, opposes, or has no comment on the
preferred alternative. The community expressed no opposition to the preferred alternative at
the public meeting. No written comments on the alternatives were received during the public
comment period. Part in of this ROD contains the Responsiveness Summary from the public
comment period and the public meeting.
ER33-K1993) P«rtII,Pmge33 24-150029-A41
-------
9 SELECTED
Alternative 6 is the remedy selected for die cleanup of the soil at the Burn Pits Operable Unit.
The 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.
9.1 Components of the Remedy
The selected remedy consists of die following components:
• ventilating the entire Burn Pits Operable Unit soils to remove VOCs;
• excavating Unit 1 soils which contain non-volatile contaminants;
• stabilizing the excavated soils;
• backfilling the excavation with ^tahiti^d soil; and
• implementing institutional controls in the form of a deed restriction and notices,
to prohibit future disturbances of the stabilized soil mass.
9.2 Cleanup Standards
Volatile Organic Compounds
The soil vapor extraction (SVE) system will reduce the TCE, PCE, and 1,2-DCE soil
concentrations to 5 micrograms/kg or less; further, soil gas concentrations will be reduced to 5
ppb or less.
This cleanup standard meets Remedial Action Objective No. 3 (see section 6.4).
Non- Volatile Compounds
The heavy metals will be solidified so that the waste extract does not exceed the following
levels as set forth in 22 CCR §66261.24: arsenic, S mg/1; cadmium 1 mg/1; chromium, 5
mg/1; and lead, 5 mg/1. These levels will render the solidified mass a non-hazardous waste
and acceptable for on-site land disposal.
This cleanup standard meets Remedial Action Objectives Nos. 1, 2, and 4 (see section 6.4).
9.3 Cost Information
The present worth cost of the selected remedy using activated carbon treatment of the extracted
vapor is estimated to be $2,811,185. The capital cost is primarily for construction and
ER33-1(1993) P«tn,Pige34 24-150029-A41
-------
operation of the soil ventilation system, excavation of Unit 1, and stabilization of the
excavated soil. As die remedial action should be completed within 15 months, no recurring
annual O&M costs for the alternative are anticipated and no long-term monitoring will be
required. A summary of cost information is presented in Table 6.
10 STATUTORY DETERMINATIONS
The Army's primary responsibility at mis NFL 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
statute expresses a preference for treatment as a principal element that reduces TMV of the
hazardous waste.
10.1 Protection of Human Health and the Environment
The selected remedy would protect human health by removing VOCs from the soil, and by
stabilizing non-volatile contaminants. Risks posed by inhalation, ingestion, or absorption of
volatile organics, and by absorption or ingestion of soil or inhalation of dust containing non-
volatile contaminants would be eliminated. Non-volatile contaminants would be bound into a
concrete mix that would eliminate the potential for exposure.
10.2 Compliance with ARARs
Section 121 of the CERCLA provides that, unless waived, remedial actions shall comply with
Federal and State laws that are applicable or relevant and appropriate to the contaminants and
circumstances of the site.
The selected remedy would meet all ARARs. The list of ARARs for the selected alternative is
presented on Table A-4 in Appendix A.
10.3 Cost Effectiveness
The selected remedy is cost-effective because it has been determined to provide overall
effectiveness proportional to its costs. The estimated cost of the selected alternative is
$2,1111,000 using activated carbon treatment for emissions control, Estimated costs for
Alternatives 2, 3 and 4 are less, but these alternatives do not meet remediation objectives as
ER33-I(I993) Part II, Page 35 24-150029-A41
-------
SttectedAtti
TAME*
rfv.Ce
Soil Vwtfflrfon. Duration. 8oB StobiBation. BaefcW
*• Mtifcal mla.4***.. Mr ateap
#»7 - EPA «40 • SMS aa.
•>!• - EPA WTO *> (TOO aa.
•1 hotttoimi axnefton waL f <**..
*» - EPA «a«o • SMC M.
*» - E^A «270 • (TOO M.
MO «M tang. 10« daap
tto.in.eo
•10JM.OO
•izno.oo
tUenratoft
1429 If . f «t . MK 40 f»C pip* • MAF
*» - «• db . wh 40 PVC E»OM • KWM.
«• - 4* dto . K»I 40 PVC TM» • Rw«*.
#1 1 - «• «l. (eft 40 PVC «*l •!*••• *t2»M.
MO ICFM Vacuum llevw. UquM/g"
p>r«eut>t* BUr. • ttoccyme X 4 i
or un«)
(1.1U.OO
tt.ioo.eo
•1.120.00
•1*0.00
•1W.OO
1 S1 X 1 j: X r eoncrM* Md (tor wOM
#« weuum B*ugM • (200 M.
•t Mai TubM ktoM •20.74C40
•174^04.00
Contnctoc Martoip |«H)
Oaale« «nd PwmMtag CM*}
R«oofttoia CS»)
•M.1W4O
•344M.W
•94.M440
M.ni4o
•-; ttTSjOTV^O
-------
S«Uca»d
TMIE«(CONTJ
iCoat&i
8oO VwrtBrfon. Emotion. 808 Stafattzfttion. Backfill
Otxwtor t«hn • aacftu
----- -----
Oat*. • wwto • «60M>
2 Dump tiueks.«. 4S MnplM • t17SWuni|»*
•1.MO.OO
•9i.on.oo
•4ft.tOO.00
ta. 100.00
•M.702.00
•M.000.00
•147JOO.OO
•020.100.00
•1S.OOO.OO
•10,000.00
•22.S4S.OO
•2.125.00
«7«.7SO.OO
aa.«aoc.Y.««i.oore.Y.
•kMlM Al> Monitoring
(23.aoo.oo
•M.M6.00
— a r\tf Mmpt»ti. a high »dum« Mmpmi • ttni9MHV*»lk
- aTO-a AralyM* • t7200/«««nVMMi
• a gnu tow HIM Mmpto • »7tO/«v«nt/w««l<
> W««th«r «t*«en • asSO/«wntAM*k
- MebWDwneb* • >92V*MKiViiMk
- Ctfbnten 9 MSW«**ntA>Mk
— S«mplng/iMnl-i
elng
Dontlor t« hra 1 aoo/hr
UM«* HO - ant d«y* • 704 KWH/dtr x »o.o»tta/KWM)
•1.400.00
•soo.00
ta.0w.oo
aa.aoo.oo
ta.ois.oo
Hworflna (S%)
Total CM! tor SUMtutton
TeW tva Plw »UbOu«on
•2Sa410.U
tsa7.«i4Jo
•tM.aor.io
•A4.403.SS
TOTAL «K«a2.10a.M
TOTAL •a.aii.iaue
-------
effectively as Alternative 6. Alternatives 2, 3, and 4 provide less long-term effectiveness and
permanence than Alternative 6. Alternative 5 would meet the objectives of the remedial
action, but would be difficult to implement, and would cost considerably more than
Alternative 6. Estimated costs for Alternative 6 are summarized on Table 6.
10.4 Utilization of Permanent Solutions, and Alternative Treatment and Resource Recovery
Technologies
The selected remedy represents the maximum extent to which permanent solutions and
technologies can be used in a cost-effective manner at the Burn Pits Operable Unit. Of those
alternatives that meet the threshold criteria of overall protection of human health and the
environment and compliance with ARARs, the selected remedy provides the best balance of
tradeoffs in terms of:
• Long-term Effectiveness and Permanence;
• Reduction of TMV;
• Short-term Effectiveness;
• Implementability; and
• - Cost
10.5 Preference for Treatment as a Principal Element
The selected remedy satisfies the statutory preference for treatment as a principal element.
The principal threats to human health and the environment are volatile organic chemicals, and
metals in soil. The selected remedy would address these threats through treatment by
removing VOCs from the soil using ventilation; metals in soil would be immobilized by
adding stabilizers to the soil.
11 REFERENCES CITED
U.S. EPA, 1989, Risk Assessment Guidance for Superfund, Human Health Risk Assessment,
U.S. EPA Recommendations; U.S. Environmental Protection Agency, Region DC, San
Francisco, California.
U.S. EPA, 1990a, Integrated Risk Information System (IRIS); U.S. Environmental Protection
Agency, Washington, D.C.
ER33-1(1993) Part II, Page 36 24-150029-A41
-------
. EPA, 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.
U.S. EPA, 1990c, User's Guide for Lead: a PC Software Application of the Uptake/Biokinetic
Model, Version 0.40; U.S. Environmental Protection Agency, Environmental Criteria and
Assessment Office, Cincinnati, Ohio.
U.S. EPA, 1990d, 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.
ER35-I<1993) Put H, Page 37 24-150029-A41
-------
m. RESPONSIVENESS SUMMARY
1 BACKGROUND ON COMMUNITY INVOLVEMENT
At various times since 1979, formal news releases have been issued by the SAAD Public
Affairs Office concerning contamination issues at SAAD. The releases have provided the local
media and general public with information on the status of investigative and remedial efforts
and continuing action to protect public health and safety.
To date, public concerns about the contamination at SAAD have mainly focused on (1) the
potential for exposure to contaminated groundwater that currently exists under the southwest
comer of SAAD and off site to the south and west of SAAD, and (2) the effects that
contamination and remedial actions have on wildlife and wildlife habitat at the facility. The
first concern is applicable to the Burn Pits Operable Unit since the unit appears to have
affected groundwater at SAAD, based on the results of soil and groundwater sampling. The
second concern is minor at the Burn Pits Operable Unit since few wildlife species have been
observed in the vicinity. SAAD has studied the wildlife population in and around the Operable
Unit and has determined that wildlife is more at risk due to the presence of contaminants in
this area than due to temporary disruption of the area during remedial activities.
Contamination at the Burn Pits site is not expected to affect businesses in the vicinity of the
site, residential property values, or traffic patterns during site cleanup since this Operable Unit
is located entirely within the SAAD facility boundary and the selected remedy will not
significantly change the number of vehicles going to or from the Depot each day. The public
has expressed no concerns with these issues. If not remediated, contaminants at the Bum Pits
Operable Unit could pose a long-term health risk to future on-site and off-site residents. No
short-term or long-term human health or environmental risks should occur during or after
remediation of this site by the selected alternative, providing that on-site workers follow
standard OSHA guidelines for working with hazardous waste during remediation and dust
control measures are implemented during construction. The public has expressed no concerns
with short- or long-term health risks of remediation, but has expressed concern about
contamination of drinking water wells.
ER33-K1993) Partlll.Pigel 24-I50029-A41
-------
2 OVERVIEW
Notice was placed in the local community daily newspaper announcing the availability of the
Operable Unit Feasibility Study (OUFS) and Proposed Plan (PP) in the local information
repositories at the California State University Library, the SAAD Visitor Center, the
Department of Toxic Substance Control, and the George Sim Community Center. Public
review and comment was invited for a period of 30 days, from August 3 to September 1,
1992. No written comments were received.
A public information and comment meeting on the PP was held on August 13, 1992 at the
George Sim Community Center. The meeting was attended by 34 people, representing the
public, the Army, EPA, DTSC and RWQCB. During the public comment period and the
public meeting, the public made one comment asking about the relative advantages of the
Army's preferred alternative for cleaning up the soil at the Bum Pits Operable Unit The
Army's preferred alternative for soil cleanup is composed of in-situ soil ventilation of the
entire Bum Pits Operable Unit followed by excavation of the contaminated soil in the pits,
stabilization of excavated soil, and backfilling the pits with
-------
QUESTION *2:
Is this site in a flood rone?
RESPONSE:
No. The water coming down from a break on the American River levee actually comes
down in ponds behind the Southern Pacific railroad tracks. A few years back, the
Morrison Creek channel was widened and deepened so that it will not flood.
QUESTION #3:
What about the channel that is south of here?
RESPONSE:
That could be Elder Creek. The creek near the depot is Morrison Creek. Elder Creek
is the next one down. The Department of Public Works may be able to give you the
status on Elder Creek.
QUESTION #4:
Aside from the cost, can you discuss the relative advantage of the selected alternative?
RESPONSE:
In the Burn Pits, we have low level dioxins, furans, and PCBs and there is no known
technology to handle these. Also, because of the variability in the soil from surface to
20 feet and the debris present throughout the Burn Pits, soil washing is less attractive
for cleanup of the Bum Pits than at the Oxidation Lagoons where metals contamination
is present only in the upper 2 to 3 feet of soil and there is no debris. The Army cannot
be guaranteed a cleanup with soil washing at the Bum Pits. The best option that
preserves DOD's intent and obligation to monitor and take responsibility for its actions
is to stabilize the soil and leave it at its present location.
ER33-1(1993) Part ID, Page 3 24-150029-A41
-------
QUESTION #5:
Is our water safe?
RESPONSE:
We are not contaminating any utility district water supplied to this area. We have
sampled wells within the confines of the contaminant plume and the levels are below
theMCLofSppb.
COMMENT #6:
At the last public meeting, you said that you would take samples and get back to us.
RESPONSE:
We are currently investigating where to install the monitoring wells, and once that
occurs, we will be sampling.
QUESTIONS:
When does the public comment period end?
RESPONSE:
September 1.
COMMENTS:
There needs to be an ongoing communication between the depot, state agencies and
community members as the cleanup proceeds. Formal lines of communication need to
be set up.
ER33-1(1993) Part ffl, Page 4 24-1S0029-A41
-------
RESPONSE:
We would be happy to set up informal community meetings, tours or whatever else is
requested by concerned community members. A public relations plan has been set up
to get the public involved and flyers have been sent put to people on the mailing list.
QUESTION #9:
Was this meeting announcement only sent to people on the mailing list?
RESPONSE:
No, a large public notice was also placed in the Sacramento Bee for 5 days.
COMMENT #10:
Flyers are better than the newspaper. The average person doesn't read the paper.
RESPONSE:
For future meetings, we will send out flyers.
QUESTION fll:
The base has to be closed by July or October of 1997, but the groundwater
contamination won't be cleaned up until 2001. Can portions of the base be given to the
public or other government agencies prior to 2001? Also, when will employees have to
leave?
RESPONSE:
Portions of the base that are cleaned up can be transferred for other uses, but the final
decision on reuse of the property has not been made. For employees, the maintenance
work will most likely end by September of 1994. The work load is being transferred to
other bases by competitive bid.
ER33-K1993) Part HI, Page 5 24-150029-A41
-------
REMAINING CONCERNS
AH public .questions expressed during die public meeting were addressed by the Army. The
Regional Water Quality Control Board offered to test the tap water of a citizen who had
expressed concern about contamination of the drinking water. A major concern expressed was
the need for additional communication to the public, which the Army is addressing through an
expanded mailing list and additional public information meetings to be set up at the request of
the community.
COMMENT:
The State of California, Department of Toxic Substances Control has stated that the California
Environmental Quality Act (CEQA) should be included as an ARAR for the SAAD site.
DTSC has adopted a Negative Declaration under CEQA.
RESPONSE:
EPA has determined that the requirements of CEQA are no more stringent than the
requirements for environmental review under CERCLA. Pursuant to the provisions of
CERCLA, the NCP and other federal requirements, EPA's prescribed procedures for
evaluation of environmental impacts, selecting a remedial action with feasible mitigation
measures, and providing for public review, are designed to ensure that the proposed action
provides for the short-term and long-term protection of public health and the environment and
hence perform the same function as and are substantially parallel to the state's requirements
under CEQA.
Since EPA has found that CERCLA, the NCP, and other federal requirements are no less
stringent man the requirements of CEQA, EPA has determined that CEQA is not an ARAR for
4 RESPONSIVENESS SUMMARY
The Community Relations activities conducted at the Bum Pits Operable Unit on the SAAD
facility to date have included the following:
ER23-I(1993) P«rtffl,P»ge6 24-150029-A41
-------
The Army placed notices in a local daily newspaper announcing the cleanup
plan, the availability of documents in the Administrative Record and other
information repositories, and an upcoming public meeting August 13, 1992.
The notices invited public participation in the selection of a cleanup alternative.
The Army issued a Proposed Plan (PP) describing the preferred alternative for
soil cleanup at the Bum Pits Operable Unit and soliciting public involvement on
August 3, 1992. The PP was mailed to contiguous, property owners and
numerous newspapers, radio, and television stations. In addition to the
Administrative Record, the PP is available at the offices of Region IX EPA, the
California EPA DTSC in Sacramento, California, and the George Sim
Community Center.
The Army held a public meeting on August 13, 1992 at the George Sim
Community Center, 6207 Logan Street in Sacramento, California. The meeting
was recorded by a court reporter and a written text of the meeting is available in
the Administrative Record.
The Army opened a public comment period from August 3 to
September 1, 1992. No written or oral comments were received during that
time, except at the public meeting on August 13 (see preceding item).
ER33-1(1993) Put IE, P»ge 7 24-150029-A41
-------
APPENDIX A
Analysis of ARARs
-------
TABLE A-1
BURN PITS
ARARs FOR ALTERNATIVE No. 2
CAPPING
February t.1W3
TYPE
Action SpeeMe
Action SpecMc
Action SpecMc
Chemical SpeeMe
SUBMITTING AGENCY
DT3C
DTSC
Regbnal Water OuaNty
Control Board (RWOCB)
RWQCB
Ak Quality Management
District (SMAQMD)
. ARAH
22 CCR 66 264.301
22 CCR 66264.310 (a)(1 -6)
23 CCR 2910 (g)
23 CCR 2M1
Rule 403
DESCRIPTION
- Design and operating requirement* tor landWI*.
- Closure care requirement* tor tandMta.
- ProvMea tor groundwakr monitoring of
discharge* at dosed wests management unto
and corrective aetton N water quaMy Impairment
Is found.
- Lwd*J closure requirements.
- FugMreDutt
COMMENTS/IMPACTS
- This regulation la relevant and appropriate to this deeure. The capping wal
reduce the migration othanrdoue constituents Mo the groundwatsr and
ImN exposure to surface soft. The factors to be considered, Istsd In section
(-6), are relevant and she! ba considered when assessing this alternative.
- This regulation Is relevant and appropriate. Tha cap wH be designed and
constructed to meet requirements of (e) 1 -6.
- This reputation re appteabb to VOC contamination. The existing
montorlng. and poff-doium maJntenftno*. *
cause or alow the emissions of tugftVe duet Horn being airborne beyond the
property tne torn which the emissions originate. Reasonable precautions
ehallnchide. but ate not ImHsd to apptymgwater or suMile chemicals tor
the eontml of dust on *uniio** whwh csin owe nee to ahborno matter > Other
measures may ba token a* approved by the Ak PoNutbn Control OMoer*.
ER33-t.WK1(t»t3)
24-1B0020-A41
-------
TABLE A-2
BURN PITS
ARAR* FOR ALTERNATIVE No. 3
SOIL VENTILATION SYSTEM WITH OUST CONTROL
•ebruaryMMl
TYPE
SUBMITTING AGENCY
AHAH
DESCRIPTION
COMMENTS/IMPACTS
Sacramento Metropottan
Ad Quality Management
District (SMAOMD)
Action SpecMc
DT8C
Hub 409
22CCRM284.1«2-tB7
Action Spa cMo
ChemfcalSpecMo
Chemical SpeoMe
DT8C
EPA
Sacran
Air Quality Management
District (SMACIMD)
Chemical Speeric
8MAQMD
22 CCN 00202.34
40 CPU 403
Hub 202. Section 301
Rub 402
- FugUveDutt
Those sections address RCRA tank standards
tor owner s/operators of hazardous waste
TSDfacMUes Including:
- design and InstailaUon
™ COftleMn IVtsMlt eWO MMK QtwCtiOfl
- operating requirements
- Inspection
- spM response
- ctotura and pott closure
Thb section aata forth storage time Mqulramantt
tor gamratora of hazardous waste.
Ganaial Pratraatntanl RaguMlont «M axIsUng
and naw aouioaa of water pollution.
Naw Souroa Raviaw. Thapurposaol this cute
b to provhto for tha ravtew of naw stationary ab
potation aouroas and to provlda mechanisms
by which authorftlaa to construct such sources
may be granted without Interfering wHh tha
attainment or maintenance of ambient ab
quatty standards.
- This rule It applicable. ^very reaeonabb precaution shall be taken not to
cause or alow the emissions of fugMVe duet from being akborre beyond the
property Una from which tha emissions originate. Reasonabb precautions
shall Include, but are not Imlbd to applying asphalt, ol, water, or suKabb
chemicals for tha control of dual on surfaces which can aba rise to airborne
matter. Other measures may be taken at approved by the Ah Pollution
Control OMcar*. Tha contractor wH bo required to comply with this tub.
- Thlt regulation to applcabb to the activated carbon vessel.
Thb reguWtonbappteabb to tr»s|>«rtMers and carbon tram 8VE
treatment
The oontractor thai meat the requ
ts of
Thtoregutettonta applcabb.
the e«lsHng eewer uaa perm! bsued to SAAD.or tha eontraoVM anal obtain
any permits from tha POTW hi accordance with tha approved POTW
Pratraatmant Program.
The rub Is applcabb. Tha rub apecMes that BACT anal be usad whan
raaeHva orgaruet emissions are greater than 0 Ib/day. Tha contractor thai
use BACT to attain ah quaMy standards.
General guideline. H the operation <
rebate ol eontamhiante to the atmosphere,
then a ease-by-ease determination of pubic
nuisance potential should be performed to
verity compliance. Thb rub states that
discharges to ah causing Injury, detriment,
nuisance, annoyance; or endangering comfort,
repose, health, aabty. or causing damage to
business or property Is prohibited.
Thb rub la applcabb. Carcinogens emitted by 8V8 operation wM require
treatment prior to embtlon to the atmosphere. Embskms from treatment
••---••- garde to pubdo enacts
done on a periodic
utfttBd.
processes wM be evaluated by the contractor wtth rega
and monitored and abated. Analytical sampling wM be
basis to monitor emissions. A1E-00 health risk crlarh
crlartawHba
EFUl-O.WKt(tOM)
toft
>4-10MM-A4t
-------
TABLE A-3
BURN PITS
ARARs FOR ALTERNATIVE No. 4
SOIL VENTILATION SYSTEM AND CAPPING
February •. 1001
TYPE
SUBMITTING AGENCY
ARAB
DESCRIPTION
COMMENTS/IMPACTS
Action Speckle
Chemical Specific
Chemical Specific
Action SpecMe
DTSC
Sacramento Metropolitan
AhQuattyManager '
OlrtricKSMAQMD)
BPA
OT8C
22 CCfl 00204.310 (a)(1-0)
Hub 403
40 CPR 403
M CCR 00204.102-107
Acnon Speckle
Chemical Spec*.
OTSC
Sacramento M»ttopollUn
Chemical SpecMe
Air Quality Management
District (SMAQMO)
8MAQMO
22 CC« 00202.34
Mute 202. Section Ml
Bub 402
- Closure care requirement* for tendWI*.
- Fugitive Duet
- Oeneral Pietraatmant HsguarHonsterenlstlng
•nd now MiffOM of w«rtM poUutloi).
These eaeHona address RCRA tank atandarda
for owners/operators of hazardous waste
TSDfacMnes Including:
- design and histaKatlen
- containment and teak detection
rating requirements
- Inspection
- spM response ^^
~ CVOMf ft fUlv pOM CtwMNO
TflW 9OdtoR HWlOHll MOffelQ*) HflW fOOJIMNIIMflll
tor generators of hazardous watte.
New Source ftevbw. The purpose of Ihla rule
fs to provfds for «M review of new stationary ah
poMlon souroaa and to provide meehanrsma
by which authoritte* to construct such eoureae
may be granted wMnut Interfering with the
attahimsnt or maintenance of ambient ah
quality standards.
Oeneral guldilna. I the operation cause*
release ol contamhiants^to the atmosphere.
tfWfl A OftAO""Dy*BCogtn«emlKed by IV« operation wO) require
treatment prior to amhaton to the atmosphara. Cmtoalone from treatnwnt
prooaesaa
and monkxed and abated. AnaMleaJ sampling wff
basrt to monitor emissions. A 1E-00 heaWi risk crit
to putaNo effects
dona on a periodic
criteria wW be utifced.
RJJ-10.WKI(t»»J)
1of1
24-160020-A41
-------
TABLE A-4
BURN PITS
ARARs FOR ALTERNATIVE No. 5
BOIL VENTILATION SYSTEM AND SOIL WASHING
F*biiMiyt.1Ml
TYPE
SUBMTTIN AGENCY
/MAR
DESCRIPTION
COMMENnUIMPACTS
Acton SpacMo
Acton SpacMe
Acton Spadfio
Acttoti SptcMo
AcVOf) SptCwIB
Acton SpacMo
ChamkalSpacMc
OT8C
OT8C
OTBC
OTSC
DTSC
OTBC
OTSC
DTSC
OTSC
OTSC
OTSC
OTBC
OTSC
OTSC
22 CCR 66264.171
21 CCR 66264.172
22 CCR 66264.173
22 CON 60264.174
22CCR66264.176W(b)
22 CCR 66264.17*
22 CCH 66264.1*2
22CCR66264.1M
22 CCH 66264.104
22 CCR 66264.106
22 OCR 66264.196
22 OCR 66262.34
22 CCR 66264.167
22 CCR 66266.41
Confekwramuat bain good condWon or tw
•wto murt to imraaKlin cornpliancawHh
INK
- ThhraguWbntaajiplkahla.
KlwM IM M QOOQ condNkoft
fa AtM^B^Blt^Lfi VtlA d^MlliTttl fta%
tanwfitpaetV •BBiapiMt eert
komtoauMwMhlngproeaaa.
•anottoeauaaar
W»aMy lnip»otena ot contalmra la caqukad
Thanontak»riiiHi'havaaoontalnri»an>»y«>»n
iMnamferl
L
Opan^h>iid^^ana>airtnBandi«or«fla
^ IfllB f•QMHIOtl • AppMOAMfe TfM OOtmttOIOf WM Mtp^Ot OOflHUfMM WBJW^f*
- Thhtaoulaltonhappfcabj^ SteraddrymaandolhateontUnamtMlha»a«
eonWrtnanl tyalwn ai outthadin t>a Ratktah MaragtmantPlan,
> Daconkuntoatonoframowlofhaiardoua
watla raaWuaa from tta eonMnmart tytlam
rnual ba eompMa al doaura of t»» tecMy.
— SaeenelaTycanWnnanlandaqulpmanlfet
d»Uctonotfalaai>aa ara t aquhM tor aM na*
•uik KyMMiM unwfi A wtanc^ M (pMntcL
- ThhaactondaicrlbadaanaialoiMnrilng
faqutwnantofer tonto tyttoma oonteWng
hndow WMto or othar mklartab) (kmtmant
-TM.
ThaoontractorwWrainovaandd»oonaimlmito
toragulaltonliappieaUk
conftfcw* and «»t%raak»mal«ahn«n>
wWkwolra
•aeuHnMlt
iDarignPlan,
AppropilaW oontrob wW ba In ptoca
*&£&$£%
th« »oH wuhkig
- Tank lrap«ton*ch*diil* and pra«Mli««*«*
- ThhraguWtonbapptoabto.
•aancytaapomaprc
•wMbaiMl
tot QMtaratoni c4 tianf itoua wasta.
poat-ckwua cara raqukamarti tor tanks.
«n^
Th* contactor ^ramov* ami dwonkvnlnat*
(«»V>JMatt^
tand. Sata fraatmantraqukamanta for RCRA
wtfta catogorkM that araraiklctod from tand
dtepoatl InSudbifl oontamlraikKl aoH
Thta ragutaton k appHcabla. Traakmnt atandwdi fcf eoraa%janta t»l hava
attoc5V^ctwa^«MowutocodMandkarinm«rao>jkwn«r*w«ba
mat Thaaa fraalwant atandudt ara t» Mtawi:
Conattuant .
ChtomOm (Total
Laad
WbOaCorla
0004
0006
0007
0006
....TPU»'ftjia«|:'i:
?:S
6.0
8.0
1o43
S4-1600M-A41
-------
TABLE A-4
BURN PITS
ARARs FOR ALTERNATIVE No. 5
SOIL VENTILATION SYSTEM AND SOIL WASHING
SUBMtTTINQ AGENCY
AHAH
OESCmPHOM
CnOWMM SpOORlO
EPA
40 Cffl 403
ChMraow SpccNte
Ak Oui
OMM
1»Min
3MAQMO
Rul* 401
(MOOTM ftofeOMflmOflt rWpJUMlOfW fcf OPtoOJ
and now Mureo* of water pollution.
f •OMNbn to •0I1MMWX TfWOOflfrMlQf Of
wMJng ww«f UM Mm* bund to SAAD. a
y p«mS »om to POTW In •ooorihno* wllh IM
lb «r«l hi i ob
f UM Mm* bund to SAAD. at toeontaclioriMlobWn
Chran*m(toW)
S2T
ssr
•no*
ffOOlUvOIIMnH. Mtfl VW
nWMNf, IfltpWpOMOf WMflM
tor In* iwtaw ol new MttanMy «k
•owe** «nd to provkte m»ch«pwn«
i we**
by which •iMnorittM to conrtuct —
invy MI ycnwowithow kiMtlwInQwNn VM
•(•linfTMfw ov nMlnHfwnoc of Atnownl AIT
*»«elllii>i«iaACT»b
«• »«Srt»n 0 Wm.g. to
iv prapcfty
H iMolribHsd
Iwi^f^fl»B |^
iirmnnH* m
I «M^hMj^Jfc^ ^fl^^^bw^ t^^ltt
Hty «l«w w««M«hlng unH
oontKtaf onMotop
L«id
^M,«
0.041
0.034
39
0.6
35
1.91
tola
I4-1600M-A41
-------
TABLE A-4
BURN PITS
ARARft FOR ALTERNATIVE No. 6
SOIL VENTILATION SYSTEM AND SOIL WA8HINQ
SUBMITTING AGENCY
ARAB
DESCRIPTION
COMMCNTBAMPACra •
Chwnk*JSp«cMc
ChwnlooM SfMCinQ
SMAOMO
EPA
SMAOMO
Huh 403
Rub 404
40 CFR 268.48
Rut. 408
- FuflKtoOMt
Jh»'in*t^
crwmfaiK «or 6w oonkol of dud
rater. CHhor m»iur«i m>y b>
CofifeoiOffifioT** TlwoufitftctoT wWoo
b* taken not to
terMMyondttw
- Dud and eenitenxit ftmm t«qulr«n«nh.
torn «ny touroMwHh
•tandvcicuHcnwl
(•qumoto comply
TMtraguMbnlicppkaibtak
oonoinMcl tanMt
n wMt Wclflkt
pa km
114
136
196
162
209
227
273
316
384
400
459
M5
636
727
•t6
MM
1138
1164
1801
1616
2049
2273
2800
2727
2099
3162
3406
280
300
480
600
600
700
600
600
1000
1200
1400
1600
1600
2000
2800
3000
3800
4000
4900
9000
8900
6000
0500
7000
7900
MBQHTAMP
3.60 6.36
;oncHA*oe
6000
6800
6000
0500
10000
12000
14000
49499
00000
136304
161616
227273
272727
316162
20000
30000
40000
80000
60000
70000
00000
00000
100000
200000
300000
400000
600000
000000
700000
400001 600000
Of
OC«M.ln
FsoohJ i***a^tt-#wri&^3^»&nii3*a*
•ny hour duilng 6w procMtt, who;* IfiojiroMn wtflflW DM hour hid p»»f»«n
flgurw M h* MR hmnd oohmtn MM •»d w«4gh; « p«mm^dtefu.f|iM< imy
^M*™*^ T^o^.^n.»lllh.,^u.,..dk.eomP.v.»ttt.thl..J.;
EII33-11.WK1(1663)
3ot3
24-180020-A41
-------
TABLE A-S
BURN PITS
ARARs FOR ALTERNATIVE 6
SOIL VENTILATION SYSTEM AND SOIL STABILIZATION
TYPE
SUBMITTING AGENCY
ARAB
DESCRIPTION
. COMMENTS/IMPACTS;
Action SpecMe
MOUOII SptClnC
Action SpscMe
AetbnSpocMc
CtMimMlSpoclfc
OTSC
OT8C
DT80
OTSC
OTSC
OTSC
22CCR00M4.102
t2CCRMM4.10J
MCCRMM4.1M
taccRMM4.its
ttCCRMM4.1t7
ttccno626«.4i
Now tank system dnlgn and InsUltaHon
rsqukomsms «ro oullnsd.
- TM*r*guMbnls
Th» sal
.
to Ih* settv*t«d evbon VMM|. Any n«w Unto «• ms«t
raqubeiMrta el thb SMtton.
wuMrtg proc*ts «• kwolv* bringing
ral«dsoIl. TN«r»ouWtonls«opfc«W»
w Unto «• ms«t th» skuetund
' SOBOfufswy cofitMnfRMN OIM oojutoivwnl for
detection of retssees ere required tor eJI new
tank systems tmtess a vsilenco Is grouted*
TWs section describes general operating
requirements for tank systems eonteWr ~
hazsTdous waste or other meterMi *
SCn^mJiM MM pfOCAOWCt ••*•
* TfM ttMK fl^fMftHW VMl MMOT WW tttOOAflsVy
conUkimtnt r«qulr«mtnl» M ouMrMd In ttw D«tlgn Pten.
TftflK
OUHfeMO.
'
- TNss
I closure end
pest-ctosui* ear* r«quk«m*nts for Unks.
- Tr**tm*nl
CnMMnMl
HseJtti and
* TMs vogutsJHMi Is oppVeaMo*
the so*.
' ifw f^fljuvMbfi • ••pvoflMv*
stendeidstor
•re eppteeMe. An Inert waste w* »<
!«stebKullon.«ieet
fl IIMfWtf ALTO ptOOMWc IfOMflMfK
wMi the (mrnoMtasilMt tachnotogloB
«*om ImmoMlistkMibysoisteMIXBUon.
standMds end artilw* iMcrMMHv IrnMs ta eomttiMnts Hwllkl Mo
ehwMterMIe hsnf dous «
MHv IrnMs ta e
» osisBortss, •
Chromium
0004
OOM
0007
OOM
1JO
•«
ChsmfeslSpoelb
Chsmfcal Spoolfe
8PA
SoMmonloMotopolUn
Ak OiMMyMMMMi
DbMet (SMAQMD)
SMAQMO
40CFRMMS
Rule SOS, Section M1
Mute 401
•• ItMRlMffll
fat MtUFOOUB VMnit
IIW |HVpOst9 wi VNB HIM
kVA
Th«rulsli
UMi0 wW InMnoMRttibfi
d •wMRiMbti*
end to i
by wMdi MiHiOfMov to CMNwfruol •udi OOKTOM
f be aranted wtjioul InterterlnB wlftthe
"leybegrenl
ejRsinmentof
OT •HWWfll ••
• Rlnglwnenn Chert
- This rule k> epifcetli. •Mmt
eoureo MheTnwfiunoombln
a;
••slokomsny
w wpofiVB? •ported or norottMA vvoe
minutes m en* one hour •h«l not bo m dsrti or derttef hi shade M
designation No. 1 on the Rkigteimnn Chwt puMshed by the U.8. Burasw of
Mines. Nor she! the emissions bo of suchopattyee to obeeuro o. human
observer's vtew. or regMw on ooertfled n-steek opeoRy montarkig system
aiale*efe«^toergreelsrlhonRlnglemBmi0^lgne)lonNo.r The
oot*actor««rbe requked to comply wth Ihh rule.
eiU3-1t.WK1(1tN)
1of»
t4-1«OM-A41
-------
TABLE A-S
BURN PITS
ARARs FOR ALTERNATIVE 6
SOIL VENTILATION SYSTEM AND SOIL STABILIZATION
TYPE
ChomtedSpeclfe
Chemlcel Speclle
ChoriNCM 8pocliD
8UBMITTINQ AGENCY
SMAQMD
8MAQMO
8MAQMO
OT8C
••" • : ;:. ' ' ARAB ' ' '• '
Rule 402
Rulo403
Rutt404
1
22 CCR 00202 44
./DESCRIPTION
i
release ol conUinkwnl* to the almoepbere,
then • cwe-by-ceie detarmtnaOon ol pubfe
repose, health, safely, 01 cawing damage to
business or property It prohibited.
- Fugitive Dutt
- Thta section set* rbrthstoreoe time requirement.
tor generator* of hrardoue waste.
"' C6»MEMt8/IMPACTS';-:':-xnv; -;> •••-V^-,/
- Thferubbappfcable. Cmkwgemem
WHMflMnK pf toff IO ORNiMlOO 1O ItM 4MMOM
pvocMtM w« b* ovdiMM by *• conk
o%nd monlloff«d and abated. AnftMeal*
Mod by 81
photo. En
•ctorwMi
•mplnaw
Muthrbke
•v«kMt* UM m*A o
•tabWnttonunll.'fh
ctRwtafof Ihb *INrf
v»ly th* SUCCMCM
•MC*«d«d. th« oonk
•Hvo. Tho conkoeta
Kipreheirtopdue1
OMMnKlo dun won
' ttotai /
Crtdmlum
2kw
._ . Lt
DfOUMiy MM wOfH VnNCfl VM AflthCtoffel 4
•heS Include, but •• not trnKed to apph
chenrirwl* to? the eonkot ol duet en eurti
IIMrtlW OttMff flMMUFMi HMtf bft tBfc*f> •
ConkolOflfcer*. Th*oor*M«MtwMbot<
- ThhruieliappOubl*. -No dhehetgee •
torn any touree* wth Mrtkukrte nwtter
ttMdwd eubto meter (9.1 grelne per dry
required to comply «rUi thi ruto.
- ThlereauleitonkiepplceMetotheepenl
keeimenl.
MlttMIOCI
dtotheHI
rehcluee
ree.Nthe
**OJMMffU
kmoMng
)
20(8
t4-1MOM-A41
-------
TABLE A-5
BURN PITS
ARARs FOR ALTERNATIVE 0
SOIL VENTILATION SYSTEM AND SOIL STABILIZATION
February 8. IMS
TYPE
CtwmteilSiMclb
SUBMITTING AGENCY
SMAQMO
\
•• • "•• - - •• ARAB . .
Mute 408
*
DESCRIPTION :
- Dutt wdeondwMd turn** rcqutorntrik.
COMMENTS/IMPACTS
™ TF1M fUW • OMMBMMt* MO flMCfHof Q9C BWO tfM HlVIOBBnOVt
M • •••
'-::::.?;V»:-:PH6CE
perkow
kj.A^ Htlifc
HBF*W WVrW
114 280
130 300
180 380
102 400
208 480
227 800
273 000
310 700
304 000
400 000
488 1000
848 1200
030 1400
727 1000
810 1300
000 2000
1130 2800
1104 3000
1801 3800
1818 4000
2048 4800
2273 8000
2800 8500
2727 0000
2088 0800
31*2 7000
3400 7800
TouMvtttaM»«bc
*^ -• VltA_ Jbutf M«J
WHnVt 1 fflVfl IWIM m
fMJfVwOf Of MowfllMW
MnHwafrmpW*
niOmtm '>i*^i.
•MtakMBMM
kg/Hr ftfHr
0.48 1.00
0.81 1.12
0.80 143
0.01 1.34
0.08 1.44
0.70 1J84
0.70 1.73
OJO IjOO
0.04 2.07
1.01 2.22
1.03 243
1.21 2.00
1.33 2.03
1.48 3.10
1.80 3.43
1.00 3.00
1.01 441
2.18 4.72
2.38 8.10
2.88 8J4
2.70 0.07
2.08 0.40
3.13 0.00
3.30 747
3.47 7.04
3.04 0.00
340 840
Au.owABi«i-DwcHARQ6:: :•:;:•: ::«;.:.;•;:::
perkoir
kolHr Mir
3030 0000
3884 8800
4001 0000
4318 0800
4848 10000
8488 12000
0304 14000
7273 10000
0102 10000
0001 20000
13038 30000
18182 40000
22727 80000
27273 00000
31818 70000
30304 00000
40000 00000
48488 100000
00000 200000
130304 3000QO
181818 400000
227273 800000
272727 000000
318182 700000
903039 0omoj0
400001 000008
484848 1000000
or Of
mm* mom
-------
APPENDIX B
Administrative Record Documents
-------
BURN PITS ADMINISTRATIVE RECORD
Administrative Record Documents
1. Bum Pits Operable Unit,
Technical Memorandum on Field
Activities, Appendix A-3
of the Remedial Investigation
2. Bum Pits Operable Unit
Feasibility Study (OUFS)
3. Bum Pits Public Health Evaluation
(Appendix C of OUFS)
4. Bum Pits Treatability Study
(Appendix G of OUFS)
5. Health and Safety Plan
Bum Pits
6. Proposed Action Plan - Bum Pits
7. Letter from Michael Mosbacher
of CVRWQCB to Dan Oburn of
SAAD, dated November 24, 1992
re: ARARs
8. Letter from Marlon Mezquita
of EPA Region 9 to Michael
Mosbacher of CVRWQCB in response
to above letter, March 1993
Submitta
October 28, 1991
May 15, 1992
May 15, 1992
May 15, 1992
March 1,1990
July 1992
ER33-1(1993)
24-150029-A41
------- |