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1040748-RSSDMS = 255138 0 D ' Jf- •Vr T.T* K^ Hill Air Force Base Final Record of Decision and Responsiveness Summary for Operable Unit 4 (IRP Sites LFIi, LF12, OT20, OT41, OT42) June 1994 Q D

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Page 1: Jf- •Vr K^ Hill Air Force Base Record of Decision and ...1040748-RSSDMS = 255138 0 D ' Jf- •Vr T.T* K^ Hill Air Force Base Final Record of Decision and Responsiveness Summary for

1040748-RSSDMS

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' Jf- •Vr T . T * K ^

Hill Air Force Base Final Record of Decision and Responsiveness Summary for Operable Unit 4 (IRP Sites LFIi, LF12, OT20, OT41, OT42)

June 1994

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n FINAL RECORD OF DECISION U FOR OPERABLE UNIT 4 n HILL AIR FORCE BASE, UTAH u

This is a primary document for Operable Unit 4 at Hill Air Force Base. It will be available in the Administrative Record, which is maintained at the following locations:

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Davis County Library Central Branch 155 N.Wasatch Drive Layton, Utah 84041

Hours: Mon-Thurs: 11:00am-9:00pm Fri-Sat: 11:00 am-6:00 pm

Enviromnental Management Directorate OaALC/EMR Building 5 7274 Wardleigh Road Hill AFB, Utah 84056-5137

Contact: Gwen Brewer (801) 777-8790

Submittal Date: June 30, 1994

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TABLE OF CONTENTS

DECLARATION FOR THE RECORD OF DECISION

DECISION SUMMARY FOR THE RECORD OF DECISION

1.0 SITE NAME, LOCATION, AND DESCRIPTION

2.0 SITE HISTORY AND ENFORCEMENT ACnVITIES

2.1 Site History 2.2 Enforcement Activities 2.3 Investigation History 2.4 Community Relations History 2.5 Scope and Role of Operable Unit 4 Within Site Strategy

3.0 SUMMARY OF SITE CHARACTERISTICS

3.1 Nature and Extent of Contamination 3.2 Public Health and Environmental Impacts

3.2.1. Contaminant Identification 3.2.2. Exposure Assessment 3.2.3. Toxicity Assessment 3.2.4. Risk Characterization 3.2.5. Summary of Site Risks

4.0 DESCRIPTION OF ALTERNATTVES

4.1 Development of Altematives 4.2 Detailed Analysis of Altematives

4.2.1. Ground-Water Altematives 4.2.2. Surface-Water Altematives 4.2.3. Landfill Contents Altematives 4.2.4. Air Altematives

4.3 Comparative Analysisof Altematives 4.3.1. Groundwater 4.3.2. Surface Water 4.3.3. Landfill Contents 4.3.4. Air

5.0 SELECTED REMEDY

5.1 Description of the Selected Remedy 5.1.1. Remediation Goals and Performance Standards 5.1.2. Restoration Time Frame 5.1.3. Costs

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2-1 2-2 2-2 2-2 2-3

3-1

3-1 3-2 3-2 3-2 3-6 3-6 3-9

4-1

4-1 4-6 4-6 4-8

10 •12 •13 •14 •15 16 16

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5-1 5-2 5-4 5-4

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Table of Contents n u

5.2 Statutory Determinations 5-7 5.2.1. Protection of Human Health and the Environment 5-7 5.2.2. Compliance with Applicable or Relevant and Appropriate 5-8

Requirements 5.2.3. Cost Effectiveness 5-10 5.2.4. Utilization of Permanent Solutions 5-10 5.2.5. Preference for Treatment as a Principal Element 5-11

5.3 Documentation of Significant Changes 5-11

RESPONSrVENESS SUMMARY

^ REFERENCES

1 APPENDIX A - APPLICABLE OR RELEVANT AND APPROPRL\TE

^ REQUIREMENTS

^ APPENDIX B - PUBLIC MEETING TRANSCRIPT

^ APPENDIX C - WRITTEN COMMENTS AND RESPONSES

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Table of Contents

LIST OF TABLES

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TABLE NO. TITLE PAGE

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3-1 Contaminants of Concem 3-3 3-2 Current Potential Exposure Pathways 3-4 3-3 Future Potential Exposure Pathways 3-5 3-4 Slope Factors (CPFs) 3-7 3-5 Reference Doses 3-8 3-6 Estimated Risks from Future Use of Shallow Ground Water on Base 3-10 3-7 Estimated Risks from Future Use of Ground Water in the Sunset Aquifer 3-11

4-1 Altematives for Ground-Water Remediation 4-2 4-2 Altematives for Surface-Water Remediation 4-3 4-3 Altematives For Landfill Contents Remediation 4-4 4-4 Altematives For Air Remediation 4-5

5-1 Remediation Goals for Hill AFB Operable Unit 4 5-5 5-2 Costs and Process Components For Selected Remedy 5-6

A-1 Federal Chemical-Specific ARARs A-2 Federal Location-Specific ARARs A-3 Federal Action-Specific ARARs A-4 State Chemical-Specific ARARs A-5 State Location-specific ARARs A-6 State Action-Specific ARARs

o LIST OF FIGURES

FIGURE NO. TITLE

FOLLOWING PAGE NO.

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1-1 Location Map 1-2 Site Plan

3-1 Areal Distribution of Trichloroethene (TCE) in Ground Water 3-2 Vertical Distribution of Trichloroethene (TCE) in Ground Water 3-3 Conceptual Model of Contaminant Transport

5-1 Conceptual Remedial Action Implementation Schedule

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3-1 3-1 3-1

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Hill Air Force Base, Utah Operable Unit 4

Declaration for the Recorti of Decision

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a p. Site Name and Location

L^ Operable Unit 4 Hill Air Force Base, Utah Weber and Davis Counties, Utah

Statement of Basis and Purpose

This decision document presents the remedy for Hill Air Force Base (Hill AFB) Operable Unit 4 (OU 4) in Utah. It was selected in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as amended by the Superfimd 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, the U.S. Environmental Protection Agency (EPA), and Hill AFB concur on the selected remedy.

Assessment of the Site

Actual or threatened releases of hazardous substances from this site, if not addressed by implementing the response action selected in this Record of Decision (ROD), may present an imminent and substantial endangerment to public health, welfare, or the environment.

Current risks to human health associated with the contaminants at OU 4 are well below levels considered by the EPA to be significant. Remedial action is warranted based on possible future risks to human health and the environment and because maximum contaminant levels (MCLs) are exceeded in ground water.

Description of the Selected Remedy

OU 4 is one of eight operable units at Hill AFB. The remaining operable units are at various stages in the remedial investigation/feasibility study (RI/FS) process. This action addresses contaminated ground water, surface water, and air at OU 4. This action also addresses landfill contents, which are the source of OU 4 ground-water, surface-water,

j and air contamination. The selected remedy for OU 4 addresses the threat to human health and the environment by containing and treating the source area and the

P contaminated ground water, surface water, and air.

L/ The major components of the selected remedy for Hill AFB OU 4 include:

ri • Extracting contaminated ground water using horizontal drains or vertical M wells, treating the ground water by air stripping, and discharging the treated

ground water to the local publicly-owned treatment works (POTW).

f] • Collecting surface water and treating it with carbon adsorption when a •- sufficient volume of water is produced to operate the treatment system.

y^ • Capping the contents of Landfill 1 and treating the source of contamination by \ j soil vapor extraction.

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Site Name and Location

L) operable Unit 4 Hill Air Force Base, Utah

n Weber and Davis Counties, Utah

Statement of Basis and Purpose

1 1 This decision document presents the remedy for Hill Air Force Base (Hill AFB) Operable ^ Unit 4 (OU 4) in Utah. It was 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

fl (NCP). This decision is based upon the Administrative Record for Hill AFB.

The State of Utah, the U.S. Environmental Protection Agency (EPA), and Hill AFB

concur on the selected remedy. n U Assessment of the Site ^ Actual or threatened releases of hazardous substances from this site, if not addressed by

implementing the response action selected in this Record of Decision (ROD), may present an imminent and substantial endangerment to public health, welfare, or the

Pl environment.

Current risks to human health associated with the contaminants at OU 4 are well below Cl levels considered by the EPA to be significant. Remedial action is warranted based on [J possible future risks to human health and the environment and because maximum

contaminant levels (MCLs) are exceeded in ground water.

j 1 Description of the Selected Remedy

OU 4 is one of eight operable units at Hill AFB. The remaining operable units are at n various stages in the remedial investigation/feasibility study (RI/FS) process. This action Ly addresses contaminated ground water, surface water, and air at OU 4. This action also

addresses landfill contents, which are the source of OU 4 ground-water, surface-water, n and air contamination. The selected remedy for OU 4 addresses the threat to human '—' health and the environment by containing and treating the source area and the

contaminated ground water, surface water, and air. rj [_/ The major components of the selected remedy for Hill AFB OU 4 include:

• Extracting contaminated ground water using horizontal drains or vertical I wells, treating the ground water by air stripping, and discharging the treated ^ ground water to the local publicly-owned treatment works (POTW).

n • Collecting surface water and treating it with carbon adsorption when a U sufficient volume of water is produced to operate the treatment system.

JS • Capping the contents of Landfill 1 and treating the source of contamination by soil vapor extraction.

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• Semi-annual air monitoring in the basements of residences overlying the contaminated ground water. If air contamination is detected at concentrations exceeding acceptable risk levels, the contaminated air in the affected residences will be collected and treated.

• Implementing instimtional controls and access restrictions upon completion of the construction ofthe remedial action that include: (1) water rights and well drilling restrictions and advisories to prevent exposure to contaminated ground water; (2) a continuing order from the base commander conceming landfill restrictions; (3) recording a notice to restrict exposure and maintain the integrity of the remedial action at Landfill 1; and (4) fencing with waming signs to restiict access to exposure areas, active construction, and treatment facilities. Leases or easements may be needed to enact some of these controls. Upon transfer of the property, the Air Force will provide a deed covenant notifying the transferee of the locations and the restrictions on use of the areas.

Statutory Determinations

The selected remedy is protective of human health and the environment, complies with Federal and state requirements that are legally applicable or relevant and appropriate to the remedial action, and is cost effective. This remedy utilizes permanent solutions and altemative treatment or resource recovery technologies to the maximum extent practicable, and satisfies the statutory preference for remedies that employ treatment that reduces toxicity, mobility, or volume as a principal element. Because this remedy will result in hazardous substances on-site above health-based levels, a review will be conducted within five years after signing of this ROD to ensure that the remedy continues to provide adequate protection of human health and the environment.

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ED STATES ENVIRONMENTAL PROTECTION AGENCY

-G^^/M^ liam P. Yellowtail

gional Administrator DATE

STATE OF

Dlafine R. Nielson, Ph. Executive Director

^H.i^U>c

OF ENVIRONMENTAL QUALITY

4 ?-( ^ -^f DATE /

HILL AIR FORCE BASE, UTAH

M I J U A T Al^ P. Babbitt, Deputy Assistance Secretary of the Air Force (Environment, Safety, and Occupational Health)

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D Hill Air Force Base, Utah Operable Unit 4

Decision Summary for the Record of Decision

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1.0 SITE NAME, LOCATION, AND DESCRIPTION

Hill Air Force Base (Hill AFB, Base) is located in northem Utah, about 25 miles north of Salt Lake City and about five miles south of Ogden, Utah as depicted in Figure 1-1. Hill AFB covers about 6,700 acres and is located on the Weber Delta, a terrace approximately 300 feet above the surrounding valley floors in Weber and Davis Counties. Operable Unit 4 (OU 4) is one of eight operable units under investigation at Hill AFB. OU 4 is located near the northem boundary of Hill AFB, as shown in Figure 1-1. OU 4, as depicted in Figure 1-2, consists of the North Gate Dump Area, the Spoils Pit, the Munitions Dump, and Landfills 1 and 2.

OU 4 is located on a steep, terraced, north-facing escarpment of the Weber Delta. The stratigraphy at OU 4 is heterogeneous, with ground water flowing mainly along thin sand layers found between low permeability clayey materials. OU 4 overlies three aquifers. The shallow aquifer consists of 200 feet of relatively low-yielding materials and lies within about 30 feet of ground surface. The shallow aquifer is designated as Class n -Drinking Water Quality based on the State of Utah classification criteria and the quality of ground water taken from uncontaminated wells (USGS, 1992). The Sunset and Delta Aquifers are approximately 300 and 600 feet below the OU 4 landfills, respectively. The Sunset and Delta Aquifers are used by Hill AFB and surrounding communities as domestic water supplies. The Sunset and Delta Aquifers are Class I - Irreplaceable Source of Drinking Water or Class IIA - Current Source of Drinking Water (USGS, 1992). Ground-water flow in the shallow aquifer is to the north, discharging to off-Base seeps along the north escarpment or to the floodplain deposits of the Weber River.

The Weber River and the Davis-Weber Canal are the primary surface water bodies near OU 4. The Weber River is located over 3,000 feet north of OU 4 and approximately 300 feet below the terrace where Landfills 1 and 2 are located. The Davis-Weber Canal, a privately owned irrigation canal used each year from April to October, is approximately

n 600 feet north and approximately 100 feet below Landfills 1 and 2. In the vicinity of OU (J 4, the canal flows in a northwesterly direction. Well response data presented in the final

remedial investigation (RI) report indicate that, in the past, water has infiltrated from the Pl canal to the shallow aquifer via leaks. However, portions of the canal were recently Li relined with concrete, which has decreased or eliminated infiltration from the canal and

reduced or cut off flow to some of the seeps. Results of analyses of canal water during |~] the RI indicated that the canal has not been a source of contamination, nor has it been U contaminated by chemicals from OU 4.

n The areas adjacent to OU 4 to the north and northeast include the communities of U Washington Terrace, Riverdale, and South Weber, which are comprised mainly of

moderately developed residential areas separated by large tracts of agricultural land. n Further north, the City of Ogden is a densely developed community and county ^ govemment center. The adjacent land south and west of OU 4, which is owned by Hill

AFB, includes unimproved areas and waste disposal sites. There is a sand and gravel n borrow area on the south end of OU 4 which has commercial value as a natural resource.

1-1

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EXPLANATION

Ground surface elevation contour (feet)

Dirt road

Canal, arrow denotes direction of canal flow

Source: Modified from USGS, 1992, Figure 3.4.4.1-1.

9 500

Scale in Feet

Hill AFB OU 4 ROD

HILL AIR FORCE BASE

OPERABLE UNIT 4

SITE PLAN FIGURE 1-2

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p-. According to the Hill AFB Comprehensive Plan (USAF, 1989), there are no wetlands I located on-Base in OU 4. However, the Davis-Weber canal, which is located along the

northem boundary of OU 4, is designated a wetiand according to the National Wetland Inventory (NWI) map (USFWS, 1986). The Davis-Weber Canal is not considered a jurisdictional wetiand by the U.S. Army Corps of Engineers because it has a lined bottom (GalUhugh, 1993).

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2.0 SITE HISTORY AND ENFORCEMENT ACTTVITIES

2.1 SITE HISTORY

Hill AFB has been the site of military activities since 1920 when the westem 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. Currentiy, 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.

1^ In the past, chemicals and waste products were disposed of at the Industrial Waste 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 currentiy treated at the IWTP, recycled on Base, or sent to off-Base treatment or disposal facilities.

OU 4 is comprised of Landfills 1 and 2, the Spoils Pit, the North Gate Dump Area, and the Munitions Dump. The locations of these areas within OU 4 are shown in Figure 1-2. The following sections describe the histories of the sites in OU 4.

Landfill 1. Solid wastes were dumped and bumed daily in Landfill 1 from 1955 to 1967. No records were found that indicate hazardous wastes were disposed of at Landfill 1. However, Landfill 1 is the source of TCE contamination observed in ground water and seeps at OU 4. Former Hill AFB employees reported that Landfill 1 received wastes from the Ogden Arsenal that included waste oils and solvents from the vehicle maintenance facility.

Landfill 2. Solid waste disposal took place at Landfill 2 from 1963 to 1965, where wastes were burned periodically. No records have been found indicating disposal of hazardous or industrial wastes at Landfill 2. Based on investigation results, Landfill 2 is not a source of contamination at OU 4.

Spoils Pit. Construction debris and yard waste from the Base were disposed of in the Spoils Pit from 1971 to 1987. There have been no records found that indicate that the Spoils Pit was used for disposal of hazardous or industrial wastes. Results of investigations indicate that the Spoils Pit is not a source of subsurface contamination at OU4.

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Munitions Dump. The Munitions Dump was operated as an aboveground munitions storage area during World War n. Investigations have shown that the Munitions Dump is not a source of contamination.

North Gate Dump Area. Several drums of waste solvent were reportedly dumped from trucks in the North Gate Dump Area. No dmms have been found in this area, and investigations have revealed that the North Gate Dump Area is not a source of contamination.

2.2 ENFORCEMENT ACTTVITIES

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 Utah Department of Environmental Quality (UDEQ)) and the U.S. Environmental Protection Agency (EPA). The purpose of the agreement was to estabUsh 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. An eighth operable unit has since been added. This Record of Decision (ROD) concludes all of the remedial investigation/feasibility study (RI/FS) requirements for OU 4. There have been no removal actions, remedial actions, notices of violation, or other enforcement actions taken at OU 4 prior to this ROD.

2.3 INVESTIGATION HISTORY

Landfills 1 and 2 are two of 13 potential hazardous waste sites identified in the Phase I Installation Restoration Program (IRP) investigation (ES, 1982). Results of ground-water monitoring done during the Phase II IRP investigation (Radian and SAIC, 1988) found trichloroethene (TCE) in ground water downgradient of Landfill 1. Results ofthe initial RI (USGS, 1992), which was conducted from 1987 to 1990, indicated volatile organic compounds (VOCs) and metals in ground water and seeps. The North Gate Dump Area was identified as part of OU 4 during the initial RI, the Munitions Dump was included as part of the Phase II RI investigation, and the Spoils Pit was designated as part of OU 4 under the FFA in 1991. A baseline risk assessment was developed from 1987 through 1991 as part of the RI (JMM, 1991). In 1992, an addendum to the RI was prepared (USGS, 1993), in which findings of the initial RI were confirmed and revised, the extent and quantity of the ground-water contamination were defined, and the primary source of contamination was identified. An addendum to the risk assessment (MW, 1993) was also prepared and included as part of the addendum to the RI. Results of the risk assessment and its addendum are summarized in Section 3.2.

2.4 COMMUNITY RELATIONS HISTORY

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 is revised as frequently as every six months. The community relations activities include: (1) a Technical Review

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Committee (TRC) which meets quarterly and includes community representatives from adjacent counties and towns, (2) a maihng 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 for obtaining technical assistance grants (TAGs). In addition, a public meeting was held for the communities north of the Base that are affected by OU 1, OU 2, and OU 4 on April 28,1993 to explain risk issues.

The RI Report (USGS, 1992), RI Addendum (USGS, 1993), Feasibility Stiidy Report (MW, 1993a), and the Proposed Plan for Operable Unit 4 (MW, 1993b) were released to the public, and are available in the administrative record maintained in the Davis County

n Library and at the Environmental Management Directorate at Hill AFB. The notices of i-J availability for these documents were published in the Salt Lake Tribune. A public

comment period was held from October 7, 1993 through November 5, 1993. In addition, n a public meeting was held on October 19, 1993. At this meeting, representatives from U Hill AFB, EPA, and the State of Utah answered questions about the site and the selected

remedy. A court reporter prepared a transcript of the meeting. Copies of the tianscript n and all written public comments received during the comment period have been placed 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 I comment period are included in the Responsiveness Summary, which is part of this ROD.

The decision process for this site is based on the Administrative Record.

n 2.5 SCOPE AND ROLE OF OPERABLE UNIT 4 WITHIN SITE STRATEGY

r-J OU 4 is one of eight 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 ground water, ri surface water, and air at OU 4. This action also addresses landfill contents, which are the iJ source of ground-water, surface-water, and air contamination. Risks to human health

associated with OU 4 are currently well below levels considered significant by EPA. n However, OU 4 poses a future threat to human health and the environment because of _j risks from exposure to contaminated soil gas, exposure to the source area, and exposure

to contaminants via domestic use of contaminated ground water and surface water from C seeps. The purpose of this remedy is to: prevent exposure to contaminated ground water, _> surface water, landfill contents, and air; reduce contaminant migration from the landfill

contents to ground water, surface water, and air; and reduce the volume of contaminants "} in the source area. OU 4 will be the first final response action for Hill AFB.

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r-l 3.0 SUMMARY OF SITE CHARACTERISTICS

^ 3.1 NATURE AND EXTENT OF CONTAMINATION

p) Landfill 1 is the source of contamination at OU 4 based upon data collected during the RI w (USGS, 1993). The North Gate Dump Area, Landfill 2, the Munitions Dump, and tiie

Spoils Pit are not sources of contamination. Contaminants detected at OU 4 consist of j ( the VOCs benzene, chloroform, 1,1-dichloroethene (DCE), cis and trans 1,2-DCE, ^ 1,2-dichloroethane (DCA), methyl ethyl ketone (MEK), tetrachloroethene (PCE), toluene,

TCE, and xylenes; and the metals arsenic, barium, boron, cobalt, nickel, and selenium. I VOCs were detected in ground water, surface water from seeps, and soils, and metals

were detected only in ground water. TCE is the principal contaminant at OU 4 because it p, is the only VOC consistently detected in ground water and seeps at concentrations

I exceeding its maximum contaminant level (MCL). Benzene and DCE were detected at concentrations slightly above their MCLs. Metals were identified at concentrations

p-j above background levels in various wells, but occurrences above MCLs are sporadic, 1 j localized, and within the TCE plume. The metals that were found at concentrations

above MCLs are arsenic, nickel, and selenium. TCE was detected at concentrations pT above its MCL in three seeps. There has been no contamination detected in the Davis-U Weber Canal.

r—. The areal and vertical limits of the TCE contamination in ground water at OU 4 are M shown in Figures 3-1 and 3-2. These limits, which are defined by the "non-detect"

isoconcentration contours, were determined from the analytical results of soil, soil gas, r l and ground water samples. The area of contaminated ground water is approximately 69 J) acres. As shown in Figure 3-2, the contamination is located in the upper 25 feet of the

shallow aquifer. Primary ground-water movement is lateral, and the vertical contaminant n profile indicates that contaminants have not migrated into the deeper aquifers. The U volume of contaminated ground water is approximately 200 million gallons. The volume

of landfill contents is approximately 140,000 cubic yards, based on a landfill area of n 150,000 square feet and a landfill depth of 25 feet.

A conceptual model of contaminant tiansport mechanisms at OU 4 is presented as Figure p , 3-3. The VOCs at OU 4 are soluble in water and volatilize into air; therefore, they are U quite mobile and likely to be transported via ground water and air. The metals detected at

OU 4 have very low volatility and are not mobile via air. Arsenic, barium, nickel, and n selenium form ionic compounds which are mobile in water. Boron and cobalt are less U soluble and less mobile in water. Potential routes of contaminant migration, as indicated

in Figure 3-3, include infiltration of contaminated ground water from the landfill contents n to underlying soil and shallow on-Base ground water; volatilization from landfill contents U and soil to on-Base air; migration of contaminated on-Base shallow ground water to deep

ground water, shallow off-Base ground water, and seeps; transport of surface mnoff from n the landfill to the Davis-Weber Canal; and volatilization from seeps and shallow ground cl water to off-Base air. The population and environmental areas that could be affected, if

exposed, include Hill AFB personnel, off-Base residents north of OU 4, future on-Base [ ( residents, and on- and off-Base plants and animals.

3-1

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I I

0 ^ ^ ^ 500

Scale in Feet

' ^ - < -EXPLANATION

® Monitoring well

• Private or public well

• " ^ S e e p

o Test hiole

D Canal sampling site

• Surface soil sampling site

• Location of existing residences tiO Non-detect

General direction of ground-water movement

Dirt road

— Trichloroethiene Isoconcen­tration contour line (ug/L))

—- Canal, arrow denotes direction of canal flow)

Source: Modified from USGS, 1992; figure 4.7.2.1-3. Contour plan based on the maximum TCE concentrations reported in each well between 1986 and 1992.

^ Hill AFB OU 4 ROD

HILL AIR FORCE BASE

OPERABLE UNIT 4

AREAL DISTRIBUTION OF TRICHLOROETHENE (TCE) IN GROUND WATER

FIGURE 3-1

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A LANDFILL 1 Hill Air Force Base Private Property

4700-

4600-

> O

1-LU LU

$ 4 5 0 0 -

4 4 0 0 -

>-cc § z o CQ

Lu|

ol P

LF1T-1

(4,185)

, Seeps during June tiirough 'December during most years

before the canal was relined

EXPLANATION

Zone of contamination

Monitoring well and number (4,185) - maximum concentration of trichloroethene during 1986 to 1992 time period as determined by laboratory analysis (In micrograms per liter)

Screened Interval

Profile of potentiometric surface

Gravel

Clay, silty clay, and clayey silt with fine sand stringers

Not Detected

A'

1-4700

- 4 6 0 0

Note; Extent of contaminated ground water versus depth was not fully delined with multi-level wells along this cross section. The detection of 7.5 fig/l TCE In well U4-36 was a result of cross contamination during dnillng.

Scale in Feet

Vertical Exaggeration x 4

LOCATION OF CROSS-SECTION SHOWN ON FIGURE 3-1

LU LLI

< > UJ

-4500

- 4 4 0 0

Source: /Modified from USGS, 1992; Figure 4.7.2.1- 5 and USGS 1993; Figure ES-6.

Hill AFB OU 4 ROD

HILL AIR FORCE BASE OPERABLE UNIT 4

VERTICAL DISTRIBUTION OF TRICHLOROETHENE (TCE) IN GROUND WATER

CROSS-SECTION A-A' FIGURE 3-2

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AAf %! AIR (ON-BASE)

LANDFILL 1

VOCs

Note1

LANDFILL 2

Note1

SPOILS PIT

Note 1

MUNITIONS DUMP

Note 1

AIR (ON-BASE)

EXPLANATION

J 1

Predominant Pathway

Minor Unllt<ely Pathway Pathway (not thought to occur

based on available data)

Soil Gas, Volatilization

Predominant Pathway

Soil Gas, Volatilization

Minor Pathway

•s Soil Gas,

Volatilization Unlikely Pathway

SOIUUNSATURATED ZONE

VOCs (TCE)

SHALLOW GROUND WATER (ON-BASE)

^Airf, .3ce /?0i loif DAVIS-WEBER CANAL

(OFF-BASE)

No Contaminants Detected

AIR (OFF-BASE)

VOCs (TCE)

f DEEP GROUND WATER (ON-BASE)

t

AIR (OFF-BASE RESIDENTS)

AIR (OFF-BASE)

SEEPS (OFF-BASE)

VOCs (TCE)

Notes:

1. Recent data collection and analysis indicate that Landfill 1 is the likely source of TCE contamination. Data collected from Landfill 2, the Spoils Pit, the Munitions Dump, and downgradient from Landfill 1 indicate no additional sources of contamination.

2. Contaminant discharges to Weber River floodplain deposits are subject to dilution. Elevated TCE concentrations have not been detected northeast of South Weber Drive.

SHALLOW GROUND WATER

(OFF-BASE)

VOCs (TCE)

SHALLOW GROUND WATER (OFF-BASE FLOODPLAIN)

NOTE 2

^

Hill AFB OU 4 ROD

DEEPER AQUIFERS (OFF-BASE)

HILL AIR FORCE BASE OPERABLE UNIT 4

CONCEPTUAL MODEL OF CONTAMINANT TRANSPORT FIGURE 3-3 J

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u 3.2 PUBLIC HEALTH AND ENVIRONMENTAL IMPACTS

^ A Baseline Risk Assessment (JMM, 1991) was prepared for OU 4 as part of the RI/FS. ^ The purpose of the risk assessment was to identify the contaminants of concem present at

f OU 4, the current and future exposure pathways for humans and environmental receptors, and the probability of the occurrence of harmful effects resulting from current and fiiture

Pl exposures. Based on the data collected and the risk assessment results, the media of \ concem are shallow ground water and soil gas. The primary contaminant of concem for

each of these media is TCE. TCE is the primary contaminant of concem because it is the pi most prevalent contaminant at the site and it contributes most to the risks. The risks Ip associated with exposure to metals were also evaluated in the risk assessment. The

current risks to human health due to OU 4 contamination are well below levels C considered significant by EPA. Future risks to human health and the environment _J include: (1) exposure to contaminated soil gas, and (2) exposure during domestic use of

contaminated ground water and surface water. Figure 3-1 presents the location of n residences in the immediate area of the TCE contamination.

3.2.1. Contaminant Identification

I The initial step of the risk assessment was selecting the contaminants of concem, which are toxic substances that have the potential to come in contact with environmental

p . receptors. Contaminants of concem were chosen for each medium of concem based upon j l frequencies of detection, concentrations, and toxicities for the relevant exposure

pathways. The VOCs for ground water and surface water are considered contaminants of pj concem via ingestion, inhalation, and dermal absorption during domestic use. Soil gas Ip contaminants affect human health via the inhalation exposure route. Metals detected in

ground water above MCLs and background levels are considered contaminants of C concem by ingestion during domestic use of ground water and surface water. The LJ contaminants of concem for OU 4, the media of concem, and the concentrations of

contaminants upon which the risk assessment was based are listed in Table 3-1.

(J Acute exposure to high concentiations of VOCs in air results in toxic affects. Chronic exposure to VOCs can affect the central nervous system, liver, kidneys, bone marrow,

p ; blood, and/or hematological system. Benzene is a proven human carcinogen; chloroform, U 1,2-DCA, PCE, and TCE are probable human carcinogens based on evidence of

carcinogenicity in animals; and 1,1-DCE is a possible human carcinogen. Acute and n chronic exposure to arsenic by ingestion may cause severe toxic effects. Barium, boron, Li cobalt, nickel, and selenium may produce toxic effects via acute and chronic exposure.

Arsenic is a proven human carcinogen.

n 3.2.2. Exposure Assessment

An exposure assessment was performed to identify current and future potential exposure pathways through which contaminants of concem could travel to environmental receptors. Current and future potential exposure pathways, media of concem, and environmental receptors are presented in Tables 3-2 and 3-3. Inhalation of VOCs from contaminated soil gas in off-Base residential basements is a significant current potential exposure route. Future potential exposure routes that are significant include: inhalation

3-2

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n TABLE 3-1

CONTAMINANTS OF CONCERN

Environmental Media

Contaminant of Concern

Concentration Used in Risk Assessment(^)

Ground Water

n u

n Surface Water (Seeps)

Indoor Air

Benzene Chloroform 1,2-Dichloroethane 1,1 -Dichloroethene Total 1,2-Dichloroethene Methyl Ethyl Ketone Tetrachloroethene Toluene Trichloroethene Xylenes Arsenic Barium Boron Nickel Selenium

Chloroform Total 1,2-Dichloroethene Trichloroethene

Trichloroethene

53 9.2 3.3 1.4 130 77 1.2 39

13,000 7.5 65

620 1,800 2,100

53

12 9.3 216

4.1 ng/m-

(a) The value for trichloroethene in ground water is the upper 95 percent confidence limit for the average concentration of five wells in the area of highest contaminant concentrations. AU other values are the maximum concentrations detected for the compounds. All values are in |j.g/I unless otherwise indicated.

3-3

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C 3 c i D c i : j c i ^ [ Z 3 C Z 3 L r ^ C D C i j C 3 c : D c i 3 c : D C 3 c : i ] c r 3 C 3 cu

TABLE 3-2

CURRENT POTENTIAL EXPOSURE PATHWAYS

Environmental Medium

Potential Receptors Potential Exposure Routes Potentially Significant Pathway?

GROUND WATER

Shallow Aquifer

Sunset Aquifer

Delta Aquifer

Nearby residents, base personnel

Nearby residents

Nearby residents, base personnel

Nearby residents, base personnel

Nearby residents, base personnel

Nearby residents.

SURFACE WATER

Davis-Weber Canal Nearby residents

Seeps

SOIL GAS

Nearby residents

Nearby residents

Nearby residents, base personnel

Nearby residents, base personnel

Ingestion, inhalation, and dennal contact with potable water.

Consumption of produce irrigated with water from the shallow aquifer, consumption of beef or dairy products fiom cattle that drink this water, consumption of beef or dairy products firom cattle consuming forage that was irrigated with this water.

Ingestion, inhalation, and dermal contact with potable water.

Consumption of produce irrigated with water from this aquifer, consumption of beef or c^ry products from cattle that drink this water, consumption of beef or dairy products fix)m cattle consuming forage that was irrigated with this water.

Ingestion, inhalation, and dermal contact with potable water.

Consumption of produce irrigated with water from this aquifer, consumption of beef or dairy products from cattie that drink this water, consumption of beef or dairy products from cattle consuming forage that was irrigated with this water.

Consumption of produce irrigated with water from the canal, consumption of beef or dairy products from cattle that drink this water, consumption of beef or dairy products from cattle consuming forage which was irrigated with this water.

Direct contact with water or inhalation of contaminants volatilizing from seeps.

Consumption of produce irrigated with water from seeps, consumption of beef or dairy products from cattle that drink this water, consumption of beef or dairy products from cattle consuming forage which was irrigated with this water.

Diffusion upward to surface followed by dispersion toward houses or base buildings, where it is inhaled.

Diffiision upward, adsorption of volatiles to surface soil, ingestion ofsoil.

No. Based on a survey conducted as part of this RI, the shallow aquifer is not used for these purposes.

No. Based on a survey conducted as part of this RI, there are no private or municipal wells completed in the shallow aquifer.

No. Wells in the Sunset Aquifer are not contaminated.

No. Wells in the Sunset Aquifer are not contaminated.

No. Wells in the Delta Aquifer are not contaminated.

No. Wells in the Delta Aquifer are not contaminated.

Residents of Cutler Diffusion of soil gas through the soil and foundation into the basement, house Volatiles are inhaled.

No. Canal is not contaminated.

No. People not known to spend significant amounts of time near seeps. No. Crops and animals do not significantly accumulate VOCs. Concentrations of VOCs in seeps are low. Metals are at background levels in seeps.

Yes.

Nearby residents - yes. Base personnel - no. Area on Hill AFB which is contaminated is not near a normal woric area and receives little use.

No. Air monitoring did not detect any VOCs associated with OU 4. However, additional monitoring needs to be performed to validate this conclusion.

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CIAa:ACAIC[ZAA(ZJCD(Z2CUC3CCJ CAJ CD CIA AAU CD AAO CD

TABLE 3-3

FUTURE POTENTUL EXPOSURE PATHWAYS

Environmental Medium

Potential Receptors Potential Exposure Routes Potentially Significant Pathway?

GROUND WATER

Shallow Aquifer Future on-base residents, base personnel

Nearby residents

Nearby residents, future on-base residents

Nearby residents, future on-base residents, base personnel

Nearby residents, future on-base residents

Davis-Weber Canal Nearby residents, future on-base residents

Sunset Aquifer

Seeps

Weber River

SOIL GAS

Nearby residents

Nearby residents

Nearby residents

Future on-base residents

Nearby residents, future on-base residents, base personnel

Ingestion, inhalation, and dermal contact with potable water in currently contaminated area.

Ingestion, inhalation, and dermal contact with potable water that has migrated north.

Consumption of crops, beef, or dairy products from crops or cattle exposed to currently contaminated water, contaminants in water which have migrated north, or forage exposed to this water.

Ingestion, inhalation, and dermal contact with contaminated water which has migrated to the Sunset Aquifer.

Consumption of crops, beef, or dairy products from crops or cattle exposed to contaminated water which has migrated to the Sunset Aquifer, or forage exposed to this water.

Groundwater level rises, canal water becomes mixed with contaminated water, water is used for irrigation, crops and forage are consumed.

Direct contact with water or inhalation of contaminants volatilizing from seeps.

Seeps increase in contaminant concentrations as contaminants migrate north. Consumption of crops, beef, or dairy products from crops or cattle exposed to this water, or forage exposed to this water.

Contaminants migrate into the river. River water is used for domestic purposes and exposed fish are consumed.

Diffusion of VOCs upward to surface foUowed by inhalation of contaminants outside.

Inhalation from soil gas diffusing into basements and into the air, ingestion of contaminated soil.

Future on-base residents - yes. Base personnel - no. Base has a stable supply of water from the Delta Aquifer.

Yes.

Yes-metals. No-VOCs. Crops and cattle do not significantly accumulate VOCs.

Yes.

No. Crops and cattle do not significantly accumulate VOCs. Metals concentrations will not be distinguishable from background levels in this aquifer.

No. VOCs are not significantly absorbed; canal water would greatly dilute the contaminant concentrations.

No. Seeps are too small to wade in. Other activities that would lead to significant exposure are unlikely, because there are no features about the seeps that make it likely that people would spend long periods of time near them.

No. VOCs are not significantly accumulated. Metals have not been detected in seeps above background levels, and do not form an identifiable plume in ground water that would migrate coherently.

No. Available evidence indicates that the shallow aquifer beneath OU 4 does not extend to the Weber River.

Yes.

Yes. However, modeling difficulties prevent quantifying the potential exposure from these pathways.

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of VOCs in contaminated soil gas in residential basements; inhalation of VOCs during excavation of contaminated landfill materials; ingestion, inhalation and dermal absorption of VOCs during the domestic use of shallow ground water; and ingestion and dermal absorption of metals during the domestic use of shallow ground water. The scenario of future domestic use of shallow ground water assumes that the future land use at Hill AFB includes building houses in the vicinity of OU 4, that the houses will have untreated domestic water supplied from wells that tap the shallow aquifer, and that untreated ground water extracted from the shallow aquifer will contain TCE concentrations comparable to those observed in the most contaminated portion of the aquifer. The "reasonable maximum exposure" was estimated for each exposure pathway to identify conservative values within the ranges for possible exposures. Exposure concentrations due to inhalation of contaminated air were estimated based upon measured soil gas concentrations. 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 (JMM, 1991) and its addendum (MW, 1993).

3.2.3. 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. Cancer potency factors 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 non­carcinogenic 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 and RfDs for the contaminants of concem at OU 4 are presented in Tables 3-4 and 3-5. The most toxic compound present at OU 4 is TCE. TCE is the most prevalent contaminant of concem, and it poses both carcinogenic and noncarcinogenic health risks. Contaminant toxicity is discussed in detail in the Baseline Risk Assessment (JMM, 1991) and its addendum (MW, 1993).

3.2.4. Risk Characterization

Carcinogenic and noncarcinogenic risks were calculated for each of the exposure pathways for the potential contaminants of concem and compared to acceptable levels of risk. For carcinogenic exposures, an excess lifetime cancer risk of 1 x 10'" 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"^ and the maximum limit for excess lifetime cancer risk is 1 X 10"4. For noncarcinogenic exposures, a total hazard index greater than one is considered to be an unacceptable risk.

The incremental cancer risks for current exposures due to inhalation of TCE in outdoor air are 2 X 10"^ for an on-Base worker and 6 x 10"^ for an off-Base resident, assuming

3-6

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cu cc ac cc CD CD CDCDCDCDCDCDCDCDCDCDCUID

TABLE 3-4

SLOPE FACTORS (CPFs)

OJ

Compound

Benzene

Chloroform

1,1-Dichloroethene

1,2-Dichloroethane

cis-1,2-Dichloroethene

trans-1,2-Dichloroethene

Methyl Ethyl Ketone

Tetrachloroethene

Toluene

Trichloroethene

Xylenes

Arsenic

Barium

Cobalt

Boron

Nickel

Selenium

Maximum Detected Ground-Water Concentration

(lig/L)

61

12

1.4

3.3

6.4

270

120

1.2

67

18,000

7.5

94

620

1,800

40

2,100

53

Ingestion SF (mg/kg/day)-l

2.9 X 10-2

6.1 x 10-3

6.0x10-1

9.1 X 10-2

NA

NA

NA

5.1 X 10-2(a)

NA

1.1 X 10-2(3>

NA

1.75 xloO

NA

NA

NA

NA

NA

Ingestion Weight

of Evidence

A

32

C

B2

D

NA

D

B2(a)

D

B2(a)

D

A

NA

NA

NA

NA

D

Source

IRIS

IRIS

IRIS

IRIS

IRIS

IRIS

IRIS

HEAST

IRIS

HEAST

IRIS

IRIS

IRIS

-

IRIS

IRIS

IRIS

Inhalation SF

(mg/kg/day)-l

2.9 X 10-2

8.1 X 10-2

1.8xl0-l(b)

9.1 X 10-2

NA

NA

NA

1.8xl0-3(a)

NA

1.7xl0-2(«)

NA

1.5 X lOl

NA

NA

NA

NA

NA

Inhalation Weight of Evidence

A

B2

C

B2

D

NA

D

B2(a)

D

B2(a)

D

A

NA

NA

NA

NA

D

Source

IRIS

IRIS

IRIS

IRIS

IRIS

IRIS

IRIS

HEAST

IRIS

HEAST

IRIS

IRIS

IRIS

~

IRIS

IRIS

IRIS

NA No information or data were available IRIS Integrated Risk Information System, searched March and July, 1993 HEAST Health Effects Assessment Summary Tables, 1992

Not listed in HEAST or IRIS

(a) This infonnation was withdrawn lirom the 1992 HEAST Tables. (b) Revision since the Baseline Risk Assessment was issued.

A Known human carcinogen B2 Probable human carcinogen C Possible human carcinogen D Not classified in terms of carcinogenicity

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CD CD CD CD CUCDCDCDCDCDCDCDCDCDCDCDCDC

I 00

Compound

Benzene

Chloroform

1,1-Dichloroethene

1,2-Dichloroethane

1,2-Dichloroethene (trans)

1,2-Dichloroethene (cis)

Methyl Ethyl Ketone

Tetrachloroethene

Toluene

Trichloroethene

Xylenes

Arsenic

Barium

Boron

Cobalt

Nickel

Selenium

TABLE 3-5

REFERENCE DOSES

Chronic Oral Reference Dose

(mg/kg/day)

NA

1 X 10-2

9 X 10-3

NA

2 X 10-2

1 X 10-2

6x10-1

1 X 10-2

2x10-1

7 X 10-3

2 x l 0 0

3 X 10-4

7 X 10-2

9 X 10-2

NA

2 X 10-2

0.005

Uncertainty Factor

NA

1000

1000

NA

1000

1000

3000

1000

1000

NA

100

3

3

100

NA

300

3

Source

IRIS

IRIS

IRIS

IRIS

IRIS

HEAST

IRIS

IRIS

IRIS

LHA

IRIS

IRIS

IRIS

IRIS

~

IRIS

IRIS

Chronic Inhalation

Reference Dose (mg/kg/day)

1 X 10-3

2x10-3

5 X 10-3

NA

NA

NA

2.9 X 10-1

NA

1.1x10-1

NA

9 X 10-2

NA

NA

NA

NA

NA

NA

Uncertainty Factor

NA

NA

NA

NA

NA

NA

1000

NA

100

NA

100

NA

NA

NA

NA

NA

NA

Source

P

P

P

IRIS

IRIS

IRIS

IRIS

IRIS

HEAST

NA

IRIS

IRIS

IRIS

IRIS

~

IRIS

IRIS

NA No information or data were available LHA Lifetime Health Advisory IRIS Integrated Risk Information System,

searched March and July 1993

HEAST Health Effects Assessment Summary Tables, 1992 P Proposed RfD, Hazardous Pollutant Assessment Branch,

Environmental Criteria and Assessment Office, EPA Not Listed in HEAST or IRIS

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receptors for both scenarios are exposed for 30 years out of a 70-year lifetime. The cancer risk due to inhalation of outdoor air by residents was estimated to equal 2 x 10"^. Hazard indices for these scenarios were not calculated because no accepted inhalation RfD for TCE exists. There are no significant risks associated with the current exposure pathways, which are inhalation of TCE from soil gas and ingestion of TCE in surface soil. This applies to on- and off-Base receptors.

For future on-Base use of the shallow ground water for drinking and showering, the total hazard index is estimated at 50, and the total lifetime excess cancer risk is estimated at 7 X 10"3. For future off-Base use of shallow ground water and surface water for drinking and showering, the hazard index was estimated at 6, and the excess carcinogenic risk is estimated at 1 x 10 "3. The risks associated with future use of shallow ground water for domestic purposes are significant. The risks associated with future use of ground water from the Sunset Aquifer for drinking and showering are well below levels considered significant by EPA. Future risks for domestic use of shallow ground water on Base and for domestic use of ground water from the Sunset Aquifer are included in Tables 3-6 and 3-7.

A qualitative evaluation of risks to ecological receptors indicates low or insignificant risks, so a quantitative ecological assessment was not performed. The only significant exposure pathway for animals is through consumption of water in seeps in the low agricultural areas off-Base below the slopes along the northeast boundary of OU 4. The contaminants of concem for surface water are TCE, chloroform, and DCE. Risks to domestic animals and wildlife due to exposure to VOCs in surface water are expected to be low or insignificant. The low bioaccumulation potential and high volatility of the VOCs indicate that exposures to animals would be low. Due to the volatility of the VOCs, concentiations in seeps will not be sufficient to affect crops or vegetation. Seeps which contain contaminants do not flow to waters containing fish; there is no exposure patiiway.

No critical habitats have been identified in the vicinity of OU 4. No threatened or endangered animal or plant species inhabit the area, although there is a diverse population of birds. The area may be within the hunting range of threatened raptors such as the bald eagle and peregrine falcon, which have been sighted near OU 4. However, the area is likely to be only a small portion of their entire hunting range. The quantity of TCE ingested by these birds will not be sufficient for bioaccumulation.

3.2.5. Summary of Site Risks

The decision to remediate the site is based upon possible future risks to human health and the environment and because remedial action is warranted when MCLs are exceeded. Future potential risks from OU 4 contamination include inhalation of VOCs in contaminated soil gas which may enter off-Base residential basements, inhalation of VOCs by workers excavating contaminated landfill contents, inhalation of VOCs during showering with contaminated ground water and surface water, and ingestion of contaminants while using contaminated ground water and surface water as a drinking water source.

3-9

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TABLE 3-6

ESTIMATED RISKS FROM FUTURE USE OF SHALLOW GROUND WATER ON BASE

CARCINOGENIC RISKS

I I—. o

Contaminant

Benzene

Chloroform

1,2-Dichloroethane

1,1-Dichloroethene

Tetrachloroethene

Trichloroethene

Oral Slope Factor

0.029

0.0061

0.091

0.6

0.051

0.011

Total Cancer Risk for Aquifei

Ingestion Lifetime Average

Dose

7.6x10-4

1.3x10-4

4.7 X 10-5

2.0 X 10-5

1.7x10-5

1.3x10-1

Cancer Risk

2x10-5

8x10-7

4 X 10-6

1 X 10-5

9x10-7

1 X 10-3

1 X 10-3

Inhalation Slope Factor

0.029

0.081

0.091

1.2

0.0018

0.017

Inhalation Lifedme Average

Dose

2.3 X 10-3

3.4x10-4

1.2x10-4

5.7 X 10-5

4.0x10-5

3.2x10-1

Cancer Risk

7 X 10-5

3x10-5

1 X 10-5

7 X 10-5

7x10-8

5 X 10-3

6 X 10-3

Dermal Lifetime Average

Dose

7.9x10-7

1.4x10-7

4.9 X 10-8

2.1 X 10-8

1.8x10-8

1.3x10-4

Cancer Risk

2x10-8

8x10-10

4 X 10-9

1 X 10-8

9x10-10

1 X 10-6

2 X 10-6

Total Cancer Risk

9x 10-5

3 X 10-5

I X 10-5

8x10-5

1 X 10-6

6 X 10-3

7 X 10-3

HAZARD INDICES

Contaminant

Benzene

Chloroform

1,2-Dichloroethane

1,1-Dichloroethene

1,2-Dichloroethene

Methyl Ethyl Ketone

Tetrachloroethene

Toluene

Trichloroethene

Xylenes

Barium

Boron

Nickel

Total Hazard Indc

Oral Reference

Dose

NA

0.01

NA

0.009

0.01

0.05

0.01

0.2

0.007

2

0.05

0.09

Ingestion Chronic

Daily Dose

1.8x10-3

3.1 X 10-4

1.1 X 10-4

4.7 X 10-5

4.3 X 10-3

2.6 X 10-3

4.0 X 10-5

1.3x10-3

3.0x10-1

2.5 X 10-4

1.4 X 10-2

6.0x10-2

0.02 7.0 X 10-2

X for Aquifer

Hazard Index(a)

NA

0.03

NA

0.005

0.4

0.05

0.004

0.007

40

0.0001

0.3

0.7

4

50

Inhalation Reference

Dose

0.001

0.002

NA

0.005

NA

0.09

NA

0.6

NA

0.09

NV

NV

NV

Inhalation Chronic

Daily Dose

5.3 X 10-3

8.0x10-4

2.9 X 10-4

1.3x10-4

1.2x10-2

3.7 X 10-3

9.2 X 10-5

3.7 X 10-3

7.5 X 10-1

6.8 X 10-4

NV

NV

NV

Hazard Index(a)

5

0.4

NA

0.03

NA

0.04

NA

0.006

NA

0.008

NV

NV

NV

6

Dermal Chronic

Daily Dose

1.8x10-6

3.2 X 10-7

1.1 X 10-7

4.8 X 10-8

4.4 X 10-6

2.7x10-6

4.2 X 10-8

1.4 X 10-6

3.1 X 10-4

2.6 X 10-7

1.5 X 10-5

6.2 X 10-5

7.3 X 10-5

Hazard Index(a)

NA

3 X 10-5

NA

5 X 10-6

4 X 10-4

5 X 10-5

4 X 10-6

7 X 10-6

4x10-2

1x10-7

3 X 10-4

7 X 10-4

4 X 10-3

0.05

Total Hazard Index(a)

5

0.4

NA

0.04

0.4

0.09

0.004

0.01

40

0.008

0.3

0.7

4

50

(a) Values for individual contaminants are hazard quotients. The sum of the hazard quotients is the hazard index. NA Value not applicable because no reference dose is available. NV Contaminant is not volatile. Inhalation route is not applicable.

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CDDDCDCDCDCDCDCD CDCDCDCDCDCDCDCDCDCD

TABLE 3-7

ESTIMATED RISKS FROM FUTURE USE OF GROUND WATER IN THE SUNSET AQUIFER

CARCINOGENIC RISKS

OJ

Contaminant

Benzene

Chloroform

1,2-Dichloroethane

1,1-Dichloroethene

Tetrachloroethene

Trichloroethene

Total Cancer Risk

Oral Slope Factor

0.029

0.0061

0.091

0.6

0.051

0.011

i for Aquif<

Ingestion Lifetime Average

Dose

7.6x10-9

1.3x10-9

4.7 X 10-10

2.0x10-10

1.7x10-10

1.3 x 10-6

jr

Cancer Risk

2x10-10

8x10-12

4x10-11

1 X 10-10

9x10-12

1 X 10-8

1 x 10-8

Inhalation Slope Factor

0.029

0.081

0.091

1.2

0.0018

0.017

Inhalation Lifetime Average

Dose

2.3 X 10-8

3.4 X 10-9

1.2x10-9

5.7x10-10

4.0 X 10-10

3.2x10-6

Cancer Risk

7x10-10

3x10-10

1 X 10-10

7x10-10

7x10-13

5x10-8

6x10-8

Dermal Lifetime Average

Dose

7.9x10-12

1.4 X 10-12

4.9x10-13

2.1 X 10-13

1.8 X 10-13

1.3x10-9

Cancer Risk

2x10-13

8x10-15

4x10-14

1 X 10-13

9x10-15

1x10-11

2x10-11

Total Cancer

Risk

9x10-10

3 X 10-10

1 X 10-10

8x10-10

1x10-11

6x10-8

7 X 10-8

HAZARD INDICES

Contaminant

Benzene Chloroform 1,2-Dichloroethane 1,1-Dichloroethene 1,2-Dichloroethene Methyl Ethyl Ketone Tetrachloroethene Toluene Trichloroethene Xylenes Barium Boron Nickel

Total Hazard Ind(

Oral Reference

Dose

NA 0.01 NA 0.009 0.01 0.05 0.01 0.2 0.007 2 0.05 0.09 0.02

ex for Aqui

Ingestion Chronic

Daily Dose

1.8 X 10-8 3.1 X 10-9 1.1 X 10-9 4.7 X 10-10 4.3x10-8 2.6 X 10-8 4.0x10-10 1.3x10-8 3.0 X 10-6 2.5 X 10-9 1.4x10-7 6.0 X 10-7 7.0 X 10-7

fer

Hazard Index(a)

NA 3 X 10-7

NA 5 X 10-8 4 X 10-6 5 X 10-7 4 X 10-8 7 X 10-8 4 X 10-4 1 X 10-9 3 X 10-6 7x10-6 4 X 10-5

5 X 10-4

Inhalation Reference

Dose

0.001 0.002 NA

0.005 NA

0.09 NA

0.6 NA

0.09 NV NV NV

Inhalation Chronic

Daily Dose

5.3x10-8 8.0x10-9 2.9x10-9 1.3x10-9 1.2x10-7 3.7 X 10-8 9.2x10-10 3.7x10-8 7.5 X 10-6 6.8 X 10-9

NV NV NV

Hazard Index(»)

5 x 10-5 4 X 10-6

NA 3 X 10-7

NA 4 X 10-7

NA 6 X 10-8

NA 8 X 10-8

NV NV NV

6 X 10-5

Dermal Chronic

Daily Dose

1.8x10-11 3.2x10-12 1.1x10-12 4.8x10-13 4.4x10-11 2.7x10-11 4.2x10-13 1.4x10-11 3.1 X 10-9 2.6x10-12 1.5x10-10 6.2x10-10 7.3 X 10-10

Hazard Index(a)

NA 3x10-10

NA 5x10-11 4x 10-9 5x10-10 4x10-11 7x 10-11 4 x 10-7 1 X 10-12 3 X 10-9 7 X 10-9 4 X 10-8

5x10-7

Total Hazard Index(a)

5 X 10-5 4x10-6

NA 4 X 10-7 4x 10-6 9x 10-7 4x10-8 1 X 10-7 4x10-4 8x10-8 3x10-6 7 X 10-6 4x10-5

5 X 10-4

(a) Value for individual contaminants are hazard quotients. The sum of the hazard quotients is the hazard index. NA Value not applicable because no reference dose is available. NV Contaminant is not volatile. Inhalation route is not applicable.

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n u r-| Results of the risk assessment indicate that human health risks associated with

contamination present at OU 4 are currently below levels considered significant by EPA. There is currently a potential that contaminated soil gas may enter residential basements

fp near OU 4. However, TCE was not detected at concentrations exceeding acceptable risk 'C levels in air samples taken from the residences located above the contaminated ground

water. Shallow ground water and seeps have TCE concentrations in excess of the MCL, n but these are not used as drinking water sources. Shallow ground-water contamination i_J has not affected the deeper aquifers. There are no current risks associated with exposure

to ground water from the deeper aquifers.

C Risks to vegetation, domestic animals, and wildlife due to exposure to VOCs in surface water are expected to be low to insignificant. This is attributed to the volatility of the

n compounds and the low potential for bioaccumulation. No critical habitats exist in the U vicinity of OU 4. No threatened or endangered plant or animal species inhabit OU 4.

The bald eagle and peregrine falcon may use part of the area for hunting, but exposures n are likely to be insignificant.

Actual or threatened releases of hazardous substances from this site, if not addressed by \ implementing the response action selected in this ROD, may present an imminent and ^ substantial endangerment to public health, welfare, or the environment.

n Current risks to human health associated with the contaminants at OU 4 are well below levels considered by EPA to be significant. Remedial action is warranted based on possible future risks to human health and the environment and because MCLs are exceeded in ground water.

3-12

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r

r 4.0 DESCRIPTION OF ALTERNATIVES

As part of the Feasibility Study (FS) for OU 4 (MW, 1993a), medium-specific remedial altematives were developed for ground water, surface water, landfill contents, and air to meet the remedial action objectives. Five altematives were developed for ground water, five for surface water, five for landfill contents, and three for air. The only contaminated soils which require remediation will be addressed as part of the landfill contents. Altematives were assembled on a medium-specific basis to allow for flexibility in selecting a site-specific remedy. 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 altematives for each medium were evaluated for short-term effectiveness, long-term effectiveness and permanence, reduction of toxicity, mobility or volume through tteatment, technical and administrative implementability, and cost effectiveness. Alternatives were then compared against these criteria for selecting the recommended remediation measures. Additionally, state and community acceptance were also considered. This section summarizes how the remedy selection process for OU 4 addressed these requirements.

4.1 DEVELOPMENT OF ALTERNATIVES

Remedial altematives were developed by assembling technologies into combinations that are applicable for each medium. The steps that were used to develop remedial altematives for OU 4 included development of response objectives, remedial action objectives, and general response actions for each medium, followed by a preliminary screening and evaluation of technologies and process options. Response objectives include prevention of human exposure to contaminated media, protection of uncontaminated ground water and surface water for current and future use, restoration of contaminated ground water for future use, and prevention of cross-contamination of media. Remedial action objectives were developed to define the extent of remediation. These include preliminary cleanup goals, areas of attainment, and estimated restoration time frames. General response actions for each medium 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 evaluation process used are presented in the FS (MW, 1993a).

The altematives assembled for each medium begin with the no action altemative, which is required by the NCP to be included in the comparison process. Subsequent altematives represent an increasing degree of technical complexity. Each altemative contains different processes and degrees of remediation for ground water, surface water, landfill contents, and air. The altematives assembled for each medium are presented in Tables 4-1 though 4-4.

4-1

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TABLE 4-1

ALTERNATIVES FOR GROUND-WATER REMEDIATION

n

n

Remedial Alternatives

General Response Action

Institutional 1 Controls

Collection

Direct Treatment

In-Situ

Discharge

Technology Type

Access Restrictions

Extraction/ Drainage

Subsurface Barriers

Physical/ Chemical

Physical/ Chemical

Surface Discharge

Process Option(s)

Well Use Advis»ies.Well Drilling

Water Rights Restrictions

Drilled Wells/Drains

In^eraieableWalls

On-Site Treatment (Ail Stripping)

On-Site Treatment (Oxidation)

On-Site Treatment (Reductive (Dehalogcnation

Weber River or POTW

Ground-Water Altemative 1

No Action

Ground-Water Ahemative 2

Limited Action

Ground-Water Ahemative 3

Collection/ , On-Site

Treatment using Air stripping/ Discharge

Ground-Water Alternative 4

Collection/ On-Site

Treatment using

Oxidation/ Discharge

Ground-Water Altemative 5

Collection/ On-Site 1

Treatment using Reductive/ 1

Debalogenation

1

1

VJ

All altematives include ground-water monitoring

u

4-2

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TABLE 4-2

ALTERNATIVES FOR SURFACE-WATER REMEDUTION

n C

U

U

n u

Remedial Altematives

General Response

Action

Institutional Controls

Collection

Treatment

Discharge

Technology Type

Access Restrictions

Surface Controls

Physical/ Chemical

Treatment in Conjunction With Ground-Water Altnnatives

Surface

Discharge in Conjunction With Ground-Water Alternatives

Process Option(s)

Fencing, Easements, Leases

Diversion/ Collection

Carbon Adsorption

Reductive Debalogenation

Sec Ground-Water Remediation Alternatives (Table 4-1)

Infiltration Trenches

See Ground-Water Remediation Alternatives (Table 4-1)

Surface-Water

Altemative 1

No Action

Surface-Water

Altemative 2

Lhnited Action

Suiface-Water Alternative

3

Collection/ Treatment

Ushig GAC Adsorption/ Discharge

Surface-Water Alternative

4

Collection/ Treatment

Using Reductive

Debalogenation /Disdtaarge

SurCace-Water Alternative

5

CoUection/Treat-mcnt/Discharge in Conjunction With Ground-

Water Altematives

Each option includes surface-water monitoring.

u

u

u

• 4-3

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TABLE 4-3

ALTERNATIVES FOR LANDFILL CONTENTS REMEDIATION

Remedial Altematives

General Response

Action

Institutional Controls

Containment

In-Situ Treatment

Removal

Disposal

Technology Type

Access Restrictions

Surface Controls

Cap

Physical

Excavation

Off-Site

Process Option(s)

Fencing, £j£ascal

Future Land Use Restrictions and Notice to Deed

Grading and Revegetation

Clay or Multi-Media

Vs^r Extraction

Backhoe/Front End Loader

RCRA Subtitle C Landfill

Landfill Contents

Alternative 1

No Action

Landfill Contents

Altemative 2

Limited Action

LandfiU Contents

Altemative 3

Containment

Landfill Contents

Altemative 4

In-Situ Treatment

Landfill Contents

Altemative 5

Excavation/ Disposal

4-4

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n

LJ

TABLE 4-4

ALTERNATIVES FOR AIR REMEDLM10N

LJ

General Response

Action

Institutional Controls

Collection

Treatment

Technology Type

Monitoring

Access Restrictions

Foundation Vratilaiion

Physical

Process Option(s)

Air Monitoring

Land Acquisition

Active Pipe and/or Trench Vents

Carbon Adsorption

Air Alternative

1

No Action

Air Altemative

2

Limited Action

Air Alternative

3

Collection/ With or Witiiout

Treatment

. (1 )

(1) If required by air emission regulations, air collected from foundation would be treated using carbon adsorption.

V_J

n

u

4-5

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4.2 DETAILED ANALYSIS OF ALTERNATFVES

During the detailed analysis for OU 4, each altemative was assessed against nine evaluation criteria developed by the EPA to compare the relative performance of the altematives and to identify the advantages and disadvantages of each. This approach was designed to provide sufficient information to adequately compare the altematives, select an appropriate site remedy, and satisfy CERCLA remedy selection requirements. The detailed analysis of altematives included fiirther definition of the volumes or areas of contaminated media to be addressed, the technologies to be used, and the performance requirements associated with those technologies. Also included was an assessment and summary profile of each altemative, and a comparative analysis among the altematives.

4.2.1. Ground-Water Alternatives

The following altematives address remediation of contaminated shallow ground water. The area of attainment for ground water is 69 acres, and the volume of contaminated ground water is approximately 200 million gallons. The chemical-specific ARARs that are currently exceeded in the shallow ground water are the drinking water MCLs for TCE, DCE, benzene, arsenic, nickel, and selenium; these are the cleanup goals for shallow ground water. Currentiy, the risk to human health and the environment due to exposure to contaminated shallow ground water does not exceed the target of 1 x 10'6. However, if a future well was installed in the contaminated part of the shallow aquifer for domestic purposes, the excess lifetime cancer risk to an individual would be 7 x 10"3 for on-Base shallow ground water and 1 x 10" for off-Base shallow ground water, and the hazard index would be 50 on-Base and 6 off-Base.

Ground-Water Altemative 1 - No Action

This altemative would involve implementing a ground-water quality monitoring program. Ground-water altemative 1 would not reduce the risk associated with future exposiu-e to shallow ground water. Under the no action altemative, the concentrations of ground­water contaminants would be expected to decline by natural attenuation. The time frame required for natural attenuation would be greater than 160 years. Implementation of this altemative would involve: obtaining leases and/or easements to install monitoring wells and to collect samples on private properties; collecting ground-water samples quarterly; analyzing the samples for VOCs, metals, and other selected parameters; performing quality assurance reviews on the data; compiling and reporting findings; and performing an overall data review every five years. The total capital cost for this altemative is $6,000. Operation and maintenance costs are $38,000 per year and $48,000 every fifth year. Based on a 30-year monitoring period, the total present worth cost of ground-water altemative 1 is $648,600.

Ground-Water Altemative 2 - Limited Action

A ground-water quality monitoring program as described for ground-water altemative 1 would be implemented along with the following institutional controls: (1) restricting water rights and well drilling, and issuing well use advisories, and (2) obtaining

4-6

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easements and/or leases on properties where monitoring is required. Short-term access restrictions, such as fencing to prevent access to constmction areas or tteatment system equipment, will also be used as needed. Ground-water altemative 2 would reduce the risk associated with future exposure to shallow ground water because the institutional conttols would prevent domestic use of contaminated ground water. The concenttations of ground-water contaminants would be expected to decline by natural attenuation, provided the source is removed or contained. The restoration time frame would be greater than 160 years. The total capital cost for this alternative is $231,500. Operation and maintenance costs are $42,300 per year and $52,300 every fifth year. The total present worth for the limited action altemative for ground water for a 30-year period is $943,500.

Ground-Water Alternative 3 - Collection/On-Site Treatment Using Air Stripping/ Discharge

Contaminated ground water would be exttacted using horizontal dredns or vertical wells. The ground water would be tteated by air stripping and discharged to the Weber River or to the local publicly-owned tteatment works (POTW); Air emissions would be tteated to meet state emission requirements, and metals pretreatment would be performed as necessary to meet discharge requirements. Institutional conttols as described in ground­water altemative 2 would be enacted, and ground-water quality would be monitored as described in altemative 1. Ground-water alternative 3 would reduce the risk to human health and the environment by removing contaminants from the ground water and reducing the potential for future exposure. Ground-water exttaction will cause flushing of the aquifer, resulting in dilution and dispersion of the metals. Since the concentrations of metals in the aquifer are slightiy above MCLs, ground-water exttaction is expected to reduce metals concentrations in the aquifer to below the remediation goals. Ground­water altemative 3 would reduce excess cancer risk and the hazard index to below 10"" and to less than 1, respectively. The restoration time frame for this alternative is estimated to be greater than 30 years. This alternative would provide hydraulic containment, which would prevent further migration of contaminated ground water. The total capital cost for this alternative is $1,829,800 for discharge to the POTW and $1,909,400 for discharge to the Weber River. The operation and maintenance costs are $164,800 per year and $174,800 every fifth year for discharge to the POTW, and $154,800 per year and $164,800 every fifth year for discharge to the Weber River. The total present worth for ground-water alternative 3 under a 30-year term is $4,437,200 for discharge to the Weber River and $4,519,100 for discharge to the local POTW.

Ground-Water Alternative 4 - Collection/On-Site Treatment Using Oxidation/ Discharge

Ground-water altemative 4 would be similar to ground-water altemative 3, except that the on-site treatment facility would consist of an ultraviolet (UV) oxidation reactor. Institutional conttols as described in ground-water altemative 2 would be enacted, and ground-water quality would be monitored as described in altemative 1. Ground-water extraction will cause flushing of the aquifer, resulting in dilution and dispersion of the metals. Since the concentrations of metals in the aquifer are slightly above MCLs,

4-7

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ground-water extraction is expected to reduce metals concentrations in the aquifer to below the remediation goals. Metals pretreatment would be performed as necessary to meet discharge requirements. This altemative would reduce the risk to human health and the environment by removing contaminants from the ground water and reducing the potential for fumre exposure. Implementation of ground-water altemative 4 would reduce the excess cancer risk to less than 10"^ and the hazard index to less than one. The time frame for ground-water restoration is estimated greater than 30 years. Ground-water altemative 4 would provide hydraulic containment. The total capital cost for this altemative is $1,838,300 for discharge to tiie POTW and $1,917,900 for discharge to the Weber River. The operation and maintenance costs are $143,450 per year and $153,450 every fifth year for discharge to the POTW, and $133,450 per year and $143,450 every fifth year for discharge to the Weber River. The total present worth cost associated with implementation of ground-water altemative 4 under a 30-year term is $4,101,100 for discharge to tiie Weber River and $4,182,900 for discharge to the local POTW.

Ground-Water Altemative 5 - Metal-Enhanced Reductive Debalogenation Funnel and Gate Svstem

Under ground-water altemative 5, contaminated ground water would be tteated in-situ by using funnels of impermeable walls to direct ground water through reductive debalogenation cells emplaced in the aquifer. The reductive debalogenation cells would contain iron filings that would degrade halogenated aliphatic compounds. Additional monitoring wells would be necessary to evaluate system performance. Institutional conttols would be enacted, and ground-water quality would be monitored as in ground­water altematives 3 and 4. Ground-water alternative 5 would reduce the risk to human health and the environment by removing ground-water contaminants and preventing fumre exposure. A tteatability study would be necessary to evaluate the effectiveness of reductive debalogenation technology. If results of the treatability study are positive, implementation of this altemative would reduce the cancer risk to less than 10"" and the hazard index to less than one. The time frame for restoring shallow ground water using altemative 5 is estimated at 160 years. This altemative would provide containment of contaminated ground water. The total capital cost for this altemative is $3,963,000. The operation and maintenance costs are $43,000 per year, $68,000 every second year, and $148,000 every fifth year. The total present worth cost for ground-water altemative 5 under a 30-year term is $5,081,000. A tteatability study is necessary to refine this cost estimate.

4.2.2. Surface-Water Alternatives

The following altematives address remediation of contaminated surface water in seeps at OU 4. The risk to human health due to exposure to contaminated surface water is currently below levels considered significant by EPA. However, there may be risks to environmental receptors from exposure to OU 4 surface water. There are also future risks to human health if the seeps are used for domestic purposes. The chemical-specific ARARs identified for surface water are the drinking water MCLs. The MCL for TCE is currently exceeded in surface water samples. Because of the hydraulic connection

4-8

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between ground water and surface water, the restoration time for all surface water I altematives is the same as that for the ground-water altemative chosen.

n

Surface-Water Altemative 1 - No Action

Under surface-water altemative I, a surface water quality monitoring program would be implemented. This program involves collecting surface water samples quarterly; analyzing the samples for VOCs, and other selected parameters; reviewing the data for quality assurance; compiling and reporting the data; and performing a data review every

p five years. This altemative would provide no means of reducing or eliminating the risk J associated with exposure to contaminated seeps. The total capital cost for this altemative

is $0. The operation and maintenance costs are $10,600 per year and $20,600 every fifth n year. The total present worth cost of surface-water altemative 1 is $200,300.

Surface-Water Alternative 2 - Limited Action n LJ Surface-water altemative 2 would involve implementing a surface-water quality

monitoring program as described for altemative I and enacting the following institutional n conttols: (1) water use advisories, and water rights restrictions for contaminated surface

water; (2) obtaining easements and/or leases on properties where monitoring is required; and (3) fencing seeps which provide sufficient flow for consumption by humans and livestock. Institutional conttols implemented under this altemative would reduce risk by preventing access and direct contact with contaminated surface water. The total capital cost for this altemative is $25,400. The operation and maintenance costs are $13,000 per year and $23,000 every fifth year. The total present worth cost of surface-water altemative 2 for a 30-year period is $264,400.

LJ

n J

u

Surface-Water Altemative 3 - Collection/Treatment Using Carbon Adsorption/ Discbarge

Surface-water altemative 3 would involve collecting surface water at each contaminated seep and treating with granular activated carbon to remove organic compounds. The treated effluent would be discharged using infiltration trenches. Surface water monitoring as described for altemative 1 would continue, and institutional conttols as described for altemative 2 would be enacted. Surface-water altemative 3 would reduce risk because it involves removal of contaminants from surface water. The total capital cost for this altemative is $46,700. The operation and maintenance costs are $14,960 per year and $24,960 every fifth year. The total present worth cost for surface-water altemative 3 over 30 years is $317,400.

Surface-Water Altemative 4 - Collection/Treatment Using Reductive Dehalogenation/Discharge

This altemative would be similar to surface-water altemative 3, except the surface water would be tteated using reductive debalogenation canisters. A tteatability study would be necessary to evaluate the effectiveness of the technology. Surface-water monitoring as described for altemative 1 would continue, and institutional controls as described for

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alternative 2 would be enacted. Surface-water altemative 4 would reduce risk by removing and desttoying the contaminants dissolved in collected siuface water. The total capital cost for this altemative is $57,900. The operation and maintenance costs are $16,050 per year and $26,050 every fifth year. The total present worth cost for surface-water altemative 4 for a 30-year period is $346,200.

Surface-Water Alternative 5 - Collection/Treatment/Discharge in Conjunction with Ground-Water Altemative

Under surface-water altemative 5, contaminated surface water would be collected, jJ tteated, and discharged in accordance with the tteatment altemative selected for ground

water. This altemative would include collecting and ttansporting surface water to the ground-water tteatment system, and perfonning surface water monitoring and enacting institutional conttols as described in altematives 1 and 2. Surface-water alternative 5 would reduce risk by tteatment and destmction of the surface water contaminants. The total capital cost for this altemative is $86,300. The operation and maintenance costs are $18,400 per year and $28,400 every fifth year. The total present worth cost of surface-water altemative 5 over 30 years is $412,500.

4.2.3. Landnil Contents Altematives

The following altematives address remediation of contaminated landfill contents. Landfill contents include the landfill materials and contaminated soils associated with Landfill 1. The area of attainment for landfill contents is approximately 150,000 square feet, and the volume of landfill contents is approximately 140,000 cubic yards. The risk to human health and the environment due to exposure to landfill contents is currently below levels considered significant by EPA. However, the landfill contents are the source of ground-water contamination at OU 4.

Landfill Contents Altemative 1 - No Action

Landfills contents altemative 1 would involve no action. The no action altemative does not reduce risk to human health and the environment because it does not prevent leaching of contaminants to underlying ground water. This altemative would involve no capital or operation and maintenance costs. The total present worth cost of this altemative is $0.

Landfill Contents Altemative 2 - Limited Action

Landfill contents altemative 2 would enact institutional conttols that restrict access at Landfill 1. The purpose of these restrictions is to limit direct exposure to landfill contents and contaminated soils and to protect the integrity of the remedial action. Deed resttiction should prevent subsurface development (excavation) and excessive vehicular ttaffic. Implementing institutional conttols would include:

• A continuing order of the Base Commander requiring implementation of the landfill resttictions as long as the property is owned by Hill AFB.

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a • Upon completion of constraction at Landfill 1, the Air Force will file notice of these resttictions in the real property records of the county(ies) in which the

p landfill is located. Upon ttansfer of the property, the Air Force will provide a M deed covenant notifying the ttansferee of the locations and the restrictions on

use of the areas.

[J • Fencing the landfill area with waming signs for the duration of the remedial action.

n Ll Additional deed restrictions may be required for effective implementation of other

technologies. Use of the ground water in the area of Landfill 1 as a drinking water soittce n would be restricted as described in the ground water altemative. Limited action would Ll not reduce risk because the potential for contamination of underlying ground water by

landfill leachate would not be eliminated. The total capital cost for this altemative is n $43,400, and the annual operation and maintenance cost is $3,040. The total present Li worth cost of implementing the limited action altemative for landfill contents for a 30-

year period is $92,500. D Landfill Contents Altemative 3 - Containment

Under landfill contents altemative 3, a clay or multi-media cap would be placed over the ^ landfill to limit infiltration and reduce the leaching of contaminants from the landfill

contents into the underlying ground water. Soil overlying the landfill cap would be ( graded and revegetated to further reduce the potential for infilttation and to control

mnoff. Land use and access within the capped area would be limited by implementing p institutional conttols as described under landfill contents altemative 2. The containment

altemative would limit direct exposure to hazardous wastes and contaminated soils in the landfill, and it would reduce the potential for contamination of underlying ground water.

p Therefore, landfill contents altemative 3 would reduce risk to human health and the IJ environment. The total capital cost for this altemative is $1,181,000 for a clay cap and

$1,286,000 for a multi-media cap. The annual operation and maintenance costs are p $65,100 for a clay cap and $70,800 for a multi-media cap. The total present worth cost U for landfill contents altemative 3 for 30 years of operation is $2,231,800 for a clay

landfill cap and $2,428,800 for a multi-media landfill cap.

n J Landfill Contents Altemative 4 - Containment and In-Situ Treatment

n Under landfill contents alternative 4, the containment options described for landfill U contents altemative 3 would be implemented. In addition, a vapor extraction system

would be installed to remediate VOCs in Landfill 1. This altemative includes installation n of air emission conttol equipment and enactment of the institutional conttols described in L-' landfill contents altemative 2. Containment and in-situ treatment of landfill contents

would reduce risk to human health and the environment. Direct exposure to hazardous wastes and contaminated soils in the landfill would be limited, and the tteatment method

- would reduce the concentrations of VOCs. Additionally, the potential for further contamination of underlying ground water would be reduced. The total capital cost for

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this altemative is $1,520,000 for a clay cap and $1,626,000 for a multi-media cap. The annual operation and maintenance costs are $181,970 for years 1 through 5 and $83,365 for years 6 through 29 for a clay cap. The annual operation and maintenance costs are $187,640 for years 1 through 5 and $89,035 for years 6 through 29 for a multi-media cap. The total present worth cost for landfill contents altemative 4 for a 30-year period is $3,391,100 for a clay landfill cap and $3,588,600 for a multi-media landfill cap.

Landfill Contents Altemative 5 - Excavation and Disposal of Landfill Contents

Under landfill contents altemative 5, the contents of Landfill 1 would be excavated and disposed of at an off-Base RCRA Subtitie C hazardous waste landfill. Landfill contents altemative 5 would remove the landfill contents as a potential source of ground-water contamination. Treatment of the excavated material may be required prior to disposal. This altemative would reduce risk to human health and the environment. The total capital cost for this altemative is $47,150,000 witiiout tteatment and $90,620,000 with tteatment. There are no operation and maintenance costs associated With this altemative. The total present worth cost of landfill contents altemative 5 over a one-year remediation period is $47,150,000. If treatment by incineration or soil washing of the landfill contents is required prior to disposal, the total present worth cost is $90,620,000.

4.2.4. Air Altematives

The following altematives address remediation of contaminated air. The area of attainment for air is the residences located above the contaminated ground water. The risk to human health and the environment due to exposure to contaminated air is well below levels EPA considers significant. Results of air sampling in residences in the vicinity of OU 4 indicated that contaminant levels are less than those that would pose risk according to EPA. However, there are potential risks associated with air contamination if the ground-water contamination continues to migrate. Implementation of ground-water alternatives 3 or 4 would prevent further migration of contaminated ground water, which would reduce risks associated with potential exposure to contaminants in air.

Air Altemative 1 - No Action

Air altemative 1 would involve semi-annual air monitoring in the basements of residences located above the ground-water contamination. Implementation of this altemative would require obtaining leases and easements required to perform monitoring, collecting and analyzing air samples, perfonning quality assurance reviews on the data, and compiling and reporting the data. This altemative would not reduce risk or contaminant levels. The no action altemative involves no capital costs. Operation and maintenance costs are $10,000 per year for years 1 through 10 and $12,000 per year for years 11 through 30. The total present worth cost of the no action altemative for a 30-year term is $176,200.

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The limited action altemative for air would involve purchasing or leasing residences overlying the ground-water plume and building restrictions on property over the plume. This altemative would reduce risk by preventing potential exposure to contaminated air. The total capital cost for this altemative is $220,000. The operation and maintenance

p cost is $0. The total present wortii cost is $220,000.

Air Altemative 3 - Collection/With or Without Treatment

p Air altemative 3 would involve instalhng foundation ventilation systems around homes containing concenttations of vapors from the underlying ground-water contamination that

n exceed acceptable risk levels. The systems would consist of ttenches excavated along L) foundation walls and backfilled with permeable material and/or perforated vent pipes

with exhaust fans to purge infilttating air from the system. The purged air would be p] tteated by carbon, as necessary, to meet state emission requirements. An air monitoring LI program would be included to measure the effectiveness of the system. This altemative

would reduce risk to human health and the environment because contaminated air would be prevented from entering residences, and the exposure pathway would be eliminated. The total capital cost for this altemative is $4,500. The operation and maintenance cost is $10,750 per year for years 1 through 10 and $12,750 per year for years 11 through 30. The total present wortii cost for this altemative for 30 years of operation is $192,900.

4.3 COMPARATTVE ANALYSIS OF ALTERNATIVES

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0 Alternatives for each of the four media were compared to assess the relative advantages and disadvantages among the altematives and to identify key ttadeoffs that were balanced in selecting an altemative for each medium. Because the selected altematives for the four media were combined to form one complete site-specific remedy, it was necessary to

p consider interactions and interdependencies among the different media and duplicate I actions among the treatment technologies when comparing the altematives. The

prefened altemative was developed based upon the following comparisons, considering p the expected results of the combination of altematives from each set. The altematives L were compared with respect to nine evaluation criteria that have been developed under

CERCLA to address the technical and policy considerations associated with selecting among the remedial altematives. The evaluation criteria are described below.

U Threshold Criteria

Threshold criteria include overall protection of human health and the environment and compliance with Applicable or Relevant and Appropriate Requirements (ARARs). These threshold criteria must be met by an altemative before it can be evaluated under the five balancing criteria.

1. Overall Protection of Human Health and tbe Environment describes whether the altemative as a whole achieves and maintains adequate protection of human health and the environment.

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n \ 2. Compliance with ARARs describes whether the altemative complies with

ARARs, or, if a waiver is required, how it is justified. Other information from p advisories, criteria, and the guidance "to be considered" is also addressed.

Balancing Criteria

U The five balancing criteria form the basis of the comparative analysis because they allow ttadeoffs among the altematives requiring different degrees of performance.

J 3. Long-Term Effectiveness and Permanence refers to the abiUty of an altemative to provide reliable protection of human health and the environment over the long

n term.

4. Reduction of Mobility, Toxicity, and Volume Through Treatment refers to the ^ preference for treatment technologies that meet this criteria.

5. Short-Term Effectiveness examines the effectiveness of alternatives in n protecting human health and the environment during the construction and L-! implementation of a remedy and until the response objectives have been met.

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6. Implementability evaluates the technical and administtative feasibility of the altematives 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 altemative. Costs are estimated and expected to provide an accuracy of plus 50 percent to minus 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 altematives equally protective of human health and the environment.

Modifving Criteria

The modifying criteria described below are generally addressed in response to comments from the State and the public, after the issuance of the ROD.

8. State Acceptance indicates the preferences of the UDEQ among or concems about altematives.

9. Community Acceptance reflects the community's preferences among or concems about the altematives.

4.3.1. Groundwater

With the exception of ground-water altemative 1, all of the ground-water altematives would be protective of human health and the environment. Ground-water altematives 3, 4, and 5 would comply with ARARs. However, the restoration time frames for these

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alternatives may exceed 30 years. Ground-water altematives 3, 4, and 5 would substantially reduce the level of ground-water contamination and provide containment of the contaminated ground water. When implemented in conjunction with institutional conttols, ground-water altematives 3,4, and 5 would provide overall protection of human health and the environment. Ground-water altematives 3, 4, and 5 also would reduce contaminant mobility. Ground-water altematives 1 and 2 would not achieve long-term effectiveness, nor would they reduce mobility, toxicity, and volume through tteatment.

None of the altematives for ground water would present any short-term risks to the public. Implementation of ground-water altematives 3,4, and 5 would present short-term risks to workers constmcting, operating, and monitoring the tteatment equipment. These risks would be minimized by following appropriate worker health and safety measures. Ground-water alternatives 3, 4, and 5 may cause the following physical effects on the environment: direct vegetation loss, nunor habitat destraction, and some wildlife disturbances. These physical effects will be minimized by restoring the cleared areas to as close as their previous condition as practicable and maintaining the areas to prevent manifestation of noxious weeds. Habitat destraction and wildlife disturbances would be temporary and would not adversely affect population distribution or abundance. All the altematives are technically feasible.

Ground-water altematives 3,4, and 5 were comparable with respect to the five balancing criteria. Ground-water altemative 5 was rated fair with respect to implementability due to the innovative nature of the technology. Given the -I-50/-30 percent accuracy in the cost estimates, the cost differential between altematives 3 and 4 was considered insignificant. Ground-water altematives 4 and 5 would require treatability studies to refine cost estimates and process requirements. Ground-water altemative 3 was chosen because it utilizes a treatment technology that has been proven and successfully implemented in removing TCE from ground water. The State of Utah agrees with the altemative selected. The community has not raised any significant concems related to the proposed altemative. Therefore, the selected altemative is acceptable to the community.

4.3.2. Surface Water

Except for surface-water altemative I, all of the surface-water altematives would be protective of human health and the environment. The no action altemative for surface water would not be protective of the environment. Surface-water altematives 3 and 4 would comply with ARARs, and they would achieve long-term effectiveness and permanence. Surface-water altemative 5 would comply with ARARs and achieve long-term effectiveness and permanence to the extent that these criteria are met by the ground­water altemative chosen. Surface-water alternatives 1 and 2 would not comply with ARARs, nor would they achieve long-term effectiveness and permanence. Contaminant mobility, toxicity and volume would be reduced through tteatment under surface-water altematives 3,4, and 5.

None of the altematives present any short-term risks to the public. Implementation of surface-water alternatives 3, 4, and 5 would pose short-term risks to workers constmcting, operating, and monitoring the tteatment equipment. These risks would be

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minimized by following appropriate health and safety requirements. All of the surface-n water altematives are technically and administtatively implementable, although surface-

water altemative 4 would require a tteatability study. U

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Alternatives 3, 4, and 5 were comparable with respect to the balancing criteria. Altemative 4 would require a treatability study. Surface-water altemative 3 was chosen because it is the least expensive of the three. The State of Utah agrees with the altemative selected. The community has not raised any significant concems related to the proposed altemative. Therefore, the selected altemative is acceptable to the community.

4.3.3. Landfill Contents

Landfill contents altematives 3, 4, and 5 would be protective of human health and the environment, would comply with ARARs, and would provide long-term effectiveness and permanence. Landfill contents altematives 4 and 5 provide the most protection of human health and the environment. Landfill contents alternatives 3, 4, and 5 would supplement the ground-water altemative chosen by removing the source of ground-water contamination. Only landfill contents altemative 4, which involves in-situ tteatment, would reduce contaminant mobility, toxicity, and volume through treatment. Landfill contents altematives 3 and 5 would reduce mobility of the contaminants, although no tteatment would be performed.

No short-term risks to the public would be associated with landfill contents altematives 1, 2, 3, and 4. However, alternatives 3 and 4 would pose short-term risks to workers constracting and maintaining the systems. These risks would be minimized by using appropriate health and safety procedures. Landfill contents altemative 5 would present short-term risks associated with excavation activities and transportation of the waste through the sunounding communities. All five landfill contents alternatives are technically and administtatively implementable.

Landfill contents altemative 3 would reduce mobility and toxicity, but would not involve treatment. Landfill contents altemative 5 may cause short-term risks associated with excavation, and it is over 10 times the cost of altemative 4. Landfill altemative 4 was chosen because it would offer reduction of mobility, toxicity, and volume through in-situ tteatment, pose no short-term risks, and its cost would be relatively reasonable. The State of Utah agrees with the alternative selected. The community has not raised any significant concerns related to the proposed alternative. Therefore, the selected altemative is acceptable to the community.

4.3.4. Air

The air altematives were compared based on a future scenario in which concenttations of contaminants in air in residential basements exceed acceptable risk levels. If air concentrations conesponding to unacceptable risk levels are measured in residences in the future and are attributable to OU 4 contamination, air altematives 2 and 3 would be protective of human health and the environment. AU three air altematives would comply with ARARs. Air altemative 3 would reduce mobility and volume of contanunants

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tiirough tteatment. None of the air altematives would present any short-term risks to the ^ I public. Air altematives 1 and 3 are technically and administtatively implementable.

Implementation of alternative 3 would pose short-term risks to workers installing and operating treatment equipment. These risks would be minimized by following health and safety procedures. In the event that air contamination levels remain at cunent non-detectable levels, all three air altematives would provide long-term effectiveness and permanence.

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Air altematives 1, 2, and 3 were considered protective under cunent conditions. No ARARs have been identified in association with these altematives. Air altematives 2 and 3 would provide more benefits for comparable cost than altemative I, but they were considered conservative based on the fact that no air contamination above risk levels has been detected in the residences above the contaminated ground water. Air altemative 1 was chosen because it would be the least expensive choice, and it would detect air contamination in residences. Air altemative 3 would be implemented in the future, if results of air monitoring indicate that concentrations of VOCs in residences exceed acceptable risk levels due to OU 4 contamination. The State of Utah agrees with the altemative selected. The community has not raised any significant concems related to the proposed altemative. Therefore, the selected altemative is acceptable to the community.

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5.0 SELECTED REMEDY

5.1 DESCRIPTION OF THE SELECTED REMEDY

The selected remedy at Hill AFB Operable Unit 4 is a combination of ground-water alternative 3, surface-water altemative 3, landfill contents altemative 4, and air altemative 1. Surface-water altemative 3 will be implemented when a sufficient volume of water is generated from the seeps to operate the surface water tteatment system. If contaminant concenttations in the air in residences overlying the contaminated ground water exceed acceptable risk levels due to OU 4 contamination, air altemative 3 will be initiated.

Under the selected remedy for OU 4, contaminants in all four media will be addressed. Contaminated shallow ground water will be exttacted, collected, tteated on site using air stripping, and discharged to the local POTW. The surface water at each seep location will be collected locally and tteated using carbon adsorption when a sufficient volume is produced to operate the treatment system. Treated surface water will be discharged through infilttation trenches. The contents of Landfill 1 will be contained using a landfill cap and tteated using vapor extraction. The landfill cap will limit infiltration and leaching of contaminants to underlying ground water. Air emissions from the soil vapor extraction system will be tteated if emissions exceed regulatory limits. Air will be addressed with the no action altemative, which includes semi-annual air monitoring in the basements of residences overlying the contaminated ground water. Institutional controls would be dependent in certain instances on cooperation of property owners and municipalities or other govemmental entities, and satisfaction of legal requirements.

According to ground-water altemative 3, contaminated ground water will be extracted and directed to an air stripping tteatment facility. The emissions from the air stripper system will be tteated, as necessary, to meet state emissions limits. The tteated ground water will be discharged to the local POTW. Ground-water will be tteated for metals as necessary to meet discharge requirements. Institutional controls, including well use advisories and water rights and well drilling resttictions, and easements and leases as necessary for monitoring and installation of equipment, will be initiated prior to constraction of the remediation equipment. Ground-water quality will be monitored quarterly to measure the progress of the remediation.

Surface-water altemative 3 consists of local collection of contaminated surface water at each seep site, tteatment using carbon adsorption, and discharge to the subsurface using infiltration trenches. Institutional controls will be enacted, including water rights restrictions, easements and leases for monitoring and installing equipment, and fencing seeps. A surface water monitoring program will be continued quarterly throughout the remediation. The seeps at OU 4 are fed by ground water and flow rates vary with climatological conditions. Extracting ground water may also affect the flow rates. The tteatment system for surface water alternative 3 would be operated when there is sufficient flow to operate the system, but will not operate when the flow is not sufficient.

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Under landfill contents altemative 4, the contents of Landfill 1 will be contained using a landfill cap. Soil overlying the cap will be graded and revegetated to further reduce infiltration and to control ranoff. A vapor exttaction system, consisting of vapor exttaction wells or ttenches, blowers, and associated equipment will be installed in the landfill. Air emissions from the soil vapor exttaction system will be tteated as necessary to meet emissions requirements. Additionally, institutional conttols will be enacted, including: (1) continuing order from the Base Commander concerning landfill restrictions, (2) recording a notice to resttict exposure to and maintain integrity of remedial action at Landfill 1, and (3) fencing and waming signs.

The selected remedy includes air altemative 1, which is the no action altemative for contaminated air. This altemative will involve semi-annual air monitoring in residences overlying the contaminated ground-water plume. If concenttations of VOCs exceeding acceptable risk levels that are attributable to OU 4 are detected within any residences above the contaminated ground water, air altemative 3 will be initiated. Air altemative 3 is comprised of collection of contaminated soil gas with or without tteatment of the contaminated air. This altemative will involve installing a ventilation system along the foundations of affected residences. An emission conttol device will be used if emissions exceed regulatory limits. Semi-atmual air monitoring will be conducted along with air altemative 3 to monitor the effectiveness of the ventilation system. Implementation of ground-water altemative 3 is expected to provide hydraulic containment of the contaminated ground water and prevent fiirther ttansport towards off-Base residences. The concenttations of VOCs available to volatilize and move into basements are expected to decrease in time.

Figure 5-1 shows a schedule of remediation activities during the initial 30 years according to the order of implementation of the components of the selected remedy. The first activities will include ground-water and air monitoring and enactment of institutional conttols. The monitoring ensures that the extent of contamination remains well defined prior to and during implementation of remediation. Institutional conttols will limit access to contaminated water and soil prior to and during the remediation. Installation of the landfill cap and the vapor exttaction system will occur at approximately the same time, followed by installation of the ground-water exttaction and tteatment systems. Soil vapor extraction will take place after the cap and vapor extraction systems are complete. Ground-water exttaction and tteatment will commence after constracting the ground­water extraction and treatment systems. The surface-water treatment system will be installed and operated when a sufficient volume of flow is produced by the seeps to operate the system.

5.1.1. Remediation Goals and Perfonnance Standards

The goals of this remedial action are described for each of the four media of concem in the following section. The performance of the remediation system with respect to meeting the remediation goals will be monitored according to the performance monitoring plan to be developed during the remedial design.

The remedial action goals for OU 4 ground water and surface water are to:

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Construction phase

Implementation phase

NOTE: "Time zero' Is defined as the beginning of substantial, continuous physical improvement, which will begin 15 months after this ROD is signed.

V Hill AFB OU 4 ROD

HILL AIR FORCE BASE

OPERABLE UNIT 4

CONCEPTUAL REMEDIAL ACTION IMPLEMENTATION SCHEDULE

FIGURE 5-1 J

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• Meet chemical-specific ARARs, which are drinking water MCLs.

• Limit cancer risk to less than 10"^ with a target of 10"^ due to accidental ingestion, dermal contact, or inhalation of vapors.

• Maintain contaminant concenttations low enough to avoid chronic health effects (as indicated by a hazard index of less than 1).

»

• Prevent further degradation of ground-water quality in accordance with the Utah Conective Action Cleanup Pohcy.

The area of attainment over which these cleanup goals are to be achieved is defined as that portion of the aquifer and those areas of surface water where MCLs are exceeded. The area of attainment for ground water, which is where TCE exceeds its MCL (5 |ig/l), is 69 acres. Other chemicals in ground water that may exceed their MCLs are within this defined area.

The remedial action goals for landfill contents at OU 4 are to:

• Limit cancer risk to less than 10"^ with a target of 10"^ due to accidental ingestion, dermal contact, or inhalation of vapors.

• Maintain contaminant concentrations low enough to avoid chronic health effects (as indicated by a hazard index of less than 1).

• Eliminate the source(s) of ground-water contamination either through removal or source conttol in accordance with Utah Conective Action Cleanup Policy.

The remedial action goals for landfill contents are applicable to Landfill 1 only. The area of attainment for landfill contents is the Landfill 1 area, which is approximately 50,000 square feet.

The remedial action goals for air at OU 4 are to:

• Prevent the migration of contaminated soil gas into residences.

• Prevent inhalation of carcinogens in excess of 10"^ cancer risk within off-Base residences.

• Prevent inhalation of noncarcinogens at levels exceeding a hazard index of 1 within off-Base residences.

The area of attainment for air includes the off-Base residences overlying contaminated ground water.

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The remediation goals for OU 4 are listed in Table 5-1. Specific performance standards used to measure the degree of attainment of ground-water, surface-water, landfill contents, and air are:

• Reduce contaminant concenttations within the areas of attainment to comply with the remediation goals.

• Meet all ARARs identified for each medium.

• Remediate ground water, surface water, and landfill contents in a timely manner in compliance with the selected remedy to achieve remedial action goals as soon as practicable.

(J A performance and compliance sampling program (PCSP) will be implemented during the remedial action to monitor performance and compliance with remediation goals. This

n program will be developed during the remedial design (RD) and will include locations of LJ performance monitoring points, monitoring frequency, analytical parameters, sampling

and analytical methods, and statistical methods for evaluating data. The PCSP will be n designed to provide information that can be used to evaluate the effectiveness of the U respect to the extent and level of contamination, contaminant migration, containment,

mass removal, and tteatment system performance. The PCSP may be modified during n the remedial action to take into consideration changed conditions.

5.1.2. Restoration Time Frame

^ The restoration time for ground water is estimated to be greater than 30 years. The restoration time frame for surface water is also estimated at greater than 30 years because

\ of the hydraulic connection between surface water and shallow ground water. The estimated restoration time frame for landfill contents is 18 months, assuming vapor exttaction is sufficient to remove VOCs from the Landfill 1 area. There is no restoration time frame for contaminated air because no air contamination exceeding acceptable risk levels has been detected in nearby residences.

[J 5.1.3. Costs

p The estimated costs for remediating OU 4 using the selected remedy are presented in LJ Table 5-2. The total capital cost of the project is estimated at $3.5 million. The total

capital cost includes: installing a ground-water extraction system, an on-site ground-water C] treatment system, a discharge system for treated ground water, collection basins and Ll GAC for surface water tteatment, a landfill cap, vapor exttaction wells, a vapor exttaction

system, emission control equipment, tankage, piping, conttols, and equipment housings; n and enacting institutional conttols. The indirect capital cost for the project is estimated at (J $1.25 million. Indirect capital costs are included in the estimated total capital costs

above. Indirect costs include engineering, contingency, administration, permitting, and n tteatability studies.

5-4

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n TABLE 5-1

REMEDIATION GOALS FOR HILL AFB OPERABLE UNIT 4

Cleanup Standards Chemicals of Concern (M-g/I) ^

Ground Water

Benzene 5 (Thloroform 1(X)(*') 1,2-Dichloroethane 5 1,1-Dichloroethene 7 cis 1,2-Dichloroethene 70 trans 1,2-Dichloroethene 100 Methyl Ethyl Ketone 830(c) Tetrachloroethene 5 Toluene 1,000 Trichloroethene 5 Total Xylenes 10,000 Arsenic 50 i Barium 2,000 Boron 2,700(c) Nickel 100

Selenium 50

Surface Water

Chloroform lOOC') cis 1,2-Dichloroethene 70 trans 1,2-Dichloroethene 100 Trichloroethene 5

Air

Trichloroethene 5 ng/m^^ ^

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(a) Unless otherwise specified, the concentrations for ground water and surface water are maximum contaminant levels (MCLs) established under the Safe Drinking Water Act.

(b) The cleanup standard for chloroform is the MCL for trihalomethanes.

(c) Concentrations for non-carcinogens without ARARs are reported at levels such that the calculated hazard index (HI) is less than 1.0.

(d) Concentrations for carcinogens without ARARs are reported at levels such that the calculated excess lifetime cancer risk is less than 1x10"°.

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TABLE 5-2

COSTS AND PROCESS COMPONENTS FOR SELECTED REMEDY

I

Ground Water

Altemative 3: Collection/On-Site Treatment with Air Stripping/Discharge Time to Implement = 27 months

Collection - Horizontal Drains System of drains and piping to b-eatment system

Treatment - Air Strlppbig Air stripper system with vapor Ureatment and metals treatment, if necessary, and heated building

Discharge - POTW

Ground-Water Treatment Costs POTW Discharge Indirect Capiul = $864,000 Total Capital = $1,830,000 Annual O&M = $165,000 Every Sth year O&M = $175,000 Present Worth = $4,520,000

Surface Water

Altemative 3: Collection/TreaUnent using GAC Adsorption/Discharge Time to Implement = IS months, minimum

Collection - Local Basins Concrete collection basins at each seep and piping to treatment unit

Treatment - GAC Adsorption GAC adsorption system

Discharge - Inflltration Trenches

Surface Water Treatment Costs

Indirect Capital = $11,200 Total Capital = $46,700 Annual O&M = $15,000 Every Sth year O&M = $2S,000 Present Worth = $317,000

Landfill Contents

Altemative 4: Containment/ln-Situ TreaUnent

Time to Implement = 15 months

Containment - Landfill Cap Landnil cap, revegetation, regrading, geotextile draining, and gas vent layers

Treatment - Vapor Extraction In-situ system of vapor extraction wells, vacuum extraction system, air-water separator, piping, controls, valves, instrumentation, vapor treatment, building to house equipment

Landflll Contents Treatment Costs

Multi-Media Cap Indirect Capital = $375,000 Total Capital = $1,630,000 Annual O&M (years 1-S) = $188,000 Annual O&M (years 6-29) = $89,000 Present Worth = $3,590,000

Air

Alternative 1: No Action

Time to Implement = 15 months

Air Monitoring Collect duplicate air samples semi-annually, analyze the samples for VOCs, QA/QC of data

Air Monitoring Costs

Indirect Capital s $0 Total Capital = $0 Annual O&M (years 1-10) = $10,000 Annual O&M (yrs 11-29) = $12,000 Present Worth = $176,200

Indirect Costs include engineering, contingency, administrative, treatability studies, and permitting; O&M Costs include monitoring program costs; Present Worth assumes 30 years of operation.

Implementation times are approximate and based on the assumption that the ROD signing date is time zero. Time to implement is defmed as the time from when the ROD is signed to when construction begins.

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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 30-year period and do not reflect costs that may be incuned if the remediation period lasts longer than 30 years. Annual O&M is estimated at $380,000 for years 1-5, $200,000 for years 6-10, and $281,000 for

j j years 11-29. An additional $20,000 will be required for O&M every fifth year. O&M costs include monitoring program costs as well as maintenance of equipment and the landfill cap.

i.n

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The total present worth cost of the selected remedy over a 30-year period, using an p interest rate of five percent, was estimated at $8.6 million. The process components for Li each of the altematives comprising the selected remedy as well as preliminary design

assumptions used to estimate costs for each process are listed in Table 5-2. These n estimates are preliminary and may change during the remedial design and constraction Ll' processes. The costs discussed here and in Table 5-2 are estimated with -f-50/-30 percent

accuracy for a 30-year period. n U 5.2 STATUTORY DETERMINATIONS

n The selected remedy for Hill AFB Operable Unit 4 meets the statutory requirements of C Section 121 of CERCLA as amended by SARA. These statutory requirements include

protectiveness of human health and the environment, compliance with ARARs, cost j j effectiveness, utilization of permanent solutions and altemative tteatment technologies to ~- the maximum extent practicable, and preference for tteatment as a principal element. The

manner in which the selected remedy for OU 4 meets each of the requirements is I presented in the following discussion.

p 5.2.1. Protection of Human Health and tbe Environment

-A The selected remedy for OU 4 protects human health and the environment through the

r-l following engineering and institutional conttols:

• Ground water will be collected and treated on site to lower contaminant p concentrations below drinking water MCLs and to reduce carcinogenic and L) non-carcinogenic risks to within acceptable ranges. Institutional controls,

including well advisories and water rights and well drilling restrictions, and n easements and leases as necessary for monitoring and installation of U equipment, will be enacted.

n • Surface water will be collected and treated on-site until all contanunant U concentrations are below drinking water MCLs and are within an acceptable

range for both carcinogenic and non-carcinogenic risks.

C • Landfill contents will be contained using a cap to prevent migration of contaminants from the landfill to underlying ground water via infilttation and

p treated in-situ to remove VOCs. Institutional controls restricting ground-^ water use and preventing direct contact with landfill contents will be enacted.

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• Air quality will be monitored within residences overlying the ground-water '\ 'i contamination plume to ensure that VOCs attributable to OU 4 contamination

are not present at concentrations exceeding acceptable risk levels in residences.

Collecting and tteating contaminated shallow ground water will reduce the health risks to future users by reducing the mass of contaminants. Ground-water tteatment will also reduce the level of contamination reaching the surface water at OU 4. Collecting and tteating contaminated surface water will reduce human health risks associated with potential future exposures to contaminated surface water. Also, protection of the environment is provided by reducing the potential exposure of wildlife and domestic animals to contaminants via surface water. Capping of the landfill contents will reduce the potential of further contamination of underlying ground water with landfill leachate, protecting ground water from continuing and future contamination. In-situ tteatment of the landfill contents will ftirther reduce the potential for contaminants from the landfill to leach to ground water by removing VOCs from the landfill area. Air monitoring reduces the health risks to residents living in homes overlying the area of contaminated ground water by determining whether this exposure pathway exists and providing a basis upon which additional remedial measures for air will be based.

The selected remedy will not pose any unacceptable short-term risks. Institutional conttols and proper health and safety procedures will be implemented during constraction and monitoring to minimize short-term risks to site workers and off-Base residents. The selected remedy will minimize cross media impacts. For example, contamination of ground water will be reduced by remediating the landfill contents, and impacts upon surface water may be reduced by collecting and tteating contaminated ground water.

5.2.2. Compliance with Applicable or Relevant and Appropriate Requirements

Section 121(d)(1) of CERCLA as amended by SARA, requires that the remedial actions at OU 4 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, requirements, criteria, or limitations under the State of Utah environmental or facility siting regulations that are more stringent than Federal standards. In addition, ARARs include State of Utah regulations that have no conesponding 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, the location, or other circumstance at the OU 4 site. "Relevant and appropriate" requirements are cleanup standards, standards of conttol, and other substantive environmental protection requirements, criteria, or linutations

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promulgated under Federal or State law that, while not "applicable" to the hazardous t substance, pollutant or contaminant, remedial action, location, or other circumstance at a

remedial action site, address problems or situations sufficiently similar to those r~i encountered at the site that their use is well-suited to the particular site.

In evaluating which requirements are relevant and appropriate, the criteria differ p depending on whether the type of requirement is chemical-specific, location-specific, or LJ action-specific. According to the NCP, chemical-specific ARARs are usually health or

risk-based numerical values that establish the acceptable amount or concenttation of a ^^ chemical that may remain in, or be discharged to, the ambient environment. Location-L) specific ARARs generally are restrictions placed upon the concenttation of hazardous

substances or activities solely because they are in special locations. Some examples of n special locations include floodplains, wetiands, historic places, and sensitive ecosystems LJ or habitats. Action-specific ARARs are usually technology or activity-based

requirements or limitations on actions taken with respect to hazardous wastes, or n requirements to conduct certain actions to address particular circumstances at the site.

Chemical-specific ground-water and surface-water quality ARARs for OU 4 are based on n the Safe Drinking Water Act maximum contaminant levels (MCLs) or the maximum C permissible level of a contaminant in water that is deUvered to any user of a public water

system. MCLs are generally relevant and appropriate as cleanup standards for j I contaminated ground water and surface water that is used or may be used for drinking.

The Utah Public Drinking Water Regulations are also relevant and appropriate to the selected remedy. In addition, the Utah Ground-Water Quality Protection, air quality, and solid and hazardous waste regulations are applicable to the selected remedy. Other applicable or relevant and appropriate requirements include the Solid Waste Disposal Act, the Clean Water Act, the Clean Air Act, and the Department of Transportation (DOT) hazardous material ttansportation regulations. Federal and State chemical-specific ARARs are presented in Appendix A, Tables A-I and A-2, respectively.

Federal location-specific ARARs for OU 4 include the Fish and Wildlife Conservation Act, the Policy on Floodplains and Wetlands Assessments for CERCLA Actions, the Executive Order on Floodplain Management, the Fish and Wildlife Coordination Act, the Endangered Species Act, the Rivers and Harbors Act, and the EPA Ground-Water Protection Sttategy. The only Utah location-specific ARAR is the Division of Wildlife Resources requirement regarding pollution of waters containing protected wildlife. Federal and State location-specific ARARs are identified in Tables A-3 and A-4, of Appendix A, respectively.

Federal action-specific ARARs that are relevant to the remediation activities at OU 4 include the National Emission Standards for Hazardous Air Pollutants (NESHAPs), The Solid Waste Disposal Act, the Safe Drinking Water Act, the Clean Water Act, DOT regulations, and RCRA. State of Utah action-specific ARARs include standards for drilling and abandoning wells, solid waste landfill rales, spill reporting requirements, Utah Conective Action Cleanup Policy for RCRA, UST and CERCLA sites, and Air Conservation and Public Drinking Water Regulations. Federal and State action-specific ARARs are identified in Appendix A, Tables A-5 and A-6, respectively.

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The remedy selected for OU 4 will meet ARARs, but the remediation time frame may exceed 30 years. Site hydrogeology and contaminant sorption behavior may limit the effectiveness of ground-water exttaction, preventing the attainment of drinking water MCLs. If it is determined, on the basis of the performance of the ground-water remediation system, that certain portions of the aquifer cannot be restored to beneficial use, all of the following measures involving long-term management may occur, for an indefinite period of time, as a modification of the existing system:

n • Engineering conttols will be continued as containment measures;

• Institutional controls will be provided/maintained to restrict access to those n portions of the aquifer which remain above remediation goals;

• Ground-water monitoring will be continued; and

C • Remedial technologies and process enhancements for ground-water restoration will be re-evaluated periodically.

n C The decision to invoke any or all of these measures may be made during a periodic

review of the remedial action, which will occur at least every five years, in accordance n witii CERCLA Section 121(c).

5.2.3. Cost Effectiveness

Overall cost effectiveness can be defined as the reduction of the threat to human health r- and the environment per dollar expended on a remedy. The selected remedy for OU 4

1 was chosen to provide the necessary protectiveness to human health and the environment. When two alternatives had an equal measure of protectiveness, the altemative with the

r~, lower cost was selected. An example of this is capping the landfill and constracting a soil I J vapor extraction system (selected remedy), versus excavating and disposing of the

contents of Landfill 1 in an off-site landfill. The selected remedy would provide r-\ protectiveness by l imting surface-water infiltration and removing the TCE source by IL) vapor exttaction. Excavation of the landfill materials would also remove the source of

TCE, but would cost approximately 13 to 25 times more than the selected remedy.

L) 5.2.4. Utilization of Permanent Solutions

f ] The selected remedy provides the best balance of tradeoffs among all the altematives U with respect to the five summary balancing criteria which include:

Long-term effectiveness and permanence; Reduction of toxicity, mobility, or volume through tteatment; Short-term effectiveness; Implementability; Cost.

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The criteria that were most critical in the selection decision were reduction of toxicity, I I mobility, and volume through tteatment and cost. The modifying criteria, which are State ^ and community acceptance, had no effect on selection of the remedy because the State ^ agrees with the altemative selected, and the community has not raised any concerns

( related to the proposed altemative. The selected remedy meets the statutory requirement to utilize permanent solutions and treatment technologies to the maximum extent

p> practicable.

5.2.5. Preference for Treatment as a Principal Element

pj The selected remedy for OU 4 utilizes permanent solutions and tteatment technologies to the maximum extent practicable. The use of air stripping to remediate contaminated

p. ground water, GAC to remediate contaminated surface water, vapor extraction to [ j remediate contaminated landfill contents, and vapor tteatment to remediate contaminated

off-gases satisfies the statutory preference for treatment that permanently and n significantly reduces the volume, toxicity, and mobility of the hazardous substances. J These treatment processes are expected to permanently reduce the concenttations of

contaminants. The potential fumre risks are domestic use of contaminated ground water n and surface water, and exposure to contaminated air in residences. To ensure the I effectiveness of the selected treatment remedy. Hill AFB will conduct a review within

five years after starting the remediation. o

5.3 DOCUMENTATION OF SIGNIFICANT CHANGES

The Proposed Plan for Hill AFB OU 4 was released for public comment in October 1993. The Proposed Plan identified ground-water altemative 3, surface-water altemative 3, landfill contents altemative 4, and air altemative 1 as the prefened combination of altematives. This remedy included: exttacting contaminated ground water and treating it using air stripping, collecting contaminated surface water and tteating it using carbon adsorption, capping the landfill contents and tteating them with soil vapor extraction, and monitoring air in residences overlying the ground-water contamination. All written and verbal comments received during the public comment period were reviewed, and it was determined that no significant changes to the remedy identified in the Proposed Plan were necessary.

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^ Hill Air Force Base, Utah J Operable Unit 4 n Responsiveness Summary

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1^ Overview

This responsiveness summary provides information about the views of the community p with regard to the proposed remedial action for Hill Air Force Base (AFB) Operable LJ Unit 4 (OU 4), documents how public comments have been considered during the

decision making process, and provides responses to concems.

U The public was informed of the selected remedial action in the following ways:

n • All items contained within the administtative record have been on file at the L) subject repositories since the final version of each document was issued

P ' A copy of the Proposed Plan was sent to all affected and interested parties just U prior to the public conunent period

n " A public conunent period was held from October 7, 1993 through November U 5,1993

' A public meeting was held on October 19, 1993 at South Weber Elementary ^ School in Soutii Weber, Utah

p I • Written comments by the public were encouraged.

p . The public meeting was well attended and residents voiced numerous concems about the C nature and extent of contamination. A transcript of the public meeting is attached as

Appendix B. No comments were made that would affect the proposed remedial action pj for OU 4. One written comment was received during the public comment period. This pj comment and the written response are included in Appendix C.

p Background on Community Involvement u

The public participation requirements of CERCLA Sections 113(k)(2)(B)(i-v) and 117 n were met. Hill AFB has a Community Relations Plan that is revised as frequently as (J every six months. The community relations activities include: (1) a Technical Review

Committee (TRC) which meets quarterly and includes community representatives from n adjacent counties and towns, (2) a maiUng list for interested parties in the community, (3) C a bi-monthly newsletter called "EnviroNews," (4) visits to nearby schools to discuss

environmental issues, (5) community involvement in a noise abatement program, (6) n semi-annual town council meetings, (7) opportunities for public comment on remedial C actions, and (8) support for the community for obtaining technical assistance grants

(TAGs). In addition, a public meeting was held for the communities north of the Base D that are affected by OU 1, OU 2, and OU 4 on April 28, 1993 to explain risk issues.

^ The RI Report (USGS, 1992), RI Addendum (USGS, 1993), Feasibility Study Report pj (MW, 1993a), and the Proposed Plan for Operable Unit 4 (MW, 1993b) were released to ^ the public, and are available in the administtative record maintained in the Davis County ^ Library and at the Environmental Management Directorate at Hill AFB. The notices of

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availability for these documents were published in the Salt Lake Tribune. A public n comment period was held from October 7, 1993 through November 5, 1993. In addition, C a pubUc meeting was held on October 19, 1993. At this meeting, representatives from

Hill AFB, EPA, and the State of Utah answered questions about the site and the selected I remedy. A court reporter prepared a ttanscript of the meeting. Copies of the ttanscript

and all written public comments received during the conunent period have been placed in PI the adnunistrative record. In addition, copies of the transcript were sent to all meeting j attendees who requested them. Responses to the comments received during the public

conunent period are included in the Responsiveness Summary, which is part of this ROD. p The decision process for this site is based on the Administtative Record. u

Summary of Public Comments and Agency Responses

U Part I - Summary and Response to Local Community Concerns. The major community concems are discussed in the following section.

n J Extent and Area of Contamination. Members of the local community were interested

in the location of OU 4 and the contaminated ground water with respect to the South n Weber Elementary School and Daren Cutler's property. In response to these comments, U the locations of the school and the Cutler Residence were indicated on a map of the

vicinity. South Weber Elementary School is approximately three miles from OU 4. n Exposure to contamination from OU 4 is not a concem for children attending the school. vJ The location of the OU 4 disposal sites was clarified. The community members were told

that the disposal sites are located on Hill AFB property and not on the property of Daren n Cutler, that the ground-water contamination extends from the source to South Weber ^ Drive, which is about 1500 feet from the source, and that the depth of contamination is 30

to 40 feet.

Methods for Determining Costs. The methods used to estimate the costs of the _, altematives were of concem to community members. Citizens were concemed that the

less expensive altematives may be of lower quality than more expensive altematives and whether the costs reported were maximum of average values. The public was told that

p the altematives present a range of methods that could be used in the remedial design, that j j costs were calculated based upon 30-year present worth estimates, and that the accuracy

of these values is plus 50% and minus 30%. An altemative that does not provide PI adequate protection would not be chosen because it was less expensive. Costs are taken LJ into account in evaluating technologies that provide comparative protectiveness and

compliance with applicable or relevant and appropriate requirements (ARARs).

n U Potential Air Pollution. A community member asked about the potential air pollution

resulting from the air stripping process. The community members were told that the C remedial process used would be designed to comply with all appropriate environmental U regulations, including the state and Davis County air quality regulations. The exhaust

from the air stripper would be monitored and treated if necessary prior to discharge to the n atmosphere. Unsafe au discharges will not be allowed.

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0 Property Values. The issues of the values of affected properties and compensation for losses were raised several times. Community concems included compensation for relocation, land use restrictions, damage to crops, using private property for locating treatment systems, and whether anyone was cunentiy being compensated for land loss. Residents were told that these issues would be handled on a case-by-case basis and that the Air Force has a formal claims process that they can use to request compensation for damages. The citizens were informed that the compensation made by the Air Force to date has been in the form of leasing property to compensate land owners for the loss of use of that property.

LJ Types and Concentrations of Contaminants. One community member inquired about the presence of other contaminants in addition to TCE, such as heavy metals and semi-

n volatiles, in the landfill area. In response to this concem, the citizen was told that there U have been low levels of metals detected in ground water. No semi-volatiles have been

detected. Members of the community were concemed as to whether the concentrations of n contaminants in ground water were increasing or decreasing with respect to the levels U observed when monitoring was first started and whether the plume is expanding. The

response to this concem was that the most recent monitoring data indicates declining n concenttations of TCE in ground water and that monitoring of the extent of the plume C continues.

n , Cur ren t Treatability Studies. Nearby residents expressed concem about risks posed by ^ contaminated ground water extracted during the cunent horizontal drain treatability

study. They were concemed about an open pit full of water resulting from the installation of the horizontal drains for the tteatability study. The community members were told that the open pit had since been filled with gravel and that the water was being tteated with an

p-s air stripper and discharged to the Central Weber Sewer District. Also, one resident thought that the tteatability studies were part of the remedial action. He was told that the tteatability study is a short term, temporary system which is being used to collect data to

PI determine the effectiveness of the technology and to gather data for designing a full scale M remediation system.

p Remedial Action Schedule. One community member asked when the constraction for the remedial action would begin. The community was told that constraction of the remediation system would begin 15 months after the final Record of Decision is signed for the site, and that the Record of Decision is expected to be signed in the Summer of 1994.

Risk Assessment Methods. Community members expressed concem about the accuracy of the risk assessment results. The community members were told that, although risk assessment is a blend of art and science and the results are estimates, that the assumptions used are conservative. Additionally, several community members wondered why OU 4 was being remediated if there is no risk. The distinction between cunent and future risk was clarified. The community members were told that cunent risk associated with the contamination at OU 4 are well below levels considered significant by EPA, but that the purpose of the remedial action is to prevent future risks to human health and the environment.

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Potential Health Effects. The issue of potential health effects on residents was raised by I Lola Patterson in her letter of August 3, 1992 and again upon resubmittal of this letter at

the public meeting. Her concems included: risks associated with consumption of fraits p and vegetables produced on contaminated land, consumption of animals raised on I J contaminated property, and long-term health effects. Mrs. Patterson was told that there

are no health risks from consuming frait, vegetables, or animals produced on land p overlying contaminated ground water because the shallow root systems for plants do not p) extend to the contaminated zone of ground water. If ground water was to come in contact

with the root systems, organic chemicals would be broken down by the plants. Mrs. p Patterson was told that risk depends upon exposure to the contaminants and that existing Li information indicates that there have been no significant public health impacts. She was

also informed that long-term risks are not expected because the clean up activities will n remove contaminants and prevent future risks. u

Air Sampling. Lynn Coy requested that Hill AFB anange to sample the air in the home p of Vem Coy. Hill Air Force Base responded by ananging sampling of this home.

Part II - Comprehensive Response to Specific Legal and Technical Questions

I Specific legal and technical questions raised by the community are described below.

Compensation for Damages. The issue of compensation for losses was raised by n several members of the community. Concems included compensation for relocation,

damage to crops, using private property for locating treatment systems, and whether anyone was cunentiy being compensated for land loss. The responses to these issues included informing residents that these issues would be handled on a case-by-case basis and that the Air Force has a formal claims process that they can use to request compensation for damages. The citizens were informed that the compensation paid by the Air Force to date has been in the form of lease payments made for access to property to conduct remedial investigations and to compensate land owners for losses they suffer as a result of that investigation.

Remaining Concerns

There are no remaining public concems that were not addressed directly during the RI/FS process.

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REFERENCES

Engineering-Science (ES), 1982. Installation Restoration Program, Phase I - Records Search, HiU AFB, Utah. Prepared for U.S. Air Force Logistics Command. January 1982.

GalUhugh, Jeanette, 1993. U.S. Army Corps of Engineers, Permits and Regulatory Office; Salt Lake City, Utah. Personal communication, September 1993.

James M. Montgomery, Consulting Engineers, Inc. (JMM), 1991. Remedial Investigation Report for Operable Unit 4, Vol 2 - Draft Final Baseline Risk Assessment. Prepared for U.S. Air Force Logistics Command, November 1991.

Montgomery Watson (MW), 1993. Draft Final Baseline Risk Assessment Addendum, Vol. 2 - Addendum to Remedial Investig for U.S. Air Force Logistics Command.

n Vol. 2 - Addendum to Remedial Investigation Report for Operable Unit 4. Prepared

Montgomery Watson (MW), 1993a. Final Feasibility Study Report Unit 4, Hill AFB, Utah,. Prepared for U.S. Air Force Logistics Command, September 1993.

Montgomery Watson (MW), 1993b. Final Proposed Plan for Operable Unit 4, Hill AFB, Utah. Prepared for U.S. Air Force Logistics Command, September 1993.

Radian Corporation and Science Applications Intemational Corporation (Radian and SAIC), 1988. Installation Restoration Program Phase II~Confirmation/Quantification Stage 2, Vol 1 - Retp. Final report: Prepared for U.S. Air Force Logistics Command.

U.S. Air Force (USAF), 1989. Hill Air Force Base Comprehensive Plan.

U.S. Fish and Wildlife Service (USFWS), 1986. National Wetiands Inventory Map: Ogden (SW) Quadrangle.

U.S. Geological Survey (USGS), 1992. Final Remedial Investigation Report for Operable Unit 4. Prepared for U.S. Air Force Logistics Command, September 1992.

U.S. Geological Survey (USGS), 1993. Addendum to the Final RI Report for Operable Unit 4. Prepared for U.S. Air Force Logistics Command, Febraary 1993.

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Appendix A

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TABLE A-1

FEDERAL CHEMICAL-SPECIFIC ARARs

Standard, Requirement, Criteria, or Limitation Citation Description

Applicable/ Relevant

and Appropriate Comment

Safe Drinking Water Act

National Primary Drinking Water Standards

Clean Water Act

Water Quality Criteria

42 USC Sec. 300g

40 CFR Part 141

33 USC Sec. 1251-1376

40 CFR Part 131

Establishes health-based standards for public water systems (maximum contaminant levels).

Sets criteria for developing water quality standards based on toxicity to aquatic organisms and human health.

No/Yes Remediation Goals

No/Yes Relevant and appropriate since shallow aquifer is a potential drinking water source and for discharge of treated water to the Weber River

Clean Air Act

National Primary and Secondary Ambient Air Quality Standards

42 USC Sec. 7401-7642

40 CFR Part 50

National Emission Standards 40 CFR Part 61 for Hazardous Pollutants Subpart A

Occupational Safety and Health 20 USC Sec. 651 -678 Act 29 CFR 1910

D.O.T. Hazardous Material Transportation Regulations

49 CFR Parts 107, 171 - 177

Establishes standards for ambient Yes/— air quality to protect public health and welfare (including standards for particulate matter and lead).

Sets emission standards for Yes/Yes designated hazardous pollutants.

Regulates worker health and Yes/— safety.

Regulates transportation of Yes/— hazardous materials.

Applicable to any activity which might result in air emissions during remedial actions at OU 4.

Applicable and relevant and appropriate to ground-water treatment facility air emissions of trichloroethene, benzene, toluene, and chloroform.

Applicable to all worker activities related to remedial action at OU 4.

Applicable to remedial actions involving off-Base movement of hazardous materials (contaminated GAC) during remediation.

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TABLE A-2

FEDERAL LOCATION-SPECinC ARARs

Standard, Requirement, Criteria, or Limitation Citation Description

Applicable/ Relevant

and Appropriate Comment

Policy on Floodplains and Wetlands Assessments for CERCLA Actions

Endangered Species Act

Executive Order on Protection of Wetlands

EPA Guidance Aug. 6,1985

16 USC Sec. 1531-1543

40 CFR 6-302(h)

50 CFR Part 200

50 CFR Part 402

Exec. Order #11,990

40 CFR Sec. 6.302(A) and Appendix A

Executive Order on Floodplain Management

Exec. Order #11,988

40 CFR Sec. 6.302(B) and Appendix A

Discusses situations that require preparation of a floodplains or wetlands assessment and the factors which should be considered in preparing an assessment for response actions taken under CERCLA.

Requires that Federal agencies insure that any action authorized, funded, or carried by the agency is not likely to jeopardize the continued existence of any threatened or endangered species or desu-oy or adversely modify critical habitat.

Requires Federal agencies to avoid, to the extent possible, the adverse impacts associated with the destruction or loss of wetlands and to avoid support of new construction in wetlands if a practicable altemative exists.

Requires Federal agencies to evaluate the potential effects of actions they may take in a floodplain to avoid, to the maximum extent possible, the adverse impacts associated with direct and indirect development of a floodplain.

Yes/— Applicable as there are floodplains designated in the vicinity of OU 4 that may be affected by the remedial action.

Yes/— Endangered species are known to frequent the Ogden area (i.e.. Peregrine falcons. Bald Eagles).

No/Yes Based on information provided by the State of Utah Division of Water Resource and United States Fish and Wildlife Service, the seep areas are not currently identified as wetland areas, hence, no wetlands are potentially endangered by contaminants or remedial actions at OU 4 and Exec. Order No. 11,990 is not applicable. May be considered relevant and appropriate.

Yes/— Applicable to remedial actions that affect or impinge on the Weber River floodplain.

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FEDERAL ACTION-SPECIFIC ARARs

Standard, Requirement, Criteria, or Limitation Citation Description

Applicable/ Relevant

and Appropriate Cmnment

National Emission Standards for Hazardous Air Pollutants

40 CFR 61 Designates substances as hazardous air pollutants and establishes emission standards.

Yes/— Applicable to benzene, trichloroethene, and toluene emissions from ground-water treatment facilities or soil vents.

Solid Waste Disposal Act

Guidelines for the Land Disposal of Solid Wastes

Criteria for Classification of Solid Waste Disposal Facilities and Practices

Standards Applicable to Generators of Hazardous Waste

Standards Applicable to Transporters of Hazardous Waste

42 USC Sec. 6901-6987

40 CFR Part 241

40 CFR Part 257

40 CFR Part 262

40 CFR Part 263

Establishes requirements and No/Yes procedures for land disposal of solid wastes.

Establishes criteria for use in No/Yes determining which solid waste disposal facilities and practices pose a reasonable probability of adverse effects on health or the environment.

Establishes standards for Yes/-generators of hazardous waste.

Establishes standards which apply Yes/— to persons transporting hazardous waste within the U.S. ifthe transportation requires a manifest under 40 CFR Part 262.

Relevant and appropriate to capping of Landfill 1.

Relevant and appropriate to capping of Landfill 1.

Applicable to remedial alternatives involving handling/transport/storage of contaminated GAC.

Transport of hazardous materials (e.g., contaminated GAC) off-site may occur during some remedial alternatives.

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TABLE A-3

FEDERAL ACTION-SPECIFIC ARARs (CONTINUED)

Standard, Requirement, Criteria, or Limitation Citation Description

Applicable/ Relevant

and Appropriate Comment

Standards for Owners and 40 CFR Part 264 Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities

General Facility Standards

Preparedness and Prevention

Contingency Plan and Emergency Procedures

Subpart B

264.11-264.18

Subpart C

264.31 -264.37

Subpart D

264.51-264.56

Manifest System, Record Subpart E Keeping, and Reporting 264.71-264.77

Releases from Solid Waste Management Units

Subpart F

264.91-264.101

Establishes minimum national standards which define the acceptable management of hazardous waste for owners and operators of facilities which treat, store, or dispose of hazardous waste.

See discussion of specific sections.

Yes/—

Yes/-

Yes/—

Yes/—

Yes/-

Applicable to off-site facilities handling/regenerating contaminated GAC.

Applicable to off-site facilities handling/regenerating contaminated GAC.

Applicable to off-site facilities handling/regenerating contaminated GAC.

Applicable to off-site facility accepting contaminated GAC.

Applicable to off-site facilities handling/regenerating contaminated GAC.

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TABLE A-3

FEDERAL ACTION-SPECIFIC ARARs (CONTINUED)

Standard, Requirement, Criteria, or Limitation Citation Description

Applicable/ Relevant

and Appropriate Comment

Closure and Post-Closure Subpart G

264.111-164.120

Financial Requirements Subpart H

264.141-264.151

Use and Management of Subpart I Containers

264.171-264.178

Waste Piles Subpart L

264.251 Design and operating requirements

264.254 Monitoring and inspection

264.256 Special requirements for ignitable or reactive waste

264.257 Special requirements for incompatible wastes

Yes/- Applicable to off-site facilities handling/regenerating contaminated GAC. Relevant and appropriate for Landfill 1.

Yes/- Applicable to off-site commercial facilities handling/regenerating contaminated GAC. Federal govemment not bound by financial requirements of RCRA.

Yes/— Applicable to containers at off-site facility handling/regenerating contaminated GAC.

Yes/- Waste piles would be temporary.

Yes/- Waste piles would be temporary.

Yes/- Waste piles would be temporary. Applicable to ignitable or reactive wastes.

Yes/- Waste piles would be temporary. Applicable to ignitable or reactive wastes.

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TABLE A-3

FEDERAL ACTION-SPECIFIC ARARs (CONTINUED)

Standard, Requirement, Criteria, or Limitation Citation Description

Applicable/ Relevant

and Appropriate Commoit

Landfills Subpart N

264.301 Design and operating requirements

264.303 Monitoring and inspection

264.309 Surveying and recordkeeping

264.310. Closure and post-closure care

264.312 Special requirements for ignitable

or reactive waste 264.313 Special requirements for

incompatible wastes 264.314 Special requirements for bulk and

containerized liquids

264.315 Special requirements for containers

Yes/- Applicable to off-site facilities handling GAC. Relevant and appropriate to capping of Landfill 1.

Yes/- Applicable to off-site facilities handling GAC. Relevant and appropriate to capping of Landfill 1.

Yes/- Applicable to off-site facilities handling GAC. Relevant and appropriate to capping of Landfill 1.

Yes/- Applicable to off-site facilities handling GAC. Relevant and appropriate to capping of Landfill 1.

Yes/No If ignitable or reactive wastesare encountered, this requirement will be applicable.

Yes/No If incompatible wastes are encountered, this requirement will be applicable.

Yes/No If liquids are encountered, this requirement will be applicable.

Yes/- Applicable to off-site facilities handling contaminated GAC.

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FEDERAL ACTION-SPECIFIC ARARs (CONTINUED)

Standard, Requirement, Criteria, or Limitation Citation Description

Applicable/ Relevant

and Appropriate Comment

264.316.. • Landfills (continued)

• Incinerators Subpart X

264.601 - 264.603

Land Disposal Restrictions 40 CFR Part 268

Disposal of small containers of Yes/No hazardous waste in overpacked drums (lab packs)

General

EPA Administered Permit Programs: The Hazardous Waste Permit Program

; Drinking Water Act

Underground Injection Control Regulations

Subpart A

268.3

268.7

40 CFR Part 270

42 USC Sec. 300g

40 CFR Part 136

40 CFR Parts 144-47

Yes/-

Identifies hazardous wastes that are restricted from land disposal.

Dilution prohibited as a substitute Yes/-for treatment

Waste analysis and recordkeeping Yes/-

Establishes provisions covering Yes/-basic EPA permitting requirements.

Sets approved test methods for No/Yes waste constituent monitoring.

Provides for protection of Yes/No underground sources of drinking water.

If laboratory packing is encountered, this requirement will be applicable.

Applicable to off-site facilities handling GAC.

See discussion of specific sections.

Applicable to regeneration or disposal of contaminated GAC.

Contaminated GAC may need to be analyzed prior to disposal.

Applicable to disposal of hazardous waste to POTW or by injection wells (40 CFR 270.60[b,c]).

Relevant and appropriate for waste constituent monitoring.

Regulates injection of treated ground water and surface water. Applicable if used.

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TABLE A-3

FEDERAL ACTION-SPECIFIC ARARs (CONTINUED)

Standard, Requirement, Criteria, or Limitation Citation Description

Applicable/ Relevant

and Appropriate Conmient

Clean Water Act

National Pretreatment

33 USC Sec. 1251-1376

40 CFR Part 403

Occupational Safety and Health 20 USC Sec. 651 -678 Act 29 CFR 1910

D.O.T. Hazardous Material Transportation Regulations

49 CFR Parts 107, 171 177

Sets standards to control pollutants which pass through or interfere with treatment processes in publicly owned treatment works or which may contaminate sewage sludge.

Regulates worker health and safety.

Regulates transportation of hazardous materials.

Yes/— Applies to treated or untreated hazardous waste discharged to POTW.

Yes/- Applicable to any remedial action at OU 4.

Yes/- Applicable to remediation altematives requiring off-site disposal of wastes.

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TABLE A-4

STATE CHEMICAL-SPECIFIC ARARS

Standard, Requirement, Criteria, or Limitation Citation Description

Applicable/ Relevant

and Appropriate Cwnment

Utah Public Drinking Water Regulations

Utah Ground-Water Quality Protection Regulations

Division of Solid and Hazardous Waste, Department of Environmental Quality

Division of Water Quality, Department of Environmental Quality

Utah Adm. Code (U.A.C.) R449 Sections 3.1.1. and 3.1.2.

Utah Adm. Code R317-6

Title 19, Chapter 6, Utah Code Annotated (U.C.A.) U.A.C. R315-101

Title 19, Chapter 5, U.C.A., U.A.C. Rule R317-1

Title 19, Chapter 5, U.C.A., U.A.C. Rule R317-2

Establishes maximum No/Yes contaminant levels for inorganic and organic chemicals.

Establishes groundwater quality Yes/— standards for the different groundwater aquifer classes.

Corrective action clean-up Yes/— standards policy - RCRA, UST, and CERCLA sites.

Definitions for Water Pollution Yes/— Rules and General Requirements.

Standards for Quality for Waters Yes/— of the State.

Requirements are relevant and appropriate to OU 4. Some MCLs established for contaminants not Federally regulated (i.e. total dissolved solids).

Standards are identical to Utah Public Drinking Water Regulations but contain MCLs for volatile organics

Lists general criteria to be considered in establishing clean-up standards. Refer to Safe Drinking Water Act and Clean Air Act. Requires removal or control of the source.

These mles are specific to Utah waters, though they are derived in part by using Federal criteria. See particularly the non-degradation policy in R448-2-3.

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TABLE A-5

STATE LOCATION-SPECIFIC ARARS

Standard, Requirement, Criteria, or Limitation Citation Description

Applicable/ Relevant

and Appropriate Comment

Division of Wildlife Resources Department of Natural Resources

Title 23, Chapter 15, U.C.A. Water pollution - pollution of waters containing protected aquatic wildlife (including specified invertebrates) unlawful.

Yes/— Remedial actions at OU 4 may affect surface waters adjacent to OU 4.

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TABLE A-6

STATE ACTION-SPECIFIC ARARs

Department, Division or Commission Statute Subject

Applicable/ Relevant and Appropriate Remarks

State Engineer, Department of Natural Resources

Industrial Commission

Division of Solid and Hazardous Waste, Department of Environmental Quality

Division of Water Quality, Department of Environmental Quality

Title 73, Chapter 3, U.C.A., Rule R625-4, U.A.C.

Title 35, Chapter 9, U.C.A. Rule R500, U.A.C.

Title 19, Chapter 6, U.C.A.

Title 19, Chapter 5, U.C.A., Rule R315, U.A.C.

Title 19, Chapter 5, U.C.A., RuIeR315-101 U.A.C.

Title 19, Chapter 5, U.C.A., Rule R317-3, U.A.C.

Title 19, Chapter 5, U.C.A., Rule 317-6, U.A.C.

Standards for drilling and abandoning wells.

Utah Occupational Safety and Health Standards.

Solid Waste. Not yet codified; copy available from the Division of Solid and Hazardous Waste.

Solid and Hazardous Waste.

Corrective Action Clean-up Standards Policy - RCRA, UST, and CERCLA sites.

Sewers and wastewater treatment works.

Ground-Water Quality Protection.

Yes/-

Yes/—

No/Yes

Yes/—

Yes/—

No/Yes

Yes/-

Includes such requirements as performance standards for casing joints, requirements for abandoning a well, etc.

These rules are identical to Federal OSHA regulations.

These rules govern solid waste landfills.

R450-0, regarding spill reporting requirements, has no corresponding Federal provisions.

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 removal or control of the source.

Constmction and performance requirements for remedial works will be relevant and appropriate.

There is no corresponding federal program.

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TABLE A-6

STATE ACTION-SPECIFIC ARARs (CONTINUED)

Department, Division or Commission Statute Subject

Applicable/ Relevant and Appropriate Remarks

Division of Air Quality, Department of Environmental Quality

Title 19, Chapter 2, U.C.A., Rule R307, U.A.C.

Utah Air Conservation Rules. Yes/-

Division of Drinking Water, Department of Environmental Quality

Rule 309, U.A.C. Utah Public Drinking Water Rules.

No/Yes

Requires application of best available control technology for any source, lists criteria to be considered in establishing visibility standards, sets visible emission standards, regulates fugitive dust emissions, allows the State to require temporary closure of air poilution sources in the event of an air pollution emergency episode, and includes a limit of 1.5 tons of annual emissions of VOCs without obtaining a permit.

See particularly R449-103 establishing drinking water standards. These standards are identical to federal standards except with respect to sulfate, TDS and fluoride.

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Appendix B

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Public Meeting re Proposed Plan for Operable

Unit 4 held on Tuesday, October 19, 1993,

7:12 p.m. at South Weber Elementary School,

1285 East Lester Street, South Weber, Utah,

reported by AMY STOLTENBERG, Certified

Shorthand Reporter, Registered Professional

Reporter and Notary Public in and for the

State of Utah.

* * * * *

IN ATTENDANCE; Ms. Gwen Brewer Mr. Bob Elliott Mr. Gary Colgan Mr. Rob Stites Mr. Muhammad Slam Lt. Col. Max Irshad Lt. Col. George New Mr. Mike Cox Mr. Duane Mortensen Ms. Diane Simmons Other Members of the Public

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KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 2

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1 SOUTH WEBER, UTAH, TUESDAY, OCTOBER 19, 1993, 7:12 P.M.

2 * * * * *

3 MS. GWEN BREWER: Welcome to the public meeting for

4 the Hill Air Force Base Operable Unit 4.

5 My name is Gwen Brewer, and I am the

6 Environmental Public Affairs Coordinator at Hill Air Force

7 Base.

8 The main purpose of this meeting is to obtain

9 your input on the proposed actions.

10 Attending tonight's presentation are the

11 following people: Mr. Rob Stites, Environmental Protection

12 Agency; Mr. Duane Mortensen, Utah Depeurtment of Environmental

13 Quality; Mr. Muheunmad Slam, Uteih Department of Environmental

14 Quality; Mr. Hal Dunning, Community Involvement for the

15 Environmental Protection Agency; Ms. Diane Sinoaons, Community

16 Relations, Utah Depairtment of Environmental Quality.

17 These individuals are here to provide answers

18 to technical questions you may have about the information

19 available to the Air Force for cleaning up the site.

20 Our presentation this evening will consist of

21 a description of the remedial alternatives and an explanation

22 of how each one would improve the environment.

23 Following the presentation, if you think you

might want a little stretch, we will take a short break, [

25 after which we will move to the most important part of this

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 3

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PUBLIC MEETING RE PROPOSED PLAN FOR OPERABLE UNIT 4, 10/19/93

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1 meeting this evening, the part where you tell us what you

2 think of the proposed plan.

3 First, however, I need to take care of some

4 administrative details. As you can see, everything being

5 said here tonight is being recorded word for word and by a

6 professional court reporter. This is required as part of the

7 CERCLA requirements.

8 The transcript will become part of the

9 administrative record and will be available for anyone to

10 view or to read at our repository and our administrative

11 site.

12 I hope all of you took the time to stop and

13 sign in at the door. We use those names and addresses to

14 make sure you get any information we have on the Hill

15 Environmental Restoration so you're kept up-to-date on what

16 we do and how we do it. That way you can tell us about it as

17 we're doing it.

18 We will give everyone an opportunity to

19 comment. There is a large crowd here tonight, so at the

20 beginning I would ask that you keep your comments to at least

21 five minutes. Everyone will have an opportunity to speak,

22 and then we'll come back to you. That way we will get

23 everyone in.

24 If you have a prepared statement to read, you

25 may read it out loud, turn it in without reading it or read

D KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS

AMY STOLTENBERG, CSR, RPR 4

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1 it and turn it in. In any case, your comments will become

2 part of the official record, and they are extremely important

3 to us.

4 If you later wish to make a comment or add

5 something that you have said or need something cleared up for

6 you, there is an address in the proposed plan. Please send

7 any comments you have to that address. Our phone number is

8 in there. Just give us a call. There is also a phone number

9 and address for Rob Stites, for Duane Mortensen, for

10 Muhammad Slam and for the community involvement from the

11 E.P.A. and U.D.E.Q.

12 I would like to emphasize that no final

13 decision has been made. That's our purpose for being here

14 this evening. However, based on all of the collected data

15 and the analyses, we do have a proposed plan to give to you.

16 What we will do this evening is to explain the

17 alternatives that we considered and then tell you why we

18 discounted those.

19 The final part of this presentation is otir

20 primary purpose tonight, and that is to listen to you. We

21 want to hear your comments on any issues, and we will try to

22 answer any questions.

23 If we can't answer them this evening, we can

24 certainly get back with you within the next couple of days

25 with an answer that is satisfactory to you hopefully. We

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1 want you to be satisfied that the action that we take

2 properly and fully addresses the problems at this site.

3 As the presentation is made, please make note

4 of any (questions that you might have. You'll be given the

5 opportunity to express them following the presentation.

6 Bob Elliott is the chief of our Environmental

7 Restoration Division, and he'll begin the presentation this

8 evening.

9 MR. BOB ELLIOTT: Thank you, Gwen.

10 This is a little bit awkward. I'm going to

11 use some overheads and slides and try to step out of your way

12 so you can see this. I want to be sure that if anybody has

13 trouble seeing, that you wave your hands or let me know.

14 Usually, that hasn't been a problem. People usually speak up

15 in these meetings to us.

16 I guess initially I would like to say that

17 it's unfortunate that we have to be here tonight because of

18 the fact that there is contamination in the community, but I

19 think the positive side of that is that we are finally after

20 a long period of study and evaluation presenting some

21 proposals to the public to fix those problems. So that's

22 certainly the positive side of the things that we're looking

23 at.

24 Can everybody see? Are we okay with that?

25 Are there any problems seeing in the back?

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 6

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1 Okay. I'll try to speak as loudly as I can.

2 If you have problems hearing me, please speak up.

3 Operable Unit 4 is located on the north side

4 of Hill Air Force Base. (Indicating.) Here is Hill Air

5 Force Base. The boundary is represented by the dotted line.

6 Most of you are very feuniliar with the base. The site is

7 located adjacent to the North Gate exit at the base.

8 (Indicating.) Here is South Weber Drive, Interstate 84.

9 MS. GWEN BREWER: You can tedce the mike off if you

10 want to hold it in your hands.

11 MR. BOB ELLIOTT: Can everybody hear me okay?

12 MEMBER OF THE PUBLIC: Can you pull that back up

13 and show us where the school would be located?

14 MR. BOB ELLIOTT: (Indicating.) The school would

15 be located over here in this vicinity. The Riverdale

16 City/South Weber City line essentially runs right down the

17 middle of the site, if you will.

18 Does that help? Any other questions or

19 orientation that I can —

20 MEMBER OF THE PUBLIC: Where is Mr. Cutler's

21 place? Can you point that out to me, where it is on this

22 map?

23 MR. BOB ELLIOTT: Mr. Cutler? Yes. (Indicating.)

24 He lives just off of South Weber Drive right here. j i

25 MEMBER OF THE PUBLIC: Where the dump stations

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR D

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1 are?

2 MEMBER OF THE PUBLIC: Is that Where it's located?

3 MEMBER OF THE PUBLIC: That's where it's located?

4 MR. BOB ELLIOTT: (Indicating.) Directly to the

5 north of this green dot.

6 MEMBER OF THE PUBLIC: On his land; right?

7 MR. BOB ELLIOTT: I'm sorry?

8 MEMBER OF THE PUBLIC: On his land; right?

9 MR. BOB ELLIOTT: The sites are on Hill Air Force

10 Base.

11 We'll go through — I think we'll go through

12 and answer those (questions as to the location and give you a

13 feel for that. So if you can hold your questions until after

14 we do the presentation, I think we'll answer a lot of those

15 as we go through it.

16 I'm filling in for one of my colleagues who is

17 out with a back injury, and his name is Shane Hirschi. Many

18 of you have worked directly with Shane. As a result of that,

19 I asked Mr. Gary Colgan, who is one of the consultants who

20 has worked with us on this project for a number of years, to

21 do a presentation on the technical issues associated with the

22 site, the exact location of the site and to review the

23 alternatives. I'd like to let Gary go through that

24 information right now.

25 MR. GARY COLGAN: Thanks, Bob.

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 8

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1 Good evening. I'm going to follow on from

2 Bob's presentation and discuss the situation at the site and

3 some of the sites that are involved and how the contamination

4 originated, what the principal contaminants are and talk

5 about some of the alternatives that we have looked at. Then

6 Bob will talk about the evaluation process that we have used

7 to develop our preferred — or the Air Force's preferred

8 alternative in this case.

9 As Bob indicated, O.U. 4 is located on the

10 hillside above the South Weber — above the Weber valley.

11 It's above the Davis-Weber Canal and South Weber Drive. I'll

12 leave that on a second.

13 The investigations have focused on several

14 sites there, including these locations. (Indicating.) There

15 is a Spoils Pit area which received construction debris; a

16 Munitions Dump area, which was World War II — was a location

17 for above-ground storage of munitions; Landfill 2, which was

18 a regular dump site basically for domestic waste, some

19 construction debris; North Gate Dump area, which is this area

20 here and this area here (indicating), which were — These two

21 areas are where some drums of chemicals were suspected to be

22 dumped. Landfill 1 is another — basically a landfill where

23 domestic debris and some other materials were placed.

24 During our investigations, we have found that

25 Landfill 1 appears to be the main source — really, the only

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1 significant source of conteunination to ground water and

2 surface water which we have found below the site which

3 extends beyond — underneath the Davis-Weber Canal and out

4 into the valley here.

5 The primary conteuainant at this site, although

6 — There are several other ones, but this is really the one

7 we're looking at that drives all of the risk and is of the

8 most concern. It's trichloroethene or trichlorethene. The

9 acronym for that chemical is TCE, and I'll be referring

10 mainly to TCE.

11 There are several other compounds associated

12 — other organic chemicals associated with this site also

13 which are at present at much lower concentrations and are not

14 as big of a concern.

15 There are also several metals that have been

16 detected, but these detections are very spotty, and they all

17 lie within the TCE pltime. We use the TCE as basically —

18 because it contains the aerial extent and is the largest of

19 any contaminants at the site.

20 Trichloroethene is a solvent that's been used

21 at the base — was used at the base for quite a long time as

22 a degreaser and for cleaning up aircraft parts and things

23 like that.

24 So as you can see, there may be some questions

25 on — (Indicating.) As you can see, here is the base

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1 boundary again. There is the Davis-Weber Canal.

2 Everyone was asking where Mr. Cutler's house

3 is. (Indicating.) His house is right in this crook here.

4 There is actually a steep hillside here which defines the

5 northern extent of conteunination as we found it, so it does

6 not extend north of South Weber Drive.

7 As far as levels or concentrations of

8 contamination, the highest levels detected have been 18,000

9 parts per billion.

10 A part per billion is equivalent to basically

11 one particle in a billion particles of either water, soil,

12 air or whatever media we're referring to.

13 Offsight, the highest conteuninations detected

14 is 3,000 parts per billion. So, really, the majority of the

15 worst of it is still on base. There are definitely some

16 significant levels off base, (indicating) mainly in this area

17 with lower concentrations off in this northwesterly

18 direction.

19 Ground water is flowing — as evidenced by the

20 plume and other factors which we examined, is basically

21 flowing off this direction. (Indicating.) That would be the

22 northeast.

23 MEMBER OF THE PUBLIC: That would be a thousand or

24 1500 feet down the North Gate road?

25 MR. GARY COLGAN: Yeah. The North Gate is

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 11

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1 actually right here (indicating), so I don't know. There is

2 probably a scale up here. That sounds pretty close. There

3 is 500 feet right there. (Indicating.) Here's the

4 North Gate dump. The worst of it is 500, a thousand,

5 1500 feet.

6 MEMBER OF THE PUBLIC: Away from the North Gate to

7 the north?

8 MR. GARY COLGAN: Okay. Yeah, that would be a

9 thousand feet this way. (Indicating.) If you start from the

10 source to South Weber Drive, that looks like about 1500 feet,

11 so approximately, you know, a little over a quarter of a

12 mile, something like that.

13 (Indicating.) This is another view of the

14 contamination. This is a cross-sectional view looking at the

15 hillside. This is a pretty steep hillside. You're all

16 familiar with the hillsides above the school here. This is

17 very similar. It's part of the South Weber Landslide

18 Complex.

19 Contaminants have migrated from the landfill

20 to the water table or down to t:he shallow ground water and

21 have moved through the ground water in a pretty shallow area.

22 (Indicating.) This is roughly 20 feet thick,

23 about 10 or 15 feet below the ground surface, so the maximum

24 depth of contamination is about 30 or 40 feet.

25 Most of the contamination is moving through

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 12

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1 sands and gravels which allow water and conteuainants to flow

2 much more easily than through clays and other fine-grain

3 materials.

4 Below these areas where we have — It's kind

5 of complicated by landslides and remnant landslide pathways.

6 Below this area where we have sand and gravel, it's a much

7 more coherent section of clays and silts and things that are

8 much harder for water and contaminants to flow through.

9 (Indicating.) Several hundred feet below this

10 area, you know, down — scalewise down here are where the

11 drinking water aquifers — Sunset Aquifer and Delta Aquifer

12 are. That's where drinking water in this area is teJcen from

13 by wells. There are no wells using this shallow water in

14 this area. No one is using the water for drinking or other

15 uses at this time.

16 MEMBER OF THE PUBLIC: Excuse me. When was the

17 last time they used that? Do you know?

18 MR. GARY COLGAN: I don't know, except maybe from

19 — The seeps from the hillside may have been used for

20 watering cattle, but I don't think anyone has used it

21 directly as a water source. If we went back 20, 30, 40

22 years, somebody could have used it at a limited basis from

23 the seeps. The seeps only flow a few cups or so a minute.

24 They're slow producers. They wouldn't be good water

25 supplies.

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 13

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1 Now, once we completed this study here, we

2 looked at the risks that this site may pose based on the

3 chemical sampling we did and the analyses that were

4 performed.

5 Now, the risk — We did a detailed risk

6 assessment on this site to identify what the health concerns

7 really were. The upshot of this risk assessment was that

8 there are no current risks opposed to the community because

9 of this site. That's because the main contaminations are

10 confined to the ground water, which is not used. There are

11 no — Because no one is using the drinking water, there is

12 really no risk, so that's one point.

13 To look at this more closely, we examined the

14 current risks based on two scenarios. The first one is the

15 inhalation of conteuainated air by on-base workers, people

16 working on base. What is the risk to them?

17 The cancer risk here was calculated as two in

18 100 million excess cancers. That means out of 100 million

19 people, two additional cancers will result because of this

20 risk or could have the potential to result. This is compared

21 to in your — In all of our lifetimes, you have the potential

22 — It's basically about a one in four potential of contacting

23 cancer sometime in your life.

24 (Indicating.) This is the incremental risk

25 E.P.A. considers an acceptable cancer risk, something that is

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 14

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1 less than one in a million. So you can see this cancer risk

2 is 50 times less than the acceptable risk.

3 For inhalation of contaminated air by the

4 Weber valley resident — This is contaminated air coming up

5 through someone's basement, from the ground water

6 contamination itself. The cancer risk is six in 100 million,

7 so this is actually slightly more than the risk to on-base

8 workers, but still much — well below the acceptable cancer

9 risk. Now you realize what are we talking about if there is

10 no current risk.

11 We also looked at future risk scenarios that

12 present a somewhat different story. The future risk

13 scenarios we looked at were mainly associated with drinking

14 the contaminated water. If someone in the future put a well

15 in the shallow atjuifer and used it as a drinking water

16 supply, the risk was seven in 1,000. This is compared to an

17 acceptable risk, as we talked about last time, of one in one

18 million. This is considered a significant risk.

19 Also, another way we calculate risk is to look

20 at illnesses or other kinds of health problems, health

21 effects that could be caused that are not cancer or related

22 to cancer, and we used something called a hazard index.

23 If the hazard index is greater than one, it's

24 a significant risk. In this case, it's 50. So, therefore,

25 if someone put a well in a contaminated shallow aquifer in

^u

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1 the future, there is a significant risk both for cancer and

2 noncancer health effects to — that could be to them.

3 Another scenario was to look — (Indicating.)

4 This was for on-base residents. Say the base closed and

5 people started building houses in the area overlying the

6 ground water plume now in the valley where concentrations are

7 somewhat less than we have shown on the base for Weber River

8 residents.

9 These risks are one in 1,000, seven times

10 less. If you look at all the numbers, it's still a

11 significant risk. The hazard index is lower than the 50,

12 which we calculated — estimated to be six, but it's still

13 greater than one. Again, this is considered by the risk

14 assessors and E.P.A. — these two things as a significant

15 risk for long-term.

16 If someone were to use domestic water from the

17 Sunset Aquifer, which is, as I said, several hundred feet

18 below the ac^ifers that are conteuninated or the shallow

19 aquifer that is contaminated — We looked at that scenario,

20 and the risk there for cancer is three in 10 million compared

21 to the one in one million, so that is not a significant risk.

22 By the same token, on the hardard index, potential for

23 noncancer illnesses, it's .0005 compared to one. Again, not

24 considered significant.

25 So to summarize the risks, there are no

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 16

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1 current risks because no one is drinking the water.

2 You say, well, is there potential for someone

3 to breathe air in their basements? We have analyzed the air

4 from basements in some of the residents overlying the ground

5 water contamination. Although there have been very low

6 levels — some trace levels of TCE detected in one of the

7 houses, the risks indicate there is no significant risk to

8 those people.

9 However, there are some future risks that if

10 things change and people use the aquifer as a drinking water

11 aquifer, it could create serious health effects, but that

12 assumes someone will use it as a drinking water source.

13 So that's why we're here talking about a

14 solution. The Air Force will propose a solution for this

15 situation to address future risks.

16 Okay. Now, in order to evaluate — in order

17 to come up with some ideas for potential solutions, we

18 divided our alternatives into foxir groups. You can follow

19 along in your proposed plan with me if you would like since

20 you have that. It's the section called Summary of Remedial

21 Alternatives on Page 8.

22 The first set of these alternatives are broken

23 into Ground-Water Alternatives, Surface-Water Alternatives,

24 Landfill Contents Alternatives — That's directed primarily

25 — or specifically at Landfill 1 — and Air Alternatives.

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 17 I

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1 Groimd water. It's fairly obvious what the

2 ground water is. It's that shallow aquifer that I indicated

3 is contaminated.

4 Surface water. We're referring to the seeps

5 that are on the hillside. To date, we have sampled the

6 Davis-Weber Canal. In fact, well water runs well underneath

7 that canal. There's no connection between the two of them,

8 and there is no contcuaination in the canal.

9 Landfill Contents refers to what's in

10 Landfill 1.

11 Air relates to the potential for contaminated

12 air to be in people's basements where they could breathe it

13 and become exposed.

14 The Ground-Water Alternatives — I'll give you

15 a quick rundown on these — Include No Action, which is

16 something we're required under E.P.A. guidance to evaluate,

17 what happens if we do nothing. That's the base line we need

18 to compare everything else to.

19 Limited Action in this case would mean

20 continuing to monitor the ground water that — to make sure

21 ground water contamination does not travel further and, also,

22 we could be restricting — basically asking the State of Utah

23 to restrict people from drilling wells in the shallow

24 aquifer.

25 Alternative 3 is the collection and on-site

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1 treatment of contaminted ground water using air stripping,

2 which is one technology to treat ground water and then

3 discharge it to the Weber River or the local sewer system.

4 Alternative 4 is similar to Alternative 3, but

5 we would be directing the water and treating it using a

6 different treatment technology, using oxidation, also called

7 U.V. oxidation, ultraviolet oxidation.

8 Alternative 5 is more interesting, and it's an

9 emerging technology that we will study ftirther. It's

10 Metal-Enhanced Reductive Debalogenation. That's a long trip,

11 but basically what it is is putting a wall which is composed

12 of iron filings and sand into the ground and allowing water

13 naturally — the ground water which flows under its natural

14 motion to flow through the wall.

15 Researchers have found that the combination of

16 iron — It's really that the iron creates a chemical system

17 such that these contaminants such as TCE will be completely

18 degraded.

19 This would be configured in a funnel and gate

20 system because we would be putting barriers like — metal

21 walls would be driven into the ground and direct conteuainated

22 ground water to the wall, which would be composed of iron

23 filings and sand.

24 So this is something we will be researching,

25 and we are carrying out studies. It shows great promise for

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 19

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1 possibly helping us with this site.

2 Surface-Water Alternatives include No Action.

3 Again, this includes continuing to monitor the seeps and

4 evaluating whether the chemical concentrations change with

5 time.

6 Limited Action, which could be things like

7 fencing the seeps to keep children and livestock away from

8 them.

9 Alternative 3, collecting and treating at the

10 seep locations using carbon absorption similar to the carbon

11 you would use in a filtering system at home and discharging

12 this back to the ground and into the ac[uifer.

13 Alternative 4 would be collection and using

14 on-site treatment, using the same technology I just described

15 with the iron filings in a canister above the ground. The

16 other one was below the ground.

17 Alternative 5 would be to collect and treat

18 the water and discharge it the seune way we would with the

19 ground water alternatives. That involves running pipes from

20 the seeps to the ground water system.

21 The Landfill Contents Alternatives include

22 No Action; Limited Action, which would include surrounding

23 the landfill with a fence to keep people out; Containment,

24 which would be putting a clay or some kind of polyethylene

25 cap on top of the landfill to prevent water and rain water.

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1 snow melt from moving through the landfill contents and

2 carrying with it contaminants which would move into the

3 ground water.

4 Alternative 4 is Containment and In-situ

5 Treatment, meaning in-place treatment. This would involve

6 both the cap from water moving in and an active treatment

7 system. In this case, soil vapor extraction where we hook up

8 wells with vacuums on them to suck out the contaminants. TCE

9 is very volatile. It will evaporate quickly.

10 Alternative 5 is Excavation and Disposal.

11 This means dig up the landfill, segregate what we can and

12 dispose of it in a hazardous waste facility, such as

13 U.S.P.C.I out west of Tooele.

14 The last set of alternatives is alternatives

15 for air directed at making sure people are not affected by

16 contaminated air in their basements.

17 Alternative 1 includes No Action. No Action

18 in this case includes monitoring in people's homes as long as

19 we feel there is still a ground water problem to make sure

20 they're not exposed to significant levels of contamination.

21 Limited Action could include the leasing of

22 people's property if it becomes a problem or asking the city

23 to impose certain building restrictions or codes to prevent

24 contaminated air from moving into people's basements.

25 Alternative 3 could be to collect any

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 21

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1 contaminated air in people's basements and either discharge

2 it to the atmosphere, if it's a minor concentration, or treat

3 it.

4 So those are the alternatives that we have

5 looked at for Operable Unit 4, and they focus mainly on what

6 to do with land and conteuainated ground water and surface

7 water coming from it.

8 Now Bob Elliott will explain the criteria we

9 used to sift through these alternatives and how the Air Force

10 has come up with their preferred alternative that they would

11 like you to comment on tonight.

12 MR. BOB ELLIOTT: It's important to understand

13 that, in addition to the alternatives that Gary just talked

14 about, many other alternatives were looked at. Some of those

15 alternatives were eliminated in a screening process for the

16 following reasons.

17 One, the technology may not reduce the

18 contamination to an acceptable level. The technology might

19 not be amenable. A simple case of 1:hat would be technology

20 that, because of the steep hillsides associated with this

21 site, could not be constructed or put in place on those

22 hillsides or an excessive cost where there was some other

23 technology that would achieve an equal protective standard.

24 The remaining alternatives were based on —

25 were evaluated based on nine criteria. I would like to go

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 22

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1 through those nine criteria with you.

2 Okay. It's important to note that the first

3 two criteria must be met. There is no option as far as

4 looking at an alternative that will not meet those first two

5 criteria.

6 The first one is the most important, being

7 protection of human health and the environment, protection of

8 people's health.

9 The second one is wrapped around insuring that

10 we comply with any state or federal laws that apply to the

11 site and that are relevant to the site. We must meet any of

12 those laws.

13 Okay. The other criteria are what we call

14 balancing criteria, and they are used to help sift through

15 the list full of technologies and alternatives that are

16 available for the site.

17 One of the things we have to look at is

18 short-term risks of anything that we do associated with this

19 technology. Will it protect the short-tema risks of the

20 resident, and will it protect the short-term risks of

21 construction workers, for example. So that's one thing we

22 have to look at.

23 Then the long-term effectiveness. Will this

24 remedy solve the problem long term.

25 Reduction of the toxicity at the site.

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 23

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1 Mobility or the ability of the contaminants to

2 move away from the site or to further degrade the environment

3 and propose additional risks.

4 Can the technology be implemented. We already

5 talked a little bit about that.

6 What is the cost associated with the

7 technology. We must, as mandated by congress, look at the

8 cost.

9 State acceptance associated with having the

10 state involved in our review, as we have had them involved

11 for — since the inception of our progreun.

12 Finally, community acceptemce, and that's the

13 important reason why we're here this evening.

14 MEMBER OF THE PUBLIC: Excuse me. The cost — Is

15 it your cost or our cost?

16 MR. BOB ELLIOTT: Well, it's your cost as the

17 taxpayer, I guess.

18 MEMBER OF THE PUBLIC: Our cost for our land or

19 your cost?

20 MR. BOB ELLIOTT: No, it's the cost associated

21 with the cleanup alternative.

22 Okay. I would like to talk about the

23 alternatives that we have sorted out of all of this. You can

24 follow along — Let's see — on Page 9.

25 MR. GARY COLGAN: Page 13.

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1 MR. BOB ELLIOTT: Here we go. There is a table on

2 Page 13. There is some background information associated

3 with those alternatives.

4 As you can see, for Ground Water,

5 Alternative No. 3 has been proposed by the Air Force, and it

6 consists of ground water collection by various means,

7 horizontal drains in the hillside, wells and then collection

8 and treatment by stripping — air stripping.

9 Again, as Gary mentioned, these compounds are

10 volatile in nature. They evaporate easily. Air stripping is

11 a mechanism to get them to evaporate and get them out of the

12 water.

13 As you may note, time of implementation would

14 be approximately 15 months. That would be the time to design

15 the system and begin construction. You can see the costs

16 associated with that.

17 Surface Water. We've proposed collection and

18 treatment with carbon. The primary reason associated with

19 that is because these small springs are scattered along the

20 hillside. These carbon filters, if you will, will treat

21 those springs very easily without the high cost of running

22 extensive pipelines along the hillside.

23 We can go back through these during the

24 question and answer period if you would like some more

25 clarification.

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 25

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1 Okay. The Landfill Contents. Alternative 4

2 is being proposed. It consists of capping the landfill and

3 treating it with a vapor removal system to remove those

4 highly evaporative or volatile chemicals that are in the

5 landfill.

6 Okay. Air is Alternative l, which includes

7 sampling and monitoring of any basements or exposure areas

8 where people would be exposed to the air to insure that those

9 levels do not change or increase.

10 MEMBER OF THE PUBLIC: Sir, could you elaborate on

11 the chart? You indicate that the costs of those preferred

12 alternatives is based on the discharge option or the type of

13 cap. Are we saying that this is the more expensive method

14 here, or is this the lower grade of the type of disposal

15 capping or discharging as another option?

16 MR. BOB ELLIOTT: Okay. Can I hold that question

17 until we get into the question and answer period? Then we

18 can go through that. I want to try to do that so that —

19 Otherwise, we tend to grade into a whole bunch of questions,

20 and we don't move forward,

21 Essentially, that identifies the alternatives

22 that the Air Force is proposing. I would like to allow

23 Mr. Stites from the E.P.A. and Mr. Muhammad Slam from the

24 Department of Environmental Quality, if they have any

25 comments they'd like to make, to make some comments, and then

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 26

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1 I think Gwen wants to begin the questioning period.

2 MR. ROBERT STITES: I'll be very brief. I just

3 wanted to welcome everybody and thank you all for coming.

4 I'm gratified to see this kind of a turnout for this.

5 I wanted to let you know this is your meeting.

6 We want your input on what you're hearing here, whether you

7 like it, whether you don't like it, what things you do like,

8 what you don't like.

9 Also, if you have some significant information

10 that you think we're overlooking, let us know because this is

11 the one big best shot at having your good input into what

12 we're going to be doing about things here.

13 Now, if you don't have any comments tonight,

14 don't think that you have to say anything, but if there is

15 something that's bothering you and you want to think about

16 it, keep in mind the comment period is open until

17 November 5th. There is a name and address here for

18 Gwen Brewer. You can send in written coiaments to that

19 address, and they will be responded to in the — as part of

20 the decision.

21 Just one last little item. We did not

22 deliberately schedule this meeting opposite a World Series

23 game. It was just poor luck.

24 Now, if you have any comments Muhammad Slam.

25 MR. MUHAMMAD SLAM: Good evening, ladies and

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 27

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1 gentlemen. My name is Maheunmad Slam. I'm with the State of

2 Utah Environmental Quality. The State of Utah has been the

3 support agency working with Hill Air Force Base and E.P.A.

4 toward the cleanup of this site.

5 With me tonight are Diane Simmons, our

6 Community Relations Coordinator, and Duane Mortensen, our

7 Section Chief.

8 I would like to say it's sincerely a pleasure

9 to be here tonight. The proposed plan you just heard being

10 presented today has been a long time in coming. All the

11 parties, the E.P.A. and Hill Air Force have worked long and

12 hard to reach this point, but I would like to say that this

13 is only a beginning.

14 I also would like to thank all the people that

15 took time out of their schedule to be here and miss the

16 World Series. The Department of Environmental Quality wishes

17 to hear from you all, the people, all the concerns you have.

18 Otir names and addresses are in the proposed

19 plan, which is the handout for today. Like Rob and everybody

20 said, the comments here are open until November 5th. You can

21 present your comments either to Hill Air Force Base, the

22 E.P.A. or the State of Utah. We'll welcome your input.

23 Thank you very much.

24 MS. GWEN BREWER: Are you all okay? You're

25 comfortable in going on? Okay. Let's start hearing from

0 KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS

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1 you. What do you have to say?

2 MR. THAYNE THOMAS: I'm Thayne Thomas.

3 T-h-a-y-n-e T-h-o-m-a-s.

4 My question was on this Preferred Alternative

5 Table 2. The footnotes here indicate that the cost depended

6 on discharge options and are evidently variable. My question

7 was, the dollar amount up there, would that be considered a

8 maximum amount or would that be considered an average amount?

9 The seune applies to the lower —

10 MR. GARY COLGAN: The costs in there — There is a

11 way we calculate costs. It's present worth — It's basically

12 if you can put the money in the bank and have a certain

13 interest over a 30 year period, how much would it cost.

14 At this point, we haven't designed these

15 systems. The estimates are minus — range from what's kind

16 of a middle ground, but it could be minus 30 percent of that

17 up to plus 50 percent of that value. So that's kind of our

18 best estimate at this time, but it could have quite a bit of

19 variability.

20 For the Ground Water, there are a couple of

21 options built in there. One is the discharge to the sewer

22 after we treat the water, and the other one is the discharge

23 to the Weber River, which would mean constructing a pipeline

24 to the Weber River. We'd need a permit with the state and

25 everything, and that's why the range in the cost. They are

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 29

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1 reflecting two options.

2 The same thing for the Landfill options. We

3 have two different kinds of caps that we looked at, a clay

4 cap and then a cap which would involve clay and — They call

5 it multi-media. It's basically — They call it high density.

6 It's some kind of polyethylene or plastic liner which would

7 be part of the clay, and the clay together would be the cap

8 or the multi-media. So that's why there is a range for the

9 Landfill.

10 MS. GWEN BREWER: (Indicating.) I'll take this

11 gentleman and then work toward the back.

12 MR. RAY GIBBONS: My neune is Ray Gibbons,

13 Riverdale area. G-i-b-b-o-n-s.

14 In this air stripping process, what happens to

15 the contaminants after it gets into the air? Is there any

16 air pollution problem then?

17 MR. BOB ELLIOTT: Again, as I mentioned, as part

18 of our criteria, we must meet all of the environmental

19 regulations and requirements that are appropriate. If we are

20 discharging something into the air that's above an acceptable

21 level to the state air quality people and to the Davis County

22 air quality people, we must treat that air. There are

23 treatment alternatives built into those alternatives.

24 MR. MUHAMMAD SLAM: Basically what he's saying is

25 the air would be monitored and treated if necessary before it

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 30

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1 escapes into the air.

2 MR. GARY COLGAN: On Page 9, midway down in the

3 left column it talks about, "Air emissions would be captured

4 and treated by a catalytic oxidizer to destroy the organic

5 contaminants in compliance with the state and federal air

6 (^ality standards."

7 So it's basically a catalytic converter

8 similar to a catalytic converter in a car. It would be

9 treated.

10 MS. GWEN BREWER: In the maroon jacket in the

11 back.

12 MR. KEN PARKINSON: Ken Parkinson,

13 P-a-r-k-i-n-s-o-n.

14 What I wanted to talk on was the alternatives

15 chosen for the ground water and surface water. How

16 equivalent, per se, would that be located on Deran Cutler's

17 grotind that would deem his ground actually worthless as far

18 as he was concerned? I think there should be some kind of a

19 compensation of fair market value for his ground for

20 relocation or whatever.

21 MS. GWEN BREWER: Sir, right now we are checking

22 out ways that we can take care of that problem for

23 Mr. Cutler.

24 MR. PATTERSON: What about for the rest of the

25 residents?

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1 MS. GWEN BREWER: If it's a situation where in the

2 conduct of a cleanup action we need to purchase that

3 property, we will go to the Air Force for it. Normally, the

4 Air Force does not purchase property. Each of those would

5 have to be tedcen on a person-by-person basis.

6 (Indicating.) Yes, ma'eun.

7 MS. LOLA PATTERSON: I'm Lola Patterson. I'd like

8 to know how long you propose this will take until we can get

9 our land back.

10 MR. BOB ELLIOTT: This is part of the painful

11 part. I guess these cleanups take — are estimated to take

12 (}uite some time, and there has been some discussion that it

13 could take up to 20 years.

14 Let me explain the reason why that occurs.

15 The contaminants that — TCE — that are in the aquifer

16 material tend to stick, if you will, to the soils that are

17 there. So as water moves through those sands and gravels,

18 the contaminants tend to like to stick on those soils and not

19 move very well.

20 If you think of oil and water together, they

21 don't mix very well, and that's a common analogy with the

22 chemicals that we're talking about, the organic chemicals

23 that tend not to go into — dissolve into water very easily.

24 So it could take a long time. The challenge

25 is that we don't know how long — we don't have a very good

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 32

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D estimate right now of how long it's going to take because we

haven't run a treatment system out there. We are currently

doing some studies to evaluate those and to get some better

estimates associated with those projects, but I want to be

real honest with you so that you understand the kind of time

tables that are associated with these cleanups. That's not

an easy thing to tell people, that it's going to take that

period of time.

MS. LOLA PATTERSON: I'm concerned on it because

you have a meeting like this and basically freak out this

city. South Weber freaks out and puts all these caps on us

for everything, and our land is virtually rendered useless to

us for this length of time.

Now you tell me it could take as many as

20 years. At the end of that time, are you going to come

back and tell us that it's free and clear and we can build

and use our land like we could, or do you let it go and hold

onto it so the restrictions will stay on the property

forever?

MR. BOB ELLIOTT: I guess the important thing to

recognize is that in cases where some building has not been

allowed, it's really been your city people who in conjunction

with us and working with us have made those decisions. They

have been made, I think, in the interest of public health,

not in the interest of tying up anyone's property for

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1 20 years.

2 It's important to recognize also that if your

3 property has been damaged, that there are alternatives

4 available to you through the Air Force to recover damages

5 through the Air Force claims system. You need to understand

6 that.

7 MS. LOLA PATTERSON: I understand that, but I

8 don't see that you're going to pay me for the value of the

9 land. I mean, we were here before Hill Air Force Base was.

10 The property has been in our family for bookoo years. Now

11 all of a sudden the Air Force has damaged it. We can't

12 subdivide it. We can't do anything on our property.

13 In fact, we have tried recently, and I have a

14 letter from you people telling me that there is no damage to

15 the crop, there is no damage and no potential problems for

16 what we have on it.

17 I asked about trees and apples and things like

18 that, and he tested for me and told me it was fine. Then I

19 read in the cotton-picking paper that all these things are

20 there and they're damaging to us and potentially a health

21 hazard. What am I to believe? How can I believe you when I

22 get hit with things like this?

23 MR. WAYNE PATTERSON: Another down winder.

24 MR. BOB ELLIOTT: The important message here is

25 we've been working for a number of years with the

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1 Environmental Protection Agency, with Environmental Quality

2 and Davis County. We hope you can use those people as

3 resources.

4 I understand your frustration. When you look

5 at this situation on a person-by-person basis and people

6 owning properties, it's a tragedy that the Air Force put

7 whatever they put into that landfill, put those solvents into

8 that landfill.

9 I can't change that other than to do today

10 something to try to fix and remedy that problem. I can't go

11 back in time and change what was done, and that's the

12 tragedy.

13 MS. LOLA PATTERSON: I wish too I could get the

14 straight story. I'm frustrated with this because I hear one

15 thing one time, and I turn around and there is another story.

16 Be straight with me. I'm an adult. I'll accept it. But

17 when you lie to me and I get one story from you and get

18 another one from the planning commission, what am I to

19 believe? See, that's where I'm coming from. I think if

20 you're straight with me, you'll have it. If you're not —

21 MR. BOB ELLIOTT: We went on the record tonight as

22 saying we're being straight with you. We're telling you,

23 yes, these are the conditions at the site, and this is the

24 story.

25 If there is a conflict in the past in

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 35

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1 statements, we apologize for that. We try our best not to

2 allow that situation to occur.

3 MS. GWEN BREWER: If you read something in the

4 papers about it, we would appreciate you're not just sitting

5 there thinking about it. If it's something that we told you

6 that's different from what Hill Air Force Base told you, come

7 and ask and/or call Mr. Stites at the E.P.A. or call U.D.E.Q.

8 MS. LOLA PATTERSON: I'll do that.

9 MR. WAYNE PATTERSON: Can we do this on the

10 record?

11 MS. GWEN BREWER: Absolutely.

12 MR. WAYNE PATTERSON: That Way you know what you

13 said in the past and can back it up.

14 MR. CLYDE GAYLERS: My name is Clyde Gaylers.

15 You're addressing only the TCE contaminate in

16 the chemical pit. Are there other things, heavy metal

17 semivolatiles that wouldn't be easily treated with air

18 stripping that you need to address, —

19 MS. GWEN BREWER: Different system —

20 MR. CLYDE GAYLERS: — that haven't migrated very

21 well?

22 MR. BOB ELLIOTT: There is no chemical pit here.

23 MR. CLYDE GAYLERS: Again, in the landfill area.

24 MR. BOB ELLIOTT: We have detected no other

25 compounds coming out of that ground water that would not be

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treatable through this method.

MR. CLYDE GAYLERS: So there is nothing like heavy

metal arsenals that may have been dumped there?

MR. ROBERT STITES: We have a level we need to

address. In other words, there is trace amounts of some

metals and other organics, but their risk and levels of

contamination are so low that they're below any cleanup

standard that would be set anyway.

MS. GWEN BREWER: Yes, sir.

MR. LYNN COY: My name is Lynn Coy, C-o-y.

You're proposing something that's already in

place. The unit is operational. I was there tonight, and

there is six horizontal wells currently drilled. The

strippers were running tonight, and they're discharging water

into the sewer system. My comment is: Why are you proposing

something that's already in place?

MR. BOB ELLIOTT: Okay. The work that's currently

in place is what is known in our business as a treatability

study. We have essentially put those six horizontal drains

or wells into the hillside to evaluate their effectiveness.

Okay? The proposed alternative will have — I don't know the

specific number.

something

MR.

like

Gary,

GARY

that.

you can

COLGAN:

probably help me

It could be 30 or

answer

40 of

that.

them or

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1 MR. BOB ELLIOTT: Some of the information that

2 will be gathered from the study will be used to design the

3 additional wells needed to be put in place to correct the

4 problem and treat the contaminants.

5 MR. GARY COLGAN: To figure out how many we really

6 would need because, without doing a test, we really — it's

7 just a wild guess.

8 MR. ROBERT STITES: More than that, it's to figure

9 out how long a horizontal drain will work and then how many

10 we need. This is only a small component of the final

11 preferred alternative, which is also the other stuff

12 addressing the air and landfill materials and that sort of

13 thing.

14 I need to point out that when you do a

15 treatability study, you're only allowed to do it to a limited

16 degree and limited amount. You're not allowed to use a

17 treatability study as an excuse to clean up outside of your

18 final decision. It's not actually cleanup in advance. This

19 is just a test to see if what we would like to do works.

20 MR. GARY COLGAN: It's a small-scale temporary

21 system basically.

22 MS. GWEN BREWER: (Indicating.) Back here.

23 MR. MARK PERKINS: Mark Perkins, P-e-r-k-i-n-s.

24 On Table 2 on Page 13, Time to Implement,

25 15 months. When does the clock start ticking on that

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1 15 months?

2 MR. ROBERT STITES: When the Record of Decision is

3 signed. Basically, this meeting is going to contribute

4 information that the Air Force is going to use to compile a

5 document called a Record of Decision. That would be probably

6 coming out in the summer is my guess, next summer.

7 MR. MARK PERKINS: Summer of '94?

8 MR. ROBERT STITES: Well, I'm talking about the

9 signing, not the draft. When that document is signed by the

10 Air Force, the State and the E.P.A., that's when this clock

11 starts ticking for the 15 months. This 15 months is a

12 statutory requirement for a federal facility. In other

13 words, they can teike no longer than 15 months to get going.

14 MR. MARK PERKINS: In 15 months after the final

15 document is signed, the cleanup procedures will be operable

16 or construction will start on them?

17 MR. ROBERT STITES: Construction must start —

18 Hopefully, certain phases will already be operable. We've

19 already discussed how we can phase things and expedite

20 construction on the initial phases.

21 MR. MARK PERKINS: When would you anticipate being

22 fully operable and going full bore on the cleanup?

23 MR. BOB ELLIOTT: We would estimate that the

24 construction period would be less than a year, possibly a

25 year in time frame.

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1 You have to remember that we've got winter

2 conditions and those kinds of things. So looking at that

3 construction season, it would take a construction season to

4 construct the alternative.

5 As far as landfill caps, those could be

6 constructed in probably two to three months once a design is

7 completed.

8 The horizontal drilling takes a little more

9 time so — but in one construction season.

10 MS. GWEN BREWER: (Indicating.) Mr. Stark and

11 then the lady in the pink.

12 MR. REID STARK: Reid Stark, s-t-a-r-k.

13 I was wondering about the station you have on

14 the Coy property. Is there more contaminants coming in now

15 or less? Is it the same as when you started?.

16 MR. BOB ELLIOTT: Gary, I'll let you answer. You

17 know the details.

18 MR. GARY COLGAN: The most recent set of data

19 indicates that the concentrations have been decreasing. So

20 it appears like a pulse had gone through the system, and now

21 it seems to be falling off because our drain — these test

22 drains are located right in that area. We're actually

23 pulling out the worst contaminated water right now. We think

24 that the worst has sort of passed, but there is still levels

25 there that are of concern if someone were to drink that

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1 water.

2 MS. GWEN BREWER: (Indicating.) In the back.

3 MS. KATIE PARKINSON: My name is Katie Parkinson.

4 My concerns were like he says. A lot of what

5 you have been talking about — I've gone on that land and

6 seen it too. One of my concerns is that there are three of

7 the horizontal wells that go through the canal — I guess

8 underneath the canal and up on Hill Air Force land. That is

9 draining directly onto what we've been talking about on

10 Cutler's land there. Is that part of your plan to use his

11 land for all of this cleanup? I meem, I know the wells are

12 directly under the canal, so what's coming out of them can't

13 be contamination under his land.

14 MR. BOB ELLIOTT: The wells in length are

15 approximately 300 feet, go back into the hillside

16 approximately 300 feet. I really can't answer the question

17 as to whether or not they are. I don't believe that they're

18 drilled back into — under Hill Air Force Base property, but

19 I'd really have to check that before I —

20 MR. GARY COLGAN: There is really three sets of

21 three. One set is on — starts and goes underneath the

22 landfill totally on Hill Air Force property. The middle set

23 does go underneath the canal and would access water that is

24 under Hill Air Force Base. They do extend three to 400 feet

25 back, and they're at a slight incline so we can use gravity

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to drain. Then there is a lower set which is above

Mr. Cutler's house that we drain. Basically, that wouldn't

go onto Hill Air Force Base property.

MR. ROB STITES: I would like to add what is

currently happening is a temporary condition. The permanent

remedy would not call for water to be openly dumped on any

ground anywhere.

MR. BOB ELLIOTT: I think it's also important to

note that that water is going to end up there anyway because

that's a natural flow pattem of the water. The water is

eventually going to move to Mr. Cutler's property, and so the

concept is the sooner we can get it out and treat it, the

sooner we can clean things up.

MS. KATIE PARKINSON: Just concerning what you

have done so far — I know you're testing. I. realize you

guys caused the problem and, yeah, you really need to clean

it up. I have no problem with that.

Have you considered the people it effects,

what you're putting them through now while you're doing this?

Are you going to compensate anybody for what you're doing to

them now?

house —

been —

I'm with Mrs. Patterson. I went by her

MR. KEN PARKINSON: The ground that's basically

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1 MS. KATIE PARKINSON: I went within a few miles of

2 the place, just the publicity that's happened here —

3 MS. GWEN BREWER: We do know we did something bad.

4 In the future — We can't change that. We're trying to clean

5 that up now. That's all we can do.

6 If there are individual cases, we can refer

7 those to — or you can call us at the base, and we'll teike

8 care of them on an individual basis. We can't say, yes,

9 we're going to take care of all your monetary problems and

10 reimburse you on everything that you have.

11 MS. KATIE PARKINSON: You are not going to

12 compensate for what you're doing?

13 MS. GWEN BREWER: I didn't say that. I said we

14 have to consider each individual case.

15 MS. KATIE PARKINSON: You're saying —

16 MS. GWEN BREWER: We're required to consider each

17 case on an individual basis.

18 MS. KATIE PARKINSON: Doing what you've done up

19 there on the property — I have gone up and seen it. To me,

20 it seems like there is a total disregard for the people

21 living around there.

22 I, for one, like to go out there and let my

23 children chase that hillside. I went up there the other day.

24 There is this big old pond of murky water that's draining out

25 of the wells, and there is nothing preventing any animal or

Q

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1 anything to go in it. Why is that condition there?

2 MR. BOB ELLIOTT: Let me explain what happened.

3 With the rain conditions that we have had — Understanding

4 that from what I heard from the weather service that this has

5 been the sixth wettest October in history here, we — more

6 water has gone into that hillside than we ever had the

7 capacity to treat and to store in the tanks that we have on

8 site.

9 We approached the Central Weber Sewer

10 Improvement District for an emergency permit to discharge

11 water from that site to eliminate that condition. That

12 permit was granted to us early this morning, so that

13 situation has been resolved.

14 MS. KATIE PARKINSON: I asked you too — If a dog

15 or child would have got into that water, could it have done

16 them damage to the extent — Was that the higher risk? That

17 water is the actual water that's contaminated.

18 MR. BOB ELLIOTT: Yes. I'm not a health expert.

19 Maybe Colonel New could better answer that question for us

20 or. Lieutenant Irshad, if you would like to discuss that.

21 LIEUTENANT COLONEL MAX IRSHAD: The contaminants

22 are at low concentrations. As we have discussed on the

23 slides, the concentrations that are there are not

24 concentrations that, if you walk by and breathe something or

25 drink some of the water, that you would, you know, die. It's

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1 not at those kinds of concentrations.

2 Would you guys like to —

3 LIEUTENANT COLONEL GEORGE NEW: George New. I'm

4 with the hospital at Hill.

5 We have looked at that situation. Right now I

6 don't have any results of what's in that pond. Especially

7 with the runoff, you would expect it to be lower. What's

8 going to happen is the rain will dilute it.

9 The levels are very, very low compared to

10 what's allowed in drinking water and even in what we normally

11 use in hospitals. You may not be aware, but we use TCE in

12 hospitals for anesthesia. We're below levels that would

13 cause acute affects.

14 What we can do is work with you and go down

15 and get samples and see if you're concerned about it. I

16 don't have any samples right now.

17 MS. KATIE PARKINSON: What I'm concerned about is

18 the safety. That should be roped off. That shouldn't be

19 accessible to animals. You're not sure yourself —

20 MR. BOB ELLIOTT: I think the situation occurred

21 over the weekend and our —

22 MS. KATIE PARKINSON: It's been a couple weeks

23 since I was out there.

24 MR. BOB ELLIOTT: Okay. We were not aware of

25 that.

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1 MS. KATIE PARKINSON: It was a ditch that had been

2 dug out by a backhoe and had been filled up with water.

3 MR. BOB ELLIOTT: Okay. Yes.

4 MR. GARY COLGAN: (Indicating.) Mike is back

5 there.

6 MR. BOB ELLIOTT: (Indicating.) This is Mike Cox

7 with Montgomery Watson.

8 MR. MICHAEL COX: I'm working on the site up

9 there, and we did — After that pit was dug, we did put a

10 small fence around it. Then recently we did dig out that

11 sump and filled it full of gravel, so there is no pond there.

12 It's been teiken care of. We did tedce care of it.

13 MS. KATIE PARKINSON: Good.

14 I would still like to stress I'm not going to

15 go out and let my children chase on the hill.anymore.

16 It's worthless. I mean, I wish there was some

17 way of compensating the people. It seems like it's not a

18 full compensation. Just get them out of there. Just do

19 something to help them not have to be around this area, and

20 make it fair because these people lived there a long time.

21 Like Mrs. Patterson says, I don't think

22 anybody will want it anymore for some time. My dad is 72.

23 He's not going to give a rat's ass in 20 years whether that

24 property is any good or not.

25 MS. GWEN BREWER: Thank you.

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 46

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1 (Indicating.) Yes, sir.

2 MR. REX FEUSTEL: Rex Feustel, F-e-u-s-t-e-1.

3 Is anybody currently being compensated for

4 land loss?

5 And, if you dump the stuff in the sewer, some

6 of the proposal costs shown here — Is any of the cities

7 involved going to be compensated for the use of their sewers?

8 MR. BOB ELLIOTT: In fact, that's part of our

9 contractual agreement with — or will be part of our

10 contractual agreement with the Central Weber Sewer

11 Improvement District and also with the City of Riverdale.

12 As many of you know, the sewer improvement

13 district is also the Mayor of Riverdale, so it has helped

14 facilitate insuring that we compensate the City of Riverdale

15 for the use of those sewer lines. We will be charged and pay

16 a fee just like anybody would to discharge down those sewer

17 lines.

18 It's important to understand that what we are

19 putting into the sewer lines after we treat it is essentially

20 water. The contaminants are at a level at or below the

21 drinking water standard. Okay? So the contaminants that are

22 being discharged into that sewer system could actually be

23 found in your drinking water. It's not as if what we're

24 putting in there is going to eat away those sewer pipes or

25 anything. It's pretty much just water by the time we treat

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 47

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1 it.

2 MR. REX FEUSTEL: The first part of my question is

3 is somebody currently being compensated for land loss.

4 MR. BOB ELLIOTT: The compensation we have made to

5 date is leasing pieces of property to compensate land owners

6 for the loss of use of that property. That's the primary

7 vehicle that we have available to us right now, so that is

8 the compensation that's been taken to date or been done to

9 date.

10 MS. GWEN BREWER: (Indicating.) Yes, sir.

11 MR. JOE THOMSEN: Joe Thomsen.

12 From what I understand, you've known about

13 this — Oh, shoot — since the early '80s. What's the plume

14 grown like since, you know, you first — your first studies

15 on it?

16 Obviously, you know, you can't control the

17 recent water. You can't even keep it in the pipe. You know,

18 the Corp of Engineers can't keep the Mississippi in the deuns.

19 What about Option No. 5 on that? Remove the

20 sucker. Dig it up and take it out to Tooele and have it

21 disposed of right.

22 MR. THAYNE THOMAS: That's $47 million worth to do

23 that type of program.

24 MR. WAYNE PATTERSON: (Indicating.) All in favor?

25 MR. BOB ELLIOTT: Let me answer your first

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 48

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1 question by deferring to Gary Colgan, who has worked on this

2 project for a number of years and has the most information in

3 his head about where the contaminants have gone.

4 Let me preface by saying you have to

5 understand how an investigation of a site like this takes

6 place. You find contaminants, and then you kind of start

7 marching out away from where you found them to find out where

8 they have moved. So back in 1980, we probably didn't have a

9 good data point to say, well, the plume is here today. The

10 contaminants have moved to this point, and in 1993 we can say

11 that it's moved this far. We can make some estimates of that

12 based on the flow of ground water and the movement of the

13 contaminants.

14 Prefacing that, I'll let Gary talk about the

15 details of that.

16 MR. GARY COLGAN: Most of the investigation work

17 done has been done by the United States Geological Survey out

18 of their Salt LeUce City office. My company took over the

19 feasibility study side of it.

20 It wasn't until about a year ago that we had

21 enough wells in place to understand the complete extent of

22 the contamination. Since then, they have been collecting

23 samples quarterly to get snapshots every three months as to

24 whether the contamination has spread, so we don't have a long

25 history to know whether the plumes spread out with time very

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1 much. We've just recently, a year ago, figured out what the

2 full extent was, so it's hard to know whether it has spread.

3 In this kind of aguifer system, the spread of

4 the contamination is on the order of tens of feet per year.

5 It's not something that's moving much greater.

6 MR. JOE THOMSEN: I have a whole lot in front of

7 my place, and they check it once a week, if not twice.

8 MR. GARY COLGAN: Lately — We've been checking a

9 lot of water levels in connection with the horizontal drain

10 study recently, in the last month or so, to see what the

11 effect of the water on the drain-out of water levels in the

12 area. That doesn't mean we're taking seunples all that time.

13 We're just checking the water level in the wells.

14 So, in fact, you know, up to a year ago, we

15 thought 1:he main source was the North Gate dump area because

16 we had information to suggest people kicked off a couple of

17 drums of TCE in some area. We checked all over there and

18 never could find the source in the soil contamination or

19 anything like that. The more wells we put in, we finally

20 narrowed it down, and it became very apparent that Landfill 1

21 was the source of the contamination.

22 So as Bob said, these investigations kind of

23 evolve. Now we have a very good picture of what it looks

24 like.

25 MR. JOE THOMSEN: Is the plume expanding?

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1 MR. GARY COLGAN: It could be expanding very

2 slowly, and that's something we'll monitor. As I said a

3 little while ago, the latest ground water samples taken

4 indicate the concentrations are decreasing.

5 MR. BOB ELLIOTT: Let me answer the second half of

6 our question, which is why not dig up everything and haul it

7 away.

8 There is certainly a number of issues

9 associated with that. I think the primary issue is that the

10 chemical TCE that we're finding in the ground water is much

11 more easily removed through vapor extraction and through

12 evaporation than by going in and digging up a hillside and

13 removing it.

14 MR. JOE THOMSEN: What I'm getting at is, if the

15 pltime is expanding or still expanding, you don't hedge around

16 it and try to not move it.

17 MR. BOB ELLIOTT: That's the important concept by

18 the horizontal drains. They will collect that water and stop

19 if there is no more water moving through the system. If

20 we're collecting that ground water, the contaminants, there

21 is no water to push the contaminants further. That's the

22 general concept, if that meOces sense.

23 MR. JOE THOMSEN: You hear, oh, so much money from

24 these folks over here. (Indicating.) When you sit in, you

25 know, hundred and fifty thousand dollar houses and all the

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1 sudden they're worth 65, how much are you paying individually

2 for the same thing? So when you say I'd rather the

3 government pay for this and chip in a few bucks on my taxes

4 to do it, individually, you ought to think about that.

5 MR. BOB ELLIOTT: I think the issue of the loss of

6 property value is a tremendous burden that the people that

7 are associated with this site carry, and the Air Force

8 certainly recognizes that.

9 We do not have the authority to, as the

10 federal government, just go and give people money, but there

11 is a formal claims process through which, if you have been

12 damaged by the Air Force, that you can be compensated for

13 those damages. It's important that everyone understand that.

14 Okay?

15 If you would just please call our office, we

16 can get you in touch with the people you need to be in touch

17 with so that you can — if you have been damaged, you can be

18 compensated for those losses, if you will.

19 MR. ROBERT STITES: It's also important to note on

20 that that, essentially, we have the authority to come up here

21 and tell you what we would like to do here. We don't have

22 the authority to settle any claims with you. What would

23 really happen is you would be referred to the appropriate

24 people.

25 MS. GWEN BREWER: (Indicating.) Let's take the

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1 one in the back here, and then we'll come back to you.

2 MR. ALAN MANUEL: My neune is Alan Manuel,

3 M-a-n-u-e-1.

4 Given the amount of time that things were

5 placed in this dump — How was it stored? Was it in metal

6 containers or openly dumped? What type of degression do you

7 predict has happened to these containers, if there are any,

8 and what future degression will happen?

9 In other words, right now my question is: You

10 may have "X" eunount coming out. If these containers have

11 degraded and fallen apart in the future, could the voltime go

12 up? I would assume it could. What will this process that

13 you're proposing do in that case?

14 MR. BOB ELLIOTT: Okay. That's a very important

15 consideration. There are not in any municipal — The

16 landfills that are up here are especially related to any

17 other landfill that someone may have gone to in the '50s or

18 '60s. There were things dumped in those landfills, and we

19 don't have a crystal ball to see inside of those landfills.

20 Records were not kept. I mean, they were the good old dumps

21 you backed up into the hillside, and you dumped stuff into

22 it. The bulldozer covered it up.

23 The concern that maybe there is a drum of —

24 another drum of TCE sitting in that landfill that hasn't

25 degraded is a possibility that exists that we can't discount.

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1 but I think the important part to recognize is that there is

2 an extensive network of monitoring systems around that

3 landfill and down below that landfill that will be monitored

4 through this entire process.

5 Once we finish the remedial action, we go into

6 a period of long-term monitoring of the site. You never get

7 rid of the site. You have them forever essentially as far as

8 a monitoring responsibility to make sure that there are no

9 additional conteuninants showing up in the ground water.

10 That long-term monitoring process runs for,

11 what, Rob, 30 years?

12 MR. ROB STITES: A minimum — Well, until you're

13 clean, which, if you don't get clean, could be forever at

14 least in the absence of a change of the laws.

15 I'd point out as part of the monitoring that

16 if there was something detected coming out, there would be

17 action taken on that before it ever got away from the base.

18 MR. BOB ELLIOTT: Can I — Let me just say one

19 more thing. Because we meJce a decision sometime next spring

20 or summer and sign a document which we call a Record of

21 Decision, the process does not end there. We have a

22 five-year review requirement in which we have to go back to

23 the E.P.A. and go through a full blown review of the site,

24 how well the treatment is working. In that review, a

25 determination is made as to whether or not the alternative

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 54

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1 that is being used is being effective. If it's not

2 effective, other alternatives can be implemented at the site

3 to enhance the cleanup.

4 MR. JOE THOMSEN: Isn't it better to do it right

5 the first time than to have to go back?

6 MR. BOB ELLIOTT: As I mentioned to

7 Mrs. Patterson, we believe we are doing the right thing.

8 This business tends to meike liars out of us

9 sometimes because we may not understand some specific element

10 of the geology that changes or that some condition changes or

11 something and we didn't understand. So the reason that is

12 there is to afford a review and just not let the Air Force

13 walk away from the problem.

14 We sincerely believe that this alternative is

15 the best approach to solving the problem at the site.

16 MR. JOE THOMSEN: It seems like it's the

17 goverrunent — it's the military's or the Air Force's priority

18 that is a problem here because cleaning up contamination is a

19 lower priority than that red flag operation. That red flag

20 operaton that they just had out there probably shot up more

21 in munitions than what it costs to dig up that landfill.

22 MR. BOB ELLIOTT: Okay. Yeah, I guess that's a

23 statement for the record. Thank you.

24 MR. ROBERT STITES: I would like to suggest that

25 you make that statement to your appropriate congressperson.

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 55

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1 Let them know your feelings on what you believe the priority

2 should be.

3 MS. GWEN BREWER: (Indicating.)

4 MR. RICHARD PEEK: Richard Peek. The last name is

5 p-e-e-k.

6 I live just east of this site, approximately a

7 (juarter of a mile from where Deran Cutler lives. There are

8 springs that run off that hill in which the state has drained

9 underneath the road into an agricultural drain that we have.

10 I was wondering if that water has been tested for any of this

11 conteunination, or has that plume evolved eastward to involve

12 that area because I don't see — I see a lot of trucks down

13 in the corner there by Deran, but no one has ever approached

14 me or — myself or my father to ask about that ground water

15 coming off the hill.

16 MR. BOB ELLIOTT: Okay. I don't know specifically

17 the area that you're talking about, but, essentially, a

18 quarter of a mile east of Mr. Cutler's. As we have

19 identified, the contaminants — I think that is to the east

20 of where there are contaminants, but we would be more than

21 happy to come and sample those areas for you to determine if

22 there is a problem there. If you would just check with me

23 right after the meeting, I'll get your phone number.

24 MR. RICHARD PEEK: Because if the canal — The

25 canal is not water tight, okay, because I notice an increased

D KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS

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1 flow when there is water in the canal. Now, if that's

2 leaking down through the hill and picking this stuff up, that

3 would be a concern because that water comes across and is

4 consumed by cattle and other livestock.

5 MR. BOB ELLIOTT: Thank you.

6 MS. GWEN BREWER: (Indicating.) We have a comment

7 back here on that. Michael Cox.

8 MR. MICHAEL COX: On Mr. Cutler's property, we

9 have drilled a number of wells. There is a number of wells

10 on the east side of the property, and we have basically seen

11 that we don't have much conteunination, if any, on that side

12 of the property. It always appears to be moving toward the

13 north and northwest, so there doesn't appear to be a lot of

14 contamination there.

15 MR. BOB ELLIOTT: Please, again, get in touch with

16 me because we haven't solved the problem if we haven't

17 addressed all the issues.

18 MS. GWEN BREWER: In the suit and then back here.

19 (Indicating.)

20 MR. MARK PERKINS: Mark Perkins, P-e-r-k-i-n-s.

21 Are there other sites on the base that have

22 similar problems that have been identified or potential sites

23 that haven't been identified where we would run into the seune

24 thing?

25 MR. BOB ELLIOTT: Could you clarify the same —

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1 what you mean by the seune thing?

2 HR. MARK PERKINS: The same kind of pollution

3 that's moving out into the town.

4 MR. BOB ELLIOTT: There are additional sites on

5 the base. The sites that have been identified on the base

6 have been broken up into groups of sites, and these sites are

7 called Operable Units. Under these Operable Units — That's

8 why we call this Operable Unit 4, which is a group of sites.

9 We're working on very similar — through t i ie exact same

10 process to come to a cleanup resolution for each of those

11 sites as well.

12 There are some areas in the industrial complex

13 of the base, some buildings, that have not been fully

14 evaluated to our satisfaction, and we are currently working

15 on a study to better understand if there were chemicals used

16 in those buildings.

17 That's in the center of the industrial complex

18 of the base, so it doesn't — it isn't up against the

19 South Weber/Hill Air Force Base boundary.

20 MR. ROBERT STITES: I would like to add that if

21 you want detailed information on the sites we know about, you

22 can go to the Davis County Library and look at the

23 administrative records for Hill Air Force Base. There will

24 be a lot of technical information in there, but there is a

25 lot of information.

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1 MR. BOB ELLIOTT: That's the library in Layton.

2 MR. ROBERT STITES: In Layton.

3 MS. GWEN BREWER: (Indicating.) You sir, and then

4 back to you.

5 MR. REX FEUSTEL: Rick Feustel.

6 I live in the 500 block of South Weber Drive.

7 Across the street on the hillside, you've had a shack for

8 three or four years now. Once and sometimes twice a day five

9 to six days a week, somebody goes up there. At first they

10 came with white suits and shoes and gas masks and threw

11 everything in a barrel with crossbones on it.

12 (Laughter.)

13 MR. REX FEUSTEL: Don't laugh. I'm serious.

14 When I asked the people what was going on,

15 they as much told me to mind my own damn business.

16 Then they drilled holes back in my property

17 and on Mr. Peterson's property. You know, nobody has come

18 one time or sent letters as to what the hell is going on.

19 When I ask, they ignore me. I would like to know what the

20 hell is going on over there.

21 MR. BOB ELLIOTT: We apologize for that. What can

22 I say, other than whoever didn't treat you courteously —

23 MR. REX FEUSTEL: Can't you send a letter saying

24 what's going on directly across the street from this thing?

25 Mr. Coy lives across the street from me, and

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1 he sees what's going on here too. When you ask them, they

2 won't tell you what time of day it is.

3 MS. GWEN BREWER: Sir, any time anybody gives you

4 an answer like this, contact us. You have our numbers.

5 Contact the command section at the base. No one should get

6 an answer like that.

7 MR. REX FEUSTEL: You give up after awhile because

8 it's Air Force —

9 MS. GWEN BREWER: That's not an acceptable —

10 MR. REX FEUSTEL: They're the biggest bunch of

11 damn liars I've ever worked for.

12 MS. GWEN BREWER: That's not an acceptable answer.

13 MR. REX FEUSTEL: I know because I worked for

14 them.

15 MR. BOB ELLIOTT: If you check with me, I'll get

16 your neune and phone number and address and make sure we

17 follow up with you on the activities that happen around your

18 property.

19 MR. KEN PARKINSON: We've talked to our

20 congressman like you suggested. We've already done that. He

21 already went to the Air Force, and the Air Force says we've

22 got it covered.

23 MS. KATIE PARKINSON: They sent him the most

24 sugar-covered letter I've ever read.

25 MR. ROBERT STITES: What I was referring to on

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 60

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1 that is if you want — (Indicating.) I believe it was a

2 complaint over here about the military priority on things.

3 If it's a case where you want the priority shifted, approach

4 a congressman.

5 Some of the other politics involved here —

6 I'm sure there's stuff going on that is probably very sad and

7 very unpleasant to all of us, including me. What I was

8 suggesting though is to let your congressman know where you

9 want this program going. I wasn't discussing the issues in

10 particular.

11 MS. GWEN BREWER: (Indicating.) Mr. Poll.

12 MR. BRENT POLL: Brent Poll is my name, P-o-1-1.

13 There was a question asked by I think Rex over

14 here. There are three operable units that affect South Weber

15 city. There is Operable Unit 1 above the school,

16 Operable Unit 2 above Cook property, and there is

17 Operable Unit 4 that we're talking.about this evening.

18 You don't have to go to the Davis County

19 Library to see that. Hill Field has been open, I think, in

20 having the public meetings and town council and explaining

21 just where these things are and at least the preliminary

22 steps to do things, but there are three succinct separate

23 operable units they'll address like this Operable Unit 4.

24 MS. GWEN BREWER: Each is addressed differently.

25 MR. BOB ELLIOTT: We update the city council.

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1 Every six months we go and brief them in their meetings. So

2 if you would get in touch with your city council —

3 MS. GWEN BREWER: Or us.

4 MR. BOB ELLIOTT: — or US, we would be glad to

5 let you know when that schedule is, and you can get an

6 update.

7 MS. GWEN BREWER: If you want us to arrange

8 another meeting, we can also do that at your request.

9 MR. BRENT POLL: While I was talking, I wanted to

10 bring up that quite a lot is predicated on your risk

11 assessment. You put a lot of weight on risk assessments. Is

12 this risk assessment an exact science?

13 MR. ROB STITES: No.

14 MR. BRENT POLL: Is it an art?

15 MR. ROBERT STITES: It's a little bit between the

16 two.

17 MR. BRENT POLL: So when you put up there one in a

18 billion or one in a million, that's a guesstimate.

19 MR. ROB STITES: It's a guesstimate, but based on

20 conservative assumptions.

21 MR. BRENT POLL: But it is very dynamic; is it

22 not?

23 MR. ROB STITES: Do you mean we'll change our mind

24 on what the risk is later?

25 MR. BRENT POLL: It vacilates frequently. For

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 62

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1 exeunple, someone called you a lieu:, and I know you don't like

2 that. Bob said sometimes this business makes liars of us

3 all.

4 Over the years, you've said we're safe here

5 and there is no problem. Now we're spending all this time

6 and meeting, and there is a problem. Over the years — Over

7 the last 25 years, we went from there is no problem to

8 spending millions and millions of dollars and conducting

9 countless meetings to resolve what you once said didn't need

10 to be addressed.

11 MR. ROBERT STITES: We need to clarify current

12 versus potential risk. You are safe here right now.

13 MR. BRENT POLL: Thank you.

14 MR. ROBERT STITES: You have no current risk.

15 MR. MUHAMMAD SLAM: There is two risks, present

16 versus future risk. We're trying to address the future risk

17 so the public is safe in the future. Right now the public is

18 safe. We want to show you're safe in the future.

19 MR. BRENT POLL: The point I'm making is you can

20 read U.S.A. Today or a news article when they talk about

21 pollution, and they'll say we don't know very much about this

22 new science or what's going to happen when you plant your

23 garden. Some of these things are going to be absorbed in the

24 vegetables. We don't know that yet. There's no succinct

25 studies.

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1 How about when the animals eat it and you eat

2 their flesh? We don't know what it will do to you. We think

3 we do, but there is no succinct studies.

4 It's like finite, like absolute when you put

5 it on yotir screen. When you do your risk assessments, you do

6 it as if it's factual, but the truth is it's not necessarily

7 factual. It's our best guess we can make at this point in

8 time.

9 MR. BOB ELLIOTT: Colonel New is really an expert

10 in the area of risk assessments, and he can give you a better

11 feel for the dynamics of the science.

12 LIEUTENANT COLONEL GEORGE NEW: Let me tell you a

13 little bit about it. For one thing, it is a blend of an art

14 and a science, but also what they say is we have taken the

15 worst case.

16 One thing you see in your brochtires is that

17 TCE is reported here as a carcinogen, and much of the

18 analysis is on that. We have now where people are refuting

19 that.

20 In our case — In the hospitals, we know we

21 have used that for years and years as anesthesia. We get

22 levels thousands of times greater than what you're exposed to

23 here with no indications. We have no cases right now of

24 documented humans with TCE.

25 We're talking about levels literally less than

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1 thousands of times what we have put people in in either one

2 operation or another. Many of you that drink decaf coffee

3 have been exposed for years and years at many higher levels

4 than this level in this population here. We see no cancer

5 trend, so these are facts we do know.

6 The actual science of putting it together in a

7 risk assessment is, as you know, a combination of this art.

8 We try to look at the worst case. If this thing does

9 20 years from now turn out to be a carcinogen, are we going

10 to have a problem. But right now, to let you know better, I

11 agree with you. We really feel we have no problem with our

12 health.

13 We worked with the National Cancer Institute,

14 with our workers on the base that are exposed to TCE at

15 thousands of times these levels. Again, in a work situation,

16 degreasers and things like that, we see no pattern there that

17 we're looking at it.

18 I have a multimillion dollar base that I look

19 at trends in. Basically, among our workers, we look for

20 chemicals they're using and look for health trends, but we're

21 looking at levels again thousands of times over what we're

22 talking about here. Yet we have seen no increased cancer

23 trends.

24 In cases where we have seen a cancer, where

25 somebody quoted in the paper where he had cancer, we looked

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 65

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into it with a medical staff. That was the cancer you can

get from the high altitude. We have none now on where we see

incidents of cancer at the base, and we have these same

people exposed in the industry. If you look at the aircraft

industry in general, we don't see those trends.

MR. WAYNE PATTERSON: I have a question. If you

guys are — if you're not concerned about the health hazards

and stuff, why are we publicizing everything and telling us

it's such a bad thing, putting it out in the public,

devaluing the land, causing building planning commissions to

zone things so you can't build houses with, you know,

10 acres of land? Why a r e we pushing all this stuff then?

LIEUTENANT COLONEL GEORGE NEW: From my

experience, it's politics.

I was involved here in a case.many years ago

where we had an indication of TCE exposure. People claimed

they had problems with — liver problems, cancer problems.

Cancer was the basis.

The cancer was from high altitude. The liver

problems were from alcoholism. Some of the guys had mental

problems. One was from — One in particular had a vasectomy,

and it destroyed his feeling of manhood. We had nothing

connected there.

Now, what happened though when all their stuff

got out about the same time? We took — I took about 500

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samples. Here we're talking about a health standard that's

— Basically, a hundred parts per million is the health

standard for occupational exposure. Now, we went in there —

At the time we had a chemical similar to this called

trichloroethane whose standard was 250. We took about 500

seunples, and it was like less than about a 20th of that level

that we found.

Papers took all this and put it together

because what was happening at the same time was the Holocaust

was shown on T.V.

Here's this clean room at the base where we

have levels over one — the electronic cleaning room. We had

a health standard of 350. The highest I got was 18 parts per

million.

They take that and combine it with the

Holocaust, and we're creating a Holocaust on the Air Force

Base. They get blown up, and sometimes they're used to

magnify and sell news. I think some of that happens here. I

really believe that, and I've had 20 years in the field.

We don't have all the answers. Mr. Poll is

21 right. We don't have all the answers on TCE. We do have

good track records, and at much higher levels we don't see

cancer.

MR. WAYNE PATTERSON: Tell the planning commission

and the newspapers about it instead of having them print that

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1 there are these kinds of things.

2 LIEUTENANT COLONEL GEORGE NEW: I think there is a

3 general tendency —

4 MR. WAYNE PATTERSON: The planning commissions say

5 they're going to do this and this to our land. They say

6 we've just devalued your land. When the newspapers say this,

7 what are we to do? You're expecting a Holocaust, I think.

8 MS. LOLA PATTERSON: You're planning a Holocaust

9 for us.

10 MS. GWEN BREWER: (Indicating.) Let's take the

11 gentleman back here.

12 MR. ALAN MANUEL: My neune is Alan again.

13 Have there been current risk studies done

14 other than those contracted by the federal government?

15 MR. BOB ELLIOTT: On this particular site, no,

16 there have not.

17 I guess the only thing that we can tell you is

18 that the risk assessments that we did have gone to the

19 Department of Environmental Quality, who has evaluated them,

20 which we see as an independent.

21 The Department of Environmental Quality for

22 the State of Utah is very interested in what goes on on the

23 patch of ground called Hill Air Force Base in the State of

24 Uteih as it relates to environmental issues and many other

25 issues.

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1 Also, those risk assessements have been sent

2 to the E.P.A., and they have had their risk assessment people

3 review them, comment on them.

4 We have gone through and changed things that

5 they have not liked, that they felt were not maybe

6 conservative enough.

7 So they have been through, I guess, an

8 independent review, but no separate document has been written

9 and published that would be an independent health risk

10 assessment.

11 MS. GWEN BREWER: Mr. Poll? Oh, okay.

12 (Indicating.) Here, and then I'll go to the back.

13 MR. DARRELL BYRAM: Darrell Byram, B-y-r-a-m.

14 I want to make a statement. I don't want to

15 discourage anybody, but I have a gut feeling that this will

16 be going on for a hundred years, this cleanup, and I don't

17 see that — You have already indicated probably 20, 30 years,

18 but I think you'll find that this will be going on for a

19 hundred years, and a lot of us in this room will be gone.

20 MS. GWEN BREWER: (Indicating.) In the back.

21 MR. LEON BIRK: Leon Birk, B-i-r-k.

22 I want to take some exceptions to the comments

23 that was made here the very first of this meeting.

24 One of them was they've looked at this water

25 around and nobody has used it. I take exception to that

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1 because how do you know nobody has used it? Because you

2 didn't see nobody drinking it or you didn't see animals there

3 the day you was up there, so you assume nobody uses that

4 water?

5 Then we hear that, hey, everything is okay.

6 No problem. Just like we're going back. Then all of a

7 sudden there is all this commotion going on, and they've been

8 100 percent. When I've tracked them down and say, hey, come

9 and test this water and do this, bleih, blah, bleih.

10 When this thing very first broke, I had

11 50 head of cattle running up here. The first thing I know

12 that anything is even going on is I go up there, and there is

13 a fence that wouldn't hold out nothing been put up there

14 around where some water is running. When I started asking

15 questions, oh, that's some pollution that's coming out there.

16 My question is just like several has alluded

17 to here tonight tJiat related to nobody will come and say

18 nothing to the owner of the property.

19 I dare say that I can teOce you on that

20 property down there, and I can show you water that's coming

21 out of that hill that probably you don't even know was there.

22 On this map you've got two or three seeps.

23 Then it says a seep is something that gives so many gallons

24 of water over "x" amount of time.

25 I dare say every one I know of will exceed

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 70

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1 that by (;uite a bit, but nobody has come and ever once asked

2 me or told me or whatever what's going on without I haven't

3 pried it out of them. But if they want property, they darn

4 sure know where to come after me. They darn sure know how to

5 try and get it out of me for nothing and threaten me with a

6 lawsuit if I don't sell it to them.

7 Then you're telling these people that they

8 have the right to complain or go through this process. I

9 agree they've got the right.

10 I was born in the night, but I wasn't born

11 last night. What is the sense of spending a thousand dollars

12 to collect a dollar? That's the bottom line. That's what

13 this whole thing revolves around is bucks. A lot of them are

14 just being passed, but that is what it's all about.

15 When you say that no one is using that water,

16 I take a big exception to that because you do not know if

17 I've got animals or if I'm drinking it.

18 MR. PATTERSON: Same on the Patterson place.

19 MR. BOB ELLIOTT: Let me clarify a statement made

20 earlier. That statement was made in too general of terms.

21 When the discussion was made about using the

22 water, the reference was to a well that someone might have,

23 that they were taking that water and drinking it, using it in

24 their house on a day-to-day basis. J

25 What I would like to do, Mr. Birk, is go walk

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 71

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along that hillside and have you show us those springs

because we have found that the local people that have owned

the land in many cases have been able to take us and say,

hey, I know that in August water comes out right here and

that's the only time it comes out. So that's been very

beneficial to us, so we'll get in touch with you.

MR. LEON BIRK: That seems to be like — Why

hasn't that been done in the past? That seems to be the

pretty logical thing. If you're looking for water or trying

to test water, come and do that to start with. Why should we

have to trace you down?

MR. BOB ELLIOTT: I wouldn't expect you have to.

Our — We've been attempting to talk to land owners and try

to evaluate the conditions along —

MR. LEON BIRK: I will say this: Every time that

I run somebody down or say check that water, they'll do it,

you know, but that's little consolation when, you know, they

say, well, your water is a hundred percent yet right next to

it they're saying now we've got this problem.

So it just all goes back to what we have been

talking about. What do we sort out and believe?

Thank you.

MS. GWEN BREWER: (Indicating.) Yes, sir.

MR. DTJIRELL BYRAM: Darrel Byram, B-y-r-a-m.

They send me a letter about every three months

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 72

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1 telling the reading on the wells that they have on our place,

2 so maybe you ought to get on the mailing list and find out

3 what is coming out of there. I really don't know how to read

4 it myself, but I get it.

5 (Laughter.)

6 MR. ROBERT STITES: I know the Air Force was

7 recently putting together a little pamphlet explaining how to

8 read those results. You have not received that yet, or has

9 it not been sufficiently explained to you?

10 MR. BOB ELLIOTT: It hasn't been sent out.

11 MR. DARRELL BYRAM: But we get information as to

12 what the wells are reading.

13 MS. GWEN BREWER: (Indicating.) Let me get this

14 one.

15 MS. GINNY ODEKIRK: My name is Ginny, G-i-n-n-y.

16 The last neune is Odekirk, 0-d-e-k-i-r-k.

17 My question was if South Weber decides to do

18 its own risk assessment study on the Operable Units 1, 3 and

19 4, is that something we could maybe have an Air Force fund

20 for or is that some type of grant from the E.P.A. or the

21 E.Q.A.?

22 MR. ROB STITES: Mr. Poll, would you care to

23 address the joys of the TAG grant?

24 MR. BRENT POLL: Of getting a grant?

25 MR. ROBERT STITES: Yes.

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 73

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1 MR. BRENT POLL: Brent Poll again.

2 We have acquired a Technical Assistance Grant.

3 It's been a while since I had one. Doctor John Carter has

4 been secured through that grant to review the data collected

5 by Hill Air Force Base and give us his independent opinion of

6 what it means. Thus, there is a lot of paperwork, a lot of

7 red tape, but they'll give you as much help as they can.

8 It's been worth our time to secure his services.

9 Would I advise anyone else to go through that

10 same process? I don't think so. He has been deemed the most

11 serious of all the Hill Air Field, and we felt for our

12 protection we needed to do something such as that.

13 MR. ROBERT STITES: I need to emphasize there is

14 one TAG grant —

15 That stands for Technical Assistance Grant.

16 Stop me if I use an acronym you don't understand.

17 There is one Technical Assistance Grant per

18 site for a maximum of $50,000, except under some extreme

19 circumstances. That grant has already been awarded to the

20 South Weber Landfill Coalition. That's Mr. Poll's

21 organization.

22 If otiher work — If the coalition is willing

23 to discuss doing other work, that may be an avenue. I do

24 know that is going to lead to a lot of extra paperwork and

25 effort not only for you, but Mr. Poll too.

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 74

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1 MR. BRENT POLL: But there is $25,000

2 approximately that has not been consumed yet of that $50,000

3 that has been awarded. If somebody wants to be with us, it's

4 worth the money.

5 MS. GINNY ODEKIRK: Is t:hat an annual grant?

6 MR. ROBERT STITES: No, $50,000 total one time.

7 MS. GINNY ODEKIRK: I have one other question.

8 MR. BOB ELLIOTT: Can I answer this first?

9 We have never explored the possibility of

10 trying to do — have an independent — I don't know how if we

11 pay for it someone could call it independent, but we have not

12 explored that option. We would like to do that, so we will

13 take an action item to explore that with our people and see

14 if there is a possibility that we can provide some assistance

15 in that way.

16 MS. GINNY ODEKIRK: That may be good.

17 I want to refer back to Rex Feustel's question

18 in regard to the people he saw across the street from him in

19 the white suits and the holes they were digging there twice a

20 day.

21 He said they would not answer his question as

22 to what they were doing. I was wondering: Do you know who

23 they were? Were they sent by you? Were they getting

24 samples? Do you know what they were doing?

25 MR. BOB ELLIOTT: We really need to know the

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 75

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G 1 specific time table in which that occurred and exactly where

2 it occurred. We can probably go back and look at who they

3 were and identify who was there.

4 MS. GINNY ODEKIRK: Have you sent people to that

5 area across the street from Rex?

6 MR. BOB ELLIOTT: Across the street from —

7 MR. REX FEUSTEL: 530 East South Weber Drive.

8 They're still coming there almost every day of the week. Not

9 always in white clothing, but it's all civil vehicles, not

10 goverrunent vehicles.

11 MR. BOB ELLIOTT: We'll check into that.

12 MR. REX FEUSTEL: 530 East South Weber Drive.

13 MR. BOB ELLIOTT: I'm not familiar on the map with

14 where that exists.

15 MS. GWEN BREWER: I have one here.

16 MR. BRAD HOLBROOK: Brad Holbrook,

17 H-o-l-b-r-o-o-k.

18 I just live several houses west of Mr. Cutler

19 on the same side of the street as him. The Pattersons live

20 between us in that area.

21 My comment is along the same lines as

22 Mr. Birk's. It was mentioned just several cups of water per

23 hour come out of these seeps.

24 I have lived there for some time and am still

25 raising my children. Some neighbors raised children from

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 76

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1 Children to adults too in that area.

2 There is much more water that comes out of

3 there some times of year and especially when the canal is

4 full. That canal is certainly not sealed, which was

5 mentioned previously, and there is a lot of water that comes

6 through tihere that would seem to me to be a real critical

7 portion of this cleanup plan and what kind of problems you

8 could end up with in years to come from that. So I want to

9 point that out, as was already done.

10 Also, I don't really apologize for the emotion

11 of me and my neighbors. We have raised our children here.

12 We're concerned about — You know, property values have been

13 mentioned, but, much more direct than that, with this scare

14 we have to be concerned about health problems as well with

15 our children playing in the water. They played in the dirt

16 before we were aware there was any problem that had certainly

17 occurred.

18 Before I let you go, if you could comment on

19 that as well. Also, can we get — Those of us who are

20 concerned and especially have land that's directly effected

21 by this, can we get a complete copy of whatever plan you

22 decide to execute before it's done, some kind of a written

23 plan to us?

24 MR. BOB ELLIOTT: Yes.

25 Again, we would be — we would like to have

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 77

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1 the opportunity to go and have you show us where some of

2 these things are in the thicket of trees that we haven't seen

3 with our eyes.

4 You know, some of those things on those

5 hillsides are tough to find. They're in a thicket of trees.

6 They run down the hillside for 10 or 15 feet, and they go

7 back in the ground.

8 We have spent a lot of time along that

9 hillside looking for springs, trying to evaluate where there

10 might be water moving out of the hillside, but we would

11 certainly welcome the opportunity for the easiest approach,

12 to go and say there it is right there.

13 MR. BRAD HOLBROOK: YOU just have to ask.

14 MR. BOB ELLIOTT: Thank you.

15 Can we answer his question?

16 LIEUTENANT COLONEL GEORGE NEW: One more part too.

17 One thing that does — It may not sound too good, but you

18 actually have a better condition when you have this big

19 runoff because the aquifers don't release the water quickly

20 when you have runoff like this. It's surface water. What it

21 does is dilutes it even more. So what may be a problem is

22 even less of a problem. It's really to your advantage in

23 diluting these concentrations to get them down lower.

24 MR. GARY COLGAN: We are aware in how the canal

25 affects the flow and the aquifer system. In fact, there is

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 78

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1 about a third of a mile that — Was it last year or the year

2 before — was relined with concrete by the canal company

3 which goes from the North Gate to the east across the top of

4 mainly Mr. Cutler's property. By lining that and preventing

5 that water from going down, it's probably actually slowing in

6 migration of contaminants.

7 MR. ROBERT STITES: But that's not the entire

8 canal line. It's one of those helpful things.

9 MR. GARY COLGAN: It's just a piece.

10 MR. BRAD HOLBROOK: Will we get copies of the

11 plan?

12 MR. BOB ELLIOTT: Yes. We like to get as much

13 information out to people as we can. We have a mailing list

14 we keep, and we send information out. So we'll be sure and

15 put your name on that list to make sure you get that

16 information.

17 MR. ROBERT STITES: I hope this is helpful. Once

18 that design is complete, there is supposed to be a fact sheet

19 out saying, look, we completed this design. These are the

20 pertinent features of it. A meeting can also be arranged at

21 that time too.

22 In other words, once we finally decide we need

23 this here, that there, all that — What we have here is a

24 very general plan of action. We're going to have to look

25 into specifics, like which seep is where, what spring is

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 79

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1 where, what is flowing, is it contaminated. We have to look

2 — We have to dot those I's and cross those T's, so to speak.

3 MR. BOB ELLIOTT: Our interest is in keeping you

4 as well-informed as we can. So if you as residents want us

5 on a monthly basis to come down here to the school and say

6 this is what we're doing or on a quarterly basis — You tell

7 us what you want us to do to keep you informed, and we'll do

8 it because we can't solve the problem without your

9 involvement.

10 MS. GWEN BREWER: If we keep sending things to you

11 and none of you respond, we also don't know how you feel

12 until you're about up to here with everything. (Indicating.)

13 Then everything blows up. So if we're not doing what you

14 want, let us know because we have to work with you to get

15 this thing done.

16 Mr. Poll?

17 MR. BRENT POLL: On your risk assessment — In

18 conjunction with Mr. Holbrook's question about tihe health of

19 his children, are you just looking at cancer-causing agents

20 in your risk assessment? Are you looking at birth defects?

21 Are you looking at skin disorders and other maladies of this

22 nature that are commonplace around toxic dumps?

23 LIEUTENANT COLONEL GEORGE NEW: In a risk

24 assessment, you have to look at all the routes of exposure

25 and contact versus inhalation versus digestion.

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 80

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1 Maybe you can —

2 MR. GARY COLGAN: Our lead risk assessor just

3 left, but we looked at all the contaminants that we did find

4 at tihis site and conducted risk assessments using

5 acctimulative and singular effects of all those chemicals for

6 both cancer risks and noncancer risks.

7 So we didn't just focus on TCE. I use TCE

8 because it's the most widespread contaminant of the highest

9 concentration, and it's the thing — If we focus on TCE in

10 the cleanup, we'll clean up everylihing else in the process.

11 LIEUTENANT COLONEL GEORGE NEW: One of the

12 omissions — Often, tihat's what drives your carcinogenic

13 compounds because it has the low level you're looking at.

14 Then you're required to look at a longer period of time, like

15 70 years. Some of the other contaminants you don't have to

16 evaluate that long. You look at acute versus chronic, and

17 the chronic one, based on carcinogens, is what drives you to

18 these high protection levels.

19 MS. GWEN BREWER: Are there any more questions or

20 comments?

21 MR. BOB FLINDERS: I have a question. My name is

22 Bob Flinders, F-1-i-n-d-e-r-s.

23 My question is: The record that's being kept

24 here tonight will become a public record, I assume, and we

25 can obtain copies of that if we need them. Where would we

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KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 81

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1 obtain tihose copies at?

2 MS. GWEN BREWER: This will be in the repository

3 at Layton at the library. We'll also have it at Hill Air

4 Force Base in the administrative record there, it will be an

5 official record, and it will be open.

6 MR. BOB ELLIOTT: Maybe we can suggest too that we

7 could send copies to the city council and have them available

8 if that's a little more convenient for you.

9 MS. GWEN BREWER: YOU can go over there.

10 MR. BOB ELLIOTT: They can keep in touch with us

11 so that — if they need some additional copies of it.

12 MR. BOB FLINDERS: Will you make a statement that

13 that will take place?

14 MS. GWEN BREWER: We'll make a statement tihat that

15 will take place.

16 (Indicating.) Yes, sir.

17 MR. RAY GIBBONS: Ray Gibbons.

18 May I suggest maybe the Riverdale area be

19 implemented in the copies, the city council of Riverdale?

20 MS. GWEN BREWER: Yes, sir. We also brief the

21 Riverdale City Council, and we send documents to them to make

22 sure they're current on the things happening here too.

23 MR. RAY GIBBONS: Thank you.

24 MS, GWEN BREWER: Are there any more questions or

25 comments?

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 82

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1 We're very pleased all of you ceune tonight.

2 Remember, if you think of anything that you didn't say

3 tonight or if you didn't say something that you wanted to

4 say, we will be taking comments until the 5th of November.

5 Once we reach the 5th of November, then they

6 will compile all of those comments and questions and then try

7 to work out a proper solution.

8 We're really happy to see all of you here this

9 evening. Please don't hesitate. You've got our names and

10 our numbers in the book. Just give us a call. Thank you all

11 for coming.

12 (At 9:15 p.m., the foregoing proceedings were

13 concluded.)

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C E R T I F I C A T E STATE OF UTAH

s s . COUNTY OF SALT LAKE )

I, AMY STOLTENBERG, C.S.R., R.P.R. and Notary Public for

the State of Utah, residing in Salt Lake County, certify:

That the Public Meeting re Proposed Plan for

Operable Unit 4 was taken before me pursuant to notice at the

time and place herein set forth;

That all proceedings had of record at the time of

the Ptiblic Meeting were recorded stenographically by me and

were thereafter transcribed into typewritten form by me, 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 teiken;

I further certify that I am neither counsel for nor

related to any party to said action nor in anywise interested

in the outcome thereof.

IN WITNESS WHEREOF, I have subscribed my name and

affixed my seal this 31st day of October, 1993.

"^CDA^

[\rmiJDTl\\h.()lUi^ ""Tpj^sx NOTARY PUBUC—1 I i n n [ - , O f a l iC 0 lUrCif, 0^^<SS, ae" ?; !?!-!."''" ^^^ STO J'ENBERG, C.Spf' R.P.R. , ^stliiMB) i;-C""'t.C'LC!(i? Notary Public ^ Notary Public

icense No. 347 . : . l rJ

KINGSBURY AND ASSOCIATES, CERTIFIED SHORTHAND REPORTERS AMY STOLTENBERG, CSR, RPR 84

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Q ^ WRITTEN COMMENTS AND RESPONSES

1 Appendix C

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08/05 /92 15:53 © 8 0 1 777 4306 00-ALC/EM -•-»-• J M M 121002

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Tir Shane Hershey 3 Aug 92 EMR Hill AFB, UT

Dear h r Hershey:

1 recentiy talked with you about our concerns with hazardous waste deposits on our hillside. As we mentioned, the Government has placed several wells in the vicinity o-f a lot where our daughter and her -faiiiiily would like to build a home.

You suggested we list our questions and you would answer them in detail. Ue would like to icnow:

1. Uiould this contamination give us reasc<n to worry aoout tne fruit/vegetables produced on this property? Even now we occasionally eat the -fruit on this hillside.

2. Is there concern about the grasses and or hay the animals eat? These animals a re raised -for my families food and I would like to know if the grasses are also cc-n tami nated.

3- I would like to know if there are any reasons regarding hazardous waste, why it should be a concern if a home were built in this siresi sucn as children playing in dirt, long term effects, etc.

4- I would like to know how long you expect this clean-up to take, if it will ever require large vehicles, heavy duty equipment and/or buildings sucn as rtave been built in the South Wetjer area.

5. I'd really like tc« know what tne possibility is of long term effects for the family I have already raised on this property.

2 would appreciate any information you may have regarding these questions and the clean—up. I hope you will oe kind enough to keep me informed as more information is released.

Thank you.

Lola Patterson eOSO So Weber Dr Ogden, Ut S4405

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flPR-2i-igg3 13:2s oo-flLC/'Eri HILL RFB UT sai 777 4306 p.002/004

JAMES M. MONTGOMERY, CONSULTING ENGINEERS, INC

MEMORANDUM

To: Mr. Shane Hirschi Date: August 31.1992 Prognun MuMger HmAFB0U4

From: Dr. Ruddle Qaikson CUent: HUI AFB JMM n

GJ Subject: Response to Mrs. Patterson's File No.: 2208.0128 Letier About Hill AFB

L 0 U 4 Risk AsCBSsment

p. Tlie following isfocination is a response to } ^ . Patterson's letter regarding her concerns I about potential impacts firom Hill Air Force Base. 0 U 4 . I have written the response as a

^ narrative in an attempt to discuss her concerns with her and not just provide clinical answers to her individual questions.

n U The response is aa follows: p In order to evaluate potential public health risks due to site-ielated e x p o s u r e , two LJ components need to be considered. These two evaluation components are as foUo'vs: P • T o a d d t y - T h e potential for the compound to cause hann 10 human health.

LG t Ezposnre • What are the potential activities in which a person may come into contact with site compounds. This also includes cvsiuation of haw often

C (firequency) and how long (duration) the activity is petfonned.

n c

Bodi of these components need to occur for even the potential for risk to be available.

Thus, the key co potential risk from this site should focus on potential exposure to contaminated groundwater.

t — I

I The Air Force site investigation has indicated that contamination has been detcscted in ^ groundwater off-site.

n The root systems ( < 5 ft) for your fruit trees would not be expected to re3.ch this U groundwater; tfaus the trees would not be exposed to the contamination. Any vei.'ctables

Srown on the property would also he nnaffected. due to their .«hal1nw root .•:y.<tetn.« n (<lft). u In addition, the compounds detected in the gronndwater would be metabolized (used by

the plant) and not expected to bioaccumulate (be stored) in the tissues of the plants. This means that even if the roots reached the groundwater and the plant would ulU' up the compound with the water; the compound would tiien be broken down by natural processes in the plaiu (called metabolism) and released firom the planL Very little of the compound would remain or be stored in the portions of the plant y o u or your animals may eat.

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flPR-21-1993 13:23 00-flLC/EM HILL RFB UT 301 777 4306

Response to atizen's -2- August 31.1992 Letters about Hill AFB

With regard to the grasses and hay eaten by your animals, again, thete is no ruison ia expect that the grasses or hay your animals eat are cofitamznated ftom the Hill Aii* Force Base site. The root systems for these plants are vety shallow (< 1 ft) and would net leach the deeper groundwater whoe contamination has been detected. Thus, the plants would not come into contact with site contamination, so your animals would not be at ri sk and neither would you and your family if you consume these animals.

Risk Assessment is a sdentific tool used to chaiacietize potential present and future risks u> public health and the environment through exposuie to site-specific chemicals. The process is designed to be conservative and thus, protective or public health {tnd the environment.

Past risks from tfae site cannot be evaluated quantitatively, because no informadon on past concentrations' levels is available but investigation does not indicate past contamination offsite^ Therefore the sampling data in die RI icflccta current concentration levels on site. However, we can look at tfae present body of infoimauon about the site and make some qualitative judgments about past exposure and p3tential

n public health impact U

Acute (short-term) exposure to trichloroethylene (TCE) may produce central nervous 1 system depression that can euige from minimal light-headedness at lower concentrations J to headache, incoordination, dizziness, decreased reaction time, loss of inhibitions,

mental confusion and anesthesia, and loss of consciousness at high concentrations. These effects usually subside qiti^y upon leimination of exposure to the compound. Nausea and gastrointestinal distress sometimes occur after exposure to high concentrations and Hver damage has also been observed in heavy users of oIcohoL

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n TCE nuty be absorbed by inhalaiion. ingestion or dermally. It is not corrosive, but may GJ be an irritant to m u c o u s membranes , particularly t o the n o s e and throat w h e n i n h t l e d and

to tile month when ingested. Repeated contact with the skin may cause a dr^ scaly fissured (cracked) dermatitis. ISgh concentrations may cause eye and nose irritaiion and eye injury can result from direct contact widi the Uquid compound.

The available data indicates that TCE can produce cancer in rats and mice, but present smdies have not shown tbis to be true in humans. Epidemiologic smdies of conuaunities consuming TCE contaminated groundwater for over 10 years have not shown an ijicrcase in cancer rates.

Other long-term studies with animals have shown that inhalation or oral exposure to high levels of TCE produced liver uid kidney damage, effects on the immune system and blood, and cancer of the liver, kidney, and lung: thus some potential long-tenn hazard to humans is possible, if exposure is prolonged and concentrations axe signiflcanL

Long-term epidemiologic smdies of humans have not indicated effeeti to kidneys, liver, immtmologic system and blood system as shown with animal smdies.

Cardiac teratogenesis has been indicated in epidemiologic smdies of areas where drinking water was contaminated by halogenated aliphatic hydrocarbons. Trichloroethylene (TCE) and other organic compounds were the major contamiiumis. A greater than expected number of pediatric patients with congenital heart disease were the primary effects noted in these studies.

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flPR-21-1993 13:29 OQ-flLC/EM HILL AFB UT ^ 001 777 4306 P.004/004

Response to Gtizen's -3- August 31,1992 Letters about HiU AfB

Again, the important consideration is potential exposure. The offsite contamination is limited to deep groundwater, thus reducing potential for you or your family to corae into contact with this compound (TCE).

Thus, given our present knowledge of die range of toxicity associated wi.th the compounds at the site and our utiderstanding of potential exposure rtmtes, we do not see any pattems to indicate past exposure would have resulted in significant public health impacL

The potential for future risks firom raising your family on this property would again dep^d upon exposure. Site cleanup activities should eliminate any Tutther contamination offeite. The risk assessment has looked at potential exposure through contact witb soil, ingestion of groundwater, and inhalation of TCE vapors. All zisla were predicted in the absence of cleanup activities at die site. Hius, long term risks would not be expected for you and your family because cleanup will make sure that contamination does not reach your propoty.

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n — L NOTE:

n You should check my assessment cf potential exposures witii responses previously L provided to Mrs. Paxterson or other usidents to ensure consistency,

rn The risk assessment indicated potential soil gas problems, but used soil gas dcJawith high uneertainty. However, the risks calculated are within the range specified by the

^ National Connngeney Plan for Superfund Sites as acceptable for carcinogenic risks, Le., IxlO"^ to IxlOr^ and for noncarcinogens, ue., hatard index lies less than .!. Soil ingesdcn and air calculations do not appear to be a problem.

It appears from dte risk assessment that shaUow ground>t»ater may be a probletn in the L fiiture, but site remediation activities should prevent this. You need to confirm-, what I J ^uivc wnsen in the text to Mrs. Patterson.

Ifyou have any questions, please contact me at (504) 835-4252,

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