EPA Superfund
Record of Decision:
PB95-964418
EPA/ROD/R08-95/116
March 1996
Hill Air Force Base,
Operable Unit 3, UT
9/28/1995
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RECORD OF DECISION FOR
OPERABLE UNIT 3
HDLL AIR FORCE BASE, UTAH
(IRP SITES ST04, WP05, WP06, ST18, SD23, SD34)
This is a primary document for Operable Unit 3 at Hill Air Force Base. It will be available
in the Administrative Record, which is maintained at the following locations:
Davis County Library
Central Branch
155 North Wasatch Drive
Layton, Utah 84041
Phone (801) 547-0729
Hours: Mon - Thurs: 11:00 am - 9:00 pm
Fri - Sat: 11:00 am - 6:00 pm
Environmental Management Directorate
Oq-ALC/PAE
Buildina 5
7274 Wardleigh Road
Hill AFB, Utah 84056-5137
Contact: Ms. Gwen Brewer (801)777-0359
Submittal Date: September 1995
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TABLE OF CONTENTS
PAGE
DECLARATION FOR THE RECORD OF DECISION
DECISION SUMMARY FOR THE RECORD OF DECISION
1.0 SITE NAME, LOCATION, AND DESCRIPTION 1-1
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES 2-1
2.1 Site History 2-1
2.2 Enforcement Activities 2-3
2.3 Investigation History 2-3
2.3.1. RVMF 2-3
2.3.2. Sodium Hydroxide Tank Site 2-3
2.3.3. IWTP Sludge Drying Beds 2-5
2.3.4. BermanPond 2-5
2.3.5. Pond 1 2-5
2.3.6. Pond 3 . 2-5
2.4 Community Relations History 2-5
2.5 Scope and Role of Operable Unit 3 Within Site Strategy 2-6
3.0 SUMMARY OF SITE CHARACTERISTICS 3-1
3.1 Nature and Extent of Contamination 3-1
3.1.1. Refueling Vehicle Maintenance Facility (RVMF) 3-1
3.1.2. Sodium Hydroxide Tank Site 3-1
3.1.3. IWTP Sludge Drying Beds 3-5
3.1.4. BermanPond 3-5
3.1.5. Pond 1 3-11
3.1.6. Pond 3 3-16
3.2 Summary of Fate and Transport of Contaminants 3-16
4.0 SUMMARY OF HEALTH AND ENVIRONMENTAL RISKS 4-1
4.1 Health Risks 4-1
4.1.1. Contaminant Identification 4-1
4.1.2. Exposure Assessment 4-1
4.1.3. Toxicity Assessment 4-6
4.1.4. Risk Characterization 4-6
4.2 Environmental Risks 4-10
4.2.1. Air Quality 4-10
4.2.2. Surface Water, Ground Water, and Wetlands 4-1
4.2.3. Vegetation 4-1
4.2.4. Wildlife 4-1
4.2.5. Archaeological Resources 4-1
4.3 Summary of Risks 4-1
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Table of Contents
5.0 DESCRIPTION OF ALTERNATIVES 5-1
5.1 Development of Alternatives 5-1
5.2 Detailed Analysis of Alternatives 5-2
5.2.1. RVMF v 5-2
5.2.2. Sodium Hydroxide Tank Site 5-8
5.2.3. Herman Pond 5-9
5.3 Comparative Analysis of Alternatives 5-15
5.3.1. Evaluation Criteria 5-15
5.3.2. Comparative Analysis 5-26
5.3.3. Summary of Selected Remedies 5-32
6.0 SELECTED REMEDIES 6-1
6.1 Description of the Selected Remedies 6-1
6.1.1. Selected Remedies 6-1
6.1.2. Remediation Goals and Performance Standards 6-4
6.1.3. Restoration Time Frame 6-5
6.1.4. Costs 6-5
6.2 Statutory Determinations 6-7
6.2.1. Protection of Human Health and the Environment ' 6-7
6.2.2. Compliance with Applicable or Relevant and Appropriate 6-8
Requirements
6.2.3. Cost Effectiveness 6-10
6.2.4. Utilization of Permanent Solutions 6-11
6.3 Documentation of Significant Changes 6-12
RESPONSIVENESS SUMMARY
REFERENCES R-l
APPENDK A - FATE AND TRANSPORT OF COMPOUNDS IN OU 3 SOIL
APPENDIX B - ARARs PERTAINING TO SELECTED REMEDIES FOR OU 3
APPENDK C - PUBLIC MEETING TRANSCRIPT
APPENDIX D - WRITTEN COMMENTS AND RESPONSES
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Table of Contents
LIST OF TABLES
TABLE
NO. TITLE
2-1 Chronological Summary of Previous Environmental Investigations at 2-4 ~
Operable Unit 3
3-1 Summary of Contaminants Detected in RVMF Soil 3-2
3-2 Summary of Contaminants Detected in Sodium Hydroxide Tank Site Soil 3-4
3-3 Summary of Contaminants Detected in Sludge Drying Beds Soil 3-6
3-4 Summary of Contaminants Detected in Berman Pond Soil 3-8
3-5 Berman Pond Contaminants and Treatment-Based Remediation Goals 3-12
3-6 Summary of Contaminants Detected in Pond 1 Surface Water 3-13
3-7 Summary of Contaminants Detected in Pond 1 Sediment 3-14
3-8 Summary of Contaminants Detected in Pond 3 Surface Water 3-17
3-9 Summary of Contaminants Detected'in Pond 3 Sediment 3-18
4-1 Hill OU 3 Contaminants of Concern 4-2
4-2 Current Potential Exposure Pathways for Hill Air Force Base OU 3 Sites 4-3
4-3 Future Potential Exposure Pathways for Hill Air Force Base OU 3 Sites 4-4
4-4 Summary of Slope Factors for Potential Contaminants of Concern 4-7
4-5 Summary of Reference Doses for Potential Compounds of Concern 4-8
4-6 Summary of Cancer Risks and Hazard Indices for Evaluated Pathways: 4-9
Future Exposures
5-1 Development of Remedial Alternatives for the RVMF 5-3
5-2 Development of Remedial Alternatives for the Sodium Hydroxide Tank Site 5-4
5-3 Summary of Remedial Alternatives for Berman Pond 5-5
5-4 Summary of Key ARARs for Each Alternative 5-17
6-1 Summary of ARARs for Selected Remedies 6-12
A-1 Summary of Fate and Transport of Compounds in OU 3 Soil
B-l Identification of Federal Chemical-Specific ARARs
B-2 Identification of Federal Action-Specific ARARs
B-3 Identification of State Chemical-Specific ARARs
B-4 Identification of State Location-Specific ARARs
B-5 Identification of State Action-Specific ARARs
111
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Table of Contents
LIST OF FIGURES
FIGURE FOLLOWING
NO. TITLE PAGE NO.
1-1 Vicinity Map 1-1
1-2 Site Location Map 1-1
3-1 RVMF Area of Attainment 3-4
3-2 Sodium Hydroxide Tank Site Area of Attainment 3-5
3-3 Berman Pond Areas of Attainment 3-11
3-4 Cross Section of the Berman Pond Areas of Attainment 3-11
3-5 RVMF Conceptual Model of Contaminant Transport 3-19
3-6 Sodium Hydroxide Tank Site Conceptual Model of Contaminant 3-19
Transport
3-7 Berman Pond Conceptual Model of Contaminant Transport 3-19
6-1 Conceptual Remedial Action Implementation Schedule-RVMF 6-2
Alternative 3
6-2 Conceptual Remedial Action Implementation Schedule-Sodium 6-3
Hydroxide Tank Site Alternative 2
6-3 Conceptual Remedial Action Implementation Schedule-Berman Pond 6-4
Alternative 2
IV
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Site Name and Location
Operable Unit 3
Hill Air Force Base, Utah
Davis County, Utah
Statement of Basis and Purpose
This decision document presents the soil cleanup remedies selected for three sites at Hill
Air Force Base (Hill AFB) Operable Unit 3 (OU 3) in Utah. The sites addressed in this
document include the Refueling Vehicle Maintenance Facility (RVMF; Buildings 511
and 514), the Sodium Hydroxide Tank Site, Berman Pond, Pond 1, Pond 3, and the
Industrial Wastewater Treatment Plant (IWTP) Sludge Drying Beds. Based on the
findings of the OU 3 remedial investigations and the risk assessments, no action is
required for Pond 1, Pond 3, and the IWTP Sludge Drying Beds because risks posed by
the contaminants at these sites are below significant levels.
The remedies for OU 3 sites were selected in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA), and, to the extent
practicable, with the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP). This decision is based upon the Administrative Record for Hill AFB.
The State of Utah Department of Environmental Quality (UDEQ), the U.S.
Environmental Protection Agency (EPA), and Hill AFB concur on the selected remedies.
Assessment of the Sites
Actual or threatened releases of hazardous substances from the RVMF, the Sodium
Hydroxide Tank Site, and Berman Pond, if not addressed by implementing the response
actions selected in this Record of Decision (ROD), may present an imminent and
substantial endangerment to public health, welfare, or the environment.
Current risks to human health associated with the contaminants at the three OU 3 sites
addressed in this decision document are well below levels considered by the EPA to be
significant. Remedial actions are warranted based on possible future risks to human
health and the environment and because of future threats to groundwater beneath OU 3.
Description of the Selected Remedies
Operable Unit 3 is one of nine operable units at Hill AFB. The remaining operable units
are at various stages in the remedial investigation/feasibility study (RI/FS) process. OU.3
is a soils-only Operable Unit (OU). Groundwater beneath OU 3 is addressed separately
in the Operable Unit 8 RI/FS. The selected remedies address the threat to human health
and the environment by limiting the exposure to contaminated soil and protecting ground
water either by reducing contaminant concentrations through treatment or by restricting
contaminant transport to ground water.
The major components of the selected remedies are summarized in the following
paragraphs.
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Refueling Vehicle Maintenance Facility (RVMF; Buildings 511 and 514)
Selected Remedy — Alternative 3, Insitu Vapor Extraction
• Reducing the concentrations of the volatile organic compound
1,1-dichloroethene (1,1-DCE) in soil using in-situ (in-place) soil vapor
extraction (SVE).
• Implementing institutional controls during the remedial action to prevent
human exposure to contaminated soil. These controls will include:
(1) installing fencing with warning signs to restrict ac.cess to the treatment
facility; and (2) issuing a continuing order to restrict on-site worker access to
the contaminated soil and to restrict or control concrete cutting arid
excavations in the area unless proper protective equipment is worn.
Sodium Hydroxide Tank Site
Selected Remedy — Alternative 2, Cap Maintenance and Institutional
Controls
• An asphalt cap was installed over the area of high-pH soil as part of an interim
remedial action. The existing cap inspection, maintenance, and repair
program will be continued throughout the duration of the action.
• Implementing institutional controls to prevent human exposure to
contaminated soil, and limit water seepage through the high-pH soil. These
controls will include: (1) issuing a continuing order to restrict on-site worker
access to high-pH soil, and restrict or control temporary construction activities
unless proper protective equipment is worn; (2) filing a notice to the deed
detailing the restrictions of the continuing order, and (3) a covenant to the
deed in the event of property transfer.
Herman Pond
Selected Remedy — Alternative 2, Cap Installation and Institutional Controls
• Extracting perched water contained within the former pond to the extent
possible.
• Capping Berman Pond to reduce the potential for exposure to the
contaminated soil and minimize water seeping through the soil to ground
water; thereby protecting ground-water quality.
• Implementing a cap inspection, maintenance, and repair program to ensure the
long-term effectiveness of the cap.
• Implementing institutional controls to maintain the integrity of the cap. These
controls will include: (1) issuing a continuing order to restrict on-site worker
access to contaminated soil and restrict construction activities; (2) filing a
notice to the deed detailing the restrictions of the continuing order, and (3) a
covenant to the deed in the event of property transfer.
Continuing order requirements will be in effect as long as the property is owned by Hill
AFB.
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For Berman Pond and the Sodium Hydroxide Tank Sites, in the case of the sale or
transfer of property within OU 3 by the United States to any other person or entity, the
Air Force will place covenants in the deed which will restrict access and prohibit
disturbance of contaminated soils or the remedial action without approval of the United
States. These covenants will be in effect until removed upon agreement of the State of
Utah, the U.S. Environmental Protection Agency, and the U.S. Air Force or their
successors in interest. The Air Force will also include in the deed the covenants required
by section 120(h)(3) of the Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA), which include (1) a warranty that the United States will
conduct any remedial action found to be necessary after the date of the transfer; (2) a
right of access in behalf of the U.S. Environmental Protection Agency and the Air Force
or their successors in interest to the property to participate in any response or corrective
action that might be required after the date of transfer. The right of access referenced in
the preceding sentence shall include the State of Utah for purposes of conducting or
participating in any response or corrective action that might be required after the date of
transfer.
In the event that the land use is changed or structures are removed, the Air Force will re-
evaluate the protectiveness of the remedy selected for OU 3, and will take any
appropriate remedial action.
Statutory Determinations
The selected remedies are protective of human health and the environment, comply with
federal and state requirements that are legally applicable or relevant and appropriate to
the remedial actions, and are cost effective. The remedies utilize permanent solutions and
alternative treatment or resource recovery technologies, to the maximum extent
practicable. The remedy for the RVMF satisfies the statutory preference for treatment as
a principal element. However, because treatment of the Sodium Hydroxide Tank site and
Berman Pond was not found to be practicable, this remedy does not satisfy the statutory
preference for treatment as a principal element in these areas. Reviews will be conducted
at a minimum of every five years after commencement of the remedial action to ensure
that the remedies continue to provide adequate protection of human health and the
environment.
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UNITED£TA
RONMENTAL PROTECTION AGENCY
Robert L. Duprey
Director, Hazardoiis^Waste Management Division
Da*T
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STATE OF UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY
_
Dianne R. Nielson, Ph.D.
Executive Director
Date
Record of Decision for
Hill Air Force Base, Utah
Operable Unit 3
-5-
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HILL AIR FORCE BASE, UTAH
OPERABLE UNIT 3
DECLARATION FOR THE RECORD OF DECISION
LAWRENCE P. FARRELL, JR.
Lieutenant General, USAF
Vice Commander
tjfk-r *?
Date
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1.0 SITE NAME, LOCATION, AND DESCRIPTION
Hill Air Force Base (Hill AFB) is located in northern Utah, about 25 miles north of Salt
Lake City and about five miles south of Ogden, Utah in Davis County (Figure 1-1). Hill
AFB covers about 6,700 acres and is located on the Weber Delta, a delta terrace
approximately 300 feet above the surrounding valley floors in Weber and Davis Counties.
The delta surface has slight to moderate relief with elevations varying from
approximately 4,600 feet above National Geodetic Vertical Datum (NGVD) along the
western boundary of Hill AFB to approximately 5,045 feet above NGVD along the
eastern boundary. In contrast, the Wasatch Mountains, about four miles to the east, rise
abruptly from the valley floor to an elevation of over 9,000 feet above NGVD. The Great
Salt Lake, approximately 12 miles to the west, is presently at an elevation of
approximately 4,201 feet above NGVD. In July 1987, the Base was placed on the
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)
National Priorities List because of several sites where hazardous liquid and solid wastes
generated by installation operations were disposed.
Operable Unit 3 (OU 3) is a soils-only OU and consists of the Refueling Vehicle
Maintenance Facility (RVMF; Buildings 511 and 514), the Sodium Hydroxide Tank Site,
the Industrial Wastewater Treatment Plant (IWTP) Sludge Drying Beds, Berman Pond,
Pond 1, and Pond 3 (Figure 1-2).
Operable Unit 3 is located in the.southeastern quadrant of Hill AFB, and most of OU 3 is
located in an industrial area that is used for servicing and maintaining aircraft. In the
Layton area south of OU 3 (now part of Operable Unit 8), land use varies from
residential, to commercial, to agricultural. This area has undergone rapid residential
development over the last 10 to 20 years, and agricultural use has declined. Crop
production in the agricultural areas primarily is the cereal grains wheat and barley, and
alfalfa. Although there is some pastureland, very few livestock are raised on the pastures
south of Hill AFB.
Subsurface conditions below OU 3 are dominated by interbedded silty sands, sandy silts,
and clays. The OU 3 area overlies three aquifers, although these aquifers are not included
as part of OU 3. The shallow aquifer consists of approximately 200 feet of relatively
low-yielding materials and lies at about 10 to 110 feet below the ground surface at OU 3.
This shallow aquifer is designated as Class II - Drinking Water Quality based on the State
of Utah classification criteria and the quality of ground water analyzed from
uncontaminated wells. The deeper Sunset and Delta aquifers are approximately 300 and
600 feet below OU 3, respectively. They are used by Hill AFB and surrounding
communities as domestic water supplies. The Sunset and Delta Aquifers are classified as
Class I - Irreplaceable Source of Drinking Water or Class IIA - Current Source of
Drinking Water (USGS, 1992).
The Davis-Weber Canal and Ponds 1 and 3 are the primary surface water bodies at and
near OU 3. The Davis-Weber Canal, a privately owned irrigation canal used each year
from April to October, is located west of Pond 3. No streams, rivers, or lakes exist on
1-1
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R.3W.
R. 2 W.
R. 1 W.
R. 1 E.
55
6
o
UI
O
oc
BOX ELDER CO.
WEBER CO.
Hill Air Force Base
Approximate Outline
Of Weber Delta
OPERABLE UNIT 3
01234
I I [
Scale in Miles
To
Salt Lake
City
MAP AREA
SaltUko
City
UTAH
HILL AIR FORCE BASE
VICINITY MAP
FIGURE 1-1
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PROJECT NO. 2208.0113 8/16/95
(Buildings
511
Sodium Hydroxide
Tank Site
Industrial Wastewater
Treatment Plant (IWTP)
Sludge Drying Beds
HILL AIR FORCE BASE
OPERABLE UNIT 3
SITE (LOCATION MAP
FIGURE 1-2
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Hill AFB. Numerous wetlands (including Ponds 1 and 3) have been identified on Hill
AFB (Sunrise and AES, 1993).
1-2
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2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.1 SITE HISTORY
Hill AFB has been the site of military activities since 1920 when the western portion of
the Base was activated as the Ogden Arsenal, an Army reserve depot. In 1940 and 1941,
four runways were built, and the Ogden Air Depot was activated. During World War II,
the Ogden Arsenal manufactured ammunition and was a distribution center for motorized
equipment, artillery, and general ordnance. The Air Depot's primary operation was.
aircraft rehabilitation. In 1948, the Ogden Air Depot was renamed Hill AFB, and in
1955, the Ogden Arsenal was transferred from the U.S. Army to the U.S. Air Force.
Since 1955, Hill AFB has been a major center for missile assembly and aircraft
maintenance. Currently, Hill AFB is part of the Air Force Materiel Command.
On-Base industrial processes associated with aircraft, missile, vehicle, and railroad
engine maintenance and repair include metal plating, degreasing, paint stripping, and
painting. These processes use numerous chemicals, including chlorinated and non-
chlorinated solvents and degreasers, petroleum hydrocarbons, acids, bases, and metals.
In the past, chemicals and waste products were disposed of at the Industrial Wastewater
Treatment Plant (IWTP), in chemical disposal pits and landfills, and off Base. Disposal
in chemical pits and landfills was discontinued by 1980. All waste products are currently
treated at the IWTP, recycled on Base, or sent to off-Base treatment or disposal facilities.
OU 3 comprises the Refueling Vehicle Maintenance Facility (RVMF; Buildings 511 and
514), the Sodium Hydroxide Tank Site, the IWTP Sludge Drying Beds, Berman Pond,
Pond 1, and Pond 3. The locations of these areas within OU 3 are shown in Figure 1-2.
RVMF
From the late 1950s until 1985, the RVMF was used for draining excess fuel from
refueling vehicles prior to their maintenance in Building 514. Although the actual source
of contaminants in soils under the RVMF is unknown, it is presumed that the drained
fuels and any solvents used for parts cleaning in maintenance procedures were collected
in a floor drain within the RVMF, passed through an oil/water separator, and either
disposed of or recycled. Defects in the drainage system and/or incidental spills inside or
outside the RVMF may have been sources for soils contamination. Collected water from
the drain was stored in a small underground storage tank (UST) and subsequently
pumped to the IWTP for treatment. Building 514 is no longer used as a collection facility
for fuel, and since September 1988. it has been the Base's Hazardous Waste Control
Facility. Although limited information is available, it appears Building 511 has had many
uses; including, an aircraft and engine repair shop, a bearing shop, a hydraulics shop, a
foundry, an investment casting flame spray shop, and an electric harness shop. Shop
processes may have included vapor degreasing, and solvents may have been used and
stored in the building.
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Sodium Hydroxide Tank Site
The Sodium Hydroxide Tank Site is the former location of two 12,000-gallon
underground storage tanks that were used to store a 25 percent by weight solution of
sodium hydroxide. During the period the tanks were in use, several hundred thousand
gallons of solution were lost, apparently due to leakage. Both tanks were removed in
September 1992, in accordance with the Underground Storage Tank Regulations
administered by the Utah Department of Environmental Quality (UDEQ). An asphalt cap
was installed over the area in August 1993 as an interim remedial action.
IWTP Sludge Drying Beds
The IWTP began operating in 1956, and consisted of a single clarifier. Sludge from the
clarifier was pumped to two sludge drying bed areas south of the facility. The sludge
consisted of paint stripping, chrome plating, and degreasing wastes. The drying bed areas
were used until 1982 to store semi-solid sludges. The area underlain by the west beds
currently is used for a parking area and a warehouse building. The east beds were
backfilled to accommodate a 220,000-gallon abbveground wastewater storage tank.
Berman Pond
From 1940 to 1956, Berman Pond was operated as an unlined evaporation pond that
received stormwater runoff and industrial wastewater, which may have included spent
solvents, heavy metals, and hydrocarbons. Information obtained from aerial photographs
indicates that the maximum dimensions of Berman Pond were approximately 800 feet
long and 420 feet wide, and encompassed an area of approximately six acres. Prior to
1956, Berman Pond was connected to Pond 1, which received overflow from Berman
Pond during high intensity storms. After construction of the IWTP in 1956, Berman
Pond was connected to a sanitary sewer line and was used only as a stormwater retention
pond. In 1958, pond overflow was re-routed to the storm drainage system, and between
1958 and 1970, the pond was filled with construction rubble and soils, and regraded.
A cap, consisting of silt and clay, was installed over a portion of the pond in 1986.
Pond 1
Pond 1 is a stormwater retention pond that holds surface water during most of the year.
Prior to 1956, Pond 1 was connected to Berman Pond, and reportedly received discharge
from Berman Pond from 1940 to 1944.
Pond 3
Pond 3 has been used as a stormwater retention pond since 1957, and currently it is
designated as a wildlife habitat area. Pond 3 receives surface water runoff from the
southern area of the Base and discharges retained water during large storm events through
a storm sewer line, which eventually discharges south of the Base to Kay's Creek. Water
discharge from the pond is controlled; the amount of water retained in the pond is
maintained at a low level for wildlife habitat.
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2.2 ENFORCEMENT ACTIVITIES
In July 1987, Hill AFB was placed on the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) National Priorities List (NPL) by the EPA.
In 1991, Hill AFB entered into a Federal Facilities Agreement (FFA) between the
U.S. Air Force (USAF), the State of Utah Department of Health (now the UDEQ), and
the U.S. Environmental Protection Agency (EPA). The purpose of the agreement was to
establish a procedural framework and schedule for developing, implementing, and-
monitoring appropriate response actions at Hill AFB in accordance with existing
regulations. Seven operable units were defined under the FFA. Two additional operable
units have since been added. This Record of Decision (ROD) concludes all of the
remedial investigation/feasibility study (RI/FS) requirements for OU 3. There have been
no removal actions, notices of violation, or other enforcement actions taken at OU 3 prior
to this ROD. A ROD for the Sodium Hydroxide Tank Site was signed in September
1992, and an asphalt cap was installed over the area in August 1993 as an interim
remedial action.
2.3 INVESTIGATION HISTORY
As shown in Table 2-1, several environmental investigations have been performed at the
RVMF, the Sodium Hydroxide Tank Site, and at the Berman Pond sites: Brief
descriptions of these investigations are presented separately for each site.
2.3.1. RVMF
A remedial investigation at the RVMF was initiated in 1988 to evaluate the
presence/absence of soil and ground-water contamination, estimate the extent of
contamination, and assess the potential for contaminant transport (Radian, 1988).
Subsequent investigations were conducted as part of the RI/FS process to define the area!
extent of soil and ground-water contamination (ESE, 1989; JMM, 1992; and Montgomery
Watson, 1995). A focused RI/FS was completed in 1993 to evaluate soil vapor extraction
as an appropriate remedial action for soil contaminated with volatile organic compounds
(VOCs). Site characterization activities at the RVMF were completed in March 1995.
2.3.2. Sodium Hydroxide Tank Site
The Sodium Hydroxide Tank Site was included.in a 1982 records search that was
conducted to identify the potential for environmental contamination from past waste
disposal practices at Hill AFB (UBTL. 1982). An additional investigation was completed
in 1988 to evaluate the presence/absence of contamination (Radian, 1988). Phase I and
Phase II remedial investigations were completed as part of the RI/FS process (JMM, 1992
and Montgomery Watson, 1995). An asphalt surface covering (cap) was installed over
the area in August 1993 as an interim remedial action. Site characterization activities at
the Sodium Hydroxide Tank Site were completed in March 1995.
2-3
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TABLE 2-1
CHRONOLOGICAL SUMMARY OF PREVIOUS ENVIRONMENTAL
INVESTIGATIONS AT OPERABLE UNIT 3
Date
Investigation
January 1982
September 1984
July 1988
October 1988
March 1989
December 1991
April 1992
March 1995
Installation Restoration Program Phase I: Records Search
Installation Restoration Program Phase IB Survey, Final Report
Installation Restoration Program Phase n, Stage 2
Soil Organic Vapor Survey Report, Industrial Wastewater Treatment Plant
Area
Data Compilation Report RI/FS Berman Pond and Building 514 Area
Draft Final Baseline Risk Assessment for Operable Unit 3
Draft Final Remedial Investigation Report for Operable Unit 3
Final Phase II Remedial Investigation Report for Operable Unit 3
2-4
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2.3.3. IWTP Sludge Drying Beds
A remedial investigation at the IWTP Sludge Drying Beds was initiated in 1985 to
evaluate the potential for soil and ground-water contamination from past sludge drying
activities (Sergerit, Hauskins, and Beckwith, 1985). Subsequent investigations were
conducted as part of the RI/FS process to further evaluate soil and ground-water
contamination in subsurface soils at and in the vicinity of the sludge drying beds
(Radian, 1988; JMM, 1992, and Montgomery .Watson, 1995). Site characterization
activities at the IWTP Sludge Drying Beds were completed in March 1995.
2.3.4. Herman Pond
Berman Pond was included in a records search that was conducted in 1982
(UBTL, 1982). The purpose of the records search was to identify the potential for
environmental contamination from past waste disposal practices at Hill AFB and to
assess the probability of contaminant transport beyond the installation boundary.
Additional investigations were conducted to evaluate the presence/absence of
contamination (Radian, 1988) and to define the areal extent of soil and ground-water
contamination (ESE, 1989). An RI/FS was initiated in 1987; Phase I and Phase II.
remedial investigations were completed as part of the RI/FS process (JMM, 1992 and
Montgomery Watson, 1995). A dewatering treatability study was completed in 1994 to
evaluate the feasibility of extracting perched water contained within the pond prior to
initiating remedial actions (Montgomery Watson, 1995a). Site characterization activities
at Berman Pond were completed in March 1995.
2.3.5. Pond 1
The RI/FS process for Pond 1 was initiated in 1989 with a study that evaluated the
presence/absence of contaminants in pond surface water and sediment (ESE, 1989a). An
additional investigation was completed to further evaluate the nature and extent of surface
water and sediment contamination (Montgomery Watson, 1995). Site characterization
activities at Pond 1 were completed in March 1995.
2.3.6. Pond 3
The RI/FS process for Pond 3 was initiated in 1989 with a study that evaluated the
presence/absence of contaminants in pond surface water and sediment (Chen Northern,
1989). An additional investigation was completed to further evaluate the nature and
extent of surface water and sediment contamination (Montgomery Watson, 1995). Site
characterization activities at Pond 3 were completed in March 1995.
2.4 COMMUNITY RELATIONS HISTORY
The public participation requirements of CERCLA Sections 113(k)(2)(B)(i-v) and 117
were met. Hill AFB completed a Community Relations Plan in February of 1992; the
community relations activities include: (1) a Restoration Advisory Board (RAB) which
meets at least quarterly (more frequent meetings are held if necessary) and includes
2-5
-------
community representatives from adjacent counties and towns, (2) a mailing list for
interested parties in the community, (3) a bimonthly newsletter called "EnviroNews,"
(4) visits to nearby schools to discuss environmental issues, (5) community involvement
in a noise abatement program, (6) semiannual town council meetings, (7) opportunities
for public comment on proposed remedial actions, and (8) support for the community for
obtaining technical assistance grants (TAGs). In addition, a public open house was held
for the communities that are adjacent to OU 3 on April 20, 1995, to explain risk issues,
present and explain the proposed remedial alternatives, and provide an opportunity for
questioning and commenting on the proposed alternatives.
The Draft Final Remedial Investigation Report for Operable Unit 3 (JMM, 1992), the
Draft Final Baseline Risk Assessment for Operable Unit 3 (JMM, December 1991), the
Final Phase II Remedial Investigation Report for Operable Unit 3 (including the
Baseline Risk Assessment Addendum [Montgomery Watson, 1995]), the Final Feasibility
Study for Operable Unit 3 (Montgomery Watson, 1995a), and the Final Proposed Plan
for Operable Unit 3 (Montgomery Watson, 1995b) were released to the public, and are
available in the administrative record maintained in the Davis County Library (Central
Branch) and at the Environmental Management Directorate at Hill AFB. The notices of
availability for these documents were published in the Salt Lake Tribune, the Ogden
Standard Examiner, and the Hilltop Times. A public comment period was held from
April 10, 1995, through May 9, 1995. In addition, a public open house was held on
April 20, 1995. At this open house, representatives from Hill AFB, EPA, and the State of
Utah answered questions about.the site and the selected remedies. A court reporter
prepared a transcript of the meeting. Copies of the transcript and all written public
comments received.during the comment period are provided in Appendices C and D, and
will be included in the administrative record. In addition, copies of the transcript were
sent to all meeting attendees who requested them. Responses to the comments received
during the public comment period are included in the Responsiveness Summary, which is
part of this ROD. The decision for these sites is based on the Administrative Record.
2.5 SCOPE AND ROLE OF OPERABLE UNIT 3 WITHIN SITE STRATEGY
Operable Unit 3 is one of nine operable units at Hill AFB. The remaining operable units
are at various stages in the RI/FS process. The remedial actions planned for the operable
units are independent of one another. This action addresses contaminated soil at OU 3;
ground water beneath OU 3 will be addressed in the OU 8 RI/FS.
2-6
-------
3.0 SUMMARY OF SITE CHARACTERISTICS
3.1 NATURE AND EXTENT OF CONTAMINATION
Data summarized in this section were collected during the OU 3 RI and during previous
investigations. The nature and extent of contamination are discussed separately for each
site.
3.1.1. Refueling Vehicle Maintenance Facility (RVMF)
The primary contaminants detected in soil near Building 514 at the RVMF include
VOCs, base, neutral, and acid extractable (BNAE) compounds, the pesticide p,p'-DDT,
polychlorinated biphenyl 1254 (PCB-1254), and metals. Table 3-1 summarizes the
minimum and maximum concentrations of the compounds present in soil. Although
borings were drilled in the vicinity of Building 511, the concentrations of contaminants
present in these borings were within acceptable limits.
The principal VOCs present at the RVMF are 1,1-dichloroethene (1,1-DCE; up to
8.7 mg/kg), 1,1,1-trichloroethane (1,1,1-TCA; up to 73 mg/kg), tetrachloroethene (PCE;
up to 12 mg/kg), and toluene (up to 11 mg/kg).. The highest concentrations of these
compounds generally were present in soil less than 10 feet below ground surface (bgs).
Although several BNAEs were detected in two samples, the source of contamination is
believed to have been either the inadvertent introduction of asphalt into the sample during
collection or the result of BNAE compounds leaching from the asphalt into the
underlying soil; therefore, the presence of BNAE compounds is not believed to be
indicative of contamination from the RVMF. The pesticide p,p'-DDT was detected in one
sample only in a concentration of 0.0079 mg/kg. PCB-1254 was present in two samples;
the maximum concentration was 0.39 mg/kg. Several metals were present in
concentrations exceeding OU 3 background levels.
Based on the findings and conclusions of the OU 3 RI/FS and the risk assessments, the
only contaminant requiring cleanup at the RVMF is 1,1-DCE; The area of contaminated
soil is centered around a floor drain located within Building 514 (see Figure 3-1). The
1,1-DCE contamination extends to an approximate depth of 5 feet bgs; approximately
100 cubic yards of soij are contained within the area of contamination. The treatment-
based remediation goal for 1,1-DCE is 0.8 milligrams per kilogram (mg/kg) based on
health risks as presented in Section 3.3.3. of the Feasibility Study for OU 3.
3.1.2. Sodium Hydroxide Tank Site
Elevated levels of soil pH (resulting from the release of sodium hydroxide solution) were
present in subsurface soil; soil pH ranged from 6.2 to 12.9 pH units. Sodium hydroxide
solutions of 25% to 50% are typically used at industrial wastewater treatment plants, and
are currently in use at the Hill AFB plant. While the concentration of solutions released
on site is not known, a 25% solution of sodium hydroxide has a pH.in excess of 14.
Several metals also were present in concentrations -above OU 3 background levels,
3-1
-------
TABLE 3-1
SUMMARY OF CONTAMINANTS DETECTED IN RVMF SOIL
(Iof2)
Analyte (units)
Minimum Maximum
Concentration Concentration
Volatile Organic Compounds (mg/kg)
Acetone
Methylene chloride
Trichlorofluoromethane
l.l-Dichloroethene(l.I-DCE)
Total 1,2-Dichlorethene
!.2-Dichloroethane
1.1.1 -Trichloroethane (1.1,1 -TCA)
Trichloroethene (TCE)
Tetrachloroethene (PCE)
Toluene
Xylenes (Total)
<0.0029
<0.0014
<0.000313
<0.000239
<0.0021
<0.000094
<0.000061
<0.000221
<0.000083
<0.0014
-------
TABLE 3-1
SUMMARY OF CONTAMINANTS DETECTED IN RVMF SOIL
(2 of 2)
Analyte (units)
Minimum Maximum
Concentration Concentration
Pesticides/Polychlorinated Biphenyls (mg/kg)
p'p'-DDT <0.0034 0.0079
PCB-1254 <0.034 0.39
Metals (mg/kg)
Aluminum 671 13320
Arsenic • <0.553 14.8
Barium 16.6 134.4
Beryllium <0.21 ... - 1.2
Cadmium <0.5 3.3
Calcium 1230 53440
Chromium, Total 2.7 ,31.2
Cobalt <1 10.8
Copper . 3.2 29.7
Iron 1870 12720
Lead 1 109
Magnesium 572 10896
Manganese 52.8 1448
Mercury <0.041 0.057
Nickel <2.1 . 21.6
Potassium <208 . 2976
Silver <1 2.5
Sodium <205 350
• Tin <10 24.4
Vanadium 2.5 21.6
Zinc 8.6 80.7
Hexavalent Chromium (mg/kg) ND ND
Cyanide (mg/kg) <0.52 <0.6
TPH (mg/kg)
Total petroleum hydrocarbons <4 30
Diesel component #2 20 99
Bolded values indicate detected analytcs.
ND Not detected in any sample
< Analyte is considered not detected at or above the associated value
mg/kg Milligrams per kilogram
3-3
-------
TABLE 3-2
SUMMARY OF CONTAMINANTS DETECTED IN SODIUM HYDROXIDE
TANK SITE SOIL
Analyte (units)
Minimum Maximum
Concentration Concentration
Volatile Organic Compounds (mg/kg)
Base, Neutral, and Acid Extractable
Compounds (mg/kg)
NA
NA
NA
NA
Metals (mg/kg)
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium, Total
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Sodium
Tin
Vanadium
Zinc
Cyanide, Total (mg/kg)
pH
1440
2.5
123
<0.22.
<0.52
13600
4
1.3
6.5
3710
2
2180
101
3
333
<220
<11
5.7
11.7
. ND
6.2
4480
5.6
171
0.49
4.2
33100
59.9
3.7
29.1
11200
8.4
5390
202
7.1
873
26800
20.2
10.7
29.8
ND
12.9
Bolded values indicate detected analytes.
NA Not analyzed
< Analyte is considered not detected at or above the associated value
mg/kg Milligrams per kilogram
3-4
-------
PHD.IFCT NO 2208.0113 5/16/95
f
j
]
]
v
^
Bermed, concrete-
containment i
'
*
/
/
/
. — . . ^
Building f^LM XI
511 \~li_ry
0 50
Scale in Feet
U3-762-BH
(ND)
• ^T»
+— © Manhole -
/
/
(\ 1 /
Building Above-ground /
514 storage tanks /
1,1-DCEAreaof /
Attainment U3-844-BH . /
• ^.1 f^"1 .J. /
surfaced ^*v /^J ^L 1
«ea N. V ]\ f /
j^ 1 1 • U3'G43DH/ ' - ^Sv . ,.
(ND) / U3-741-BH .:....-?•
U3-739-BH • /
(ND) • • i /
J U3-744-BH ' 1 /
(ND) «ff/»U3:747-BH
' b 'O..w.
Underground '
storage tank l\
1 .
Building / \
512 9 U3-7B2-BH
/ T
J /*^- Wastewater
^ hnatolWtP
/ i ^
/ i r^^.
/ * /
WOTE; Exact connection / ' 1
location is unknown \ / 1 /
\ / ' /
\ / J I Building ;
<_ 4 At ^ / 584 /
, Wastp^a'cr / /
/ linetolWTP / . /
' Building / /
567 i /
J
•>
EXPLANATION
m Phase II Rl vertical soil boring •< ~ Contaminant
v concentration in mg/kg HILL AIR FORCE BASE
*» Phase II Rl slant soil bor ng nneoAei c nurr o
Not detected, betow OPERABLE UNIT 3
f. Previously-drilled soil boring ND analytical method RVMP ARPA DP
9 (prior to Phase II Rl) detection limits nvmr MIICM wr
IM7B7BH ATTAINMENT
USf Soil boring designation FIGURE 3-1
^ 4
-------
including cadmium and total chromium. Table 3-2 summarizes the compounds present in
soil.
Based on the findings and conclusions of the OU 3 RI/FS and the risk assessments, only
high pH soil (soil with pH greater than 8.5) requires remedial action at the Sodium
Hydroxide Tank Site. The area of soil impacted by the sodium hydroxide solution
extends vertically to an approximate depth of 70 feet bgs and laterally to a width of
approximately 170 feet (see Figure 3-2). The zone of highest pH appears to be located
between 25 and 40 feet bgs.
3.1.3. IWTP Sludge Drying Beds
The primary contaminants detected in soil at the IWTP Sludge Drying Beds include
VOCs, BNAEs, PCB-1254, metals, and cyanide. Table 3-3 summarizes the minimum
and maximum concentrations of the compounds detected in soil.
The VOC compounds detected in the highest concentrations were tetrachloroethene
(PCE; maximum concentration of 13 mg/kg) and TCA (maximum concentration of
3.8 mg/kg). The highest concentrations of PCE and TCA were present in soil less than
1 foot below the base of the former west sludge drying beds. The organic compounds
2-methylnaphthalene (4.0 mg/kg), bis (2-ethylhexyl) phthalate (29 mg/kg), and PCB-
1248 (0.054 mg/kg) were each present in one analyzed sample. Cyanide and several
metals were present in concentrations exceeding normal OU 3 background levels.
c
Based on the findings and conclusions of the OU 3 RI/FS and the risk assessments,
contaminants in subsurface soil below the former sludge drying beds do not pose current
or future health risks or present a threat to ground water. Consequently, cleanup actions
are not necessary at the IWTP Sludge Drying Beds; this area is not discussed further in
this ROD. The reader is referred to the Draft Final Remedial Investigation Report for
Operable Unit 3 (JMM, 1992), the Draft Final Baseline Risk Assessment for Operable
Unit 3 (JMM, December 1991), the Final Phase II Remedial Investigation Report for
Operable Unit 3 (including the Baseline Risk Assessment Addendum [Montgomery
Watson. 1995]), and the Final Feasibility Study for Operable Unit 3 (Montgomery
Watson, 1995a) for complete summaries of the data used to support a no action decision
for the IWTP Sludge Drying Beds.
3.1.4. BermanPond
Soil within and beneath the limits of the former pond is contaminated with VOCs,
BNAEs, PCBs, metals, and cyanide. Table 3-4 summarizes the minimum and maximum
concentrations of these compounds detecied in soil. The principal VOCs in Berman Pond
were chlorobenzene (up to 1,000 mg/kg). benzene (up to 1.7 mg/kg), 1,1,1-TCA (up to
348 mg/kg), and TCE (up to 55.6 mg/kg). High concentrations of BNAEs also were
measured in soil collected within Berman Pond. The BNAEs detected in the highest
concentrations were 1,2-dichlorobenzene (up to 8,200 mg/kg) and 1,4-dichlorobenzene
(up to 1,700 mg/kg).
3-5
-------
EXPLANATION
A Ground-water
i monitoring well
• Soil boring
A A'
Cross-section line
Ground-water level
Approximate extent
of high-pH soil
Spillage Inlet
Containment
i
FORMER SODIUM
HYDROXIDE TANKS
U3-756
i-BH • •' >
2
O
i
SHA-2
n
1-75
'-U
Sulturic
Acid Tank
U3-757-BH
Building
577
U3-026
FORMER SODIUM
HYDROXIDE TANKS
HILL AIR FORCE BASE
OPERABLE UNIT 3
SODIUM HYDROXIDE TANK SITE
AREA OF ATTAINMENT
FIGURE 3-2
-------
TABLE 3-3
SUMMARY OF CONTAMINANTS DETECTED
IN SLUDGE DRYING BEDS SOIL
(Iof2)
Minimum Maximum
Analyte (units) Concentration Concentration
Volatile Organic Compounds (mg/kg)
Acetone <0.010 0.039 U
Chloroform <0.0052 0.02
U-dichloroethene(DCE) <0.005 0.03
1,1 -dichloroethane <0.001 0.02
1,2-dichloroethane <0.005 0.05
Tetrachloroethane (PCE) <0.005 13
l,l,l-trichloroethane(TCA) <0.005 3.8
Trichloroethene (TCE) <0.005 0.062
Trichlorofluoromethane <0.05 0.043
2-butanone (MEK) <0.010 0.010 J
Base, Neutral, and Acid Extractable
Compounds (mg/kg)
2-methylnaphthalene <0.34 4.0
Bis(2-ethylhexyl)phthalate <0.34 29
Pesticides/Polychlorinated Biphenyls PCBs (mg/kg)
PCB.-1248 * <0.034 0.054
Metals (mg/kg)
Aluminum 769 5430
Arsenic 0.9 13.6
Bolded values indicate detected analytes.
U or < Analyte is considered not detected at or above the associated value
mg/kg Milligrams per kilogram
3-6
-------
TABLE 3-3
SUMMARY OF CONTAMINANTS DETECTED
IN SLUDGE DRYING BEDS SOIL
(2 of 2)
Analyte (units)
Metals (mg/kg) (continued)
Barium
Beryllium
Cadmium
Calcium
Chromium, Total
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Silver
Sodium
Tin
Vanadium
Zinc
Cyanide, Total (mg/kg)
Minimum
Concentration
8.4
<0.21
<0.3
1410
<1.4
1
2.4
2310
1.3
397
72.4
<0.02
2.2
<0.9
<1
<209
<10.4
3.8
7
<0.52
Maximum
Concentration
82
0.76
66.8
30100
1120
3.4
43.8
6800
71.2
4760
166
0.049
22.4
595
1.5
<237
44.2
11.4
42.7
11.6
Bolded values indicate detected analytes.
< Analyte is considered not detected at or above the associated value
mg/kg Milligrams per kilogram
3-7
-------
TABLE 3-4
SUMMARY OF CONTAMINANTS DETECTED IN
HERMAN POND SOIL
(1 of 3)
Analyte (units)
Volatile Organic Compounds (mg/kg)
1,1,2-Trichloroethane
1 , 1 ,2,2-Tetrachloroethane
total Dichlorobenzene
Vinyl chloride
Acetone
Benzene
Chlorobenzene
Chloroform
total 1 ,2-Dichloroethene
1,2-Dichloroethane
Dibromochloromethane
trans 1 ,2-Dichloroethene
Tetrachloroethene (PCE)
1,1,1 -Trichloroethane (1,1,1 -TCA)
Trichlorofluoromethane
Trichloroethene (TCE)
Toluene
Methylene chloride
Xylenes, Total
2-butanone (MEK)
Methyl isobutyl ketone
Ethyl methacrylate
Base, Neutral, and Acid Extractable
Compounds (mg/kg)
1 .2,4-Trichlorobenzene
Naphthalene
2-Methylnaphthalene
Anthracene
Phenanthrene
Pyrene
Chrysene .
Bis(2-ethylhexyl)phthalatc
Minimum
Concentration
<0.00025
<0.000133
<0.000011
<0.011
<0.011
<0.007
<0.000044
<0.0001 1
<0.0025
<0.00006
<0!00099
<0.00021
<0.000133
<0.000679
<0.000221
<0.000265
<0.0017
<0.00052
<0.001 1
<0.010
<0.010
0.0017J
<0.34
<0.34
<0.34
<0.34
<0.34
<0.34
<0.34
<0.34
Maximum
Concentration
0.28
0.295
20SOO
0.035
0.038U
1.7
1000
0.068
0.030
0.084
0.28
23.7
0.295
348
0.44
55.6
0.013J
26.8
0.0895
0.0050J
0.0041J
0.0017J
4.1
16
27
1.1J
0.94J
24
12
56
Bolded values indicate detected analytcs.
J Estimated concentration
U or < Analyte is considered not detected at or above the associated value
mg/kg Milligrams per kilogram
3-8
-------
TABLE 3-4
SUMMARY OF CONTAMINANTS DETECTED IN
BERMAN POND SOIL
(2 of 3)
Analyte (units)
Minimum Maximum
Concentration Concentration
Base, Neutral, and Acid Extractable
Compounds (mg/kg) (continued)
Benzo(a)pyrene
1 ,2-dichlorobenzene
1 ,3-dichlorobenzene
1 ,4-dichlorobenzene
2,4-dimethylphenol
4-chloroaniline
Metals (mg/kg)
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium, Total
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Silver
Sodium
Thallium
Tin
Vanadium
Zinc
<0.34
<0.0063
<0.34
<0.005
<0.34
<0.34
72.4
<0.003
0.6
113
<0.21
<0.25
2203.0
3.7
<1.1
4.3
2470
2.0
1030
40
<0.032
2.3
224.8
<0.09
<8
<0.1
<10.5
2.6
9.6
4.1
8200
8.7
1700
0.68
0.60J
10600
133
30.3
465
1.1
257
64200
4616
22.6
339
25000
1770
9650
580
5.6
152.5
2090
36.9
421
0.66
162
25.2
564
Bolded values indicate detected analytes.
J Estimated concentration
< Analyte is considered not detected at or above the associated value
mg/kg Milligrams per kilogram
3-9
-------
TABLE 3-4
SUMMARY OF CONTAMINANTS DETECTED IN
HERMAN POND SOIL
(3 of 3)
Analyte (units)
Minimum Maximum
Concentration Concentration
Pesticides/Polychlorinated Biphenyls (mg/kg)
PCB-1254 <0.0035 5.2
PCB-1260
-------
The contaminants within the area of attainment for Berman Pond appear to fall into two
distinct ranges or "zones" (based on the distribution of contaminant concentrations), as
shown in Figures 3-3 and 3-4. The highest degree of contamination occurs within Zone 1
in soil in the interval from approximately 8 feet bgs to approximately 5 feet below the
base of the former pond (approximately 25 feet bgs). The lateral limits of Zone 1 are the
historical limits of the former pond! Zone 1 contains mostly VOCs and BNAEs, with the
highest concentrations detected in samples collected at, or near, the pond bottom. Zone 2
encompasses the western two-thirds of the historical limits of the former pond and
extends vertically from a depth of 5 feet below the base of the pond to the capillary fringe
(approximately 65 feet bgs) of the ground-water table. Zone 2 contains VOCs, BNAEs,
and some pesticides and PCBs at moderately elevated concentrations. .
Based on the findings and conclusions of the QU 3 RI/FS and the risk assessments,
several VOC and BNAE compounds are present in Berman Pond soil at concentrations
that, based on modeling results, have the potential to contaminate underlying ground
water to levels that may exceed Utah Ground Water Quality Standards, maximum
contaminant levels (MCLs), or may present a health risk. The contaminants requiring
remediation and their corresponding treatment-based remediation goals are summarized
in Table 3-5.
3.1.5. Pond 1
Surface water samples collected from Pond 1 have been analyzed for VOCs, BNAEs, and
metals. Table 3-6 summarizes the minimum and maximum concentrations of the
compounds detected in Pond 1 surface water. The only compound that exceeded its MCL
was cadmium; the maximum concentration of cadmium (7 micrograms per liter; u.g/1)
was slightly over the cadmium MCL of 5 ug/1.
Pond 1 sediment samples have been analyzed for VOGs, BNAEs, pesticides, PCBs, and
metals. Table 3-7 summarizes the minimum and maximum concentrations.of the
compounds detected in Pond 1 sediment. Although BNAE compounds were present in
several samples, most concentrations were below the quanification limit of the analytical
method. The PCBs detected in the sediment samples (PCB-1248 and PCB-1260) were
present in concentrations slightly above the detection limits of the analytical method.
Although a direct comparison between the sediment and normal soil background metals
concentrations is qualitative, the metals present above OU 3 background soil
concentrations include barium, cadmium, total chromium, cobalt, copper, iron, lead,
mercury, nickel, silver, sodium, vanadium, and zinc.
Based on the findings and conclusions of the OU 3 RI/FS and the risk assessments,
contaminants in Pond 1 surface water and sediment do not pose current or future health
risks or present a threat to ground water. Consequently, cleanup actions are not necessary
at Pond 1, and Pond 1 will not be discussed further in this ROD. The reader is referred to
the Draft Final Remedial Investigation Report for Operable Unit 3 (JMM, 1992), the
Draft Final Baseline Risk Assessment for Operable Unit 3 (JMM, December 1991), the
Final Phase II Remedial Investigation Report for Operable Unit 3 (including the
Baseline Risk Assessment Addendum [Montgomery Watson, 1995]), and the Final
3-11
-------
LU
3
rr
o_
Area of Attainment Zone 1
» \ i (from B feet bgs to S feet
T Phase II Rl vapor extraction wen
• Phase II Rl piezometer
• Phase II Rl soil boring
4 Phase II Rl perched water monitoring well
Previously drilled soil boring (prior to
Phase II Rl)
Previously installed
ground-water monitoring well
(prior to Phase II Rl)
K—x Fence
Ground surface elevation contour (feet
above National Geodetic Vertical Datum) — « — Industrial waste line
bgs Below ground surface
<2 Tree or bush
HILL AIR FORCE BASE
OPERABLE UNIT 3
BERMAN POND AREAS
OF ATTAINMENT
FIGURE 3-3
-------
Northwest
c
4765 r-
4760
4755
4750
Q
O
4745
e 4740
4735 •?
4730 -
Foulds 3 . . ,, Asphalt
""" =1 Roadgji
.... -
NOTE: All material contained «w>/n tfw pond limits Is
till: the units shown are based on substantial
lithological differences. The majority ol pond fill
consists of a mixture olsilfy sands, dayey sends.
sands, and miscellaneous hit meterial (asphalt.
Honzonlal Scale in feel
Venical Exasgeraiion = I2x
4735
4730
65' —
ID=7V
Zono t ol Berman PondAroa ol
Attainnwnt
Zone 2 o) Barrrian Pond Area of
Anainment
Perched water level
Date of water level
measurement
T0.79-
NGVD
EXPLANATION
Screened Interval of rjraund-waler
monitoring wen Inslaled In borehole
Total'depth ol borehole
National Geodetic Vertical Datum .
Rn material
Gravel (SP.oyv.GM)
S«.day(Ct.,CH.ML)
Silly sand (SM), silly clay (SO
Sands, sands to silly sands, sands lo clayey
sands (SP, SW, SP-SM, SW-SM. SP-SC)
I
HILL AIR FORCE BASE
OPERABLE UNIT 3
CROSS SECTION OF THE BERMAN
POND AREAS OF ATTAINMENT
FIGURE 3-4
-------
TABLE 3-5
HERMAN POND CONTAMINANTS AND TREATMENT-BASED
REMEDIATION GOALS
Remedial Action Goal for
Treatment of Soils
Contaminants (mg/kg)
Benzene 0.05
Bis(2-Ethylhexyl)phthlate 6
Chlorobenzene 0.95
1,2-Dichlorobenzene 20
1,4-Dichlorobenzene 2.8
1,2-Dichloroethane 0.03
trans-1,2-Dichloroethene 0.7
Heptachlor epoxide 0.004
Methylene chloride 0.02
1,1,2,2,-Tetrachloroethane 0.001
l,l,l-Trichloroethane(l,l,l-TCA) 4
1,1,2-Trichloroethane 0.04
Trichloroethene (TCE) 0.07
Vinyl chloride 0.02
Benzofa'ipyrene 0.07
PCB-1254 . 0.06
Arsenic 4.1 *
Cadmium 16
Underlined compounds require cleanup based on health risks. All other compounds
require cleanup based oh their potential to leach to ground water and result in
<• groundwater contaminant concentrations in excess of MCLs.
* The remediation goal for arsenic is based on background arsenic concentrations
because the calculated risk-based goal was lower than background levels. A
potential health risk will still exist with this remediation goal.
mg/kg Milligrams per kilogram
PCB Polychlorinated biphenyl
3-12
-------
TABLE 3-6
SUMMARY OF CONTAMINANTS DETECTED IN
POND 1 SURFACE WATER
Analyte (units)
Volatile Organic Compounds (|ig/l)
Chloroform
Trichlorethane (TCA)
Bromodichloromethane
Base, Neutral, and Acid Extractable
Compounds (|ig/l)
Metals (ng/1)
Aluminum
Arsenic
Barium
Cadmium
Calcium
Chromium, Total
Copper
Iron
Magnesium
Manganese
Nickel
.Potassium
Selenium
Sodium
Vanadium
Zinc
Bold values indicate detected analytes.
NA Not Analyzed
< Analyte is considered not detected
u.g/1 Micrograms per liter-
Minimum
Concentration
3.93
1.01
1.34
NA
120
<1.0
220
<5.0
66800
30
20
780
17700
40
20
2,900
<1.0
25800
10
12
Maximum
Concentration
4.16
1.15
10.9
NA
170
3.6
240
7
75500
40
50
1110
19200
50
30
3700
6
32300
10
58
at or above the associated value
3-13
-------
TABLE 3-7
SUMMARY OF CONTAMINANTS DETECTED IN
POND 1 SEDIMENT
(Iof2)
Analyte (units)
Minimum Maximum
Concentration Concentration
Volatile Organic Compounds (mg/kg)
Base, Neutral, and Acid Extractable
Compounds (mg/kg)
1,2-Dichlorobenzene
1,4-Dichlorpbenzene
1,2,4-Trichlorobenzene
2-Methylnaphthalene
Acenaphthalene
Dibenzofuran
Fluorene
Phenanthrene
Anthracene
Di-n-butylphthalate
Fluoranthene
Pyrene
Benzo(a)anthracene
bis(2-ethylhexyl)phthalate
Chrysene
Di-n-octylphthalate
Benzo(b)fluoranthene
Benzo(a)pyrene
Indeno( 1,2,3-cd)pyrene
Dibenzo(a,h)anthracene
Benzo(g,h,i)perylene
Pesticides/Polychlorinated Biphenyls (mg/kg)
PCB-1248 (Aroclor 1248)
PCB-1260 (Aroclor 1260)
ND
0.122J
0.198J
0.147J
0.197J
<0.330
0.205J
<0.330
0.316J
<0.330
<0.330
0.563
0.368
<0.330
<0.330
0.021J
0.073J
0.224
0.115J
0.177J
<0.330
0.178J
0.039J
0.024J
ND
<0.33
<0.33
<0.33
1.552
0.376
<0.330
0.386
2.628
0.458
0.54
4.164
3.691
1.711
1.825
2.143
<0.330
1.96
1.664
1.654
0.331J
1.513
0.090
0.057
Bolded values indicate detected analytes.
ND Not detected in any sample
< Analyte considered not detected at or above the associated value
J Estimated concentration
mg/kg Milligrams per kilogram
3-14
-------
TABLE 3-7
SUMMARY OF CONTAMINANTS DETECTED IN
POND 1 SEDIMENT
(2 of 2)
Analyte (units)
Metals (mg/kg)
Aluminum
Antimony
Arsenic
Barium
Cadmium
Calcium
Chromium, Total
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Silver
Sodium
Vanadium
Zinc
Minimum
Concentration
5131
<0.1
4.24
124.18
22.22
21967
107.84
6.54
143.79
8366
173.2
3880
88.24
0.66
19.61
1304
6.54
486.93
19.61
388.89
Maximum
Concentration
6202
2.57
4.79
795.08
48.36
23464
325.14
16.39
956.28
14918
366
3987
183
14.3
79.23
1339
30.05
1071
24.59
795.08
Bolded values indicate detected analytes.
ND Not detected in any sample
< Analyte considered not detected at or above the associated value
J Estimated concentration
mg/kg Milligrams per kilogram
3-15
-------
Feasibility Study for Operable Unit 3 (Montgomery Watson, 1995a) for complete
summaries of the data used to support a no action decision for Pond 1.
3.1.6. Pond 3
Surface water samples collected from Pond 3 have been analyzed for VOCs, BNAEs,
pesticides, PCBs, hexavalent chromium, cyanide, metals, total petroleum hydrocarbons
(TPH), and phenols. Table 3-8 summarizes the minimum and maximum concentrations
of the compounds detected in Pond 3 surface water. Concentrations of benzo (a) pyrene
(maximum concentration of 0.27 u.g/1) and cadmium (maximum concentration of 23 |ig/l)
exceeded their MCLs (0.20 u.g/1 and 5 u.g/1, respectively) in at least one analyzed sample.
Subsequent sampling conducted to verify the presence of these compounds did not
confirm the presence of cadmium and benzo (a) pyrene in Pond 3 surface water.
Pond 3 sediment samples have been analyzed for VOCs, BNAEs, pesticides, PCBs,
metals, hexavalent chromium, cyanide, and TPH. Table 3-9 summarizes the minimum
and maximum concentrations of the compounds detected in Pond 3 sediment. Although
BNAE compounds were present in several samples, most concentrations were below the
quanification limit of the analytical method. Although a direct comparison between the
sediment and soil background metals concentrations is qualitative, the metals present
above OU 3 background soil concentrations include barium, beryllium, cadmium, total
chromium, copper, magnesium, mercury, silver, sodium, and zinc. Total petroleum
hydrocarbons and several chlorinated pesticides also were present in Pond 3 sediments.
Based on the findings and conclusions of the OU 3 RI/FS and the risk assessments,
contaminants in Pond 3 surface water and sediment do not pose current or future health
risks or present a threat to ground water. Consequently, cleanup actions are not necessary
at Pond 3, and Pond 3 will not be discussed further in this ROD. The reader is referred to
the Draft Final Remedial Investigation Report for Operable Unit 3 (JMM, 1992), the
Draft Final Baseline Risk Assessment for Operable Unit 3 (JMM, December 1991), the
Final Phase II Remedial Investigation Report for Operable Unit 3 (including the
Baseline Risk Assessment Addendum [Montgomery Watson, 1995]), and the Final
Feasibility Study for Operable Unit 3 (Montgomery Watson, 1995a) for complete
summaries of the data used to support a no action decision for Pond 3.
3.2 SUMMARY OF FATE AND TRANSPORT OF CONTAMINANTS
Conceptual site models depicting the RVMF, the Sodium Hydroxide Tank Site, and
Berman Pond contaminant source areas, and the contaminants and routes of
contamination transport are shown in Figures 3-5, 3-6, and 3-7, respectively.- Specific
characteristics and processes that affect the fate and transport of OU 3 contaminants in
soil, water, and air are summarized in Appendix A, Table A-l.
Fate
Numerous types of environmental contaminants were detected in OU 3 soil. These
include VOCs, BNAEs, pesticides, PCBs, and metals. Of these, natural degradation of
3-16
-------
TABLE 3-8
SUMMARY OF CONTAMINANTS DETECTED EN
POND 3 SURFACE WATER
Analyte (units)
Volatile Organic Compounds (|ig/l)
Acetone
Methylene chloride
Chloroform
Toluene
Base, Neutral, and Acid Extractable
Compounds (M-g/1)
Benzo(a)pyrene
Phenol
Pesticides/Polychlorinated Biphenyls (p.g/1)
Metals (ng/1)
Aluminum
Arsenic
Barium
Cadmium
Calcium
Chromium
Copper
Iron
Magnesium
Manganese
Mercury
Potassium
Sodium
Zinc
Hexavalent Chromium (p.g/1)
Cyanide (jig/1)
Bolded values indicate detected analytes.
ND Not detected in any sample
< Analyte is considered not detected at or
J Estimated concentration
p.g/1 Micrograms per liter
Minimum
Concentration
<10
2.7J
2.7J
0.25J
<0.20
2.2
ND
316
<2.0
63.5
18
15500
10
372
2500
26
<0.2
2040
9350
46
ND
ND
Maximum
Concentration
15
3.4J
2.7J
0.25J
0.27
48
ND
5100
5.8
78.3
23
30300
10
37
3800
7320
110
0.2
2270
29000
280
ND
ND
above the associated value
3-17
-------
TABLE 3-9
SUMMARY OF CONTAMINANTS DETECTED IN
POND 3 SEDIMENT
(1 of 2)
Analyte (units)
Minimum Maximum
Concentration Concentration
Volatile Organic Compounds (mg/kg)
Acetone <0.0042 0.0088J
1,2-dichloroethane <0.0015 0.0014J
Base, Neutral, and Acid Extractable
Compounds (mg/kg)
Phenanthrene 0.5J 0.5J
Fluoroanthene 0.4J 0.4J
Pyrene 0.5J 0.5J
Butylbenzylphthalate 0.4J 0.4J
Bis(2-ethylhexyl)phthalate 17B 17B
Polychlorinated Biphenyls (mg/kg) ND ND
Pesticides (mg/kg)
p.p'-DDE <0.0034 0.012
p,p'-DDD <0.0034 0.023
p,p'-DDT <0.0034 0.018
Total Petroleum Hydrocarbons (TPH) (mg/kg)
TPH <30 2600
Diesel Component #2 <11 2800
Metals (mg/kg)
Aluminum 3540 4990
Arsenic 1.9 8.6
Barium 41.6 88.1
Beryllium <0.24 0.59
Cadmium 0.79 4
Calcium 1810 26700
Chromium, Total 8.1 15.7
Bolded values indicate detected analytes.
ND Not detected in any sample
< Analyte is considered not detected at or above the associated value
J Estimated concentration
B Analyte detected in an associated blank
mg/kg Milligrams per kilogram
3-18
-------
TABLE 3-9
SUMMARY OF CONTAMINANTS DETECTED IN
POND 3 SEDIMENT
(2 of 2)
Analyte (units)
Minimum Maximum
Concentration Concentration
Metals (mg/kg) (continued)
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Silver
Sodium
Tin
Vanadium
Zinc
2.0
10.4
5290
7.6
1080
29.6
<0.048
4.5
807
<1.2
<239
<12.2
9.0
48.1
4.0
39.9
7970
34
3690
101
0.17
9.2
1110
3.9
496
41
123
115
Hexavalent Chromium (mg/kg)
ND
ND
Bolded values indicate detected analytcs.
ND Not detected in any sample
< Analyte is considered not detected at or above the associated value
J Estimated concentration
B Analyte detected in an associated blank
mg/kg Milligrams per kilogram
3-19
-------
2208.01135/17/95
$$M£M'^»«= -::•:•<
••--....^.y^m
Hi
Not sampled
Mechanism
Contaminant —
Source '
STORAGETANKS
Chlorinated Solvents, Fuel Constituents, Metals,
Pesticides. PCBs, BNAEs
Volatilization, suspended dust
EXPLANATION
\ \
Predominant
Pathway
Minor
Pathway
Minor Minor
Soil Gas Airborne
Pathway Pathway
TCA 1,1,1-Trichloroethane
TCE Trichloroethene
DCE 1,1-Dichloroethene; 1,2-Dlchloroethene
PCE Tetrachloroethene
VOCs Volatile organic compounds
BNAEs Base, neutral, or acid extractables
PCBs Polychlorinated blphenyls
PAHs Polycycllc aromatic hydrocarbons
Mechanism
Spills, leaks
Mechanism
Volatilization
Secondary.
Contaminant—
Source
•SOILOJNSATURATEDZONE : ^
VOCs (TCA. TCE. DCA, PCE, DCE, toluene)
Metals (calcium, total chromium, lead, vanadium)
BNAEs (naphthalenes, PAHs, pyrenes. phthalates)
Pesticides (p,p'-DDT)
PCBs (PCB-1254)
Mechanism
Surface runoff
Not evaluated
Mechanism
Infiltration
(Will be addressed In the OU 8 Remedial Investigation)
VOCs (TCA. TCE. toluene)
Metals (arsenic, barium, cadmium, total chromium, lead, nickel, silver)
HILL AIR FORCE BASE
OPERABLE UNIT 3
RVMF CONCEPTUAL MODEL OF
CONTAMINANT TRANSPORT
FIGURE 3-5
-------
PROJECT NO. 220S.0113 5/17/95
AIR
Not sampled
Contaminant
Sources
. ' :;. .• "• ' V" SULFURiC ACID TANK
Sodium hydroxide
Sulfuric acid
Metals
\
Predominant
Pathway
TCA
TCE
DCE
DCA
PCE
VOCs
EXPLANATION
1 4 4.
Minor Minor Minor
Pathway Soil Gas Airborne
Pathway Pathway
1 ,1 . 1-Trichloroethane
Trichloroethene
1,1-Dichloroethene
Dichloroethane
Tetrachloroethene
Volatile organic compounds
Mechanism
Spills, leaks
\
Mechanism
Volatilization
Secondary
Contaminant —
Source
; i , -.. .;•
Sodium hydroxide (pH >10, conductivity > 10,000 umhos/cm)
Metals (arsenic, barium, cadmium, calcium, total chromium, copper, iron, magnesium, sodium)
Mechanism
*
*
_, !
Mechanism
Surface runoff
Not evaluated
Infiltration
(Will be addressed In the OU 8 Remedial Investigation)
Metals (total chromium, barium)
VOCs (benzene, DCA, DCE. PCE, TCA, TCE)
Phenols
HILL AIR FORCE BASE
OPERABLE UNIT 3
SODIUM HYDROXIDE TANK SITE CONCEPTUAL
MODEL OF CONTAMINANT TRANSPORT
FIGURE 3-6
-------
PROJECT NO. 2208.01135/17/95
AIR
Not sampled
Contaminant
Source
cdNTAMINATED SURFACE WATER RUNOFF
- 'Jv> AND INDUSTRIAL WASTEWATER x
•'' " r _-:v' (Prior to 1956) * Y
Residual electroplating waste, chlorinated
solvents, metals, fuel constituents, industrial
wastewater, pesticides, PCBs
Mechanism
Storm water
runoff
Secondary
Contaminant —
Source
I
Mechanism
Volatilization
\ \
Minor
Airborne
Pathway
EXPLANATION
f %
Predominant Minor Unlikely Minor
Pathway Pathway Pathway Soil Gas
(not thought to Pathway
occur based on
available data)
TCA 1,1,1-Trlchloroethane
TCE Trichloroethene
DBCM Dibromochloromethane
DCE 1,1-Dichloroethene, 1,2 Dichloroethene
DCA 1,1-Dichloroethene,
MEK Methyl ethyl ketone
PCE 1,1-Dichloroethane
VOCs Volatile organic compounds
BNAEs Base, neutral, or acid extractables
PCBs Polychlorinated biphenyls
TPH Total petroleum hydrocarbons
SOIL/SEDIMENT WITHIN FORMER POND AREA
Metals (cadmium, total chromium, lead, antimony, cobalt, copper, silver, zinc, mercury)
VOCs (chlorobenzene. benzene, MEK, TCA, TCE. DCE. DCA, PCE, DBCM, vinyl chloride)
BNAEs (naphthalenes, phenathrene. anthracene, pyrenes, chrysene, phthalates,
dichlorobenzene, trichlorobenzene)
Pesticides (heptachlor, DDD, DDE, DDT, chlorodane)
PCBs (PCB-1254, PCB-1260)
TPH (diesel and gasoline)
Mechanism
Surface runoff
Mechanism
Infiltration
\
\
4
Not evaluated
,^»*^K&.^/w.^^;;j?^
Metals (arsenic, barium, cadmium, total chromium, copper, lead, nickel, mercury, zinc)
VOCs (vinyl chloride, 1,2-DCE. TCE, benzene, chlorobenzene, xylenes)
BNAEs (phenols, dichlorobenzene. trichlorobenzene, phthalates, pyrene, fluoranthene,
phenanthrene, acenaphthene, naphthalenes
(Will be addressed In the OU 8 Remedial Investigation)
VOCs (TCE, DCE, chlorobenzene)
HILL AIR FORCE BASE
OPERABLE UNIT 3
BERMAN POND CONCEPTUAL MODEL
OF CONTAMINANT TRANSPORT
FIGURE 3-7
-------
non-chlorinated VOCs, most BNAEs, and cyanide is expected to occur fairly rapidly. In
contrast, chlorinated VOCs, pesticides, PCBs, and metals tend to persist in the soil.
Transport
The least mobile compounds detected at OU 3 are pesticides, PCBs, some BNAEs, and
most metals due to their relatively strong sorptive nature. Except for soils saturated by
the perched water in Berman Pond, there is no evidence that the current soil condition is
high in moisture or that other fluids are present. Consequently, those more soluble and
less sorptive compounds such as VOCs that could mobilize under saturated conditions are
not expected to be transported further under these current conditions. If conditions
change, and fluids are introduced, these chemicals could be transported through the
subsurface soils to ground water. At Berman Pond, the infiltration of the perched water
through the base of the pond could mobilize some of the more soluble and less sorptive
compounds (VOCs); these compounds could migrate to shallow ground water and impact
ground-water quality.
3-20
-------
4.0 SUMMARY OF HEALTH AND ENVIRONMENTAL RISKS
4.1 HEALTH RISKS
A baseline risk assessment (JMM, 1991) and a baseline risk assessment addendum
(included in the Final Phase II Remedial Investigation Report for Operable Unit 3',
Montgomery Watson, 1995) were prepared as part of the RI/FS. The purpose of the risk
assessments was to identify the contaminants of concern present at OU 3, the current and
future exposure pathways for humans and environmental receptors, and the probability of,
harmful effects resulting from current and future exposures. Based on the data collected
and the risk assessment results, the medium of concern at OU 3 is the shallow soil. The
primary contaminants of concern for this medium were VOCs, BNAEs, PCBs, and
metals. These compounds are the primary contaminants of concern because they are the
most prevalent contaminants at the site and contribute most to the risks.
Because most of OU 3 is covered with asphalt, buildings, or vegetation, current exposure
to contaminants in near-surface soil (less than 12 feet below ground surface) is unlikely.
The current risks to human health due to OU 3 contamination are well below levels
considered significant by EPA.
It is possible that Hill AFB could be closed in the future. If future residential housing is
built at the RVMF or at Berman Pond, construction workers and residents could be
exposed to unhealthy levels of contaminants through inhalation and ingestion of
contaminated soil or by dermal contact with contaminated soil. Future cancer and
noncancer health risks associated with exposure to contaminated soil at the Sodium
Hydroxide Tank Site are insignificant through direct exposure routes. The remedial
action at the Sodium Hydroxide Tank Site is to prevent degradation of ground-water
quality.
4.1.1. Contaminant Identification
The initial step of the risk assessment was to select the contaminants of potential concern,
which are toxic substances that have the potential to come in contact with environmental
receptors. Contaminants of potential concern were chosen for each of the source areas at
OU 3 and were based upon frequencies of detection, concentrations, and toxicities for the
relevant exposure pathways. The data used to select contaminants of potential concern
for shallow soil were from soil samples collected within 12 feet of the ground surface.
The contaminants of potential concern for shallow soil at the RVMF, the Sodium
Hydroxide Tank Site, and Berman Pond are presented in Table 4-1.
4.1.2. Exposure Assessment
An exposure assessment was performed to identify current and future potential exposure
pathways through which contaminants of potential concern could travel to environmental
receptors. Current and future potential exposure pathways, media of concern, and
environmental receptors are presented in Tables 4-2 and 4-3,
4-1
-------
TABLE 4-1
HILL OU 3 CONTAMINANTS OF POTENTIAL CONCERN
Soil from the Herman Pond Area
Compound NC C_
Benzo(a)pyrene X
PCB-1254 X
Arsenic X X
Barium X
Cadmium X X
Copper X
Lead X
Mercury X
Soil from the
Sodium Hydroxide Tank Site
Compound NC C_
Arsenic X X
Soil from the RVMF
Compound NC C_
1,1-Dichloroethene X X
Tetrachloroethene (PCE) X X
Toluene X
PCB-1254 X
Chromium, Trivalent X
Vanadium X
NC Noncarcinogenic compound
C Carcinogenic compound
An "X" in both categories indicates that the chemical of potential concern
poses both carcinogenic and noncarcinogenic health risks depending on the
exposure pathways and concentrations.
4-2
-------
TABLE 4-2
CURRENT POTENTIAL EXPOSURE PATHWAYS FOR
HILL AIR FORCE BASE OU 3 SITES
Environmental Medium
Potential Receptors
Potential Exposure Routes
Potentially
Significant Pathway
Soil
Soil at the surface Nearby on-base residents,
(0 to 2 feet below surface) Base personnel
Incidental ingestion of dust,
inhalation, and dermal contact
with surface soil.
No. Exposures expected to be
low. Surface soil show low-level
contamination, but are generally
covered with buildings, asphalt, or
vegetation. Base restrictions
prevent access, but occasional
visitor and maintenance workers
may be exposed.
Near surface soil Base personnel and/or
(below surface to 12 feet) residents, construction
workers
Incidental ingestion, inhalation of
dust, and dermal contact with soil.
No. Exposure to soil is not likely
since sampled areas are generally
paved, or covered and/or
surrounded by existing buildings.
Air
Base personnel
Inhalation of VOCs emitted from
subsurface soil (on Base).
No. Exposure levels expected to
be low and will be qualitatively
analyzed only due to lack of
definite air concentrations.
-------
TABLE 4-3
FUTURE POTENTIAL EXPOSURE PATHWAYS FOR
HILL AIR FORCE BASE OU 3 SITES
Environmental Medium
Potential Receptors
Potential Exposure Routes
Potentially
Significant Pathway
Soil
Soil at the surface Future residents
(0 to 2 feet below surface)
Near surface soil Future construction worker
(below surface to 12 feet)
Incidental ingestion, inhalation of Yes. Surface soil shows limited
dust, and dermal contact with contamination.
surface soil.
Incidental ingestion, dermal
contact, and/or inhalation of soil.
Yes. Exposure could occur to a
construction worker at the site.
The frequency and duration would
be limited.
Air
Future residents
Inhalation of VOCs from
subsurface soil.
Yes. Exposure levels expected to
be low. Residents with basements
most likely affected (analyzed
semi-quantitatively).
-------
Potential current exposures are associated with three media: surface soil (0 to 2 feet bgs)
in uncovered areas, near surface soil (less than 12 feet bgs), and air. Exposure to soil in
areas covered with buildings or asphalt would be unlikely. The degree of exposure to
surface soils in uncovered areas of OU 3 depends on the amount of vegetation present at
each of the areas that may prevent or limit exposure. A portion of Berman Pond is
covered with vegetation; the only possible exposure to soil in this area would be to
maintenance workers who mow the lawn. However, the exposure would be limited
because this area is small and the grass is mowed infrequently. Because of the vegetative
cover over the open portion of Berman Pond and the limited potential for exposure of
current workers to incidental ingestion of contaminated soil, inhalation of fugitive dust,
and dermal contact with contaminated soil were not evaluated under current conditions.
No known sources of contaminant emissions to the air currently exist at OU 3.
Volatilization from the soil into the air is considered to be very minor at OU 3, especially
in areas that are covered with concrete or asphalt.
For future land use scenarios, it was assumed that residential, commercial, and industrial
development could take place within the current boundaries of Hill AFB. If Hill AFB is
closed, residential or commercial and industrial operations would most likely replace
existing uses; although there are no current plans to close the Base. Complete removal of
the heavy industrial infrastructure in the OU 3 area, followed by returning the land usage
to farming, is considered highly unlikely. If Hill AFB is closed, potential future land use
in the OU 3 area may be similar to the current residential land use in the area of Layton,
next to the Base. Potential future exposures at OU 3 would be associated with two
media: soil (within 12 feet of the surface), and air.
Under potential future land use, residential, commercial, and industrial operations may be
developed within the present boundaries of Hill AFB. Where construction does occur,
shallow soils near the surface (to a depth of 12 feet) might be considered potential
exposure routes because foundation and basement construction could penetrate to this
depth (i.e., construction workers building homes and industrial or commercial buildings
may become exposed to shallow soils during construction activities). Three exposure
routes were considered for construction workers: incidental ingestion, inhalation of
fugitive dust, and dermal contact with soils and fugitive dust. However, employees of -
future commercial or industrial operations were assumed to have no exposure to soils for
two reasons: most employees were assumed to spend their working time indoors, and
paved land surfaces at these operations will prevent exposure to soils among those
employees who do work outdoors. Like construction workers, persons living in
residential developments (including children) could be exposed to chemicals in surface
soil (to a depth of 2 feet) via three exposure routes: (1) incidental ingestion of soil (where
food may be ingested with unwashed hands, unwashed hands may be placed in the
mouth), (2) inhalation of fugitive dust from areas of exposed surface soil such as gardens,
and (3) dermal absorption as a result of dermal contact with surface soils or fugitive dust
on exposed skin.
There are no known current emissions to the air at OU 3. Under the current exposure
scenario, volatilization from the soil into outdoor air is considered to be minor (relative to
other exposures quantified in the Baseline Risk Assessment for Operable Unit 3
4-5
-------
[JMM, 1991]). The concentrations at points of potential human exposure are expected to
be extremely low. No evidence suggests that the potential for volatile emissions will
change in the future.
The assumptions, models, and parameters used to estimate the concentrations at the
receptors and the chronic daily doses for each exposure pathway are presented in the
Baseline Risk Assessment for Operable Unit 3 (JMM, 1991) and the Baseline Risk
Assessment Addendum (Montgomery Watson, 1995).
4.1.3. Toxicity Assessment
Cancer potency factors (CPFs), or slope factors, are used to provide conservative
estimates of excess lifetime cancer risks associated with exposure to potentially
carcinogenic chemicals. CPFs are derived from the results of human epidemiological
studies and chronic animal bioassays to which animal-to-human extrapolation and
uncertainty factors have been applied. Reference doses (RfDs) are used to indicate the
potential for adverse effects from exposure to chemicals exhibiting non-carcinogenic
effects. RfDs are estimates of lifetime daily exposure levels for humans, including
sensitive individuals, which are compared to estimated intakes of chemicals from
environmental media. RfDs are derived from human epidemiological studies and animal
studies to which uncertainties have been applied. CPFs (slope factors) and RfDs for the
contaminants of potential concern at OU 3 are presented in Tables 4-4 and 4-5.
Contaminants of potential concern at OU 3 are listed in Table 4-1 and were identified
through the risk assessment process.
4.1.4. Risk Characterization
Cancer and noncancer risks were calculated for each of the exposure pathways for the
potential contaminants of concern on the basis of Reasonable Maximum Exposure (RME)
as required by EPA guidance documents. Calculated risks were then compared to
acceptable levels of riski For exposures to carcinogenic compounds, an excess lifetime
cancer risk of 1 x 1(H> indicates a one in a million chance that an individual will develop
cancer after being exposed to a carcinogen under the site-specific conditions for a 70-year
lifetime. The target excess lifetime cancer risk is 1 x 10'6 and the maximum limit for
excess lifetime cancer risk is 1 x 1(H. For exposures to noncarcinogenic compounds, a
total hazard index greater than one is considered jo be an unacceptable risk.
Current surface soil exposure was not quantified because the potential for, and possible
duration of, exposure is minor compared to other pathways evaluated in the risk
assessments (e.g., future residential). For potential future exposure scenarios, risks were
calculated for the construction worker scenario and the residential scenario. The
construction worker scenario assumes exposure to shallow soils (from the surface to
12 feet bgs) while the residential scenario assumes exposure to the top two feet of soil
only. The risk estimates for future exposure pathways for soil contaminants at all of the
OU 3 source areas are presented in Table 4-6, and are discussed separately for each site in
the following paragraphs.
4-6
-------
TABLE 4-4
SUMMARY OF SLOPE FACTORS FOR CONTAMINANTS OF POTENTIAL CONCERN
VOCs
BNAEs
Ingestion
Slope Factor
Compound (mg/kg/day)-l
.
Chloroform 6.10E-03
Dichlorobromomethane 6.20E-02
1,1-Dichloroethene 6.00E-01
Tetrachloroethene (PCE) 5. 1 OE-02
Benzo(a)anthracene 7.30E-01
Benzo(a)pyrene 7.30E+00
Benzo(b)fluoranthene 7.30E-01
bis(2-Ethy lhexyl)phthalate 1 .40E-02
Chrysene 7.30E-02
Indeno( 1 ,2,3-c,d)pyrene 7.30E-0 1
Ingestion
Weight of
Evidence
B2
B2
C
B2
B2
B2
B2
B2
B2
B2
Source
I
I
I
STSC
EPA
I
EPA
I
EPA
EPA
Inhalation
Slope Factor
(mg/kg/dayH
8.10E-02
-
1.20E+00
2.00E-03
-
-
-
-
-
-
Inhalation
Weight of
Evidence
B2
—
C
B2
B2
B2
B2
B2
B2
B2
Source
H
—
H
STSC
I
I
I
I
I
I
Pesticides and PCBs
Inorganic
BNAEs
PCBs
I
H
H(2)
STSC
—
EPA
mg/kg/day
A
Bl
B2
C
D
PCB-1248 7.70E-fOO
PCB-1254 7.70E+00
PCB-1260 7.70E+00
Arsenic 1.80E+00
Beryllium 4.30E+00
Cadmium
Chromium, Hexavalent ~
Lead
Base, neutral, and acid extractables
Polychlorinated biphenyls
IRIS database searched in November 1993
B2
B2
B2
A
B2
D
D
B2
I
I
I
I
I
H
I
I
—
—
—
5.00E+01
8.40E+00
6.30E+00
4.10E+01
—
B2
B2
B2
A
B2
Bl
A
B2
I
I
I
I
I
I
I
I
Health Effects Assessment Summary Tables (HEAST, 1 993)
HEASTTable2: Alternate Methods
Superfund Technical .Support Center
Not available on IRIS or HEAST
EPA Region Vm, 1993. See Section 6.1.3.1.
milligrams per kilogram per day
Human carcinogen
Probable human carcinogen
Probable human carcinogen
Possible human carcinogen
Not classified
, of this Addendum for further information.
4-7
-------
TABLETS
SUMMARY OF REFERENCE DOSES FOR CONTAMINANTS OF POTENTIAL CONCERN
Chronic Subchronic Chronic Subchronic
Ingestion Ingestion Inhalation Inhalation
Reference Dose Reference Dose Reference Dose Reference Dose
Compound (mg/kg/day) Source (mg/kg/day) Source (mg/kg/day) Source (mg/kg/day)
VOCs
Chloroform
Dichlorobromomethane
1.1-Dichloroethene
Tetrachloroethene (PCE)
Toluene
l.OOE-02
2.00E-02
- 9.00E-03
l.OOE-02
2.00E-0!
l.OOE-02
2.00E-02
9.00E-03
l.OOE-01
2.00E+00
H
H
H
H
H
_ _
_ .. _ ~
_ _ _
_ _ _
1.10E-OI I
BNAEs
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g,h,i)pcrylene
bis(2-EthyIhexyl)phthalate
Chrysene • •
Fluoramhene
Fluorene
lndeno( 1,2.3-c,d)pyrene
Pyrene
Pesticides and PCBs
PCB-I248
PCB-1254
PCB-1260
Inorganic
2.00E-02
4.00E-02
4.00E-02
3.00E-02
4.00E-OI
4.00E-01
3.00E-01
H
H
VOCs
BNAEs
PCBs
H
H(2)
1
LHA
—
mg/kg/day
Arsenic 3.00E-04
Barium 7.00E-02
Beryllium 5.00E-03
Cadmium (water) 5.00E-04
Cadmium (food) l.OOE-03
Chromium. Hexavalent 5.00E-03
Chromium. Trivalent l.OOE+00
Copper 3.71E-02 (
Lead . -
Manganese (water) 5.00E-03
Manganese (food) 1.40E-OI
Mercury 3.00E-04 1
Nickel 2.00E-02
Selenium 5.00E-03
Silver 5.00E-03
Tin 6.00E-01 1
Vanadium 7.00E-03 1
Zinc 3.00E-OI
Cyanide 2.00E-02
3.00E-04
7.00E-02
5.00E-03
—
—
2.00E-02
I.OOE+OI
H 3.7IE-02
—
-
1.40E-OI
i 3.00E-04
2.00E-02
5.00E-03
5.00E-03
1 6.00E-OI
1 7.00E-03
3.00E-OI
2.00E-02
Volatile Organic Compounds
Base, neutral, and acid extractable compounds
Polychlorinated biphenyls
Health Effects Assessment Summary Tables (HKAST. IW)
HEAST Table 2: Alternate Methods
IRIS database searched in November 1993
Lifetime Health Advisory
Not available on IRIS or HEAST
milligrams per kilogram per day
H
H
H
—
-
H
H
H
-
-
H
H
H
H
H
H
H
H
H
_ .. _
I.OOE-04 H(2) l.OOE-03
_ .. _
_ _ _
_ — _
_
_ .. _
„
— — . —
I I.40E-05
I.40E-05 I I.40E-05
8.60E-05 H 8.60E-05
_ .. _
-- • J ?-
•_ .. _
_
_ — _
_ _ _
-----
4-8
-------
TABLE 4-6
SUMMARY OF CANCER RISKS AND HAZARD INDICES
FOR EVALUATED PATHWAYS:
FUTURE EXPOSURES
Scenario
FUTURE - Reasonable Maximum Exposure
Soil On Base, Construction Workers
Bermnn Pond
Sodium Hydroxide Tank Site
RVMF
Soil On Base, Potential Residents
Berman Pond
Sodium Hydroxide Tank Sile
RVMF
Ingestion
of Soil
IE-01
4E-02
5E-03
2E-OI
7E-02
2E-02
Hazard Index
Inhalation
of Fugitive Dermal Contact
Dust with Soil
5E-02 2E-03
NC 5E-04
IE-05 2E-04
6E-03
2E-03
2E-03
.
Total
Hazard Index
2E-OI
4E-02.
5E-03
2E-01
7E-02
2E-02
Ingestion
of Soil
3E-06
7E-07
4E-07
8E-05
2E-05
IE-05
Cancer Risk
Inhalation
of Fugitive Dermal Contact
Dust with Soil
1
8E-06 8E-07
4E-06 8E-09
2E-08 1E-07
4E-05
4E-07
8E-06
Total
Cancer Risk
IE-05
5E-06
6E-07
1E-04
2E-05
2E-05
Exposure route not part of the pathway
NC Not calculated
-------
RVMF
For future construction workers, the estimated excess cancer risk is 6 x 10"7 and the
hazard index is 0.005, both of which are considered insignificant. For future on-Base
residents, the estimated excess cancer risk from ingestion of and dermal contact with soil
is 2 x 10'5, which may be significant. The estimated resident hazard index is 0.02, which
is considered insignificant. The only contaminant of potential concern with individual
excess cancer risk greater than 1 x 10'6 is 1,1 -DCE. The compound 1,1-DCE is a Class C
carcinogen, (a possible human carcinogen) and, thus presents a high degree of uncertainty-
in estimating risks.
Sodium Hydroxide Tank Site
Arsenic presents an estimated baseline cancer risk of 5 x 10'6 and an estimated hazard
index of 0.04 to future construction workers, and an estimated excess cancer risk of 2 x
10~5 and an estimated hazard index of 0.07 to future residents. However, the maximum
concentration of arsenic detected in this area and used in the risk assessment is within the
range of arsenic concentrations detected in background soil samples. The range of
arsenic concentrations in background soil is 0.68 to 10 mg/kg with a mean of 3.0 mg/kg
for analyzed samples. Arsenic concentrations in soil from the sodium hydroxide tank
area ranged between 3.8 mg/kg and 5.6 ing/kg with a mean concentration of 4.4 mg/kg
(see Table 6-8 of the Remedial Investigation .report, March 1995). Because arsenic
concentrations are not significantly different from background concentrations, arsenic
does not require remediation.
Herman Pond
For future construction workers, the estimated excess cancer risk is 1 x 10'5, which may
be significant. Compounds with individual excess cancer risks greater than 1 x 10'6
include benzo(a)pyrene, arsenic, and cadmium. The hazard index is estimated to be 0.2,
which is considered insignificant.
The estimated excess cancer risk to future residents is 1 x 10~4, which is considered
significant. Compounds with individual cancer risks greater than 1' x 10'6 include
benzo(a)pyrene, PCB-1254, and arsenic. The estimated future hazard index is 0.2, which
is considered insignificant.
4.2 ENVIRONMENTAL RISKS
4.2.1. Air Quality
The existing building structure at the RVMF minimizes the potential for emission of
contaminants to the atmosphere. The air quality iii the vicinity of the Sodium Hydroxide
Tank Site and Berman Pond is not impacted due to the non-volatile nature of
contaminants in the sodium hydroxide tanks area and the lack of any VOCs in the soils in
the vadose zone of Berman Pond.
4-10
-------
4.2.2. Surface Water, Ground Water, and Wetlands
No streams, rivers, or lakes exist on Hill AFB. Numerous wetlands have been identified
on Hill AFB, but none occur within 400 feet of the RVMF, the Sodium Hydroxide Tank
Site, or Berman Pond. Therefore, no impacts to surface waters or wetlands are
anticipated or have been observed.
4.2.3. Vegetation
All areas of OU 3 are highly modified and do not contain any threatened or endangered
species. Therefore, no adverse effects on the local ecosystem are anticipated. The ranges
of some endangered birds (e.g., bald eagles and peregrine falcons) in the vicinity may
include portions of Hill AFB.
4.2.4. Wildlife
Hill AFB and OU 3 do not provide critical or important habitat for any wildlife species,
and no threatened or endangered species are known to inhabit the Base.
4.2.5. Archaeological Resources
There are no known cultural or archeological resources on Hill AFB in the vicinity of
OU 3 that could be affected by the actions included in this ROD.
4.3 SUMMARY OF RISKS
The results of the risk assessments indicate current health risks at OU 3 are below
significant levels due to lack of exposure. The areas of contamination at the RVMF and
Sodium Hydroxide Tank site are beneath concrete floor slabs under existing buildings or
under asphalt surface coverings, which prevent the exposure pathways from being
complete. The buildings and surrounding asphalt covered areas also act as a barrier to
precipitation and other fluids that could transport contaminants from the soil to the
underlying ground water. There are future health risks from potential exposure to
contaminated soil at the RVMF and at Berman Pond. The main contributors requiring
remediation to address future excess risk are 1,1-DCE at the RVMF and PCB,
benzo(a)pyrene, arsenic, and cadmium at Berman Pond.
No ecological risks, such as adverse effects of contamination on critical habitats or
endangered species, are expected at OU 3 sites. No critical habitats have been identified
in the area. No endangered species inhabit the area, but the ranges of some endangered
birds (e.g., bald eagles and peregrine falcons) in the vicinity may include portions of Hill
AFB.
Actual or threatened releases of hazardous substances from these sites, if not addressed
by implementing the response actions selected in this ROD, may present imminent and
substantial endangerment to public health, welfare, or the environment.
4-11
-------
5.0 DESCRIPTION OF ALTERNATIVES
As part of the feasibility study (FS) for OU 3 (Montgomery Watson, 1995a), three
specific remedial alternatives were developed for soil cleanup at the RVMF, four
alternatives were developed for the Sodium Hydroxide Tank Site, and six alternatives
were developed for Berman Pond to meet the remedial action objectives (RAOs). Under
Section 121 of CERCLA, a selected remedial action must be protective of human health
and the environment, and it must comply with applicable or relevant and appropriate
requirements (ARARs). The alternatives for soil cleanup were evaluated for short-term-
effectiveness; long-term effectiveness and permanence; reduction of toxicity, mobility or
volume through treatment; technical and administrative implementability; and cost
effectiveness. Alternatives were then compared against these criteria for selecting the
recommended remediation measures. State and community acceptance also were
considered. This section summarizes how the remedy selection process for OU 3
addressed these requirements.
5.1 DEVELOPMENT OF ALTERNATIVES
Remedial alternatives were developed by assembling technologies into combinations
applicable for the medium of concern at OU 3 (soil). The steps that were used to develop
remedial alternatives for OU 3 included development of response objectives, RAOs, and
general response actions for contaminated soil, followed by a preliminary screening and
evaluation of technologies and process options. Response objectives include prevention
of human exposure to contaminated soil through direct contact, ingestion, or inhalation,
arid enable long-term attainment of shallow ground-water RAOs developed to define the
extent of the remedial action. The RAOs for OU 3 are:
s
• Reduce contaminant transport from within source areas and reduce chemical
transport from soil to ground water by minimizing surface water infiltration.
• Prevent human exposure to contaminated soil through ingestion, inhalation,
and dermal contact, so that the individual excess cancer risk is below 1 x 10"4
with a target of 1 x 10"^, and the threshold non-cancer hazard index is less
.than 1.0.
• Reduce concentrations of contaminants so that the individual cancer risk is
below 1 x 10~4 with a target of 1 x 10~6 and the threshold non-cancer index is
less than 1.0.
Included within the RAOs are preliminary cleanup goals, areas of attainment, and
estimated restoration time frames. General response actions for soil identify basic actions
that might be undertaken as part of a remedial action. Several technologies may exist for
each general response action. The preliminary screening of technologies for each general
response action involved evaluation of technical implementability. In the process option
evaluation, technically implementable technologies were evaluated with respect to
effectiveness, implementability, and cost. Details of the technologies evaluated and the
5-1
-------
evaluation process used are presented in the Feasibility Study for Operable Unit 3
(Montgomery Watson, 1995a).
The alternatives assembled for the cleanup of contaminated soil begin with the No Action
alternative, which is required by the NCP to be included in the comparison process.
Subsequent alternatives represent an increasing degree of technical complexity. Each
alternative contains different processes and degrees of remediation for contaminated soil.
The assembled alternatives are presented in Tables 5-1 through 5-3.
5.2 DETAILED ANALYSIS OF ALTERNATIVES
During the detailed analysis in the OU 3 FS, each alternative was assessed against nine
evaluation criteria defined in the NCP to compare the relative performance of the
alternatives and to identify the advantages and disadvantages of each. This approach was
designed to provide sufficient information to adequately compare the alternatives, select
an appropriate site remedy, and satisfy CERCLA remedy selection requirements. The
detailed analysis of alternatives included further definition of the volumes or areas of
contaminated soil to be addressed, the technologies to be used, and the performance
requirements associated with those technologies. Also included in the FS is a n
assessment and summary profile of each alternative, and a comparative analysis of the
alternatives.
5.2.1. RVMF
Alternative 1: No Action
Alternative 1 consists of long-term ground-water monitoring to monitor for contaminants
potentially leaching from the RVMF area. The No Action alternative takes no action to
reduce 1,1-DCE concentrations in soil or to limit future health risks associated with
human and animal exposure to the contaminated soil. Although Building 514 has a
concrete floor (which acts as a barrier) that covers the entire 1,1-DCE area of attainment
and limits current exposure to the 1,1-DCE contamination, there are no provisions for
long-term maintenance of the concrete floor or provisions for preventing excavation or-
further subsurface development in the area. Thus, future health risks due to exposure to
the 1,1-DCE- contaminated soils are not reduced.
The capital costs associated with Alternative 1 are estimated at $24,530. The average
annual operation and maintenance (O & M) costs are estimated at $6,590 over the
duration of the alternative (30+ years). The total 30-year present worth cost for
Alternative 1 is estimated at $99,000.
5-2
-------
TABLE 5-1
DEVELOPMENT OF REMEDIAL ALTERNATIVES FOR THE RVMF
Remedial Alternatives
General
Response
Actions
Institutional
Controls
In-silu
Treatment
Technology
Type
Access and Use Restrictions
Ground-Water Monitoring
Maintenance of Building
Floor
Physical
Vapor Extraction
Alternative
1
No Further
Action
•
Alternative
2
Institutional
Controls
•
•
•
Alternative
3
In-Situ Vapor
Extraction
•
•
•
-------
TABLE 5-2
DEVELOPMENT OF REMEDIAL ALTERNATIVES FOR THE SODIUM HYDROXIDE TANK SITE
Remedial Alternatives
General
Response
Actions
Institutional
Controls
Containment
Removal
Ex-silu
Treatment
In-situ
Treatment
Disposal
Technology
Type
Access and Use Restrictions
Ground-Water Monitoring
Capping
Asphalt
Excavation
Backhoc
Clam shell
Chemical .
pH Neutralization
Chemical
pH Neutralization
On-Base Disposal
Backfill (after
treatment)
Alternative
1
No Further
Action
•
Alternative
2
Cap
Maintenance and
Institutional
Controls
•
•
0 (a)
Alternative
3
Excavation,
Neutralization, and
Backfill
•
•
•
•
•
Alternative
4
In-Situ
Neutralization
•
•
•
(a) Refers to the long-term maintenance of the existing asphalt surface as a cap
-------
TABLE 5-3
SUMMARY OF REMEDIAL ALTERNATIVES FOR HERMAN POND
Remedial Alternatives
General
Response
Actions
Institutional
Controls
Containment
Removal
Ex-Shu
Treatment
In-Siiu
Treatment
Disposal
Technology
Type
Access and Use Restrictions/
Continuing Order
Ground-Water Monitoring
Capping
Synthetic membrane
Multi-media
Stabilization
Po7.7nlonic processes
Excavation
Backhoc
Thermal Ucsnrpttim
Vapor Extraction
On-Base Disposal
Backfill (after treatment)
Off-Base Treatment and
Disposal
RCRA Subtitle C Landfill
Alternative
1
No Action
•
Alternative
2
Cnp Installation :uul
Institutional
Controls
•
•
•
Alternative
3
In-SItu Solidification,
Soil Vapor Extraction,
and Cap Installation
•
•
•
•
•
Alternative
4
Excavation, Off-site
Disposal, and Soil Vapor
Extraction
•
•
' •
•
•
Alternative
5
Excavation, On-slte
Treatment,
and Cap Installation
•
•
•
«
•
•
Alternative
6
Excavation, On-slte
Treatment, and Soil
Vapor Extraction
•
•
•
•
• •
•
(J\
RCRA Resource Conservation and Recovery Act
-------
Natural attenuation would reduce 1,1-DCE concentrations in soil but the rate at which
natural attenuation would occur is not expected to reach the soil cleanup goal within the
foreseeable time frame.
Alternative 2: Institutional Controls .
Alternative 2 consists of long-term ground-water monitoring as described in Alternative 1
with the addition of institutional controls. No .additional remedial action would be
implemented to reduce the concentrations of 1,1-DCE in soil. The objective of this
alternative is to prevent future exposure and further movement of 1,1-DCE in the soil by
ensuring long-term maintenance of the floor.
A maintenance program would be established to ensure the long-term integrity of the
concrete floor and the floor drain system beneath Building 514. The maintenance
program would include development of standard operating procedures (SOPs) to provide
for inspections, floor repairs (from operations performed within the building), and leak
response actions in the event that the underground utility lines beneath the building need
repair.
A continuing order from the Installation Commander would be issued to ensure that any
future development at the site would maintain the integrity of the building floor. The
continuing order would also restrict access to or disturbance of contaminated soils as long
as Hill AFB owns the property. Specifically it would:
• Restrict the installation of any new underground utilities or other construction
activities beneath the floor in the area of attainment, thus preventing
accidental exposures to the construction worker.
• Provide for the use of proper protective equipment in the event that access
through the concrete floor is required.
• Require that the integrity of the concrete floor slab be maintained (i.e., repair
cracks that may develop) so that fluids cannot infiltrate to the subsurface.
Maintenance of the floor slab would require development of SOPs to provide
for inspections, floor repairs, and responses to spills in critical areas.
The institutional controls provide for warning signs cautioning of subsurface
contaminated soil that would be pos'ied in the area. . A long-term ground-water
monitoring program would be established to evaluate the effectiveness of the building
floor as a barrier and monitor whether contaminants beneath the building are leaching to
the shallow ground water.
In the event that the land use is changed or structures are removed, the Air Force will re-
evaluate the protectiveness of the remedy selected for OU 3, and will take any
appropriate remedial action.
5-6
-------
In the case of the sale or transfer of property within OU 3 by the United States to any
other person or entity, the Air Force will place covenants in the deed which will restrict
access and prohibit disturbance of contaminated soil or the remedial action without
approval of the United States. These covenants will be in effect until removed upon
agreement of the State of Utah, the U.S. Environmental Protection Agency, and the
U.S. Air Force or their successors in interest. The Air Force will also include in the deed
the covenants required by section 120(h)(3) of CERCLA, which include (1) a warranty
that the United States will conduct any remedial action found to be necessary after the
date of the transfer; (2) a right of access in behalf of the U.S. Environmental Protection
Agency and the Air Force or their successors in interest to the property to participate in
any response or corrective action that might be required after the date of transfer. The
right of access referenced in the preceding sentence shall include the State of Utah for
purposes of conducting or participating in any response or corrective action that might be
required after the date of transfer.
The capital costs associated with Alternative 2 are estimated at $37,770. The average
annual operation and maintenance (O & M) costs are estimated at $7,090 over the
duration of the alternative (30+ years). The total 30-year present worth cost for
Alternative 2 is estimated at $112,000.
Alternative 3: In-Situ Vapor Extraction
In addition to the provisions included in Alternative 2, Alternative 3 includes in-situ
vapor extraction of the 1,1-DCE area of attainment. The objective of this alternative is to
treat (in-situ) soil contaminated with 1,1-DCE. Soil vapor extraction is a presumptive
remedy for VOCs in soil.
The soil vapor extraction technique involves extracting air and volatilizing 1,1-DCE from
the near surface soil by applying a vacuum to a vertical extraction well. 1,1-DCE in the
vapor phase would be removed from soil, collected above the ground surface, and
discharged directly to the atmosphere or treated prior to discharge (if vapor
concentrations exceed allowable discharge limits). A maintenance program would be
established, and a continuing order would be issued by the Installation Commander to
limit excavation or other development in the area to ensure that the building floor would
continue to be an effective seal throughout the duration of the SVE process. Maintenance
of the floor would be as discussed in Alternative 2. The SVE system is anticipated to
operate for one year.
1,1-DCE concentrations in the vapor stream would be monitored to evaluate the
effectiveness of the system in removing VOCs from the subsurface. Once vapor
concentrations were reduced to acceptable levels (based on partitioning modeling), soil
samples would be collected within the area of attainment and analyzed to verify that
remediation goals have been met in subsurface soil.
The capital costs associated with Alternative 3 are estimated at $134,250. The average
annual operation and maintenance (O & M) costs are estimated at $30,310 over the
5-7
-------
duration of the alternative (three years). The total three-year present worth cost for
Alternative 3 is estimated at $217,000.
5.2.2. Sodium Hydroxide Tank Site
Alternative 1: No Further Action
As an interim remedial measure, an engineered asphalt cap was placed over the area of
attainment in August 1993. A cap maintenance and yearly inspection program (to ensure
the long-term effectiveness of the cap) was included as part of the interim remedial
measure, but provisions have not been made to require long-term enforcement of the
maintenance program. The cap maintenance program includes development of SOPs to
provide for inspections, cap repair, and maintenance (from normal wear and tear of the
asphalt surface), and because there are existing underground utility lines within the area
of attainment, emergency leak response actions would be added to the maintenance
program in the event that the utility lines within the area need repair. Alternative 1
includes no further actions to reduce pH levels in soil or provide long-term integrity of
the asphalt cap.
Alternative 1 currently meets the soil RAOs by limiting exposure to, and reducing
leaching of, the soil with elevated pH. However, elevated pH could leach to ground
water in the future, or exposure (during subsurface construction) to elevated pH soil could
occur because there are no provisions in this alternative that limit construction activities
in the area, enforce long-term maintenance and inspection programs, or prevent removal
of the existing cap. Natural attenuation is not expected to reduce soil pH to the target of
8.5 within a foreseeable timeframe.
The capital costs associated with Alternative 1 are estimated at $24,500. The average
annual operation and maintenance (O & M) costs are estimated at $5,500 over the
duration of the alternative (30+ years). The total 30-year present worth cost for
Alternative 1 is estimated at $79,000.
Alternative 2: Cap Maintenance and Institutional Controls
Alternative 2 consists of continuing the existing cap inspection and maintenance
program, but also includes ground-water monitoring, a covenant to the deed, and a
continuing order issued by the Installation Commander. No additional remedial actions
would be taken to reduce soil pH. The objectives of the alternative are to enforce the
existing inspection and maintenance program as part of the interim remedial action (as
discussed in Alternative 1) and place additional specific requirements or restrictions on
future site development.
The maintenance program would be established to protect the continued integrity of the
cap. This will include provisions for inspections, repairs, and leak response actions if
repair is needed for underground utility lines.
5-8
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A continuing order would be issued by the Installation Commander to restrict access to or
disturbance of contaminated soils as long as Hill AFB owns the property. Specifically, it
would:
j
• Restrict or place limitations on the installation of any new underground
utilities or other construction activities in the area of the cap; thus preventing
accidental exposures to construction workers.
• Provide for the use of proper protective equipment, in the event that access
through the cap is required.
• Require that the integrity of the asphalt cap is maintained (i.e., repair cracks
that may develop) so that fluids cannot infiltrate to the subsurface.
Maintenance of the cap will require development of SOPs to provide for
inspections, repairs, and responses to spills in critical areas.
The continuing order also would mandate that, if the cap were ever removed or destroyed,
the area of attainment would be re-evaluated to determine the need for a replacement cap
or other remedial action.
Ground-water sampling would be conducted to monitor for elevated pH and/or an
increase in TDS caused by contaminants potentially leaching from the area. As in
Alternative 1, because the integrity of the cap would be maintained over the long term,
natural attenuation is not expected to attain soil pH cleanup goals within a foreseeable
time frame.
A notice to the deed for Hill AFB would be filed detailing the restrictions of the
continuing order. In the case of the sale or transfer of property within OU 3 by the
United States to any other person or entity, the Air Force will place covenants in the deed
which will restrict access and prohibit disturbance of contaminated soils or the remedial
action without approval of the United States. These covenants will be in effect until
removed upon agreement of the State of Utah, the U.S. Environmental Protection
Agency, and the U.S. Air Force or their successors in interest. The Air Force will also
include in the deed the covenants required by section 120(h)(3) of CERCLA, which
include (1) a warranty that the United States will conduct any remedial action found to be
necessary after the date of the transfer; (2) a right of access in behalf of the U.S.
Environmental Protection Agency and the Air Force or their successors in interest to the
property to participate in any response or corrective action that might be required after the
date of transfer. The right of access referenced in the preceding sentence shall include the
State of Utah for purposes of conducting or participating in any response or corrective
action that might be required after the date of transfer.
In the event that the land use is changed or structures are removed, the Air Force will re-
evaluate the protectiveness of the remedy selected for OU 3, and will take any
appropriate remedial action.
The capital costs associated with Alternative 2 are estimated at $31,700. The average
annual operation and maintenance (O & M) costs are estimated at $7,200 over the
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duration of the alternative (30+ years). The total 30-year present worth cost for
Alternative 2 is estimated at $97,900.
Alternative 3: Excavation, Neutralization, and Backfill
Alternative 3 consists of ground-water monitoring and excavation, on-site treatment, and
backfilling of treated soil. Soil with pH greater than 8.5 would be excavated, stockpiled,
and mixed in a pug mill with acidic reagents until the final soil pH is between 6.5 and 8.5.
The total volume of excavated soil is estimated at 15,000 cubic yards; the volume of soil *
to be treated is approximately 12,000 cubic yards. The excavated soil would be sampled
to confirm the removal of all soil with pH greater than 8.5. Leachate produced during the
neutralization process would be disposed of at the IWTP in accordance with the permit
requirements for this facility. After neutralization, the soil would be sampled to confirm
neutralization of soil to within the range of pH 6.5 to 8.5, backfilled into the excavation,
compacted in place, and the site would be paved to restore it to its original condition. A
treatability study would be necessary to select the appropriate neutralizing agent (solid or
liquid) and the dosage rate.
The capital costs associated with Alternative 3 are estimated at $1,458,000. The average
annual operation and maintenance (O & M) costs are estimated at $5,600 over the
duration of the alternative (five years). The total five-year present worth cost for
Alternative 3 is estimated at $1,480,000.
Alternative 4: In-Situ Neutralization
Alternative 4 consists of ground-water monitoring, and in-situ neutralization. Soil would
be mixed with neutralizing agents in-situ (in place) using a large-diameter auger equipped
with nozzles capable of injecting neutralizing agents into the soil during augering. The
augering and mixing process would cover the area of attainment by overlapping the
augering locations. Soil in the interval from 10 feet to 50 feet bgs within the area of
attainment would be neutralized; the associated volume of soil requiring treatment would
be approximately 12,000 cubic yards. Because the mixing process loosens the soil, soil
recompaction would be required to make the site acceptable for any future development.
A treatability study would be necessary to select the appropriate neutralizing agent (solid
or liquid) and the dosage rate.
Preliminary soil sampling would be necessary to define the extent of pH-contaminated
soil and samples of the treated soil would be taken to confirm neutralization to within the
range of pH 6.5 to 8.5.
The capital costs associated with Alternative 4 are estimated at $554,760. The average
annual operation and maintenance (O & M) costs are estimated at $5,600 over the
duration of the alternative (five years). The total five-year present worth cost for
Alternative 4 is estimated at $577,000.
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5.2.3. Herman Pond
Alternative 1: No Action
Alternative 1 takes no action to reduce contaminant concentrations in soil and perched
water at Herman Pond or to limit health risks associated with human or animal exposure
to the contaminated soil. Alternative 1 consists of long-term ground-water monitoring to
evaluate the potential leaching of contaminants from the Berman Pond area.
The capital costs associated with Alternative 1 are estimated at $69,700. The average
annual operation and maintenance (O & M) costs are estimated at $20,100 over the
duration of the alternative (30+ years). The total 30-year present worth cost for
Alternative 1 is estimated at $295,000.
Alternative 2: Cap Installation and Institutional Controls
Alternative 2 consists of capping with a multi-media cap, perched water extraction,
surface drainage controls, long-term ground-water monitoring, a continuing order issued
by the Installation Commander, and a covenant to the deed. The objectives of the
alternative are to extract perched water in the former pond to the extent possible using
technologies such as extraction wells or trenches and reduce surface water infiltration to
reduce the potential for contaminants to leach to ground water. Extracted groundwater
would be discharged to Hill AFB's IWTP, which is permitted to accept the contaminants
present in perched water from Berman Pond.
The existing roads, parking areas, and possibly utilities within the proposed capped area
would be relocated temporarily during cap construction, and may be permanently
relocated depending on future land use, long-term cap integrity considerations, and other
issues to be resolved during the design phase of the cap. Surface.drainage controls would
be included as part of the cap design to divert any surface water away from the capped
area. Institutional controls would include provision for long-term maintenance of the cap
and development of SOPs to ensure it remains effective, posting of signs warning of
subsurface contaminated soil in the area, and issuing a continuing order from the
Installation Commander. The continuing order would restrict access to or disturbance of,
contaminated soils as long as Hill AFB owns the property. Specifically, it would:
• Restrict or place limitations on the installation of any new underground
utilities or other construction activities in the area of the cap; thus preventing
accidental exposures to construction workers.
• Provide for the use of proper protective equipment, in the event that access
through the cap is required.
• Require that the integrity of the cap is maintained (i.e., repair cracks that may
develop) so that fluids cannot infiltrate to the subsurface. Maintenance of the
cap will require development of SOPs to provide fpr inspections, repairs, and
responses to spills in critical areas.
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Although natural attenuation would reduce contaminant concentrations in the soil while
the cap is in place, the rate and extent at which natural attenuation would .occur is not
expected to result in attainment of the soil cleanup goals in the foreseeable time frame.
A notice to the deed for Hill AFB would be filed detailing the restrictions of the
continuing order. In the case of the sale or transfer of property within OU 3 by the
United States to any other person or entity, the Air Force will place covenants in the deed
which will restrict access and prohibit disturbance of contaminated soils or the remedial
action without approval of the United States. These covenants will be in effect until
removed upon agreement of the State of Utah, the U.S. Environmental Protection
Agency, and the U.S. Air Force or their successor in interest. The Air Force will also
include in the deed the covenants required by section 120(h)(3) of CERCLA, which
include (1) a warranty that the United States will conduct any remedial action found to be
necessary after the date of the transfer; (2) a right of access in behalf of the U.S.
Environmental Protection Agency and the Air Force or their successors in interest to the
property to participate in any response or corrective action that might be required after the
date of transfer. The right of access referenced in the preceding sentence shall include the
State of Utah for purposes of conducting or participating in any response or corrective
action that might be required after the date of transfer.
In the event that the land use is changed or structures are removed, the Air Force will re-
evaluate the protectiveness of the remedy selected for OU 3, and will take any
appropriate remedial action.
The capital costs associated with Alternative 2 are estimated at $3,838,000. The average
annual operation and maintenance (O & M) costs are estimated at $36,600 over the
duration of the alternative (30+ years). The total 30-year present worth cost for
Alternative 2 is estimated at $4,234,000.
Alternative 3: In-Situ Solidification, Soil Vapor Extraction, and Cap Installation
In addition to the provisions contained in Alternative 2, Alternative 3 includes in-situ
solidification and vapor extraction. The objectives of this alternative are to extract
perched water in the former pond to the extent possible using technologies such as
extraction wells or trenches, solidify a majority of the contaminants within Zone 1 soil,
minimize the infiltration of surface water through the solidified soil, and reduce
contaminant concentrations in Zone 2 soil.
An augering system that mixes the solidifying agents into the subsurface soil and captures
and treats contaminants volatilized during the process would be used to solidify soil
within Zone 1. Samples of the solidified material would be taken periodically to evaluate
the effectiveness of the solidification process. A treatability study would be required to
select the type of solidification agent (or agents) and determine the application dosage.
Because of the high percentage of debris expected in the pond, a backhoe would be
employed to help locate and remove debris. Prior to in-situ soil treatment, the pond
would be dewatered to the extent possible using extraction wells or trenches.
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After treatment, a cap would be placed over the site to reduce infiltration of surface water
through the solidified material, and therefore reduce the potential movement of
contaminants not bound fully by the solidification process. Because the infiltration of
surface water would be significantly reduced, the leaching of contaminants from Zone 2
also would be reduced. Appropriate vegetation would be established over the cap to
enhance the cap aesthetics and further reduce surface water infiltration.
The concentrations of the volatile organic contaminants in Zone 2 would be reduced
using soil vapor extraction (SVE). The SVE system will consist of several zones across-
the area of attainment, each containing a series of wells. Approximately thirty eight wells
and a 300 SCFM (at 13 inches Hg) compressor would be used for a five-year period. The
number and placement of wells would depend on pre-exploratory sampling of the area of
attainment and may consist of vent wells or multiple-screened extraction wells. Each
well would be piped to a central shed where the main control panel and blower would be
located. The system would be designed to allow zones to be operated at different times to
optimize the contaminant extraction process. Because the treatment system would be part
of an on-site CERCLA response action, no off-gas discharge permitting would be
necessary; however, air modeling may be necessary to satisfy certain State ARARs.
Periodic monitoring of the vapors would evaluate the effectiveness of the system at
removing VOCs from the subsurface. A long-term ground-water monitoring program
would be established to evaluate the effectiveness of the remedial action and whether
contaminants are leaching to the ground water.
The capital costs associated with Alternative 3 are estimated at $6,862,000. The average
annual operation and maintenance (O & M) costs are estimated at $45,100 over the
duration of the alternative (30+ years). The total 30-year present worth cost for
Alternative 3 is estimated at $7,435,000.
Alternative 4: Excavation, Off-Site Treatment and Disposal, and Soil Vapor
Extraction
Alternative 4 consists of excavation, off-site treatment and disposal, ground-water
monitoring, and SVE. The objectives of this alternative are to extract perched water in
the former pond to the extent possible using technologies such as extraction wells or
trenches, reduce the concentrations of all contaminants of concern to acceptable levels,
and provide unrestricted future land use. The SVE provisions are as discussed for
Alternative 3. Perched water extraction provisions are as discussed for Alternative 2.
Contaminated soil within Zone l.of the area of attainment would be excavated, sampled,
and transported to a RCRA-permitted treatment storage and disposal facility (TSDF) for
disposal. The excavation of Berman Pond would be accomplished using backhoes or
trackhoes for the deeper contaminated soils, and bulldozers to remove the shallow
uncontaminated soil. Subsurface utility lines and existing surface features would be
relocated as discussed in Alternative 2. Samples would be taken from the excavation to
confirm the removal of all soil with contaminant concentrations greater than the soil
cleanup goals. Clean soil would be placed back into the excavation and compacted.
Because a moderately large volume of debris may be contained within the pond,
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additional efforts may be necessary to remove the debris for separate treatment or
disposal.
The capital costs associated with Alternative 4 are estimated at $28,300,000. The average
annual operation and maintenance (O & M) costs are estimated at $60,200 over the
duration of the alternative (10 years). The total 10-year present worth cost for
Alternative 4 is estimated at $28,703,000.
Alternative 5: Excavation, On-site Treatment, Backfill, and Cap Installation
In addition to the provisions for institutional controls and perched water extraction
contained in Alternative 2, Alternative 5 includes excavation, on-site treatment, and
backfill of treated Zone 1 soil. The objectives of this alternative .are to extract perched
water in the former pond to the extent possible using technologies such as extraction
wells or trenches, excavate and treat the soil (on site) within Zone 1 with-contaminant
concentrations above the cleanup goals, backfill the excavation with the treated soil, and
place a cap (with future land-use restrictions) over the area to limit surface water
infiltration and leaching of contaminants from the soils beneath Berman Pond.
Soil excavated from Zone 1 would be treated on site using a thermal desorption system.
Excavated soil would be placed in covered stockpiles and subsequently fed through the
on-site treatment system. If thermal desorption by itself does not reduce contaminant
concentrations to the soil cleanup goals, optional processes could be added to the
treatment process. For example, a chemical dehalogenation unit could be added to the
thermal desorber to enhance contaminant removal or, if vapor concentrations from the
treatment process are too high for direct atmospheric discharge, a catalytic oxidizer could
be added to reduce vapor concentrations to acceptable levels. After treatment, the
processed soil would be tested to evaluate the effectiveness of the treatment process and,
if necessary, stabilization agents would be added to the treated soil to minimize the
transport potential of metals in soil used as backfill material.
Because of the debris expected within the pond, additional efforts would be necessary to
segregate the debris prior to on-site treatment. A debris washing system could be
included as pan of the overall treatment process. After washing, the debris would be
transported to an appropriate disposal facility either on or off Base. Washdown water
from the debris washing system would be stored in on-site tanks and periodically
transported to the IWTP for disposal in accordance with the permit requirements for this
facility. A soil crushing system also may be necessary to reduce the soil particle size to
within limits acceptable for the thermal desorption unit. Any additional soil needed for
backfilling would be hauled in from an on or off Base location. The processed soil and
any needed fill material would be placed back into the excavation and compacted.
Because contaminant concentrations in Zone 2 soil are not reduced, a cap would be
placed over the pond. The cap installation is the same as in Alternative 3. Because
surface water infiltration would be reduced significantly or eliminated by the cap, the
leaching of contaminants from soil beneath Berman Pond to ground water would be
minimal. Natural attenuation would reduce contaminant concentrations in the soil
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beneath Berman Pond while the cap is in place, but this is not expected to be significant
within the foreseeable time frame.
The capital costs associated with Alternative 5 are estimated at $10,978,000. The average
annual operation and maintenance (O & M) costs are estimated at $33,200 over the
duration of the alternative (30+ years). The total 30-year present worth cost for
Alternative 5 is estimated at $11,322,000.
Alternative 6: Excavation, On-Site Treatment, and Soil Vapor Extraction
In addition to the provisions contained in Alternative 2, Alternative 6 includes
excavation, on-site treatment and backfill of soil, and SVE. The objectives of this
alternative are similar to those of Alternative 5 except the reduction of organic compound
concentrations within Zone 2 would be accelerated greatly using SVE. Perched water
extraction, SVE, and ground-water monitoring provisions would be the same as discussed
in Alternative 3. Excavation and on-site treatment of Zone 1 soil would be the same as
for Alternative 5. A ground-water monitoring program would be established to evaluate
the effectiveness of the SVE process.
The capital costs associated with Alternative 6 are estimated at $10,286,000. The average
annual operation and maintenance (O & M) costs are estimated at $24,100 over the
duration of the alternative (10 years). The total 10-year present worth cost for
Alternative 6 is estimated at $10,477,000.
/"•
5.3 COMPARATIVE ANALYSIS OF ALTERNATIVES
The alternatives for each site were compared to assess the relative advantages and
disadvantages of the alternatives and to identify key tradeoffs that were balanced in
selecting an alternative for soil cleanup. The preferred alternative for each site was
developed based upon the following comparisons, considering the expected results of the
combination of alternatives from each set.
5.3.1. Evaluation Criteria
The alternatives were compared with respect to nine evaluation criteria (two threshold
criteria, five balancing criteria, and two -modifying criteria) that have been developed
under CERCLA to address the technical and policy considerations associated with
selecting among the remedial alternatives. The nine evaluation criteria are described
below.
Threshold Criteria
Threshold criteria include overall protection of human health and the environment and
compliance with ARARs. These threshold criteria must be met by any given alternative
before it can be evaluated under the five balancing criteria.
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1. Overall Protection of Human Health and the Environment describes whether
the alternative as a whole achieves and maintains adequate protection of human
health and the environment.
2. Compliance with ARARs describes whether the alternative complies with
ARARs or, if a waiver is required, how it is justified. Other information from
advisories, criteria, and the guidance "to be considered" is also addressed.
Compliance of alternatives with this criteria are discussed in Table 5-4.
Balancing Criteria
The five balancing criteria form the basis of the comparative analysis because they allow
tradeoffs among the alternatives offering different degrees of performance.
3. Long-Term Effectiveness and Permanence refers to the ability of an alternative
to provide reliable protection of human health and the environment over the long
term.
4. Reduction of Mobility, Toxicity, and Volume (TMV) Through Treatment
refers to the preference for treatment technologies that meet this criterion at the
site.
5. Short-Term Effectiveness examines the effectiveness of alternatives in
protecting human health and the environment during the construction and
implementation of a remedy and until the response objectives have been met.
6. Implementability evaluates the technical and administrative feasibility of the
alternatives and the availability of the goods and services needed to implement
them.
7. Cost refers to the capital, indirect, and operation and maintenance costs of each
alternative. Costs are estimated, and are expected to provide an accuracy of plus
50 percent to minus 30 (+50/-30) percent for a 30-year period. The 30-year
period is used as a common point of comparison. Cost can only be a deciding
factor for alternatives that are equally protective of human health and the
environment.
Modifying Criteria
The modifying criteria described below generally are addressed in response to comments
from the State and the public, after the issuance of the ROD.
8. State Acceptance indicates whether the state agrees with, opposes, or has no
comment on the preferred alternative.
9. Community Acceptance indicates whether the community agrees with, opposes,
or has no comment on the preferred alternative.
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TABLE 5-4
SUMMARY OK KEY ARARs FOR EACH ALTERNATIVE
dor 10)
Alternative
Key ARARs VVKIi Which (he Alternative Musi Comply
ARAR Would Alternative Meet ARAR?
Refueling Vehicle Maintenance Facility (RVMF)
Allcrnalive I (No Action)
Alternative 2 (Institutional Controls)
40 CFR 264. Suhpart F (Requirements for detection of releases from
Solid Waste Management Units)
40 CFR 264. Subpart G (Closure and Post Closure Standards)
UAC R311-211 (State of Utah corrective action cleanup standards for
CERCLA and UST sites)
UAC R315-8-6 (Ground-water protection)
UAC R315-8-7 (State of Utah Closure and Post Closure Standards)
U AC R315-101 (State of .Utah cleanup action and risk-based closure
standards for RCRA sites)
UAC R317-6 (Stale ground-water quality prelection standards)'
40 CFR 264. Subpart F (Requirements for detection of releases from
Solid Waste Management Units)
• 40 CFR 264. Subpart G (Closure and Post Closure Standards)
UAC R311 -211 (State of Utah corrective action cleanup standards for
CERCLA and UST sites)
UAC R315-8-6 (Ground-water protection)
UAC R315-8-7 (Stale of Utah Closure and Post Closure Standards)
UAC R3I5-IOI (Suite of Utah cleanup action and risk-based closure
standards for RCRA sites)
UAC R317-6 (State ground-water quality protection standards)
R Yes - The ARAR would be met with ground-water monitoring.
R No - This alternative does not make provision for landfill closure
regulations.
Ap No- Partially meets this ARAR with ground-water monitoring but
does not achieve source control.
R Yes - The alternative would meet ground-water monitoring
requirements of the ARAR.
R No - This alternative does not make provision for control of access to
contaminants.
Ap No- Partially meets ARAR with ground-water monitoring but does
not meet closure requirements.
Ap No - The alternative does not ensure maintenance of the existing
concrete floor or prevent leachale from potentially impacting ground
water.
R Yes - The ARAR would be met with ground-water monitoring.
R Yes - Complies with relevant and appropriate portions of hybrid
landfill closure regulations. The soil cover requirement is relevant,
but not appropriate in this case.
Ap Yes - Partially meets this ARAR with environmental monitoring and
source control (leaving and maintaining the concrete slab).
R Yes - The alternative would meet ground-water monitoring
requirements of the ARAR.
R Yes - Complies with relevant and appropriate portions of hybrid
landfill closure regulations. The soil cover requirement is relevant,
but not appropriate in (his case.
Ap Yes - Meets this ARAR with environmental monitoring, source
control (leaving and maintaining existing cover), and post-closure
requirements. Long term management plans in institutional controls
will also ensure compliance with risk-based closure standards.
Ap Yes - Complies with ground-water quality protection standards
because it prevents leachale from reaching ground water by leaving
and maintaining the concrete slab.
ARAR Applicable or relevant and appropriate requirements
BACT Best available control technology
CAMU Corrected Action Management Unit
CFR Code of Federal Regulations
PCBs Polychlorinaied Biphenyls
RCRA Resource Conservation and Recovery Act
TCE Trichloroethene
UAC Utah Administrative Code
VOC Volatile Organic Compounds
Ap Applicable
R Relevant and Appropriate
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TABLE 5-4
SUMMARY OF KEY ARARs FOR EACH ALTERNATIVE
(2oflO)
Alternative
Key ARARs With Which the Alternative Must Comply*")
ARAR Would Alternative Meet ARAR?
Alternative 3 (In-Silu Vnpor
Extraction)
40 CFR 50 (Primary and secondary air quality standards) Ap
40 CFR 61 (NESHAPs standards) Ap
40 CFR 262 (Generators of hazardous waste) Ap
40 CFR 264, Suhpart F (Requirements for detection of releases from R
Solid Waste Management Units)
40 CFR 264, Subpan G (Closure and Post Closure Standards) R
UAC R307-1 -3 (Standards for Control of Installations) Ap
U AC R307-1 -4 (Establishes standards for VOC emissions) Ap
UAC R307-IO (NESHAPs standards) Ap
UACR3II-2II (Specified Slate of Utah corrective action cleanup Ap
standards for CERCLA and UST sites)
IIAC R.t 15-5 (Generators (if hazardous waste) Ap
UACR.M5-8-6 (Ground-water protection) R
UAC R.M5-8-7 (Slate of Utah closure and post closure standards) .R
I "AC" R .115-101 (Slate of Utah cleanup action and risk-based closure Ap
standards for RCRA sites)
U AC R317-6 (Slate ground-water quality protection standards) Ap
Yes - Air emissions would be treated to comply with national
primary and secondary air quality standards.
Yes - Air emissions of toluene and TCE would be controlled to
comply with air emissions requirements.
Yes - Spent granular activated carbon canisters on-site would be
managed in compliance with this ARAR.
Yes - The ARAR would be met with ground-water monitoring.
Yes - Complies with clean closure regulations.
Yes - B ACT would be used for control of vapor emissions.
Yes - VOC emissions from the vapor extraction system will be
controlled (o compliance with VOC emission standards.
Yes - Air emissions of toluene and TCE would be controlled to
comply with air emissions requirements.
Yes - The source will be controlled by maintaining the existing
concrete floor. Vapor extraction will remove VOCs from the source
area. The alternative will comply with cleanup standards for soils.
Yes • Spent granular activated carbon can isters on-site would be
managed in compliance with this ARAR.
Yes - The alternative would meet ground-water monitoring
requirements of the ARAR.
Yes - Complies with clean closure regulations.
Yes - The source would be controlled by maintaining the existing
concrete floor. VOCs would be removed using vapor extraction to
meet closure standards.
Yes - The ARAR would be met by maintaining the existing concrete
floor and removing contaminants by vapor extraction.
ARAR Applicable or relevant and appropriate requirements
BACT Best available control technology
CAMU Corrected Action Management Unit
CFR Code of Federal Regulations
PCBs Polychlorinated Biphenyls
RCRA Resource Conservation and Recovery Act
TCE Trichloroethene
UAC Utah Administrative Code
VOC Volatile Organic Compounds
Ap Applicable
R Relevant and Appropriate
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TABLE 5-4
SUMMARY OF KEY ARARs FOR EACH ALTERNATIVE
(3 of 10)
Alternative
Key ARARs With Which (he Alternative Musi Comply*3)
ARAR Would AHernatlve Meet ARAR?
Sodium Hydroxide Tank Site
Alternative I (No Further Action)
40 CFR 264, Subparl F (Requirements for detection of releases from R
Solid Waste Management Units)
40 CFR 264, Subparl G (Closure and Post Closure Standards) R
U AC R311 -211 (State of Utah corrective action cleanup standards for Ap
CERCLA and UST sites)
U AC R315-8-6 (Ground-water protection) R
UAC R315-8-7 (State of Utah Closure and Post Closure Standards) R
U AC R315-101 (Stale of Utah cleanup action and risk-based closure Ap
standards for RCRA sites)
U AC R317-6 (Slate ground-water quality protection standards) Ap
Yes - The ARAR would be met with ground-water monitoring.
No - This alternative does not make provision for landfill closure
regulations.
No- Partially meets this ARAR with ground-water monitoring but
does not achieve source control.
Yes - The alternative would meet ground-water monitoring
requirements of the ARAR.
No - This alternative does not make provision for control of access to
contaminants.
No- Partially meets ARAR with ground-water monitoring but does
not meet closure requirements.
No - The alternative does not ensure maintenance of the existing
concrete floor or prevent leachate from potentially impacting ground
water.
Alternative 2 (Cap Maintenance and Institutional Controls)
40 CFR 264. Subpart F (Requirements for detection of releases from R
Solid Waste Management Units)
40 CFR 264. Subparl G (Closure and Post Closure Standards) R
U AC R311 -211 (State of Utah corrective action cleanup standards for Ap
CERCLA and UST sites)
UAC R315-8-6 (Ground-water protection) R
U AC R315-8-7 (Stale of Utah Closure and Post Closure Standards) R
UACR3I5-I01 (State of Utah cleanup action and risk-based closure Ap
standards for RCRA sites)
UAC R3I7-6 (Stale ground-water quality protection standards) Ap
Yes - The ARAR would be met with ground-water monitoring.
Yes - Complies with relevant and appropriate portions of hybrid
landfill closure regulations. The soil cover requirement is relevant,
but not appropriate in (his case. .
Yes - The source is controlled by the existing cap and long-term cap
maintenance and institutional controls.
Yes - The alternative would meet ground-water monitoring
requirements of the ARAR.
Yes - Complies with relevant and appropriate portions of hybrid
landfill closure regulations. The soil cover requirement is relevant,
but not appropriate in this case.
Yes - Meets this ARAR with environmental monitoring, source
control (leaving and maintaining existing cover), and post-closure
requirements. Long term management plans in institutional controls
will also ensure compliance with risk-based closure standards.
Yes - Ground-water would be monitored and the source would be
controlled with the cap.
ARAR Applicable or relevant and appropriate requirements
BACT Best available control technology
CAMU Corrected Action Management Unit
CFR Code of Federal Regulations
PCBs Polychlorinaled Biphenyls
hCRA Resource Conservation and Recovery Act
TCE Trichloroethene
UAC Utah Administrative Code
VOC Volatile Organic Compounds
Ap Applicable
R Relevant and Appropriate
-------
TABLE 5-4
SUMMARY OF KEY ARARs FOR EACH ALTERNATIVE
(4 of 10)
Alternative
Key ARARs With Which the Alternative Must Comply(">
ARAR Would Alternative Meet ARAR?
Alternative .1 (Excavalion. On-Site Neutralization, and Backfill)
• -10 CFR 50 (Primary and secondary air quality standards) Ap
40 CFR Part 264 Subpart B, 264.18 Ap
(Characteristics Tor location of hazardous waste management units)
• 40 CFR 264, Subpart F (Requirements for deteciion of releases from Solid Ap
Waste Management Units)
• 40 CFR 264, Subpart G (Closure and Post Closure Standards) Ap
• 40 CFR 264 Subpart L (Standards for treatment of wastes in piles) Ap
• 40 CFR 264 Subpart S (CAMU Rules) Ap
• 40 CFR 264 Subpart X (Design/operation requirements for misc. hazardous Ap
waste mnn.igement units)
• -10 CKR 2f>8 (Land disposal restrictions) Ap
• UAC R.V17-1 -.1 (Emission standards for control of installations) Ap
• UAC R.W7.1-4 (Establishes emission standards) Ap
• UAC R.1II-2I I (Specified SlateofUiah corrective action cleanup standards Ap
for CKRCLA and UST sites)
• UAC R31:5-8-6 (Ground-water protection) Ap
• U AC R315-8-7 (Stale of Utah Closure and Post Closure Standards) Ap
• UAC R315-8-12 (Standards for treatment of wastes in piles) Ap
• UAC R315-8-16 (Design and operation requirements for miscellaneous units) Ap
• UAC R315-S-21 (CAMU Designation and management) Ap
• U AC R315-13 (Stale of Utah land disposal regulations) Ap
• UACR3I5-IOI (State of Utah cleanup action and risk-based closure standards Ap
for RCRA sites)
• U AC R317-6 (State ground-water quality protection standards) Ap
Yes • Air emissions during excavation will be controlled to comply with
national primary and secondary air quality standards.
Yes - Soil treatment units will be sited in accordance with this ARAR.
Yes - The ARAR would be met with ground-water monitoring.
Yes - Complies with clean closure regulations.
Yes - The ARAR would be met by following the design and operating
requirements for storage or treatment or waste in piles; monitoring and
inspection; and closure and post-closure care.
Yes - CAMU management practices would be followed to comply with
LDRs.
Yes - Performance standards; monitoring, analysis, inspection, response,
reporting, corrective action, and post-closure care requirements would be
followed.
Yes - Any hazardous waste generated would be managed to comply with
this ARAR.
Yes - Air emissions during remediation will be controlled to comply with
air emissions requirements.
Yes - Air emissions during remediation would be controlled to comply
with air emissions requirements.
Yes - The ARAR would be met because the source would be removed and
cleanup standards would be met.
Yes - The alternative would meet ground-water monitoring
requirements of the ARAR.
Yes - Complies with clean closure regulations,
Yes - The ARAR would be met by following the design and operating
requirements for storage or treatment of hazardous waste (untreated soil)
in piles; monitoring and inspection; and closure and post-closure care.
Yes - Performance standards; monitoring, analysis, inspection, response,
reporting, corrective action, and post-closure care requirements would be
followed.
Yes - CAMU management practices would be followed to comply with
LDRs.
Yes - Any hazardous waste generated would be managed to comply with
this ARAR.
Yes - The ARAR would be met because the source would be removed and
cleanup standards would be met.
Yes - The ARAR would be met with ground-water monitoring and
removal of the source.
ARAR Applicable or relevant and appropriate requirements
BACT Best available control technology
CAMU Corrected Action Management Unit
CFR Code of Federal Regulations
PCBs Polychlorinated Biphenyls
RCRA Resource Conservation and Recovery Act
TCE Trichloroethene
UAC Utah Administrative Code
VOC . Volatile Organic Compounds
Ap Applicable
R Relevant and Appropriate
-------
TADLE5-4
SUMMARY OF KEY ARARs FOR EACH ALTERNATIVE
(5 of 10)
Alternative
Key ARARs With Which the Alternative Must Comply(a)
ARAR Would Alternative Meet ARAR?
Alternative 4 (In-Situ Neutralization)
Berman Pond
Alternative I (No Action)
40 CFR 50 (Primary and secondary air quality standards) Ap
40 CFR 264, Subpart F (Requirements for detection of releases from R
Solid Waste Management Units)
40 CFR 264, Subpart G (Closure and Post Closure Standards) R
U AC R307-1 -3 (Emission standards for control of installations) Ap
UACR307-I-4 (Establishes emission standards) Ap
UAC R311 -211 (Slate of Utah corrective action cleanup standards for Ap
CERCLA and UST sites)
U AC R315-8-6 (Ground-water protection) R
U AC R315-8-7 (Slate of Utah Closure and Post Closure Standards) R
UACR3I5-IOI (Slate of Utah cleanup action and risk-based closure Ap
standards for RCRA sites)
UAC R317-6 (State ground-water quality protection standards) Ap
40 CFR 264, Subpart F (Requirements for detection of releases from R
Solid Waste Management Units)
40 CFR 264, Subpart G (Closure and Post Closure Standards) R
UAC R311 -211 (Specified State of Utah corrective action cleanup Ap
standards for CERCLA and UST sites)
UAC R315-8-6 (Ground-water protection) R
U AC R315-8-7 (State of Utah Closure and Post Closure Standards) R
UACR3I5-IOI (Specifies State of Utah cleanup action and risk-based Ap
closure standards for RCRA sites)
UAC R317-6 (State ground-water quality protection standards) Ap
Yes - Air emissions during excavation will be controlled to comply
with national primary and secondary air quality standards.
Yes - The ARAR would be met with ground-water monitoring.
Yes - Complies with clean closure regulations.
Yes - Air emissions during remediation will be controlled to comply
with air emissions requirements.
Yes - Air emissions during remediation would be controlled to
comply with air emissions requirements.
Yes - The ARAR would be met because the source would be removed
and cleanup standards would be met.
Yes - The alternative would meet ground-water monitoring
requirements of the ARAR.
Yes - Complies with clean closure regulations.
Yes - The ARAR would be met because the source would be removed
and cleanup standards would be met.
Yes - The ARAR would be met with ground-water monitoring and
removal of the source. Also applicable to neutralizing agent used
and any metals or compounds mobilized by the neutralizing agent.
Yes - The ARAR would be met with ground-water monitoring.
No - This alternative does not make provision for landfill closure
regulations.
No- Partially meets this ARAR with ground-water monitoring but
does not achieve source control.
Yes - The alternative would meet ground-water monitoring
requirements of the ARAR.
No - This alternative does not make provision for control of access to
contaminants.
No- Partially meets ARAR with ground-water monitoring but does
not meet closure requirements.
No - The alternative does not ensure maintenance of the cap or
prevent leachate from potentially impacting ground water.
ARAR Applicable or relevant and appropriate requirements
BACT Best available control technology
CAMU Corrected Action Management Unit
CFR Code of Federal Regulations
PCBs Polychlorinaled Biphenyls
RCRA Resource Conservation and Recovery Act
TCE Trichloroethene
• UAC Utah Administrative Code
VOC Volatile Organic Compounds
Ap Applicable
R ~ Relevant and Appropriate
-------
TABLE 5-4
SUMMARY OF KEY ARARs FOR EACH ALTERNATIVE
(6 of 10)
Alternative
Key ARARs With Which the Alternative Must Comply
ARAR
Would Alternative Meet ARAR?
Alternative 2 (Cap Installation and Institutional Control!;)
• 40 CFR 61 Subpart A (NESHAPs standards) Ap
• 40 CFR 264, Subpart F (Requirements for detection of releases from Solid R
Waste Management Units)
• 40 CFR 264, Subpart 0 (Closure and Post Closure Standards) R
• 40 CFR 264 Subpart N (Standards for RCRA landfills and caps) R
• UAC R307-1 -4 (Standards for VOC emissions and dust) Ap
• UAC R307-10 (National Emission Standards for Hazardous Air Pollutants) Ap
• UAC R.I 11-211 (Specified State of Utah corrective action cleanup standards Ap
for CRRCLA and UST sites)
• UAC R}l5-R-6(Ground-walerprotection) R
• UAC R.M5-R-7 (State of Utah Closure and Post Closure Standards) R
• UAC R1IS-R-14 (Design Operation, ami Management Requirements for R
l-andlitkl
• UACR.M5-IOI (Slate of Utah cleanup action and risk-based closure standards Ap
for RCRA sites)
• UAC R317-6 (Stale ground-water quality protection standards) Ap
Alternative 3 (In-Situ Solidification, Vapor Extraction, and Cap Installation)
• 40 CFR 50 (Primary and secondary air quality standards) Ap
• 40 CFR 61 Subpart A (NESHAPs standards) Ap
• 40 CFR 262 (Generators of hazardous waste) Ap
• 40CFR264, Subpart F (Requirements for detection of releases from Solid R
Waste Management Units)
• 40 CFR 264, Subpart 0 (Closure and Post Closure Standards) R
• 40 CFR 264 Subpart N (Standards for RCRA landfills and caps) R
• UAC R307-I-3 (Standards for Control of Installations) . Ap
Yes - Air emissions during remediation would be controlled to comply with
air emissions requirements.
Yes - The ARAR would be met with ground-water monitoring.
Yes - Complies with relevant and appropriate portions of hybrid landfill
closure regulations. Trie soil cover requirement is relevant and appropriate
in this case.
Yes - The ARAR will be met by following RCRA landfill cap
requirements.
Yes - Air emissions during remediation would be controlled to comply with
air emissions requirements.
Yes - Air emissions during remediation would be controlled to comply with
air emissions requirements.
Yes - The source is controlled by (he cap and long-term cap maintenance.
Yes' The alternative would meet ground-water monitoring requirements of
the ARAR.
Yes - Complies with relevant and appropriate portions of hybrid landfill
closure regulations. The soil cover requirement is relevant and appropriate
in this case.
Yes - The ARAR would be met by institutional controls and by following
RCRA cap requirements.
Yes - Meets this ARAR with environmental monitoring, source control
(leaving and maintaining existing coyer), and post-closure requirements.
Long term management plans in institutional controls will also ensure
compliance with risk-based closure standards.
Yes - The ARAR would be met with ground-water monitoring and control
of the source with a cap.
Yes - The alternative will comply with national primary and secondary air
quality standards.
Yes - Air emissions during remediation would be controlled to comply with
air emissions requirements.
Yes - Spent granular activated carbon canisters on-site would be managed in
compliance with this ARAR.
Yes - The ARAR would be met with ground-water monitoring.
Yes - Complies with clean closure regulations.
Yes - The ARAR will be met by following RCRA landfill cap
requirements.
Yes - Air emissions during remediation will be controlled to comply with air
emissions requirements.
ARAR Applicable or relevant and appropriate requirements
BACT , Best available control technology
CAMU Corrected Action Management Unit
CFR Code of Federal Regulations
PCBs Polychlorinated Biphenyls
RCRA Resource Conservation and Recovery Act
TCE Trichloroethene
UAC Utah Administrative Code
VOC Volatile Organic Compounds
Ap Applicable
R Relevant and Appropriate
-------
TABLE 5-4
SUMMARY OF KEY ARARs FOR EACH ALTERNATIVE
(7 of 10)
Alternative
Key ARARs With Which the Alternative Must Comply'"*
ARAR Would Alternative Meet ARAR?
Alternative 3 (In-Silu Solidification, Vapor Extraction, and Cap Installation) (continued)
• UAC R307-1-4 (Standards for VOC emissions) Ap
• UAC.R307-10 (National Emission Standards for Hazardous Air Pollutants) Ap
• UAC R311-211 (Specified Stale or Utah corrective action cleanup standards Ap
forCERCLA nnd UST sites)
• UAC R315-5 (Generators of hazardous waste) Ap
• UAC R315-8-6 (Ground-water protection) R
• UAC R315-8-7 (Stale of Utah Closure and Post Closure Standards) Ap
• UAC R3I5-8-I4 (Design Operation, and Management Requirements for R
Landfills)
• UACR3I5-IOI (Specifies Stale of.Ulah cleanup action and risk-based closure Ap
standards for RCRA sites)
• UAC R3l7-6(Stale ground-water quality protection standards) Ap
Alternative 4 (Excavation, Off-Site Trcalincm & Disposal, and In-situ Vapor Extraction)
• 40 Cl-'R 50 (Primary and secondary air quality standards) Ap
• 40 CFR 61 Subpart A (NESIIAPs standards) ' Ap
• 40 CFR 262 (Establishes standards for generators of hazardous waste) Ap
• 40 CFR 264, Subpart F (Requirements for detection of releases from Solid R
Waste Management Units)
• 40 CFR 264, Subpart G (Closure and Post Closure Standards) R
• 40 CFR 761 (Establishes storage/disposal requirements for PCBs) Ap
• UAC R307-1-3 (Standards for Control of Installations) Ap
• UAC R307-1 -4 (Establishes standards for VOC emissions) Ap
• UAC R307-IO (National Emission Standards for Hazardous Air Pollutants) Ap
• UACR3I1-21I (Specified Slate of Utah corrective action cleanup standards Ap
for CERCLA and UST sites)
• UAC R315-5 (State of Utah requirements for generators of hazardous waste) Ap
• UAC R315T8-6 (Ground-water protection) R
• UAC R315-8-7 (State of Utah closure and post closure standards) • R
• UACR3IS-IOI (Specifies State of Utah cleanup action and risk-based closure Ap
standards for RCRA sites)
• U AC R317-6 (State ground-water quality protection standards) Ap
Yes - Air emissions during remediation would be controlled to comply with
air emissions requirements.
Yes - The ARAR would be met with use of vapor control systems on the
soil vapor extraction system.
Yes - The source would be controlled with the cap and solidification. VOCs
would be removed using vapor extraction to meet closure standards.
Yes - Spent granular activated carbon canisters on-sile would be managed in
compliance with ihis ARAR.
Yes - The alternative would meet ground-water monitoring requirements of
the ARAR.
Yes • Complies with clean closure regulations.
Yes - The ARAR would be met by institutional controls and by following
RCRA cap requirements.
Yes - The source would be controlled with the cap and solidification. VOCs
would be removed using vapor extraction to meet closure standards.
Yes - The ARAR would be met with ground-water monitoring and control
of the source with the cap and solidification, and removing VOCs with
vapor extraction.
Yes - Air emissions will be controlled to comply with national primary and
secondary air quality standards.
Yes - Air emissions will be controlled to comply with NESHAPs standards.
Yes - The ARAR will be met by complying with standards for generators
of hazardous wastes.
Yes - The ARAR would be met with ground-water monitoring.
Yes - Complies with clean closure regulations.
Yes - Storage and disposal requirements for PCB-conlaminnted soils
removed from the site will be met.
Yes - BACT would be used for control of non-petroleum vapor emissions.
Yes - VOC emissions from the vapor extraction system will be controlled
to comply with VOC emission standards.
Yes - The ARAR would be met with use of vapor control systems on the
soil vapor extraction system.
Yes - The source will be removed by excavation and vapor extraction and
cleanup standards would be met.
Yes - The ARAR will be met by complying with standards for generators
of hazardous wastes.
Yes - The alternative would meet ground-water monitoring requirements of
(he ARAR.
Yes - Complies with clean closure regulations.
Yes - The source will be removed by excavation and vapor extraction and
will comply with the risk-based closure standards.
Yes - The ARAR would be met with ground-water monitoring and by
removing the source. •
ARAR Applicable or relevant and appropriate requirements
BACT Best available .control technology
CAMU Corrected Action Management Unit
CFR Code of Federal Regulations
PCBs Polychlorinated Biphenyls
RCRA Resource Conservation and Recovery Act
TCE
UAC
Trichloroethene
Utah Administrative Code
VOC Volatile Organic Compounds
Ap Applicable
R Relevant and Appropriate
-------
TABLE 5-4
SUMMARY OF KEY ARARs FOR EACH ALTERNATIVE
(8oflO)
Alternative
Key ARARs With Which the Alternative Must ComplyW
ARAR Would Alternative Meet ARAR?
Alternative 5 (Excavation. On-Sile Treatment. Backfill, ami Cap Installation)
• 40 CFR 50 (Primary and secondary air quality standards) Ap
• 40 CFR 61 Subpart A (NESHAPs standards) ' Ap
• 40 CFR 262 (Establishes standards for generators of hazardous waste) Ap
• 40 CFR Part 264 Subpart 8,264.18 ' . Ap
(Characteristics for location or hazardous waste management units)
• 40 CFR 264, Subpart F (Requirements for detection of releases from Solid Ap
Waste Management Units)
• 40 CFR 264, Subpart G (Closure and Post Closure Standards) Ap
• 40 CFR 264 Suhpan J (Tanks) Ap
• 40 CFR 2M Suhpart L (Standards for treatment of wastes in piles) Ap
• 411CIR JW Suhpart N (Standards for RCRA landfills and cnps) Ap
• 40 CTR 2M Suhpart S (CAMU Rules) Ap
• 40 ("I R 2M Suhpart X (Design/operation requirements for misc. hazardous Ap
» aste management units)
• 40 CIR Part 268 (Land disposal restrictions) Ap
• 40 CFR 761 (Establishes storage/disposal requirement* for PCBs) Ap
• UACR307-l-.1(SlandardsforControloflnstallalions) Ap
• UAC R307-1-4 (Establishes standards for VOC emissions) Ap
• U AC R307-10 (National Emission Standards for Hazardous Air Pollutants) Ap
• UAC R.111-211 (Specified State of Utah corrective action cleanup standards Ap
for CERCLA and UST sites)
• U AC R315-5 (Slate of Utah requirements for generators of hazardous waste) Ap
• UAC R3I5-I3 (Land disposal restrictions) Ap
• U AC R315-8-6 (Ground-water protection) Ap
• UAC R315-8-7 (Stale of Utah closure and post closure standards) Ap
• UAC R315-8-IO (Tanks) Ap
• U AC R315-8-12 (Standards for treatment of wastes in piles) Ap
• UAC R315-8-14 (Design Operation, and Management Requirements for Ap
Landfills) •
5 - Performance standards; monitoring, analysis, inspection, response,
orting, corrective action, and post-closure care requirements would be
Yes - Air emissions during excavation will be controlled to comply with
national primary and secondary air quality standards.
Yes - Air emissions during excavation will be controlled to comply with
NESHAPs standards.
Yes - The ARAR will be met by complying with standards for generators
of hazardous wastes.
Yes - Soil treatment units will be sited in accordance with this ARAR.
Yes - The ARAR would be met with ground-water monitoring.
Yes - Complies with landfill closure regulations.
Yes - The ARAR would be met by complying with the requirements for
storage of hazardous waste in tanks..
Yes - The ARAR would be met by following the design and operating
requirements for storage or treatmenl or waste in piles; monitoring and
inspection; and closure and post-closure care.
Yes - The ARAR would be met by complying with RCRA cap
requirements.
Yes - CAMU management practices would be followed to comply with
LDRs.
Yes-
reporting, i
•followed.
Wastes disposed of on site will comply with LDRs
Yes - Storage and disposal requirements for PCB-contaminatcd soils will
be met
Yes - BACT would be used for control of vapor emissions.
Yes - VOC emissions will be controlled to comply with VOC emission
standards.
Yes - The ARAR would be met with use of vapor control systems on the
soil vapor extraction system.
Yes - The source will be removed by excavation and controlled with a cap.
Yes - The ARAR will be met by complying with standards for generators
of hazardous wastes.
Wastes disposed of on site will comply with LDRs
Yes - The alternative would meet ground-water monitoring
requirements of (he ARAR.
Yes - Complies with landfill closure regulations.
Yes - The ARAR would be met by complying with the requirements for
storage of hazardous waste in tanks..
Yes - The ARAR would be met by following the design and operating
requirements for storage or trealmenl or waste in piles; monitoring and
inspection; and closure and post-closure care.
Yes - The ARAR would be met by institutional controls and by following
RCRA cap requirements.
ARAR Applicable or relevant and appropriate requirements
BACT Best available control technology
CAMU Corrected Action Management Unit
CFR Code of Federal Regulations
PCBs Polychlorinated Biphenyls
RCRA Resource Conservation and Recovery Act
TCE Trichloroethene
UAC Utah Administrative Code
VOC Volatile Organic Compounds
Ap Applicable
R Relevant and Appropriate
-------
TABLE 5-4
SUMMARY OF KEY ARARs FOR EACH ALTERNATIVE
(9 of 10)
Alternative
Key ARARs With Which the Alternative Must Comply*")
ARAR Would Alternative Meet ARAR?
Alternative 5 (Excavation. On-Site Treatment. Backfill, and Cap Installation) (continued)
• UAC R315-8-16 (Design and operation requirements for miscellaneous Ap
units)
• UAC R315-8-21 (CAMU Designation and management) Ap
• UAC R315-101 (Slate of Utah cleanup action and risk-based closure Ap
standards for RCRA sites)
• UAC R317-6 (Slate ground-water quality protection standards) Ap
Alternative 6 (Excavation. On-Site Treatment, Backfill, and In-situ Vapor Extraction) .
• 40 CFR 50 (Primary and secondary air quality standards) Ap
• 40 CFR 61 Suhpart A (NESHAPs standards) Ap
• 40 CFR 262 (Establishes standards for generators of hazardous waste) Ap
• 40CFR 264. Subpart F (Requirements for detection of releases from Ap
Solid Waste Management Units)
••40 CFR 264. Subpart G (Closure and Post Closure Standards) Ap
• 40 CFR 264 Subpart L (Standards for treatment of wastes, in piles) Ap
• 40 CFR 264 Subpart S (CAMU Rules) Ap
• 40 CFR 264 Subpart X (Design/operation requirements for misc. Ap
hazardous waste management units)
• 40 CFR Part 268 (Land disposal restrictions) Ap
• 40 CFR 761 (Establishes storage/disposal requirements for PCBs) Ap
• UAC R307-1 -3 (Standards for Control of Installations) Ap
• UAC R307-1-4 (Establishes standards for VOC emissions) Ap
• UAC R307-10 (National Emission Standards for Hazardous Air Ap
Pollutants)
• UAC R311-211 (Specified Stale of Utah corrective action cleanup Ap
standards for CERCLA and UST sites)
Yes - Performance standards; monitoring, analysis, inspection,
response, reporting, corrective action, and post-closure care
requirements would be followed.
Yes - CAMU management practices would be followed.
Yes - The source will be removed by excavation and controlled with a
cap. The alternative will comply with risk-based closure standards.
Yes - The ARAR would be met with ground-water monitoring and
by removing and/or containing the source.
Yes - Air emissions during excavation and trealmenl will be
controlled to comply with national primary and secondary air quality
standards.
Yes - Air emissions during excavation and treatment will be
controlled to comply with NESHAPs standards.
Yes - The ARAR will be met by complying with standards for
generators of hazardous wastes.
Yes - The ARAR would be met with ground-water monitoring.
Yes - Complies with clean closure regulations.
Yes - The ARAR would be met by following the design and
operating requirements for storage or treatment or waste in piles;
monitoring and inspection; and closure and post-closure care.
Yes - CAMU management practices would be followed to comply
with LDRs.
Yes - Performance standards; monitoring, analysis, inspection,
response, reporting, corrective action, and post-closure care
requirements would be followed.
Wastes disposed of on site will comply with LDRs.
Yes - Storage and disposal requirements for PCB-contaminated soils
will be met.
Yes - BACT would be used for control of vapor emissions.
Yes - VOC emissions would be controlled to comply with VOC
emission standards.
Yes - The ARAR would be met with use of vapor control systems on
the soil vapor extraction system.
Yes - The source will be removed.
ARAR Applicable or relevant and appropriate requirements
BACT Best available control technology
CAMU Corrected Action Management Unit
CFR Code of Federal Regulations
PCBs Polychlorinated Biphenyls
RCRA ' Resource Conservation and Recovery Act
TCE Trichloroethene
UAC Utah Administrative Code
VOC Volatile Organic Compounds
Ap • Applicable
R Relevant and Appropriate
-------
TABLE 5-4
SUMMARY OF KEY ARARs FOR EACH ALTERNATIVE
(10 of 10)
Alternative
Key ARARs With Which the Alternative Must Comply^)
ARAR Would Alternative Meet ARAR?
Alternative 6 (Excavation, On-Silc Treatment, Backfill, and In-situ Vapor Extraction)
UAC R315-5 (Slate of Utah requirements for generators of hazardous Ap
waste)
UAC R315-8-6 (Ground-water protection) Ap
U AC R315-8-7 (State of Utah closure and post closure standards) Ap
UAC R315-8-12 (Standards for treatment of wastes in piles) Ap
UAC R315-8-21 (CAMU Designation and management) Ap
UAC R315-13. (Land disposal restrictions) Ap
UACR3I5-IOI (Specifies State of Utah cleanup action and risk-based Ap
closure standards for RCRA sites)
UAC R.I 17-6 (State ground-water quality protection standards) Ap
Yes - The ARAR will be met by complying with standards for
generators of hazardous wastes. .
Yes - The alternative would meet ground-water monitoring
requirements of the ARAR.
Yes - Complies with clean closure regulations.
Yes - The ARAR would be met by.following the design and
operating requirements for storage or treatment or waste in piles;
monitoring and inspection; and closure and post-closure care.
Yes - CAMU management practices would be followed.
Wastes disposed of on site will comply with LDRs
Yes - The source will be removed and will comply with the risk-based
closure standards.
Yes - The ARAR would be met with ground-water monitoring and
by removing the source.
ARAR Applicable or relevant and appropriate requirements
BACT Best available control technology
CAMU Corrected Action Management Unit
CFR Code of Federal Regulations
PCBs Polychlorinated Biphenyls .
RCRA Resource Conservation and Recovery Act
TCE Trichloroethene
UAC Utah Administrative Code
VOC Volatile Organic Compounds
Ap Applicable
R Relevant and Appropriate
-------
5.3.2. Comparative Analysis
In this section, the alternatives for each site are compared to evaluate their relative
performance according to each of the evaluating criteria. The objectives of the
comparison is to assess the relative advantages and disadvantages of the alternatives and
to identify the key tradeoffs that must be balanced in selecting a preferred alternative. A
comparison of alternatives for each criterion is briefly discussed in the following
paragraphs.
Comparative Analysis of RVMF Alternatives
Overall Protection of Human Health and the Environment
With the exception of the No Action alternative, each alternative is protective of human
health and the environment. Alternatives 2 and 3 differ on how 1,1-DCE contamination
is addressed. Aiiemaiive 2 wuuiu cumiui ami icuuCc Llic poiciitial for contaminant
movement to ground water and prevent health risks from exposure by using the existing
concrete floor of Building 514 as a permeability barrier. Alternative 2 would be
protective, but the 1,1-DCE would remain in soil at elevated concentrations; natural
attenuation would reduce the contaminant concentrations in soil but it is unknown how
long this would take and to what extent the concentrations would be reduced.
Alternative 3 would be protective because in-situ SVE would reduce the concentration of
1,1 -DCE to below the remediation goal.
Compliance with ARARs
All alternatives would comply with ARARs except the no-action alternative
(Alternative 1). Key ARARs and the means of compliance for each alternative are
presented in Table 5-4.
Long-Term Effectiveness and Permanence
Alternative 3 reduces contaminant concentrations in soil and does not require long-term
provisions to ensure protectiveness; therefore, Alternative 3 provides the highest degree
of long-term effectiveness and permanence. Alternatives 1 and 2 do not actively reduce
contaminant concentrations in soil: therefore, provisions must be made (e.g. institutional
controls, long-term monitoring) to ensure long-term effectiveness for protecting human
health and the environment. Alternative 1 does not include provisions to assure long-
term effectiveness; therefore, it rates lowest for this criterion. Alternative 2 includes
issuing a continuing order and long-term monitoring to ensure effectiveness, so it rates
higher than Alternative 1.
Reduction of Toxicity, Mobility, or Volume through Treatment
Alternative 3 rates highest in reducing TMV. Only Alternative 3 would reduce the
volume of 1,1-DCE in soil through treatment, whereas Alternative 2 does not involve
5-27
-------
treatment and would only minimize the potential for movement of 1,1-DCE from soil to
ground water. Although the inherent mobility of 1,1-DCE is not affected by the building
over the area of attainment, the existing concrete floor would continue to minimize the
transport of 1,1-DCE from soil to ground water. Alternative 1 would maintain the
existing short-term reduction of the mobility of 1,1-DCE. Thus, Alternative 1 rates
lowest in this category.
Short-Term Effectiveness
Alternative 1 does not require any additional site activities, does not adversely impact
human health and the environment, and currently achieves the soil RAOs; consequently,
Alternative 1 provides the highest degree of short-term effectiveness. Alternative 2 also
provides short-term effectiveness; however, since additional site activities are required, it
rates slightly lower'at short-term effectiveness than Alternative 1. Alternative 3 includes
installation of a SVE system, which could expose workers to contaminated soil during
installation and to vapors discharged from the SVE system during operation. The risks
associated with Alternative 3 could be controlled by implementing protective health and.
safety measures during system installation and by restricting worker access to the SVE
system vapor discharge location. Because of the potential health risks associated with the
construction and implementation of the SVE system, Alternative 3 provides the lowest
degree of short-term effectiveness of all the alternatives.
Implementability
All alternatives are technically and administratively feasible, and the goods and services
required to implement the alternatives are available. Because no action is required and
current Base operations in the area would not be affected, Alternative 1 is the most
implementable alternative. Alternative 2 would require additional administrative efforts
related to implementation of institutional controls; therefore, it rates lower than
Alternative 1 in implementability. In addition to the administrative efforts related to
implementation of institutional controls required while the Alternative is in effect, current
Base operations at Building 514 would be affected by installation and operation of the
SVE system. Consequently, Alternative 3 rates lowest for implementability.
Costs
Alternative 3 has the highest overall cost, while Alternative 1 has the lowest overall cost.
Therefore, Alternative 1 scores the highest in this criteria.
State and Community Acceptance
The State of Utah agrees with the selected alternative for the RVMF (Alternative 3), and
the preferred alternative is acceptable to the community.
5-28
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Comparative Analysis of Sodium Hydroxide Tank Site Alternatives
Overall Protection of Human Health and the Environment
All alternatives currently are protective of human health and the environment. Although
Alternatives 1 and 2 would leave elevated-pH soil in place, both currently are protective
because the asphalt cap reduces the potential for elevated pH to move from soil to ground
water, and the cap acts as a barrier against exposure to the affected soil. Alternative 1
would not be protective in the future because no provisions are included to prevent the
cap from being removed or to restrict construction or development in the area.
Alternative 2 (unlike Alternative 1) protects human health and the environment over the
long term because it contains provisions to maintain the long-term integrity of the asphalt
cap. Alternatives 3 and 4 would be protective because soil pH would be reduced by
adding neutralizing agents to the soil.
Compliance with ARARs
All alternatives except Alternative 1 (no-action) would comply with ARARs. Key
ARARs for each alternative are presented in Table 5-4, along with a discussion of how
compliance would be achieved.
Long-Term Effectiveness and Permanence
Alternative 3 rates the highest in providing long-term effectiveness and permanence.
Alternatives 3 and 4 reduce concentrations of contaminants in soil and do not require
long-term provisions to ensure protectiveness; therefore, these alternatives provide the
highest degree of long-term effectiveness and permanence. Because of uncertainties
regarding the completeness of in-situ neutralization, Alternative 4 is rated less effective
than Alternative 3. Alternatives 1 and 2 do not actively reduce the toxicity of the soil;
therefore, provisions must be made (e.g., institutional controls, long-term monitoring) to
ensure long-term protection of human health and the environment. Alternative 1 contains
no provisions to assure long-term effectiveness, so it rates lowest of all alternatives.
Alternative 2 includes a continuing order and long-term monitoring to ensure
effectiveness, so it rates higher than Alternative 1. .
Reduction of Toxicity, Mobility, or Volume through Treatment
Alternative 3 rates the highest in providing a reduction of toxicity, mobility, or volume
through treatment of the site. Alternative 4 also would reduce the toxicity of the soil, but
because of uncertainties regarding the completeness of the in-situ neutralization process,
Alternative 4 rates lower than Alternative 3 for reducing TMV. The existing asphalt cap
in Alternatives 1 and 2 only restricts the mobility of sodium hydroxide and thus soil pH.
Therefore, these alternatives rate low in this category.
5-29
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Short-Term Effectiveness
Alternatives 1 and 2 do not require additional site activities, presently achieve soil RAOs,
and would not have any adverse impacts on human health and the environment during
implementation; therefore, these alternatives rate highest at providing short-term
effectiveness. Alternative 4 could be implemented quickly and would achieve soil RAOs
with minimal exposure risks to construction workers during treatment because of the in-
situ treatment process. Alternative 3 also could be implemented quickly, and would
achieve RAOs; however, excavating contaminated soil would pose additional risks to -
construction workers, so it is rated less effective than Alternative 4.
Implementability
All alternatives are technically and administratively feasible, and the goods and services
required to implement the alternatives are available. Because no action is required and
current Base operations in the area would not be affected, Alternative 1 is the most
implementable alternative. Alternative 2 would require additional administrative efforts
related to implementation of institutional controls; therefore, Alternative 2 rates slightly
lower that Alternative 1 in implementability. Alternatives 3 and 4 would affect current
IWTP operations; therefore, they have the lowest implementability rating.
Costs
Alternative 1 (No Action) and Alternative 2 (Institutional Controls) have the lowest
overall costs while Alternative 3 has the highest costs. Therefore, Alternatives 1 and 2
score highest in this criteria.
State and Community Acceptance
The State of Utah agrees with the selected alternative (Alternative 2). One member of the
community expressed reservations related to the permanence of the proposed alternative.
Hill AFB believes the selected remedy does provide permanence, as described in the
response to the community member's comments in the responsiveness summary.
Comparative Analysis of the Berman Pond Alternatives
Overall Protection of Human Health and the Environment
With the exception of the No Action alternative, each alternative is protective of human
health and the environment. The multi-media cap (included in Alternative 2) would
protect human health and the environment by preventing human exposure to the
contaminated soil and limiting the movement of contaminants from soil to ground water.
Alternatives 3, 4, 5, and 6 would be protective because concentrations of contaminants in
Zone 1 soil would be reduced by excavation and disposal or by treatment. Alternative 5
does not reduce contaminant concentrations in Zone 2 soil, but the long-term cap would
prevent exposure and prevent contaminants from moving from soil to ground water. In
addition, Alternatives 3,4, and 6 reduce contaminant concentrations in Zone 2 soil.
5-30
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Compliance with ARARs
All alternatives except Alternative 1 (no-action) would comply with ARARs. Key
ARARs for each alternative are presented in Table 5-4, along with a discussion of how
compliance would be achieved.
Long-Term Effectiveness and Permanence
Alternatives 4 and 6 provide the highest degree of long-term effectiveness because they
reduce contaminant concentrations in Zone 1 and Zone 2 soil, and do not require long-
term provisions to ensure protectiveness. Alternative 1 does not achieve RAOs and does
not contain provisions for long-term effectiveness, so it is the least effective alternative.
Alternative 2 would achieve RAOs, but would require institutional controls and long-
term monitoring to ensure its effectiveness, so it rates only slightly higher than
Alternative 1. Alternatives 3, 4, 5, and 6 reduce the majority of the contaminant
concentrations in the soil, thus they provide higher degrees of long-term effectiveness
than Alternatives 1 and 2. Alternative 5 would reduce the potential for movement of
contaminants from soil to ground water, but institutional controls and long-term
monitoring would be required for this alternative to remain effective. Alternative 3
would solidify the contaminants to reduce their mobility, but the contaminants would
remain in the soil. Because some potential for contaminants to move from the solidified
soil to ground water would remain, Alternative 3 is not considered as effective as
Alternatives 4 and 6.
Reduction of Toxicity, Mobility, or Volume through Treatment
All alternatives (except Alternative 1) would reduce TMV. Alternatives 4 and 6 would
provide the greatest reduction of TMV because these alternatives reduce contaminant
concentrations in both Zone 1 and Zone 2 soil; however, because Alternative 6 reduces
TMV through treatment at the site, it rates highest at reducing TMV. Alternative 5 rates
slightly lower in reducing TMV than Alternatives 4 and 6 because it would only
minimize the potential movement of contaminants from soil to ground water in Zone 2
soil. Alternative 3 also rates slightly lower than Alternatives 4 and 6 because the in-situ
solidification process would only reduce the potential movement of contaminants from
soil to ground water and would not reduce the volume of contaminants remaining in
Zone 1 soil. Alternative 2 would only minimize the potential for the movement .of
contaminants from soil to ground water; therefore, it rates lowest in this category.
Short-Term Effectiveness
Alternative 1 does not require any additional site activities and does not adversely impact
human health and the environment during implementation; consequently, Alternative 1
provides the highest degree of short-term effectiveness. Because of the limited depth of
excavation and short implementation time, Alternative 2 has limited adverse health
affects during implementation and rates slightly lower than Alternative 1 at providing
short-term effectiveness. Site workers may be subjected to elevated VOC vapors for
5-31
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short durations during implementation of Alternative 3, so it rates slightly lower at
providing short-term effectiveness than Alternative 2. Alternatives 4, 5, and 6 involve
extensive excavation that could impose adverse health affects on site workers during
implementation; therefore, these alternatives provide the lowest degree of short-term
effectiveness. The exposure risks associated with all alternatives involving site activities
could be reduced by implementing protective health and safety measures.
Implementability
All alternatives are technically and administratively implementable, and the goods and
services required to implement the alternatives are available. Because no action is
required, and current Base operations in the area would not be affected, Alternative 1 is
the most implementable alternative. Alternative 2 would require additional
administrative efforts related to implementation of institutional controls; therefore,
Alternative 2 rates lower than Alternative 1. Alternative 4 rates slightly lower in
implementability than Alternative 2 because additional site activities (e.g., soil
excavation, soil transport to disposal facility, installation of SVE system, and site capping
activities) would impact Base operations in the area during implementation of the
alternative. The implementability of Alternatives 5 and 6 are similar, but they rate lower
than Alternative 4 because additional material handling activities (e.g., debris sorting and
material stockpiling) would be required. Alternative 3 is rated as the least implementable
.alternative because the large amount of debris present in the former pond may make in-
situ treatment of the soil difficult.
Costs
The No Action alternative has the lowest overall cost. The costs for all of the treatment
alternatives (Alternatives 3, 5, and 6) are relatively high because of the large volume of
contaminated soil present within the areas of attainment. The excavation and off-site
treatment alternative (Alternative 4) has the highest cost of any of the alternatives.
State and Community Acceptance
The State of Utah agrees with the selected alternative (Alternative 2). One member of the
community expressed reservations related to the permanence of the proposed alternative.
Hill AFB believes the selected remedy does provide permanence, as described in the
response to community member's comments in the responsiveness summary.
5.3.3. Summary of Selected Remedies
RVMF
Alternative 3 (In-Situ Vapor Extraction) was chosen as the selected remedy for the
RVMF. This alternative provides the best balance of trade-offs with respect to the nine
criteria. This alternative protects human health and the environment, complies with
ARARs, and is cost effective. In addition, this alternative is acceptable to the State of
Utah and the community.
5-32
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Sodium Hydroxide Tank Site
Alternative 2 (Cap Maintenance and Institutional Controls) was chosen as the selected
remedy for the Sodium Hydroxide Tank Site. This alternative provides the best balance
of trade-offs with respect to the nine criteria. This alternative protects human health and
the environment, complies with ARARs, and is cost effective. In addition, this
alternative is acceptable to the State of Utah and is generally acceptable to the
community.
Berman Pond
Alternative 2 (Cap Installation and Institutional Controls) was chosen as the selected
remedy for Berman Pond. This alternative provides the best balance of trade-offs with
respect to the nine criteria. This alternative protects human health and the environment,
complies with ARARs, and is cost effective. In addition, this alternative is acceptable to
the State of Utah and is generally acceptable to the community.
5-33
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6.0 SELECTED REMEDIES
6.1 DESCRIPTION OF THE SELECTED REMEDIES
6.1.1. Selected Remedies
The selected remedies at Hill AFB OU 3 are summarized separately for each site.
RVMF
The selected remedy for the RVMF is Alternative 3 (In-Situ Vapor Extraction).
Alternative 3 consists of soil vapor extraction; providing long-term environmental
(ground-water) monitoring; establishing an inspection, maintenance, and repair program
for the building floor; and limiting exposure to contaminated soil by issuing a continuing
order from the Installation Commander.
The concentrations of 1,1-DCE in soil will be reduced to meet remediation goals using
the presumptive remedy of soil vapor extraction (SVE). Soil samples will be taken to
confirm achievement of remediation goals. Air emissions from the SVE system will be
discharged directly to the atmosphere or treated prior to discharge (if vapor
concentrations exceed modeled allowable discharge limits).
Long-term ground-water monitoring will be conducted so that the potential for
contaminant transport can be evaluated. The area of contamination currently is covered
with concrete that acts as a barrier over the contaminated soil; this barrier limits
infiltration of surface water and prevents human exposure to the soil. An inspection,
maintenance, and repair program will be established to ensure that the building floor
continues to be an effective seal over the area of contamination throughout the duration
of the SVE process.
A continuing order will be issued by the Installation Commander; the continuing order
will:
• Restrict or place limitations on the installation of any new underground
utilities or other construction activities beneath the floor in the RVMF; thus
preventing accidental exposures to construction workers.
• Provide for the use of proper protective equipment, in the event that access
through the concrete floor is required.
• Require that the integrity of the concrete floor slab be maintained (i.e., repair
cracks that may develop) so that fluids cannot infiltrate to the subsurface.
Maintenance of the floor slab will require development of SOPs to provide for
inspections, floor repairs, and responses to spills in critical areas.
6-1
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The continuing order will be in effect until 1,1-DCE concentrations in soil are reduced to
acceptable levels by the SVE process or as long as the property is owned by the Air
Force.
Figure 6-1 shows a conceptual schedule for the order of implementation of the
components of the selected remedy. The first activities will include issuance of a
continuing order and installation of the ground-water monitoring wells. The vapor
extraction system then will be installed.
Sodium Hydroxide Tank Site
The selected remedy for the Sodium Hydroxide Tank Site is Alternative 2 (Cap
Maintenance and Institutional Controls). Alternative 2 incorporates the asphalt cap
installed as an interim remedial action and continues the inspection, maintenance and
repair program, provides long-term ground water monitoring, and institutional controls.
The selected remedy will meet remediation goals by limiting exposure to contaminated
soils and will control potential migration of contaminants to the underlying ground water.
The existing inspection and maintenance program requires periodic inspection and
maintenance of the cap, as well as a requirement for repairs to the cap if access to the
subsurface is needed, such as for utility repairs. Long-term ground-water monitoring will
be conducted so that the potential for transport of contaminants to ground-water can be
evaluated.
Institutional controls include a continuing order from the Installation Commander and
covenants to the deed. The continuing order will be in effect as long as the property is
owned by the Air Force. The continuing order will:
• Restrict or place limitations on the installation of any new underground
utilities of other construction activities in the area of the cap; thus preventing
accidental exposures to construction workers.
• Provide for the use of proper protective equipment, in the event that access
through the cap is required.
• Require that the integrity of the cap is maintained (i.e., repair cracks that may
develop) so that fluids cannot infiltrate to the subsurface. Maintenance of the
cap will require development of SOPs to provide for inspections, repairs, and
responses to spills in critical areas.
A notice to the deed for Hill AFB would be filed detailing the restrictions of the
continuing order. In the case of the sale or transfer of property within OU 3 by the
United States to any other person or entity, the Air Force will place covenants in the deed
which will restrict access and prohibit disturbance of contaminated soils or the remedial
action without approval of the United States. These covenants will be in effect until
removed upon agreement of the State of Utah, the U.S. Environmental Protection
Agency, and the U.S. Air Force or their successors in interest. The Air Force will also
6-2
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PROJECT NO. 2208-OV3 5/31/95
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SCHEDULE—RVMF ALTERNATIVE 3
FIGURE 6-1
-------
include in the deed the covenants required by section 120(h)(3) of CERCLA, which
include (1) a warranty that the United States will conduct any remedial action found to be
necessary after the date of the transfer; (2) a right of access in behalf of the U.S;
Environmental Protection Agency and the Air Force or their successors in interest to the
property to participate in any response or corrective action that might be required after the
date of transfer. The right of access referenced in the preceding sentence shall include the
State of Utah for purposes of conducting or participating in any response or corrective
action that might be required after the date of transfer.
In the event that the land use is changed or structures are removed, the Air Force will re-
evaluate the protectiveness of the remedy selected for the Sodium Hydroxide Tank Site,
and will take any appropriate remedial action.
Figure 6-2 shows a conceptual schedule for the order of implementation of the
components of the selected remedy. The first activities include the issuance of a
continuing order and installation of the ground-water monitoring network. The cap
inspection, maintenance, and repair program will be continued throughout the duration of
the alternative.
Herman Pond
The selected remedy for Berman Pond is Alternative 2 (Cap Installation and Institutional
Controls). Alternative 2 consists of extracting perched water from the pond; installing a
multi-media cap; conducting long-term ground-water monitoring; and implementing
institutional controls. The selected remedy will meet remediation goals by limiting
exposure to contaminated soils and controlling potential migration of contaminants to the
underlying ground water.
Perched water present within Berman Pond will be extracted to the extent possible using
technologies such as extraction wells or trenches and piped to the IWTP for treatment in
accordance with the permit for this facility for contaminants present in the perched water.
A multi-media cap will be installed over the former pond to prevent exposure to the
contaminated soil and control infiltration of water through the soil to the ground water.
The cap will consist of multiple layers and will be designed to meet relevant and
appropriate RCRA landfill closure requirements and provide drainage of surface water
away from the contaminated soils. Periodic inspection, maintenance, and repairs of the
cap will be required. Long-term ground-water monitoring will be conducted so that the
potential for transport of contaminants to ground water can be evaluated.
Institutional controls are the same as for the Sodium Hydroxide Tank Site, except that
warning signs will be posted to prevent unauthorized excavation of the cap. Because
contaminant levels are not expected to significantly decrease, the continuing order will
remain in effect as long as the property is owned by the Air Force.
A notice to the deed for Hill AFB would be filed detailing the restrictions of the
continuing order. In the case of the sale or transfer of property within OU 3 by the
United States to any other person or entity, the Air Force will place covenants in the deed
6-3
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PROJECT NO. 2208.0113 S/31/95
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FIGURE 6-2
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which will restrict access and prohibit disturbance of contaminated soils or the remedial
action without approval of the United States. These covenants will be in effect until
removed upon agreement of the State of Utah, the U.S. Environmental Protection
Agency, and the U.S. Air Force or their successors in interest. The Air Force will also
include in the deed the covenants required by section 120(h)(3) of CERCLA, which
include (1) a warranty that the United States will conduct any remedial action found to be
necessary after the date of the transfer; (2) a right of access in behalf of the U.S.
Environmental Protection Agency and the Air Force or their successors in interest to the
property to participate in any response or corrective action that might be required after the
date of transfer. The right of access referenced in the preceding sentence shall include the
State of Utah for purposes of conducting or participating in any response or corrective
action that might be required after the date of transfer.
In the event that the land use is changed or structures are removed, the Air Force will re-
evaluate the protectiveness of the remedy selected for Berman Pond, and will take any
appropriate remedial action.
Figure 6-3 shows a conceptual schedule for the order of implementation for the
components of the selected remedy. The first activities include issuance of a continuing
order and installing the perched water extraction system. Next, the multi-media cap will
be installed, followed by installation of ground-water monitoring wells and posting of
warning signs. This is followed by commencement of the ground-water monitoring
program and implementation o f the cap installation and inspection, maintenance, and
repair program.
6.1.2. Remediation Goals and Performance Standards
The remediation goals for the selected remedies are discussed separately for each site.
For all sites, a performance and compliance sampling program (PCSP) will be
implemented during the remedial action to monitor performance and compliance with
remediation goals. This program will be developed during the implementation of the
selected remedy and will include locations of performance monitoring points, monitoring
frequency, analytical parameters, sampling and analytical methods, and statistical
methods for evaluating data. The PCSP will be designed to provide information to
evaluate the effectiveness of the remedial action with respect to levels of contamination
in ground water and the potential for contaminant transport, and will provide for site
evaluations. The PCSP may be modified during the remedial action to take into
consideration changing site conditions.
RVMF
The remediation goal for the RVMF is to reduce 1,1 -DCE concentrations in soils to 0.8
mg/kg or less and is based on the 10-6 residential exposure. Based on partitioning
modeling, achieving this goal is expected to be protective of ground water. The area of
attainment is where 1,1-DCE exists in the soil above the 0.8 mg/kg level (see Figure 3-1)
near a floor drain in Building 514. This zone extends to a depth of approximately five
feet below ground surface and constitutes approximately 100 cubic yards of soils.
6-4
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PROJECT NO. 2208.0113 8/17/95
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HILL AIR FORCE BASE
OPERABLE UNIT 3
CONCEPTUAL REMEDIAL ACTION'lMPLEMENTATION
SCHEDULE—BERMAN POND ALTERNATIVE 2
FIGURE 6-3
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Sodium Hydroxide Tank Site
The remediation goals for the Sodium Hydroxide Tank Site are to reduce transport of
contaminants from soil to ground water by minimizing surface water infiltration and
preventing exposure to contaminated soils. Because sodium hydroxide is non-
carcinogenic and of low toxiciry, achieving this goal will meet or exceed risk-based
remedial action objectives. The area of attainment is where soil pH exceeds 8.5 (see
Figure 3-2), where contaminants are likeliest to be geochemically mobile. This zone
extends from 10 to 50 feet below ground surface and constitutes approximately 12;000-
cubic yards of soils.
Berman Pond
The remediation goals for Berman Pond are to reduce transport of contaminants from soil
to ground water by minimizing surface water infiltration and preventing exposure to
contaminated soils. The area of attainment for both defined zones of contamination of
Berman Pond (Figures 3-3 and 3-4) is based on preliminary remediation goals that
evaluate the potential to contaminate shallow ground water in excess of drinking water
standards and on risk-based concentrations (see Table 3-5). Standards to protect ground
water predominate in defining the area of attainment. The contamination extends to as
deep as 65 feet and constitutes at least 60,000 cubic yards of soils.
6.1.3. Restoration Time Frame
The restoration time frame for the RVMF is one to three years to allow for system
operation and confirmation sampling. The cap is already in place for the Sodium
Hydroxide Tank Site and the institutional controls are expected to be in place within a
year of beginning the remedial action. The cap and institutional controls for Berman
Pond are expected to be complete within three years of beginning the design.
Contaminant concentrations beneath the Sodium Hydroxide Tank Site and Berman Pond
are not expected to attenuate naturally within any foreseeable time frame.
6.1.4. Costs
The estimated costs for remediating the three OU 3 sites are discussed separately for each
site.
RVMF
The total capital cost of the project is estimated at $134,250. The total capital cost
includes: installation of the ground-water monitoring wells, engineering design, vapor
extraction system installation and operation, and administrative and legal costs of
initiating the institutional controls. The indirect capital cost for the project is estimated at
$41,928. Indirect capital costs are included in the estimated total capital costs above.
Indirect costs include engineering, construction management, and contract administration.
6-5
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Operation and maintenance (O&M) costs change over the duration of the remedial action.
Operation and maintenance costs are calculated for a.three-year period, and do not reflect
costs that may be incurred if the remediation period lasts longer than three years. Annual
O&M is estimated at $28,746 for years one and two and $33,438 for year three. O&M
costs include monitoring program costs as well as maintenance of equipment. The total
present-worth cost of the selected remedy over a three-year period, using an interest rate
of ten percent, is estimated at $217,000. The costs discussed here are estimated with
+50/-30 percent accuracy for a three-year period. During the implementation process for
the selected alternative, some changes could occur as a result of the remedial design
process; these changes could result in changes to the estimated costs for this alternative.
Sodium Hydroxide Tank Site
The total capital cost of the project is estimated at $31,700. The total capital cost
includes: installation of the ground-water monitoring wells, administrative and legal cost
of initiating the institutional controls, and filing a notice to the deed for Hill AFB. The
indirect capital cost for the project is estimated at $11,305. Indirect capital costs are
included in the estimated total capital costs above. Indirect costs include engineering,
construction management, and contract administration.
Operation and maintenance (O&M) costs change over the duration of the remedial action.
Operation and maintenance costs are calculated for a 30-year period and do not reflect
costs that may be incurred if the remediation period lasts longer than 30 years. Annual
O&M is estimated at $3,620 for years 0 through 3, and 5 through 8; $3,090 for years 10
through 13, 15 through 18, 20 through 23, and 25 through 28; $16,200 for year 4;
$30,420 for year 9; $15,670 for years 14 and 24; and $29,890 for years 19 and 29. O&M
costs include monitoring program costs, as well as maintenance of the asphalt cap. The
total present^worth cost of the selected remedy over a 30-year period, using an interest
rate of ten percent, is estimated at $97,900. The costs discussed here are estimated with
+50/-30 percent accuracy for a 30-year period.
Herman Pond
The total capital cost of the project is estimated at $3,838,000. The total capital cost
includes: installation of a perched-water extraction system, installation of the ground-
water monitoring wells, cap design, cap installation and maintenance, administrative and
legal costs of initiating the institutional controls, and filing a notice to the deed for Hill
AFB. The indirect capital cost for the project is estimated at $539,650. Indirect capital
costs are included in the estimated total capital costs above. Indirect costs include
engineering, construction management, filing a notice to the deed, and contract
administration.
Operation and maintenance (O&M) costs change over the duration of the remedial action.
Operation and maintenance costs are calculated for a 30-year period and do not reflect
costs that may be incurred if the remediation period lasts longer than 30 years. Annual
O&M is estimated at $38,326 for years 0 through 3, and 5 through 8; $31,858 for years
10 through 13, 15 through 18, 20 through 23, and 25 through 28; $51,326 for years 4 and
6-6
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9; and $44,858 for years 14, 19, 24, and 29. O&M costs include monitoring program
costs, as well as maintenance of the cap. The total present-worth cost of the selected
remedy over a 30-year period, using an interest rate of ten percent, is estimated at
$4,234,000. The costs discussed here are estimated with +50/-30 percent accuracy for a
30-year period. During the implementation process for the selected alternative, some
changes could occur as a result of the remedial design process; these changes could result
in changes to the estimated costs for this alternative.
6.2 STATUTORY DETERMINATIONS
The selected remedies for OU 3 meet the statutory requirements of Section 121 of
CERCLA as amended by SARA. These statutory requirements include protection of
human health and the environment, compliance with ARARs, cost effectiveness,
utilization of permanent solutions and alternative treatment technologies to the maximum
extent practicable, and preference for treatment as a principal element. The manner in
which the selected remedies for OU 3 meet each of the requirements is presented in the
following discussion. The purposes of the remedies discussed in this ROD are to prevent
exposure to contaminated soil and reduce contaminant transport from soil to either
ground water or air. As long as contaminants remain above health-based levels at the
site, the selected remedies will be formally reviewed at least every five years to determine
if the alternative still is protective of human health and the environment. If, during the
review process, the alternative is determined to not be protective of human health and the
environment, the site will be re-evaluated and an appropriate action (i.e., selection of an
alternate or additional remedy) will be taken to solve the problem.
6.2.1. Protection of Human Health and the Environment
RVMF
The selected remedy for the RVMF protects human health and the environment during
operation of the vapor extraction system by restricting direct contact with contaminants.
This will be achieved through issuance of a continuing order by the Installation
Commander. The continuing order will be in effect throughout the duration of the
alternative, and will include maintaining the concrete slab, restricting cutting of the
concrete building floor, and limiting excavations unless proper protective equipment is
used. The soil vapor extraction system will reduce the concentrations of 1,1-DCE in soil,
thereby eliminating future exposure risks.
Sodium Hydroxide Tank Site
The selected remedy for the Sodium Hydroxide Tank Site protects human health and the
environment by restricting direct contact with contaminants by maintaining the asphalt
cap, and issuing a continuing order by the Installation Commander. The continuing order
will be in effect throughout the duration of the alternative, and will include maintaining
the asphalt cap, restricting asphalt cutting, and limiting excavations unless proper
protective equipment is used. Upon transfer of the property, the Air Force will provide a
deed covenant notifying the transferee of the location of the high-pH soil, restrictions on
use of the area, and provide for future rights of access for Hill AFB.
6-7
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Berman Pond
The selected remedy for Berman Pond protects human health and the environment by
restricting direct contact with contaminants by installing a multi-media cap over the area
of contaminated soil, and issuing a continuing order by the Installation Commander. The
cap will reduce infiltration of surface water, and subsequent transport of contaminants to
ground water. The cap also will prevent direct contact with contaminants. The
continuing order will be in effect throughout the duration of the alternative, and will
include maintaining the cap, restricting access through the cap, and limiting excavation in
the area unless proper protective equipment is used. Upon transfer of the property, the
Air Force will provide a deed covenant notifying the transferee of the location of the
contaminated soil, restrictions on use of the area, and provides for future rights of access
for Hill AFB.
6.2.2. Compliance with Applicable or Relevant and Appropriate Requirements
Section 121(d)(l) of CERCLA, as amended by SARA, requires that the remedial actions
must attain a degree of cleanup that assures protection of human health and the
environment. In addition, remedial actions that leave any hazardous substances,
pollutants, or contaminants on the site must, upon completion, meet a level or standard
that at least attains legally applicable or relevant and appropriate standards, requirements,
limitations, or criteria that are applicable or relevant and appropriate requirements
(ARARs) under the circumstances of the release. ARARs include Federal standards,
requirements, criteria, and limitations and any promulgated standards, rules,
requirements, criteria, or limitations under the State of Utah environmental or facility
siting regulations including those that are more stringent than Federal standards. In
addition, ARARs include State of Utah regulations that have no corresponding federal
regulations.
"Applicable" requirements are those cleanup standards, standards of control, and other
substantive environmental protection requirements, criteria, or limitations promulgated
under Federal or State law that specifically address the hazardous substances, pollutants,
or contaminants, remedial action, location, or other circumstance at the OU 3 sites.
"Relevant and appropriate" requirements are cleanup standards, standards of control, and
other substantive environmental protection requirements, criteria, or limitations
promulgated under Federal or State law that, while not "applicable" to the hazardous
substance, pollutant or contaminant, remedial action, location, or other circumstance at a
remedial action site, address problems or situations sufficiently similar to those
encountered at the site that their use is well suited to the particular site.
The key ARARs for all alternatives were presented in Table 5-4. All ARARs for the
selected remedies are presented in Table 6-1.
In evaluating which requirements are applicable or relevant and appropriate, the criteria
differ depending on whether the type of requirement is chemical-specific, location-
specific, or action-specific. According to the NCP, chemical-specific ARARs usually are
6-8
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TABLE 6-1
SUMMARY OF ARARs FOR SELECTED REMEDIES
Alternative
ARARs With Which Each Alternative Must Comply(a)
ARARs Common to AH Alternatives
40 CFR 261 (Identification and Listing of Hazardous Waste)
40 CFR 264, Suhpart F (Requirements for detection of releases)
40 CFR 264, Suhpart G (Closure and Post Closure Standards)
UAC R311 -211 (Specified Slate of Utah corrective action cleanup standards for CERCLA and UST sites)
UAC R3I5-I01 (Specifies State of Utah cleanup action and risk-based closure standards for RCRA sites)
UAC R3I5-2 (Criteria for the Indentification and Listing of Hazardous Waste)
UAC R315-8-6 (Ground-water protection)
UAC R315-8-7 (Closure and post closure standards—same as federal) '
UAC R3I7-6 (State ground-water quality protection standards)
UAC R655-4 (Standards for drilling and abandonment of wells)
Refueling Vehicle Maintenance Facility (RVMF)
Alternative 3 (In-Situ Vapor Extraction)
a\
40 CFR 50 (Primary and secondary air quality standards)
40 CFR 61 (NESHAPs standards)
40 CFR 262 (Generators of hazardous waste)
UAC R307-1 -3 (Requires use of BACT for emissions control)
UAC R307-I-4 (Establishes standards for VOC emissions and dust)
UAC R307-10 (NESHAPs standards)
UAC R315-5 (Generators of hazardous waste)
Sodium Hydroxide Tank Site
Alternative 2 (Cap Maintenance ansd Institutional Controls)
No Additional ARARs
Herman Pond
Alternative 2 (Cap Installation and Institutional Controls)
40 CFR 61 (NESHAPs standards)
40 CFR 264 Subpart N (Standards for RCRA landfills and caps)
U AC R307-1 -4 (Establishes standards for VOC emissions and dust)
UACR307-10 (NESHAPs standards)
UAC R315-8-14 (Design Operation, and Management Requirements for Landfills)
(a) Appendix B contains a listing of these ARARs with respect to their chemical, location, or action specific requirements
ARAR Applicable or relevant and appropriate requirements
BACT Best available control technology
CFR Code of Federal Regulations
RCRA Resource Conservation and Recovery Act
UAC Utah Administrative Code
VOC Volatile Organic Compounds
-------
health or risk-based numerical values that establish the acceptable amount or
concentration of a chemical that may remain in, or be discharged to, the ambient
environment. Location-specific ARARs generally are restrictions placed upon the
concentration of hazardous substances or activities solely because they are in special
locations. Some examples of special locations include floodplains, wetlands, historic
places, and sensitive ecosystems or habitats. Action-specific ARARs usually are
technology or activity-based requirements or limitations on actions taken with respect to
hazardous wastes, or requirements to conduct certain actions to address particular
circumstances at the site.
The Federal and State maximum contaminant levels (MCLs) and State Ground Water
Quality Standards were used as a basis for calculating soil contaminant levels that are
protective of ground water beneath the OU 3 area. Federal and State chemical-specific
ARARs are identified in Appendix B, Tables B-l and B-3, respectively. There are no
Federal location-specific ARARs. State location-specific ARARs are identified in
Table B-4. Federal and State action-specific ARARs are identified in Tables B-2 and
B-5, respectively.
The remedies selected for OU 3 will meet ARARs. However, because contaminants are
left in place at the Sodium Hydroxide Tank Site and at Berman Pond, the remedial action
time frame for these sites will likely exceed 30 years. As long as the institutional controls
are in place, these selected remedies will be permanent solutions that will be protective of
human health and the environment.
Because the remedies for Berman Pond and the Sodium Hydroxide Tank Site will result
in hazardous substances remaining on-site above health-based levels, a review will be
conducted within five years after commencement of the remedial action to ensure that the
remedy continues to provide adequate protection of human health and the environment.
6.2.3. Cost Effectiveness
Cost effectiveness evaluates how the selected remedy provides overall effectiveness
proportionate to its cost, such that it represents a reasonable value. For the RVMF, soil
vapor extraction will remove contaminants permanently and effectively with relatively
low cost. For the Sodium Hydroxide Tank Site, the.risks posed are relatively low-level,
pertaining mainly to protection of ground water. Costs of over an order of magnitude
higher for treatment would not represent a reasonable value compared to maintaining the
asphalt cap which will meet remediation goals. For Berman Pond, alternatives which
would completely reduce or remove contaminants such that little or no long-term
management is needed would cost over an order of magnitude more than the selected
alternative of capping. Alternatives combining treatment or removal with capping would
still require long-term management similar to the selected remedy, but at substantially
greater cost.
6-10
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6.2.4. Utilization of Permanent Solutions and Alternative Treatment Technologies
or Resource Recovery Technologies to the Maximum Extent Practicable
The selected remedies utilize permanent solutions and treatment technologies to the
maximum extent practicable while providing the best balance of tradeoffs with respect to
the criteria of long-term effectiveness and permanence; reduction in toxicity, mobility
and volume through treatment; short-term effectiveness; implementability; and cost.
The selected remedy for the RVMF provides a high degree of long-term effectiveness and
permanence because removal of the 1,1-DCE would be permanent and irreversible. The
selected remedy meets the statutory preference to utilize permanent solutions and
treatment technologies to the maximum extent practicable. Soil vapor extraction
provides significant reductions in the toxicity, mobility, and volume of 1,1-DCE through
treatment which the other RVMF alternatives would not provide. The other RVMF
alternatives would leave the 1,1-DCE permanently in place, and long-term effectiveness
would require long-term maintenance. Short-term risks are readily addressed. The added
cost over the other alternatives is relatively low, particularly when long-term maintenance
past the 30 years used for estimating purposes is considered.
The selected remedy for the Sodium Hydroxide Tank Site relies on long-term
maintenance for long-term effectiveness and permanence. There is no reduction in
toxicity, mobility, or volume through treatment. Because treatment of contaminated soils
was not found to be practicable, this remedy does not satisfy the statutory preference for
treatment as a principal element. The remedy utilizes permanent solutions and treatment
technologies to the maximum extent practicable. The risks posed at the site are relatively
low-level. Short-term risks are readily addressed, and maintaining the cap installed as
part of an interim action is easily implemented. Costs of an order of magnitude higher in
the treatment alternatives would not represent a reasonable value in comparison to the
selected remedy.
The selected remedy for Berman Pond relies on capping to address exposure threats and
ground water protection. It also relies on long-term maintenance for long-term
effectiveness. Because treatment of the pond contents and surrounding contaminated
soils was not found to be practicable, this remedy does not satisfy the statutory preference
for treatment as a principal element. Permanent solutions and treatment technologies
were utilized to the maximum extent practicable. Short-term risks are readily addressed.
Implementability and costs were criteria key to the decision. All of the treatment and
removal alternatives would be difficult to implement; most would still require long-term
maintenance of the site. Those which would require little or no long-term maintenance of
the site would be at least an order of magnitude more costly than the selected remedy.
State and community acceptance criteria did not offer concerns to substantially affect the
decisions. One community member expressed reservations concerning the permanence
of the Sodium Hydroxide Tank Site and Berman Pond preferred alternatives. However,
the Air Force believes the long-term maintenance and institutional controls provide long-
term effectiveness and permanence.
6-11
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Because these remedies will result in hazardous substances remaining on-site at the
Sodium Hydroxide Tank Site and Herman Pond above health-based levels, a review will
be conducted within five years after commencement of the remedial action to ensure that
the remedy continues to provide adequate protection of human health and the
environment.
6.3 DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for Hill AFB OU 3 was released for public comment in April 1995.
The Proposed Plan identified Alternative 3 (In-Situ Vapor Extraction), Alternative 2
(Cap Maintenance and Institutional Controls), and Alternative 2 (Cap Installation and
Institutional Controls) as the preferred alternatives for the RVMF, the Sodium Hydroxide
Tank Site, and Herman Pond, respectively. All written and verbal comments received
during the public comment period were reviewed, and it was determined that no
significant changes were necessary to the remedies identified in the Proposed Plan. A
copy of the proceedings of the Proposed Plan public open house, as well as the comments
received, are included as Appendices C and D, respectively.
6-12
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Overview
This responsiveness summary provides information about the views of the community
with regard to the proposed remedial actions for Hill Air Force Base (AFB) Operable
Unit 3 (OU 3), documents how public comments have been considered during the
decision making process, and provides responses to concerns.
The public was informed of the preferred remedial actions in the following ways:
• All items contained within the Administrative Record have been on file at the
subject repositories since the final version of each document was issued
• A copy of the Final Proposed Plan for Operable Unit 3 (Montgomery
Watson, 1995b) was sent to local citizens and other interested parties (284
total) on Hill AFB's IRP mailing list prior to the public comment period
• A public comment period was held from April 10, 1995, through May 9, 1995
• A public open house was held on April 20, 1995, at the North Davis Library
(North Branch) located in Clearfield, Utah
• Oral and written comments by the public were encouraged.
The public open house was poorly attended, and residents voiced few concerns about the
nature and extent of contamination. A transcript of oral comments recorded during the
open house is attached as Appendix C. No oral or written comments were made that
affect the proposed remedial actions for OU 3. Written comments were received from
three people during the public comment period; the comments are included in
Appendix D.
Background on Community Involvement
The public participation requirements of CERCLA Sections 113(k)(2)(B)(i-v) and 117
were met. Hill AFB has a Community Relations Plan that was completed in February
1992. The community relations activities include: (1) a Restoration Advisory Board
(RAB), which meets quarterly and includes community representatives from adjacent
counties and towns, (2) a mailing list for interested parties in the community, (3) a bi-
monthly newsletter called "EnviroNews," (4) visits to nearby schools to discuss
environmental issues, (5) community involvement in a noise abatement program,
(6) semi-annual town council meetings, (7) opportunities for public comment on remedial
actions, and (8) support for the community in obtaining technical assistance grants
(TAGs).
The Draft Final Remedial Investigation Report (JMM, 1992), the Draft Final Baseline
Risk Assessment Addendum for Operable Unit 3 (JMM, December 1991), the Final
Phase II^Remedial Investigation Report for Operable Unit 3 (including the Baseline Risk
Assessment Addendum; Montgomery Watson, 1995), the Final Feasibility Study for
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Operable Unit 3 (Montgomery Watson, 1995a), and the Final Proposed Plan for
Operable Unit 3 (Montgomery Watson, 19955) were released to the public, and are
available in the administrative record maintained in the Davis County Library (Central
Branch) and at the Environmental Management Directorate at Hill AFB. The notices of
availability for these documents were published in the Salt Lake Tribune and the Ogden
Standard Examiner. A public comment period was held from April 10, 1995, through
May 9, 1995. In addition, a public open house was held on April 20, 1995. At this open
house, representatives from Hill AFB, the EPA, and the State of Utah answered questions
about the site and the selected remedies. A court reporter was present to record specific
comments that community members wanted to submit for Public Record. Copies of the
transcript and all written public comments received during the comment period are
provided in Appendices C and D, and will be included in the administrative record. In
addition, copies of the transcript were sent to all meeting attendees who requested them.
Responses to the comments received during the public comment period are included
below. The decision process for this site is based on the Administrative Record.
Summary of Public Comments and Agency Responses
Part I - Summary and Response to Local Community Concerns.
Community Involvement
Several community members expressed concern regarding the poor attendance by the
community. One community member suggested that the public meetings should have
more coverage in the local press and other forms of media. Comments and responses are
presented in Appendix D.
Remedial Alternative Effectiveness
One community member expressed his long-term concern that the proposed remedial
actions for the Sodium Hydroxide Tank Site and Herman Pond do not permanently
dispose of the contamination, and his preference was towards alternatives that provide
permanent disposal of contaminants. The community member was told that although the
concentrations of contaminants are not reduced at the Sodium Hydroxide Tank site and
Berman Pond, the proposed solutions are considered a permanent because they will be in
effect for as long as needed. The 30-year time frame described in the alternatives is used
for cost-estimating purposes, and does not imply that the remedy will be removed in 30
years. The proposed alternatives for both sites satisfy the remedial action objectives
(RAOs) that were established for the sites: these objectives are to:
• Minimize human exposure to contaminated soil through ingestion, inhalation,
and dermal contact
• Minimize or prevent the transport of contaminants from the unsaturated soils
to the ground water so the MCLs can be met for ground water.
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Alternative Selection
One community member expressed concern that the selection of most of the preferred
alternatives was driven more by cost than by future concerns. His feeling was that covering an
area of contamination, and subsequent monitoring for thirty years, did not provide a permanent
solution. As discussed above, the community member was told that the Sodium Hydroxide
Tanks Site and Berman Pond proposed alternatives are considered permanent, and they meet the
RAOs that were established for the sites. The selection of the proposed alternatives was partially
dependent on cost; however, cost was only a deciding factor for alternatives that are considered
equally protective of human health and the environment.
Part II - Comprehensive Response to Specific Legal and Technical Questions
No specific legal and technical questions were raised by the community.
Remaining Concerns
No remaining concerns have been identified for OU 3.
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REFERENCES
Chen-Northern 1989. Pond 3 Site Evaluation Report, Hill Air Force Base, Ogden, Utah.
Prepared for Hill Air Force Base, September, 1989.
Chio, C. T., L. J. Peters, and V. H. Freed, 1979. A Physical Concept of Soil-Water
Equilibria for Nonionic Organic Compounds. Science, 206: 831-832.
Dixon, W., and F. Massey, 1983. Introduction to Statistical Analysis, Fourth Edition.
Dragun, J., 1988. Organic Chemical Biodegradation in Soil. The Soil Chemistry of
Hazardous Materials. The Hazardous Materials Control Research Institute, Silver
Springs, MD., pp. 325-445.
Drever J.I., 1982. The Geochemistry of Natural Waters: New Jersey, Prentice-Hall, Inc.,
388 p.
Engineering-Science, Inc. (ES), 1982. Installation Restoration Program Phase I: Records
Search, Hill Air Force Base, Utah, January, 1982.
Health Effects Summary Tables (HEAST), 1991. EPA (United States Environmental
Protection Agency), NTIS No. PB91 -921199.
Health Effects Summary Tables (HEAST), 1993. EPA (United States Environmental
Protection Agency), NTIS No. PB93-921199.
Hunter/Environmental Science and Engineering (ESE), 1989a. Data Compilation Report
RI/FS Berman Pond and Building 514 Area, March, 1989.
James M. Montgomery, Consulting Engineers. Inc. (JMM), 1989a. Summary of Site
Characterization Data Collected During 1988, IWTP Area.
James M. Montgomery, Consulting Engineers, Inc. (JMM), 1989b. Hill Air Force Base,
Utah, Internal Draft Remedial Investigation Report for Operable Unit 3, July
1989.
James M. Montgomery, Consulting Engineers. Inc. (JMM), 1991a. Draft Final Baseline
Risk Assessment for Operable Unit 3, Hill Air Force Base, Utah, December,
1991.
James M. Montgomery, Consulting Engineers, Inc. (JMM), 1992. Draft Final Focused
RI/FS for the Sodium Hydroxide Tank Site at Operable Unit 3, Hill Air Force
Base, Utah, January 1992.
James M. Montgomery, Consulting Engineers, Inc. (JMM), 1992a. Draft Final Remedial
Investigation Report for Operable Unit 3, Hill Air Force Base, Utah, April, 1992.
R-l
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James M. Montgomery, Consulting Engineers, Inc. (JMM), 1992c. IWTP Leak
Investigation Interim Report, Hill Air Force Base, Utah, December 1992.
Johnson, R.L., C.D. Palmer, and W. Fish, 1989. Subsurface Chemical Processes: Field
Examples. Transport and Fate of Contaminants in the Subsurface, U.S. EPA
Seminar Publication, EPA/625/4-891019.
Little, A. D., Inc., 1985. The Installation Restoration Program Toxicology Guide,
Volume I.
Montgomery Watson, 1993b. Draft Focused Remedial Investigation/Feasibility Study for
the Refueling Vehicle Maintenance Facility at Operable Unit 3, Hill Air Force
Base, Utah, March 1993.
Montgomery Watson, 1994a. Draft Quality Control Summary Report for the Phase II
Remedial Investigation for Operable Unit 3, Hill Air Force Base, Utah, March
1995.
Montgomery Watson, 1995. Final Phase II Remedial Investigation Report for Operable
Unit 3, Hill Air Force Base, Utah, March 1995.
Montgomery Watson, 1995a. Final Feasibility Study for Operable Unit 3, Hill Air Force
Base, Utah, March 1995.
Montgomery Watson, 1995b. Final Proposed Plan for Operable Unit 3, Hill Air Force
Base, Utah, March 1995.
National Research Council (NRC), 1989. Recommended Dietary Allowances, 10th
Edition.
Radian Corporation (Radian), 1988. Installation Restoration Program Phase II, Stage 2,
Hill Air Force Base, Utah, July, 1988.
Sergent, Hauskins, and Beckwith (SHB), 1985. Field Soil Boring Logs and Sketch Maps
for a Site Investigation at the IWTP Sludge Drying Beds, Hill Air Force Base,
Utah.
Stumm, W. and J.J. Morgan, 1981. Aquatic Chemistry, 2nd ed.: Wiley-Interscience,
New York, 780 p.
Sunrise Engineering, Inc. and Applied Ecological Services, Inc. (Sunrise and AES), 1.993.
Hill Air Force Base Wetlands Delineation and Management Plan, October, 1993.
U.S. Environmental Protection Agency (EPA), 1985. Guidance on Remedial
Investigations Under CERCLA. EPA-540G-85-003, June, 1985.
R-2
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U.S. Environmental Protection Agency (EPA), 1986. Test Methods for Evaluating Solid
Waste, SW-846, Third Edition, November, 1986.
U.S. Environmental Protection Agency (EPA), 1986a. Superfund Public Health
Evaluation Manual. EPA 540/1-86-060.
U.S. Environmental Protection Agency (EPA), 1989. Risk Assessment Guidance for
Superfund. Vol. 1: Human Health Evaluation Manual, Part A EPA/540/-89/002,
December, 1989.
U.S. Environmental Protection Agency (EPA), 1989a, Exposure Factors Handbook.
EPA/600/8-89/043, July, 1989.
U.S. Environmental Protection Agency (EPA), 1991. Human Health Evaluation Manual*
Supplemental Guidance: "Standard Default Exposure Factors," OSWER Directive
9285.6-03, March, 1991.
U.S. Environmental Protection Agency (EPA), 1992. Dermal Exposure Assessment:
Principles and Applications. EPA/600/8-91/01 IB, January, 1992.
U.S. Environmental Protection Agency (EPA), 1993a. Provisional Guidance for
Quantitative Risk Assessment of Polycyclic Aromatic Hydrocarbons.
EPA/600/R-93/089, July, 1993.
UBTL, Inc., 1984. Hill AFB, Utah Installation Restoration Program Phase IB Survey,
Final Report, September 11, 1984.
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APPENDIX A
SUMMARY OF FATE AND TRANSPORT OF COMPOUNDS
INOU3SOIL
A summary of the fate and transport of contaminants present in OU 3 soil is presented in
the following table. For each chemical listed, the fate and transport mechanisms
associated with that chemical in soil, water, and air are discussed. Contaminant
susceptibility to biodegradation is also addressed.
A-l
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TABLE A-l
SUMMARY OF FATE AND TRANSPORT OK COMPOUNDS IN OU 3 SOIL
(Iof8)
Chemical
Soil
Water
Air
Biological Systems
INORGANIC
Aluminum (Al)
Antimony (Sb), may be present in
several oxidaiion states (Sb III) to
(SbV)
Arsenic (As), may be prcseni in
several oxidaiion stales ranging
from arscnatc (As VI) lo arsincs
(As III)
Barium (Ba), present as Ba(ll)
caiion
Beryllium (Be)
Cadmium (Cd), present as Cd(ll)
cation
Calcium (Ca)
Chromium (Cr4*), present in
Cr(VI) oxidation state as oxyanion
Chromium (Cr+3), present as
Cr(lll) cation
Will have moderate mobility in soil and
will likely occur as antimonate in
soluble form. Low adsorption by soil
components over long duration
(especially at elevated pH). May be
adsorbed by clay and hydrous oxides
and will complex with soil huinales.
Oxidized slates sorb to soil under
normal pll/F.li ranges, especially in the
presence of Fe. Mn and Al oxides.
Reduced slates arc more mobile.
Mobile in soil under normal Eh-pll
conditions.
Will adsorb to soils at pH of >4. At pH
values <4. metals become mobile.
Sorbed lo soil at pH of >6, especially in
the presence of Fe oxides and soil
organic mailer. However, can be
displaced in competition with other
more strongly sorbing metals such as
Ca, Cr, and Zn and at low pH values.
Mobile in soil between pH 4 and 9.
Sorb to soil at pH values of >6,
especially in the presence of Fe oxides
and soil organic matter.
Solubility in water of oxidi?.ed
form is decreased by sorption to
sediment.
Solubility in water of oxidized
form is decreased by sorption to
sediment.
High solubility in normal Eh-pH
waters.
Low solubility under normal pH
conditions (4 to 9).
Under normal pH conditions, is
moderately sorbed to sediment.
Will become soluble al low pH
values (<4).
Soluble in water under normal pH
condition. Under reducing
conditions, will convert to Cr (III)
sorbed to sediment.
Under normal pH conditions, is
moderately sorbed to sediment.
Will become soluble at low pH
Oxidized forms are not volatile, but
may be on airborne particulale.
Reduced forms may be subject to
biomethylation and be volatile.
Oxidized forms (arsenate, arsenite)
are not volatile, but may be on
airborne particulate. Reduced
forms (methyl arsines) are volatile.
Not volatile. May adsorb lo
airborne particles.
Not volatile. May adsorb to
airborne particles.
Not volatile. May adsorb to
airborne particles.
Not volatile. May adsorb to
airborne particles.
Not volatile. May adsorb lo
airborne particles.
Resistant to biodegradation but will
readily be taken up by many plant
species. Will bioconcentrate.
Susceptible to biomelhylation
reactions over a wide range of pH
and under reducing conditions.
Will be taken up by many plant
species.
Resistant (o biodegradation, but
will be taken up by many plant
species.
Resistant to biodegradation, but
will be taken up by many plant
species.
Resistant to biodegradation, but
will be taken up by plants in
regions of low soil pH.
Likely lo be reduced to Cr(III) stale
in presence of organic mailer.
Resistant lo biodegradation and low
bioavailabilily to plants.
-------
TABLE A-l
SUMMARY OF FATK AND TRANSPORT OF COMPOUNDS IN OU 3 SOIL
(2 of 8)
Chemical
Soil
Water
Air
Biological Systems
Cobalt (Co), present as Co(ll) and
Cb(lll) cations
Copper (Cu). typically present in
Cu(ll) cation
Cyanide (CnJ
Iron (Fe)
Lead (Ph), present as Pb(ll) cation
Manganese (Mn), Most likely in
Mn(II) and Mn (IV) cations
Will readily adsorb to Mn and Fe
oxides. Elevated organic content tends
to make it exchangeable so that it is
relatively easy to desorb.
Will be retained in soils through
exchange and specific adsorption
mechanisms. High affinity forsorption
to soluble organic and inorganic ligands
may increase its mobility.
Will complex with iron and other
cations ami adsorb to soils. However, if
completing mrlals and/or clay arc not
present, can he mobile under elevated
pi I conditions.
Immobile at normal pi I ranges. Strong
sorption to soil, especially in the
presence of Fe, Mn and At oxides.
Will be mobile in most soil due to
exchangeability with many other
cations, water soluble organic and
inorganic complexes
Low solubility in normal pH
conditions, moderately sorbed to
sediment and Fe and Mn oxides.
Becomes increasingly soluble as
pH values decreases.
Relatively insoluble under normal
Eh-pH conditions. Will undergo
hydrolysis, complex formation, and
or organic complex formation
under normal pH conditions (4 to
9).
Moderate water solubility, but
complexation and deposition will
control availability.
Mercury (Hg), present in the Hg°, w'" be immobile in most soil. Will
Hg22+. and Hg2+ valence states *{tm$y adsorb to clay, oxides and
0 organic material. The potential to be
adsorbed increases with increasing pH.
Will form precipitates in alkaline soil
and form several complexes with
inorganic and organic materials.
Nickel (Ni), present in Ni(ll) cation
Will adsorb to clay, Fe and Mn oxides,
and organic matter. The formation of
complexes with organic and inorganic
ligands will increase mobility in soils.
Not soluble in water.
low pH.
Will leach at
Not volatile. May adsorb to
airborne particles.
Not volatile. May adsorb to
airborne particles.
May volatilize at low pH as HCN
in shallow soil, where the water to
surface area ratio is high.
Not volatile. May adsorb to
airborne particles.
Will readily form oxide precipitates Not volatile. May adsorb to
under normal-pH and oxygenated airborne particles.
conditions. Reducing
environments and low pH increase
solubility.
Virtually insoluble in water and is
strongly attenuated by sorption to
sediment.
Low water solubility at normal Eh-
pH conditions, solubility increases
with decreasing pH.
Resistant to biodegradation.
Readily taken up by plants and
animals. Tends to bioconcentrate
in plants and animals.
Resistant to biodegradation.
Readily taken up by plants and
animals. J
Will biodegrade in soil and
groundwater under aerobic
conditions.
Resistant to biodegradation and
may bioconcentrate.
Resistant to biodegradation and
may bioconcentrate.
May volatilize from surface soil
and water under a variety of
conditions. May adsorb to airborne
particles.
Not volatile. May adsorb to
airborne particles.
May undergo biomethylation
reactions over a wide range of
conditions. Will bioconcentrate in
many plant and animal species.
Resistant to biodcgradalion and
may bioconcenlrate.
-------
TABLE A-l
SUMMARY OF FATE AND TRANSPORT OF COMPOUNDS IN OU 3 SOIL
(3 of 8)
Chemical
Soil
Water
Air
Biological Systems
Selenium (Se), mostly present as
the oxyanions selenite (II) or
selenate (IV)
Silver(AR), present as Ag(I) cation
Tin (Sn)
Vanadium (V), present as V(!||).
and V(V) cations
Zinc (Zn), present as Zn(ll) cation
ORGANIC
VOCs
Benzene
Will be mobile in many soils under
normal Eh-pH conditions; with
increasing oxidation state it becomes
more mobile. Will adsorb to soils by
ligand exchange under low pH
conditions.
Immobile in most soils under normal
Eh-pH conditions. Strongly adsorbed to
clay and organic material, and will form
several insoluble precipitates.
Under normal Hh-pH conditions V will
be in an oxidated state as V5+ nnd will
be mobile in Ihc soil. Will form
immobile complexes with organic
material and mobile complexes with
inorganics. Under reducing condition
will form V-3+ and precipitate and
adsorb to soils.
Moderately mobile in soil under normal
Eh-pH conditions with mobility
increasing with decrease in pH. Readily
adsorbed by clays, carbonates, or
hydrous oxides but will desorb if high
concentrations of other metals are
present. Will form complexes with
inorganic and organic ligands.
Highly mobile in soil, subject to rapid
volatilization from shallow soil.
Adsorption to soil is insignificant
Solubility in water of oxidized
form (selenate) makes it highly
mobile and easily transported in
groundwater. Under acidic or
reduced conditions it is strongly
attenuated by sorption to sediment.
Most forms insoluble in water.
Solubility will increase under low
pH conditions.
Will volatilize by melhylation
processes. Melhylation tends to
make selenate forms less mobile
and toxic in soils.
Not volatile. May adsorb to
airborne particles.
Oxyanions of V5+ are soluble over Not volatile. May adsorb to
a wide range of pH and are airborne particles.
generally mobile. Reduced
compounds are virtually insoluble
and will readily form oxide
precipitates with Fe and Al.
Some complexes have relatively Not volatile. May adsorb to
high solubilities and will be airborne particles.
mobile. Will hydrolyze at pH > 7.7
and the hydrolyzed species are
strongly absorbed to sediment.
Susceptible to biomethylation
reactions, microbial induced
oxidation reduction reactions
forming precipitates,
immobilization through formation
of organic compounds. Will be
taken up and bioconcentrated by
many plant species.
\
Resistant to biodegradation and
may bioconcentrate in some plant
species.
Resistant to biodegradation. may
be taken up by some plant and
animal species and may
bioconcentrate.
Resistant to biodegradation. Will
readily be taken up by most plant
species and will bioconcentrate/
Moderately soluble in water and
subject to volatilization from
surface waters. Not expected to
adsorb to sediments or hydrolyze.
May be subject to
photodegradation.
Readily volatilizes and is persistent Subject to biodegradation under
in atmosphere. Not subject to aerobic conditions. Resistant to
direct photolysis. May degrade by anaerobic biodegradation. Does
reaction with photochemically not bioconcentrate.
produced hydroxyl radicals.
Removed from atmosphere by rain.
-------
TABLE A-l
SUMMARY OF FATE AND TRANSPORT OF COMPOUNDS IN OU 3 SOIL
(4 of 8)
Chemical
Soil
Water
Air
Biological Systems
Chloroform
Chlorobenzene
Highly mobile in soil, subject to rapid
volatilization from shallow soil.
Adsorption to soil is insignificant.
Mobile in soil, subject to rapid
volatilization from shallow soil.
Adsorption to soil is insignificant in low
organic content soil.
High solubility in water and subject
to volatilization from surface
waters. Not expected to adsorb to
sediments or hydrolyze.
Moderate solubility in water and
subject to volatilization from
surface waters. Not expected to
adsorb to sediments or hydrolyze.
May be subject to
pholodcgradalion.
Readily volatilizes. Not subject to
direct photolysis. May degrade by
reaction with photochemically
produced hydroxyl radicals.
Subject to removal from
atmosphere by rain.
Readily volatilizes and subject to
direct photooxidation reactions
with photochemically produced
hydroxyl radicals. May be subject
to direct photolysis and removal
from atmosphere by rain.
Subject to biodegradalion. Does
not bioconcentrate.
Biodegradation is slow under most
conditions and can in some
conditions is insignificant.
Bioconcentration is minor.
1,2-Dichlorocthnnc (1,2-DCA)
1,2-Dichloroethene (1,2-DCE)
(cii) and (trans)
Ethylbenzene
Methyl ethyl ketone
Methyl isobutyl ketone
Mobile in soil, subject to rapid
volatili/.aiion from shallow soil.
Adsorption is insignificant in low
organic content soil.
Mobile in soil, subject to rapid
volatilization from shallow soils.
Adsorption is insignificant in low
organic content soil.
Mobile to moderately mobile; only
moderate sorption to soil and will be
susceptible to leaching. Will volatilize
from shallow soil, and slowly
biodegradc '
Highly mobile in soil and susceptible to
leaching. May be removed by direct
photolysis and/or volatilization in
surface soil. Not expected to undergo
hydrolysis.
Highly mobile in soil and susceptible to
leaching. May be removed by direct
photolysis and/or volatilization in
surface soil. Not expected to undergo
hydrolysis.
Moderate solubility in water.
Subject to volatilization from
surface water. Not expected to
adsorb to sediments or hydrolyze.
Moderate solubility in water.
Subject lo volatilization from
surface waters. Not expected to
adsorb to sediments or hydrolyze.
Moderate to low solubility in
water. Will volatilize quickly from
water. Weakly adsorbed to
sediment. Will not photolyze or
hydrolyze.
Highly soluble in water and will
volatilize and undergo direct
photolysis in surface water. Not
expected to undergo hydrolysis and
oxidation nor sorb to sediments.
Readily volatilizes. Not subject to
direct photolysis. May degrade by
reaction with photochemically
produced hydroxyl radicals.
Removed from atmosphere by rain.
Readily volatilizes. Not subject to
direct photolysis. May degrade by
reaction with photochemically
produced hydroxyl radicals.
Removed from atmosphere by rain.
Readily volatilizes and persistent in
atmosphere. May degrade by
reaction with photochemically
produced hydroxyl radicals.
Readily volatilizes. Subject to
direct photolysis and reactions with
photochemically produced
hydroxyl radicals. Removed from
atmosphere by rain.
Highly soluble in water and will
volatilize and undergo direct '
Readily volatilizes. Subject to
direct photolysis and reactions with
photolysis in surface waters. Not photochemically produced
expected to undergo hydrolysis and hydroxyl radicals. Removed from
oxidation nor adsorb to sediments, atmosphere by rain.
Biodegradation is very slow under
most conditions. Will not
bioconcentrate.
Biodegradation is very slow under
most conditions. Will not
bioconcentrate.
Biodegradation is fairly slow but
may be accelerated in acclimated
systems. Resistant to anaerobic
biodegradation. Docs not
bioconcentrate.
Subject to biodegradation under
aerobic conditions. Resistant to
anaerobic biodegradation. Does
not bioconcentrate.
Subject to biodegradation under
aerobic conditions. Resistant to
anaerobic biodegradation. Docs
not bioconcenlrate.
-------
TABLE A-l
SUMMARY OF FATE AND TRANSPORT OF COMPOUNDS IN OU 3 SOIL
(5 of 8)
Chemical
Soil
Water
Air
Biological Systems
Tetrachloroethene (PCE)
Toluene
U.I-Trichloroclhnnc (TCAl
Trichloroethcnc (TCE)
Vinyl chloride
Xylenes
BNAEs
4-Chloroaniline
Moderate to high mobility in soil.
susceptible to leaching. Highly volatile
in shallow soil. Does not hydrolyze
significantly.
Moderate to high mobility in soil.
susceptible to leaching. Highly volatile
in shallow soil. Does not hydrolyze
significantly.
Moderate to high mobility in soil.
susceptible 10 loathing. Highly volatile
in shallow soil. Docs not hydroly/.e
significantly.
Moderate to high mobility in soil and
susceptible to leaching. Highly volatile
in shallow soil. Docs not significantly
hydrolyze.
Very high mobility in soil and
susceptible lo leaching.
Sorption to soil is moderate.
Susceptible to leaching, especially from
soil with a low organic carbon content.
Volatilization is significant from surface
and shallow soil.
Binds tightly to soil and mineralizes.
No significant leaching after a few
weeks. Subject to acylation and
oxidation reactions and total
biodegradation. Will initially volatilize
to the atmosphere.
Moderate to high solubility in
water. Expected to volatilize
rapidly. Does not significantly
hydrolyze, photolyze, or adsorb to
sediment.
Volatilization and biodegradation
arc likely fate processes. Does not
significantly hydrolyze, photolyze,
or adsorb lo sediment.
Modcralc lo high solubility in
water. Expected to rapidly
volatilize. Docs not significantly
hydroly/.e, photolyze, or adsorb to
sediment.
Moderate to high solubility in
waicr. Expected to rapidly
volatilize. Docs not significantly
hydrolyze, photolyze, or adsorb to
sediment.
Moderate to high solubility in
waier. Expected to rapidly
volatilize. Does not significantly
hydrolyze, photolyze, or adsorb to
sediment.
Biodegradalion is likely. Some
adsorption lo soil/sediment may
occur.
Volatilizes initially, then
photooxidizes and biodegrades.
Chemically binds to sediments.
Readily volatilizes. Subject to
reactions with photochemically
produced hydroxyl radicals and
removal from atmosphere by rain.
Volatilization form surface soil and
water in a significant fate process.
Degrades by reaction with
photochemically produced
hydroxyl radicals and will be
washed out with rain. Not subject
to direct photolysis.
Readily volatilizes. Subject to
reactions with photochemically
produced hydroxyl radicals and
removal from atmosphere by rain.
Readily volatilizes. Subject lo
reactions with photochemically
produced hydroxyl radicals and
removal from atmosphere by rain.
Readily volatilizes. Subject to
reactions with photochemically
produced hydroxyl radicals and
removal from atmosphere by rain.
Readily volatilizes and may
degrade by reaction with
photochemically produced
hydroxyl radicals.
Resistant to biodegradation except
under anaerobic conditions. Does
not bioconcentrate.
Readily biodegradable in soil and
water. Bioconcentration not
significant.
Resistant to biodegradation except
under anaerobic conditions. Docs
not bioconcentrate.
Resistant to biodegradation except
under anaerobic conditions. Does
not bioconcentrate.
Resistant to biodegradation under
aerobic conditions. Does not
bioconcentrate.
Biodegrades fairly rapidly in
acclimated systems. Resistant to
anaerobic biodegradation. Does
not bioconcentrate.
Degrades by photolysis and by
reaction with hydroxyl radicals.
High solubility indicates that the
compound will be removed by rain.
Probably biodegrades slowly, with
acclimation, although studies are
contradictory. Bioconcentration is
unlikely.
-------
TABLE A-l
SUMMARY OF FATE AND TRANSPORT OF COMPOUNDS IN OU 3 SOIL
(6 of 8)
Chemical
Soil
Water
Air
Biological Systems
Dichlorobenzene
1,2-
1,3-
1,4-
Dimclhylphenol
Naphthalene
Phthalates
Bis(2-ethylhexyl)phthalale
Dimethylphthalate
Di-n-butylphihalate
2-methylphthalate
1,2,4-Trichlorobenzene
Low molecular weight BNAEs
Acenaphthene
Anthracene
Fluorene
Phenanthrene
Moderately to tightly adsorbed in soil.
Leaching can occur. Volatilization from
soil surfaces may be an important
transport mechanism. Possibility of
slow biodegradation under aerobic
conditions.
Adsorption to sediment is a major
environmental fate process.
Expected to volatilize rapidly if not
adsorbed to sediment. May be
subject to biodegradation after
microbial adaptation. Hydrolysis,
oxidation, and photolysis are not
important.
Relatively mobile and subject to rapid Biodegrades rapidly under aerobic
biodegradation. Oxidized by metal
cations. High pH and iron oxides
reduce mobility.
Low to miHlerate sorption to soil, will
undergo slow hiodegradation (except in
presence of PAHs). Will volatilize from
surface soil.
Tends to adsorb to soil and be resistant
to leaching (may leach in low organic
soils).
Sorplion increases as organic content
increases. May leach in low organic
soil. Biodegradation is the major fate
process.
be sorbed and be deposited into
sediment where biodegradation is
the major fate process. May also
photodegrade. Hydrolysis and
oxidation are insignificant soil
processes.
Readily volatilizes. Direct
photolysis not important. Subject
to gradual reaction with hydroxyl
radicals. Can be removed from the
atmosphere by rain.
conditions; half-life is
approximately two days.
Photolysis may degrade this
compound in surface water.
Oxidized by iron and manganese
ions.
Will volatilize from water and may
adsorbed to sediment. Will
undergo photolysis, hydrolysis and
biodegradalion.
Low solubility in water, will
complex with humic material and
will moderately sorb to sediments
and other solids. Biodegradation is
the principal fate process in water
but may also undergo hydrolysis
and photolysis.
Low mobility in soil. Moderately sorbed Low solubility in water. Expected
to soil, and resist leaching. to adsorb to sediments and other
solids.
Moderate potential to be sorbed to soil. Very low solubilities in water, will
Subject to rapid photodegradation
and reaction with nitrate radicals.
Half-life is measured in hours.
Volatilization is not important.
Biodegradation is possible after
microbial adaptation, under aerobic
conditions only. Bioconcentration
occurs, but generally at a low rate.
Not expected to bioconcentrate.
Low volatilization, and may
degrade by reaction with
photochemically produced
hydroxyl radicals.
Biodegradation is fairly slow and
tends not to bioconcentrate.
Limited volatilization from surface Expected to slowly biodegrade in
soil and water. May adsorb to
airborne particles and be removed
by wet and dry deposition. Vapor
phase will photodegrade by
reaction with hydroxyl radicals.
Moderate volatility from surface
soil and water, May adsorb to
airborne sediments and be removed
by wet and dry deposition.
Volatilization is significant from
surface soil and water. May adsorb
to airborne particles. Will
photodegrade or oxidize and be
removed by wet and dry deposition.
soil and at a more rapid rale in
water. Will bioconcentrate.
May biodegrade. Not expected to
bioconcentrate.
Expected to biodegrade and
bioconcentrate in aquatic and plant
organisms.
-------
TABLE A-l
SUMMARY OF FATE AND TRANSPORT OF COMPOUNDS IN OU 3 SOIL
(7 of 8)
Chemical
Soil
Water
Air
Biological Systems
Medium molecular weight BNAEs
Fluoranthene
Pyrene
High molecular weight BNAEs
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(g,h,i)perylene
Bcnzo(b)Fluoranthcne
Chrysene
lndeno(l.2.3-cd)pyrcnc
Pesticides and Herbicides
Aldrine
Chlordane
Dieldrin
Endrin
Heptachlor
Immohile in soil, strongly sorbed to soil.
Resist leaching. Biodegradalion is (he
major fate process.
Immobile in soil, strongly sorbed to soil.
Resist leaching. Biodegradation is the
major fate process.
Immobile in soil slrongly adsorbs lo soil
and will resist leaching. Will transform
quickly lodicldrin.
Immobile and strongly sorbed (o soil.
Resists leaching.
Immobile and slrongly sorbed lo soil.
Resists leaching.
Immobile and strongly sorbed to soil.
Resists leaching.
Immobile and strongly sorbed to soil.
Will resist leaching. Hydrolysis in most
soils is expected to be significant.
Virtually insoluble in water, will be
sorbed and deposited into sediment.
Biodegradalion is the major fate
process. May also photodegrade.
Hydrolysis and oxidation are
insignificant soil processes.
Virtually insoluble in water, will be
sorbed and deposited into sediment.
Biodegradalion is the major fale
process. May also photodegrade.
Hydrolysis and oxidation are
insignificant soil processes.
Virtually insoluble in water and
will be sorbed and deposited into
sedimeni. Residuals will volatilize
from surface water
Very low solubility in water, and
will be sorbed and deposited into
sedimeni.
Very low solubility in water, and
will be sorbed and deposited into
sediment.
Very low solubility in water, and
will be sorbed and deposited into
sediment. May photodegrade by
photoisomerization in surface
water.
Very low solubility in water, and
will be sorbed and deposited into
sedimeni. Hydrolysis is expected
to be significant in water.
Limited volatilization from surface
soil and water. May adsorb to
airborne particles. Will
photodegrade or oxidize and be
removed by wet and dry deposition.
Limited volatilization from surface
soil and water. May adsorb lo
airborne particles. Will
photodegrade or oxidize and be
removed by wet and dry deposition.
Expected (o volatilize from surface
soil and water. May be sorbed to
airborne particulates.
Residuals will volatilize from
surface water.
Expected to volatilize very slowly
from surface soil and water or may
be sorbed to airborne particulates.
Very persistent, but will slowly
photorearrange to photodieldrin.
Expected to biodegrade and
bioconcentrate in aquatic and plant
organisms.
Expected to biodegrade and
bioconcentrate in aquatic and plant
organisms.
Will undergo very slow
biodegradation. May
bioconcentrate.
Expected to be resistant to
biodegradalion. May
bioconcentrate.
Resistant to biodegradation and will
bioconcentrate.
Expected to slowly volatilize from Resistant to biodegradation and will
surface soil and water or may be bioconcentrate significantly in
sorbed to airborne parliculales. aquatic organisms.
Expected to volatilize from surface
soil and water. May be sorbed to
airborne particulates. Will react
with photochemically generated
hydroxyl radicals and ozone.
Will biodegrade slowly but is
insignificant compared to
hydrolysis. Will bioconcentrale.
-------
TABLE A-l
SUMMARY OF FA IE AND TRANSPORT OF COMPOUNDS IN OU 3 SOIL
(8 of 8)
Chemical
Soil
Water
Air
Biological Systems
p',p-DDD
p',p-DDE
p',p-DDT
Immobile and strongly sorhcd lo soil.
Resists leaching.
Virtually insoluble in water and
will be sorbed and be deposited
into sediment.
Expected to slowly volatilize from
surface soil and water. May be
sorbed to airborne particulates.
Resistant to biodegradalion and will
bioconcentrate significantly.
PCBs
PCB-1248
PCB-1254
PCB-1260
Immobile in soil. Strong adsorption to
soil and resistant lo leaching under most
conditions. Will leach in the presence
of organic solvents.
Virtually insoluble in water and
will be sorbed and be deposited
into sediment. Hydrolysis and
oxidation are not significant.
Volatilization is slow. May sorb to
airborne particles. Removed from
atmosphere by wet and dry
deposition.
Resistant to biodegradation and will
bioconcemrate significantly.
Eh Redo* potential
VOCs Volatile Organic Compounds
BNAEs Base, neutral, and acid cxlractablc compounds
-------
ARARs PERTAINING TO SELECTED REMEDIES
AT OU 3
Appendix B
-------
APPENDIX B
ARARs PERTAINING TO SELECTED REMEDIES FOR AT OU 3
B.0.0.1. This appendix presents the ARARs for the selected remedies for OU 3. The
ARARs are presented on five tables, B-l through B-5. Each table reports the Standard,
Requirement, Criterion or Limitation applicable to OU 3, the citation, a description, tells
whether the ARAR is applicable and/or relevant and appropriate, and gives comments on
how the ARAR may be applied.
B.0.0.2. Tables B-l and B-2 identify Federal ARARs applicable to OU 3 and Tables B-3
through B-5 identify State ARARs applicable to OU 3. Tables B-2 and B-5 summarize
action-specific ARARs, Tables B-l and B-3 summarize chemical-specific ARARs, and
Table B-4 summarizes location-specific ARARs.
B-l
-------
TABLE B-l
IDENTIFICATION OF FEDERAL CHEMICAL-SPECIFIC ARARs
Standard, Requirement,
Criteria, or Limitation
Citation
Description
Relevant
and
Applicable Appropriate
Comment
Solid Waste Disposal Act 42 USC Sec. 6901 -6987
Identification and Listing 40 CFR
of Hazardous Waste Part 261
Clean Air Act
Defines those solids that are subject to
regulation as hazardous wastes under 40
CFR Parts 262-265 and Parts 270, 271,
124.
42 USC Sec. 7401-7642
National Primary and 40 CFR
Secondary Ambient Air Part 50
Quality Standards
National Emission 40 CITC
Standards Tor Hazardous Pnrtftl
Air Pollutants (NESHAPs) Subpart A
Establishes standards for ambient air
quality to protect public health and
welfare (including standards for'
paniculate matter and lead).
Sets emission standards for designated
hazardous pollutants.
Yes
Yes
Yes
Determines potential waste classifications and applicability of
land disposal restrictions under 40 CFR 268.
Applicable to any activity that might result in air emissions
during remedial actions at OU 3.
Applicable to ground-water treatment facility air emissions of
trichlorocthene, benzene, toluene, and chloroform.
-------
TABLE B-2
IDENTIFICATION OF FEDERAL ACTION-SPECIFIC ARARs
Standard, Requirement,
Criteria, or Limitation
Citation
Description
Relevant
and
Applicable Appropriate
Comment
National Emission Standards 40CFR6I
Tor Hazardous
Air Pollutants (NESHAPs)
Designates substances as hazardous air
pollutants and establishes emission
standards.
Yes
Applicable to benzene, chloroform, trichloroethene, and
toluene emissions from ground-water or surface water
treatment facilities or soil/landfill vents.
Solid Waste Disposal Act
Standards Applicable to.
Generators of Hazardous
Waste
Standards for Owners and
Operators of Hazardous
Waste Treatment, Storage,
and Disposal Facilities
Releases from .Solid
Waste Management
Units
42 USC Sec.
6901-6987
40CFR
Part 262
40 CFR
Part 264
Subpart F
264.91
264.92
264.93
264.94
264.95
264.96
264.97
Establishes standards for generators of
hazardous waste.
Establishes minimum national standards
that define the acceptable management
of hazardous waste for owners and
operators of facilities that treat, store, or
dispose of hazardous waste.
Required programs
Ground-water protection standard
Hazardous constituents
Concentration limits
Point of compliance
Compliance period
General ground-water monitoring
requirements
Yes
— Applicable to spent GAC canisters.
See discussion of specific subparts.
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Relevant and appropriate to on-site remediation remedies.
Relevant and appropriate to on-
Relevant and appropriate to on-
Relevant and appropriate to on-
Relevant and appropriate to on-
Relevant and appropriate to on-
Relevant and appropriate to on-
Relevant and appropriate to en-
sile remediation remedies.
site remediation remedies.
site remediation remedies.
site remediation remedies.
site remediation remedies.
site remediation remedies.
site remediation remedies.
264.98 Detection monitoring program
Yes
Relevant and appropriate to on-site remediation remedies.
-------
TABLE B-2
IDENTIFICATION OF FEDERAL ACTION-SPECIFIC ARARs
(CONTINUED)
Standard, Requirement,
Criteria, or Limitation Citation
• Releases from Solid 264.99
Waste Management
Units (continued)
264.100
264.101
• Closure nnd Post- Suhpart G
Closure
264. 1 1 1
2W.II2
2M.II.1
264.114
264.115
264.116
264.117
264.118
264.119
264.120
Description
Compliance monitoring program . .
Corrective action program
Corrective action for solid waste
management units
Closure performance standard-
Closure plan: amendment of plan
Closure: time allowed for closure
Disposal or decontamination of
equipment, structures and soils
Certification of closure
Survey plat
Post-closure care and use of property
Post-closure plan; amendment of plan
Post-closure notices
Certification of completion of post -
Relevant
and
Applicable Appropriate
— Yes
— Yes
— Yes
— Yes
— Yes
— Yes
— Yes
— Yes
— Yes
— Yes
— Yes
— Yes
— Yes
— Yes
Comment
Relevant and appropriate to on-site remediation remedies.
Relevant and appropriate to.on-site remediation remedies.
Relevant and appropriate to on-site remediation remedies.
Relevant and appropriate to on-sile remediation remedies.
Relevant and appropriate to on-sile remediation remedies.
Relevant and appropriate to on-site remediation remedies.
Relevant and 'appropriate to on-site remediation remedies.
Relevant and appropriate to on-site remediation remedies.
Relevant and appropriate to on-site remediation remedies.
Relevant and appropriate to on-site remediation remedies.
Relevant and appropriate to on-site remediation remedies.
Relevant and appropriate to on-site remediation remedies.
Relevant and appropriate to on-site remediation remedies.
Relevant and appropriate toon-site remediation remedies.
closure care
Standards for RCRA
Landfills and Caps
Subpart N
264.310 Final cover design and performance
requirements
Yes Relevant and appropriate to cap design and maintenance.
Yes Relevant and appropriate to cap design and maintenance.
-------
TABLE B-3
IDENTIFICATION OF STATE CHEMICAL-SPECIFIC ARARS
Standard, Requirement,
Criteria, or Limitation
Citation
Description
Relevant
and
Applicable Appropriate
Comment
Utah Ground Water
Quality Protection
Division of Solid and
Hazardous Waste,
Department or
Environmental Quality
Utah Air Conservation
Regulations
R317-6 State ground-water quality protection
UAC standards
R315-2 Criteria for the Identification and Listing of
UAC Hazardous Waste.
R311 -211 Corrective Action Clean-up Standards
UAC Policy—UST and CERCLA Sites.
R307-I-3 Air Quality Standards for Control of
UAC Installations.
R307-1-3.1.8 Pollution Control for Emissions
(A)&(B)
UAC
R307-I-4
R307-10
UAC
Emission Standards
Emission Standards.
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Applicable to all remedies where contaminants will
remain on site. .
Definition of hazardous waste mirrors federal
definition. If wastes generated during the remediation
phase are determined to contain hazardous
constituents, they will be subject to these requirements.
Lists general criteria to be considered in establishing
clean-up standards including compliance with MCLs in
Safe Drinking Water Act and Clean Air Act. Requires
action to be taken to be protective.
Regulates new installations which will or might
reasonably be expected to become a source or indirect
source of air pollution including soil venting, air
stripping, and other projects.
Requires that pollution control for emissions meet
BACT, including those for soil venting, air stripping,
and other projects.
Sets emission standards for visible emissions, fugitive
emissions, construction and demolition activities.
National Emission Standards for Hazardous Air
Pollutants (NESHAPs) are incorporated by reference
(see 40 CFR 61 Subpart A in Table B-1). Also
identified as an action-specific ARAR (see Table B-4).
-------
TABLE B-4
IDENTIFICATION OF STATE LOCATION-SPECIFIC ARARS
Relevant
Standard, Requirement, Applicable and
Criteria, or Limitation Citation Description Appropriate Comment
Emissions Standards R307-1-4 Establishes standards for fugitive Yes — Davis County is a non-attainment
UAC emissions and VOCs in non- area for ozone and VOC standards
attainment areas must be met.
-------
TABLE B-5
IDENTIFICATION OF STATE ACTION-SPECIFIC ARARs
Department, Division
or Commission
Statute
Subject
Relevant
and
Applicable Appropriate
Remarks
Utah Ground Water Quality R317-6
Protection UAC
State ground-water quality protection
standards
Division of Solid and R311-211 Corrective Action Clean-up Standards
Hazardous Waste, Department UAC Policy—UST and CERCLA Sites.
of Environmental Quality
Hazardous Waste Generator
Requirements
Standards for Owners and
Operators of Hazardous
Waste Treatment, Storage,
and Disposal Facilities
• Ground-water Protection
Closure and Post-Closure
Landfills
Clean-up Action and Risk-
Based Closure Standards for
RCRA Sites.
Division of Air Quality,
Department of Environmental
Quality
R3I5 Solid and Hazardous Waste
UAC
R315-5 Establishes standards for generators of
UAC hazardous waste.
R315-8 Establishes minimum standards that
UAC define the acceptable management of
hazardous waste for owners and
operators of TSDFs.
R315-8-6 Describes ground-water monitoring
UAC requirements for TSDFs.
R315-8-7 Establishes closure and post-closure
UAC performance standards and plan
requirements for TSDFs.
R315-8-14 Establishes design, operation, and
UAC management requirements for landfills.
R315-101 Cleanup Action and Risk-Based Closure
UAC Standards for RCRA sites.
R307-1 -3 Utah Air Conservation Rules - Control
UAC of Installations
Yes — Applicable to all remedies where contaminants
will remain on site.
Yes — Lists general criteria to be considered in
establishing clean-up standards including
compliance with MCLs in Safe Drinking Water
Act and Clean Air Act. Requires action to be
taken to be protective.
See discussion of specific subparts below
Yes — Applicable to spent GAC canisters.
See discussion for specific subparts below.
— Yes Ground-water monitoring requirements are
relevant and appropriate to alternatives for which
contaminants will remain on site. State
counterpart of 40 CFR 264 Subpart F.
— Yes Relevant and appropriate to alternatives
involving disposal to on-site landfills. State
counterpart of 40 CFR 264 Subpart G.
— Yes Relevant and appropriate to capping of Landfills.
State counterpart of 40 CFR 264 Subpart N.
Yes — Risk based closure required if any contaminant is
left on site above background levels.
Yes — Requires a degree of pollution control for
emissions (including fugitive emissions and
fugitive dust) that is at least BACT for soil
venting, air stripping, or other projects.
-------
TABLE B-5
IDENTIFICATION OF STATE ACTION-SPECIFIC ARARs
(CONTINUED)
Department, Division
or Commission
Statute
Subject
Relevant
and
Applicable Appropriate
Remarks
Division of Air Quality,
Department of Environmental
Quality
(continued)
R307-1 -4 Utah Air Conservation Rules •
UAC Emissions Standards
Yes
State Engineer, Department of
Natural Resources
R307-10
UAC
R655-4
UAC
Emission Standards.
Standards for drilling and abandonment
of wells.
Yes
Yes
These rules establish opacity limits for visible
emissions and fugitive emissions, and fugitive
dust control (R307-1-4.5). They require controls
and/or operating procedures to minimize fugitive
dust and they require application of reasonably
available control technology (RACT) to control
VOC emissions in ozone non-attainment areas.
National Emission Standards for Hazardous Air
Pollutants (NESHAPs) are incorporated by
reference (see 40 CFR 61 Subpart A in
Table B-l). Also identified as an action-specific
ARAR (see Table B-4).
Includes such requirements as performance
standards for casing joints, requirements for
abandoning a well, etc.
-------
PUBLIC MEETING TRANSCRIPT
Appendix C
-------
OUR FILE H 54348-110 Duplicate Original
ORAL COMMENTS AT PUBLIC OPEN HOUSE
OPERABLE UNIT 3 AT HILL AIR FORCE BASE
North Davis Library, North Branch
562 South 1000 East
Clearfield, Utah
4:00 p.m. to 7:00 p.m.
Reported by SUSAN WILCOX KINGSBURY, CSR, RPR
Utah CSR License 96, California License 2758
Certified Shorthand Reporters
One Utah Center. Suite 900
. 201 South Main Street
Salt Lake City, Utah 841 1 1
(801)350-9141 (800) 222-8298 FAX (801) 572-0085
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Public Open House re Operable Unit 3 at Hill Air
Force Base held on Thursday, April 20, 1995, at
the North Davis Library, North Branch, 562 South
1000 East, Clearfield, Utah, oral comments
reported by SUSAN WILCOX KINGSBURY, Certified
Shorthand Reporter, Registered Professional
Reporter and Notary Public in and for the State
of Utah.
*****
IN ATTENDANCE:
Col. Phil Liller
Capt.. Curtis
Ms. Gwen Brewer
Mr. Muhammad Slam
Mr. Carl Anderson
Mr. David Harris
Mr. Greg Stevens
Mr. Andrew Gemperline -
Ms. Marty .Rozelle
Mr. Peter LeVon
Mr. Bob Elliott
Mr. Dave Fulton
Ms. Natalie Lewis
Mr. Edward Cassin
Other Members of the Public
KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS
SUSAN WILCOX KINGSBURY, CSR, RPR
2 ••
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15
CLEARFIELD, UTAH, THURSDAY, APRIL 20, 1995, 4:00 P.M.
MR. EDWARD CASSIN: 'I think the process that the
environmental management director has put towards the
people of Hill Air Force Base and the community around
it is one that is very productive, one that can really
disseminate the information to the expert and to the
layman. I think this personable, one-on-one atmosphere
gives us a really good vehicle that can get that
information out to our populace. And I think this
process should continue for all of the operable units
within the Hill Air Force Base.
Some concern that I have as the Hill Air
Force Base community representative would be the showing
of people. Far too many people that should be at an
16 event like this are not. And if they decided to make
17 more of a conscious effort and be more proactive about
18 some of the problems at Hill they would probably feel
19 much more welcome and much more informed by the whole
20 process.
21 If people took the time to actually try to
22 learn about some of the things and situations going on
23 at Hill it would probably lessen a lot of the myths,
24 rumors and feuds that they've had here at Hill and they
25 would make much better and much more informed decisions
KINGSBURY AND1 ASSOCIATES, CERTIFIED SHORTHAND REPORTERS
SUSAN WILCOX KINGSBURY, CSR, RPR
3
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1 about their health in the future.
2 That's about it. Thank you.
3 (Open house concluded at 7:00 p.m.)
4 * * * * *
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KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS
SUSAN WILCOX KINGSBURY, CSR, RPR
4
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STATE OF UTAH )
: ss.
COUNTY OF SALT LAKE )
I, SUSAN WILCOX KINGSBURY, C.S.R., R.P.R. and
Notary Public for the State of Utah, residing, in Salt
Lake County, certify:
1 ' "That the foregoing transcript of the Public
Open House for Operable Unit.3 at Hill Air Force Base
was prepared by me from my stenographic notes taken at
the time of the public open house therein reflected;
That the foregoing transcript contains all
oral comments for the record' given by members of the
public at time of the open house;
That only one person gave oral comments, as
reflected by the foregoing transcript;
And I hereby further certify that the
foregoing typewritten transcript as typed by me is a
full, true and correct record of my stenographic notes
so taken;
IN WITNESS WHEREOF, I have subscribed my name and
affixed my seal this_.
COX KINGSBUR^, C
KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS
SUSAN WILCOX KINGSBURY, CSR, RPR
5 "
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WRITTEN COMMENTS AND RESPONSES
Appendix D
-------
APPENDIX D
WRITTEN COMMENTS AND RESPONSES
The submittal of written comments from community members was requested at the
public open house and during the public comment period. Forms asking specific
questions regarding the open house format, the RI/FS process, and the preferred
alternatives were available at the public open house, and attendees were encouraged to
respond. The following comments were received; where appropriate, Hill AFB's
responses are also included.
D-l
-------
COMMENTS RECEIVED FROM MR. EDWARD CASSIN
(See pages following this cover page)
HILL AFB'S RESPONSE
None Required
D-2
-------
What do you think?
Hill Air Force Base Operable Unit 3 Open House April 20,1995
Thank you for attending. The purpose of today's open house is to present the preferred ~
alternatives for soil cleanup at three locations within "Operable Unit 3 " at Hill Air Force
Base and to hear your comments. We have designed this meeting to be informal. It is
arranged by topical stations with project personnel at each one. Review the boards and
handouts and ask our staff your questions. Also, be sure to complete these sheets
before you leave tonight or mail them back by May 9th to Ms. Given Brewer,
Environmental Public Affairs, OO-ALC/EM, 7274 Wardleigh Road, HillAFB,
UT 84506-5137. A court reporter is present tonight to record oral comments, if
desired. We will consider your comments as we finalize the proposed plans.
Printed name
How did you hear of today's open house?
Q Newspaper Q Public Q Proposed [pjf Word of Q Other
advertisements notice Plan mailing mouth
Do you like the way tonight's open house was organized? fpes Q no
Do you have suggstions to improve future meetings? (if yes, please describe)
Are there any other groups, companies, or individuals you feel should be sent site-
related information? (please provide names and addresses, if possible)
Name—= Name.
Address '. Address-
City, Zip Code City, Zip Code-
-------
Additional thoughts?
-------
What do you think?
Preferred Alternatives April 20,1995
Background
Using the nine criteria, several clean-up options were evaluated for the RVMF, the Sodium Hydroxide Tank Site,
and Herman Pond. The option of doing nothing, or "no action" for each site was also compared. The Mardv1995
"Proposed Plan" summarizes the preferred alternatives.
To reduce the amounts of DCE at the RVMF site, a soil vapor extraction system will be installed and used.
At the Sodium Hydroxide Tank Site, the existing asphalt cap will be maintained, construction activities will be
limited, and restrictions will be placed on the removal of the asphalt cap until clean-up objectives are met.
The preferred alternative for Berman Pond includes covering the site with a multi-media (multiple layers of clay,
dirt, and liners) cap to reduce potential exposure to the contaminated soil and to minimize water from seeping
through the soil to ground water. The integrity of this cap will be maintained. In addition, perched water from
Berman Pond will be removed to the extent possible.
Questions (use opposite side of page for writing your comments, if needed)
Overall, do the preferred alternatives meet your expectations or address your concerns?
Q^es QNo Q Not sure.
If you answered no or not sure, please explain __
How does the Berman Pond Site preferred alternative, i.e. multi-media capping and perched
water removal, meet your expectations?
(J
2 / 3 4 5
A lot. Comfortable. Not at all.
If you rated 4 or 5, please explain why. ________—'.
How does the RVMF preferred alternative, i.e. soil vapor extraction, meet your expectations?
3 4 5
A lot. Comfortable. Not at all.
If you rated 4 or 5, please explain why.
(continued on opposite side)
-------
What do you think?
Preferred Alternatives - Page 2 April 20,1995
How does the Sodium Hydroxide Site preferred alternative, Le. asphalt cap maintenance and
institutional controls, meet your expectations?
1 2 4 5
A lot Comfortable. Not at all.
If you rated 4 or 5, please explain why.
Additional thoughts?
JvU.-2^-~S aS
^
-------
COMMENTS RECEIVED FROM MR. GEORGE SCHRADER (RAB MEMBER)
(See pages following this cover page)
,s
HILL AFB'S RESPONSE
1. Herman Pond Preferred Alternative. Although contaminated soil is not physically
removed from the site, Herman Pond Alternative 2 (Cap Installation and Institutional
Controls) is considered a'permanent solution because it will be in effect for greater than
30 years. While Alternative 4 (Excavation, Off-site Disposal, and Soil Vapor Extraction)
would completely reduce or remove contaminants such that little or no long-term
management is needed, it would cost over an order of magnitude more than the selected
alternative of capping. In addition, the implementability of Alternative 4 is significantly
more difficult than the selected remedy because of the disruption to Hill AFB operations
and the administrative issues that must be addressed. Alternative 3, while being the most
questionable alternative with respect to implementability, would also require a 30-year or
longer program for cap inspection, maintenance, and repair, due to the nature of
solidifying chlorinated VOCs within a hydrocarbon/water matrix. Alternative 2 does
meet the general objective of any remedial action that is contained in the NCP; this
objective is to effectively mitigate and minimize threats to, and provide adequate
protection of, public health, welfare, and the-environment. In addition, Alternative 2
satisfies the remedial action objectives (RAOs) that were established for the site; these
objectives are to:
• Minimize human exposure to contaminated soil through ingestion, inhalation,
and dermal contact
• Minimize or prevent the migration of contaminants from the unsaturated soils
to the ground water so the MCLs can be met for ground water.
Five year site reviews are included in the preferred alternative to evaluate whether the
selected remedy is still protective of human health and the environment. If, during the
review process, the alternative is determined not to be protective of human health and the
environment, the site will be re-evaluated and appropriate actions (e.g., selection of an
alternate or additional remedial action) will be taken to solve the problem.
2. Sodium Hydroxide Tank Site Preferred Alternative. As discussed above, the
preferred alternative does meet the soil RAOs established for the site. In addition,
D-3
-------
five-year site reviews are included to evaluate whether the selected remedy is still
protective of human health and the environment. If, during the review process, the
alternative is determined not to be protective of human health and the environment, the
site will be re-evaluated and appropriate actions (e.g., selection of an alternate or
additional remedial action) will be taken to solve the problem.
D-4
-------
What do you think?
Hill Air Force Base Operable Unit 3 Open House April 20,1995
Thank you for attending. The purpose of today's open house is to present the preferred
alternatives for soil cleanup at three locations within "Operable Unit 3 " at Hill Air Force
Base and to hear your comments. We have designed this meeting to be informal. It is
arranged by topical stations with project personnel at each one. Review the boards and
handouts and ask our staff your questions. Also, be sure to complete these sheets
before you leave tonight or mail them back by May 9th to Ms. Given Brewer,
Environmental Public Affairs, OO-ALC/EM, 7274 Wardleigh Road, Hill AFB,
UT 84506-5137. A court reporter is present tonight to record oral comments, if
desired. We will consider your comments as we finalize the proposed plans.
Printed n^e
How did you hear of today's open house?
Q Newspaper Q Public Q Proposed (~| Word of
advertisements notice Plan mailing mouth -ft>
Do you like the way tonight's open house was organized? 12f yes Q no
/
Do you have suggstions to improve future meetings? (if yes, please describe)
Are there any other groups, companies, or individuals you feel should be sent site-
related information? (please provide names and addresses, if possible)
Name fad^ L^// olc/C^ Name
Address H77 >* >"< _ Address
City, Zip Code>V Qty, Zip Cod
-------
What do you think?
Preferred Alternatives April 20,1995
Background
Using the nine criteria, several clean-up options were evaluated for the RVMF, the Sodium Hydroxide Tank Site,
and Herman Pond. The option of doing nothing, or "no action" for each site was also compared. The March 1995
"Proposed Plan" summarizes the preferred alternatives.
To reduce the amounts of DCE at the RVMF site, a soil vapor extraction system will be installed and used.
At the Sodium Hydroxide Tank Site, the existing asphalt cap will be maintained, construction activities will be
limited, and restrictions will be placed on the removal of the asphalt cap until clean-up objectives are met. .
The preferred alternative for Herman Pond includes covering the site with a multi-media (multiple layers of clay,
dirt, and liners) cap to reduce potential exposure to the contaminated soil and to minimize water from seeping
through the soil to groundwater. The integrity of this cap will be maintained. In addition, perched water from
Herman Pond will be removed to the extent possible.
Questions (use opposite side of page for writing your comments, if needed)
Overall, do the preferred alternatives meet your expectations or address your concerns?
QYes JgJNo Q Not sure.
If you answered no or not sure, please explain.
,£
How does the Bennan Pond Site preferred alternative, i.e. multi-media capping and perched
water removal, meet your expectations?
1 2 3 r^) 5
A lot. Comfortable. • Not at all.
If you rated 4 or 5, please explain why. _^
How does the RVMF preferred alternative, i.e. soil vapor extraction, meet your expectations?
3 4 5
A lot Comfortable. Not at all.
If you rated 4 or 5, please explain why. _ ••
(continued on opposite side)
-------
What do you think?
Preferred Alternatives - Page 2
April 20,1995
How does the Sodium Hydroxide Site preferred alternative, Le. asphalt cap maintenance and
institutional controls, meet your expectations?
1 2 " G) 4 5
A lot Comfortable. Not at all.
If you rated 4 or 5, please explain why. —
Additional thoughts? (/' /• x
.^ t
fZ/7 ss^-, _
^^
~^7^f^^L^if^t'(y/^ •
^C, ^ZPJ/
/ ~.
-------
What do you think?
Remedial Investigation/Feasibility Study (RI/FS) April 20,1995
Background ..
The overall objective of the RI/FS at Hill Air Force Base OU-3 was to gather information necessary to determine
the nature and extent of contamination and ultimately to support a specific action for cleaning up the sites. Past
operations and waste disposal practices at these sites have resulted in releases of solvents, fuels, and industrial
wastes to the below-surface soil. ' ... . •--.••'•-.'
VOCs (for example, benzene and trichloroethylene) were the contaminants most frequently detected in the soil
at the OU-3 sites. Based on the findings of the RI and Health Risk Assessment, only the RVMF, the Sodium
Hydroxide Tank Site, and the Berman Pond need to be cleaned up. Three other sites at OU-3 were found noi to
pose a risk to human health nor the environment. Therefore, these sites will not need cleanup.
Many soil clean-up alternatives were considered. Some were rejected because they did not effectively reduce
contaminant concentrations, could not be readily implemented, or were too costly. The remaining alternatives
were compared against each other using the following criteria: overall protection of human health and the
environment; reduction of toxicity, mobility, volume; implementability; cost; compliance with applicable or
relevant and appropriate requirements; and short- and long-term effectiveness. Also, state and community
acceptance is required before the Proposed Plan is finalized. .., • " ••••:•'.:' .. . • . ''
. - ..• •' * - ' " • , .... •.. ...•••.•' .;.'. ••'•.•-, ; ••-,•'••'-• ." - —
Questions (use opposite side of page for writing your comments, if needed) ^'^H'r.-'
Do you have any "questions or concerns regarding the RI/5S study process? '. •" " - '*i^" - • '-.
'^l^^O^lt^^ ^r- . ^3 ;•;':'. /
S*l* ' • *•"_• • • ' 7y ' • ' »— iF — • •.' • , •"— S ' fc3i\ii^*'~ *• -I*'
M-~l ^^r^i^C^t^r^y s5Z<^£ ^^^rt^- ^{J>s^?>fa ' }t~*s • j&*s&^ Tff5".- '
Do you know anything else about the site or surrounding areas that you believe should be '.•*••'••• - •"'
considered? ", - . ,.-v.5v.:
' ' - • • • . " ' ' •'•••. ?•';*'£•'. '•
-------
COMMENTS RECEIVED FROM MR. JOSEPH DECARIA
(See pages following this cover page)
HILL AFB'S RESPONSE
None Required
D-5
-------
What do you think?
Hill Air Force Base Operable Unit 3 Open House April 20,1995
Thank you for attending. The purpose of today's open house is to present the preferred ~
alternatives for soil cleanup at three locations within "Operable Unit 3" at Hill Air Force
Base and to hear your comments. We have designed this meeting to be informal. It is
arranged by topical stations with project personnel at each one. Review the boards and
handouts and ask our staff your questions. Also, be sure to complete these sheets
before you leave tonight or mail them back by May 9th to Ms. Given Brewer,
Environmental Public Affairs, OO-ALC/EM, 7274 Wardleigh Road, HillAFB,
UT 84506-5137. A court reporter is present tonight to record oral comments, if
desired. We will consider your comments as we finalize the proposed plans.
Printed name (optional!; ^A? •^-P-l/H '' /&£*%f * £\
How did you hear of today's open house?
Q Newspaper Q Public Q Proposed Q Word of DjOther.
advertisements notice .Plan mailing mouth
Do you lilce the way tonight's open house was organized? P^f yes Q no
Do you have suggstions to improve future meetings? (if yes, please describe)
) Ct f(
Are there any other groups, companies, or individuals you feel should be sent site-
related information? (please provide names and addresses, if possible)
Name Name-
Address '. Address-
City, Zip Code City, Zip Code-
-------
What do you think?
Preferred Alternatives April 20,1995
Background
Using the nine criteria, several clean-up options were evaluated for the RVMF, the Sodium Hydroxide Tank Site,
and Herman Pond. The option of doing nothing, or "no action" for each site was also compared. The March 1995
"Proposed Plan" summarizes the preferred alternatives.
To reduce the amounts of DCE at the RVMF site, a soil vapor extraction system will be installed and used.
At the Sodium Hydroxide Tank Site, the existing asphalt cap will be maintained, construction activities will be
limited, and restrictions will be placed on the removal of the asphalt cap until clean-up objectives are met.
The preferred alternative for Herman Pond includes covering the site with a multi-media (multiple layers of clay,
dirt, and liners) cap to reduce potential exposure to the contaminated soil and to minimize water from seeping
through the soil to ground water. The integrity of this cap will be maintained. In addition, perched water from
Berman Pond will be removed to the extent possible.
Questions (use opposite side of page for writing your comments, if needed)
Overall, do the preferred alternatives meet your expectations or address your concerns?
Q
-------
What do you think?
Preferred Alternatives - Page 2 April 20,1995
How does the Sodium Hydroxide Site preferred alternative, Le. asphalt cap maintenance and
institutional controls, meet your expectations?
1 2 /3 J 4 5
A lot Comfortable. Not at all.
If you rated 4 or 5, please explain why.
Additional thoughts?
-------
What do you think?
Health Risk Assessment April 20,1995
Background
The purpose of the heal th risk assessment was to determine if contaminants present in soil less than 12 feet below
ground surface pose any health risks to people, plants,or animals. Currentand future health risks were evaluated
for each OU-3 site.
Because most of OU-3 sites are covered with asphalt, buildings, or vegetation, current exposure to contaminants
in near-surface soil is unlikely. If no remedial action were to occur at Herman Pond and the RVMF, there may be
some risk to construction workers who could be exposed to contaminants in soil. Likewise, if homes were ever
built at the Herman Pond and RVMF sites, future residents could be exposed to soil vapors in their basements.
There are no future health risks associated with the Sodium Hydroxide Tank Site.
The remedial alternatives have been evaluated on their ability to provide adequate protection of human health
and the environment.
Questions (use opposite side of page for writing your comments, if needed)
Do you have any questions or concerns regarding the way the risk assessment was done?
'
Do you have any questions or comments regarding the risk assessment's conclusions?
//„• ••
Do you have additional information regarding the risk assessment that you believe should be
included?
f/d
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What do you think?
Remedial Investigation/Feasibility Study (RI/FS) April 20,1995
Background
The overall objective of the RI /FS at Hill Air Force Base OU-3 was to gather information necessary to determine-
the nature and extent of contamination and ultimately to support a specific action for cleaning up the sites. Past
operations and waste disposal practices at these sites have resulted in releases of solvents, fuels, and industrial
wastes to the below-surface soil. . .'.-,- _;'..;
VOCs (for example, benzene and trichloroethylene) were the contaminants most frequently detected in the soil
at the OU-3 sites. Based on the findings of the RI and Health Risk Assessment, only the RVMF, the Sodium
Hydroxide Tank Site, and the Herman Pond need to be cleaned up. Three other sites at OU-3 were found not to
pose a risk to human health nor the environment. Therefore, these sites wfll not need cleanup. .;'; - .
Many soil clean-up alternatives were considered. Some were rejected because they did not effectively reduce
contaminant concentrations, could not be readily implemented, or were too costly. The remaining alternatives
were compared against each other using the following criteria: overall protection of human health and the
environment; reduction of toxicity, mobility, volume; implementability; cost; compliance with applicable or
relevant and appropriate requirements; and short- and long-term effectiveness. "Also, state and community
.acceptance is required before the Proposed Plan is finalized. : ' . ' • . .-.'.- :.•£•;,,
Questions (use opposite side of page for writing your comments, if needed) \;';'vjr
Do you have any questions or concerns regarding the RI/FS study process?
• . . ••
Do you have specific comments regarding the proposed clean-up recommendations?
* '•
Do you know anything else about the site or surrounding areas that you believe should be ."/.' ]
considered? /l-V*
/yd
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