United States Environmental Protection Agency · TABLE OF CONTENTS DECLARATION OF THE INTERIM...

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u. s. ARMY INSTALLATION RESTORATION PROGRAM INTERIM RECORD OF DECISION ALABAMA.ARMY AMMUNITION PLANT CHILDERSBURG, ALABAMA AREA B SOILS OPERABLE UNIT (STUDY AREAS 6, 7, 10, AND 21) NOVEMBER 1994 In accordance with Army Regulation 200-2, this document is intended by the Army to comply with the National Environmental Policy Act (NEPA) of 1969.

Transcript of United States Environmental Protection Agency · TABLE OF CONTENTS DECLARATION OF THE INTERIM...

Page 1: United States Environmental Protection Agency · TABLE OF CONTENTS DECLARATION OF THE INTERIM RECORD OF DECISION . . . . . . ... . . . . . . . . . 1 DECISION SlJMMARY 0 • 0

u. s. ARMY INSTALLATIONRESTORATION PROGRAM

INTERIM RECORD OF DECISION

ALABAMA.ARMY AMMUNITION PLANTCHILDERSBURG, ALABAMA

AREA B SOILS OPERABLE UNIT(STUDY AREAS 6, 7, 10, AND 21)

NOVEMBER 1994

In accordance with Army Regulation 200-2, this document is intended by the Army to complywith the National Environmental Policy Act (NEPA) of 1969.

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TABLE OF CONTENTS

DECLARATION OF THE INTERIM RECORD OF DECISION . . . . . . ... . . . . . . . . . 1

DECISION SlJMMARY 0 • 0 • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • 7

1.0 SITE NAME, LOCATION, AND DESCRIPTION . . • • • • • • . • • • . . • • . . . • • . . 7

1.1 Physiography. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . 71.2 Climate. . . . . . . . . . . . . . . . . . . . . . . .. '. . . . . . . . . . . . . . . . . . . . . . . . 71.3 Surface Hydrology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71.4 Geologic Setting 111.5 lAnd Use 111.6 Soils. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 111.7 Groundwater . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 121.8 Ecological System .... :................................... 12

2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES •••••••• . • • • • . • • •• 13

3.0 HIGHLlGHTS OF COMMUNI'IY PARTICIPATION •••••••••.•••...••• 15

4.0 .' SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY·. • •. 15

. 5.0 NATURE AND EXTENT OF CONTAMINATION ••••••.••••.•••...••• 16

5.1 Soils. and Sediments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 165.1.1 Combined TNT Manufacturing Area (Study Area 6- Southern

TNT Manufacturing Area and Study Area 7 - Northern TNTManufacturing Area) . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . .. 16

5.1.2 Study Area 21 - Red Water Ditch . . . . . . . .. 195.2 Industrial Sewer System . . . . . . . . . . '. . . . . . . . . . . . . . . . . . . . . . . . .. 20

5.2.1 Study Area 6 - Southern TNT Manufacturing Area 205.2.2 Study Area 7 - Northern TNT Manufacturing Area 245.2.3 Study Area 10 - Tetryl Manufacturing Area 25

6.0 SUMMAR.Y OF SITE RISKS • • . • • . • • • . . • • • . . • • • • • • • • • • • . • • • • . • • •• 25

6.1 Exposure Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 256.2 Intermediate Cleanup Levels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 26

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TABLE OF CONTENTS(Continued)

7.0 DESCRIPTION OF ALTERNATIVES .••.•..•.••...••..••...••..••. 26

7.1 Soils and Sediment Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 267.1.1 Alternative lA: Stabilization of Metals- and PAH-

Contaminated Soils and Sediments 297.1.2 Alternative lC: Off-Site Disposal of Metals- and PAR-

Contaminated Soils and Sediments 297.1.3 Alternative ID: Incineration of Explosives-Contaminated

Soils and Sediments 297.1.4 Alternative IG: Incineration/Stabilization of Metals-

and Explosives-Contaminated Soils and Sediments . . . . . . . . . .. 307.1.5 Alternative 11: No Action 30

7.2 Industrial Sewer System Alternatives 307.2.1 Alternative ISS!: Excavation, On-Site Flashing

and Off-Site Landfilling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 317.2.2 Alternative ISS2: Excavation, On-Site Mobile Rotary Kiln

Incineration, and Off-Site Landfilling . . . . . . . . . .. . . . . . . . . .. 327.2.3 Alternative ISS3: Deactiv~tion and Grouting of Concrete-

Encased VCP; Excavation, Decontamination or On-SiteIncineration, and On-Site Disposal of vep .. ~ . . . . . . . .. 32

7.2.4 Alternative ISS7: No Action 0 •••••••••••••• 32

8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES •••••••• 32

8.1 Threshold Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 328.2 Primary Balancing Criteria 358.3 Modifying Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . o. .' 37

9.0 SELECTED REMEDY AND REMEDIATION GOALS •••••••••••••••••• 38

9.1 Basis for Selection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . .. 409.2 Remediation Goals 41

10.0 STATUTORY DETERMINATIONS ••••••••••••••••••..••••.••••••• 46

10.1 Protection of Human Health and the Environment 4610.2 Compliance with Applicable or Relevant and Appropriate

Requirements '........................ 4710.3 Cost-Effectiveness........................................ 48

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TABLE OF CONTENTS(Continued)

10.4 Utilization of Permanent Solutions and Alternative TreatmentTechnologies or Resource Recovery Technologies to theMaximum Extent Practicable . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48

10.5 Preference for Treatment as a Principal Element . . . . . . . . . . . . . . . .. 49

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LIST OF TABLES

1 Exposure Concentrations of Contaminants of Potential Concern(COpes) in Shallow Soil and Sediment atStudy Areas 6, 7, 10, and 21 at ALAAP Area B 17

2 Contaminants in Soils and Sediments that Require RemedialAlternative Screening Based on the Ecological Risk Assessment . . . . .. 27

3 Intermediate Cleanup Levels for Soils ~d Sediments .Co~idering Multiple Exposures . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 28

4 Contaminated Soil and Sediment Volumes for Alternative IG 42

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LIST OF FIGURES

1 Location Map of ALAAP 8

2 Study Areas at ALAAP . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

3 Area B Soils Operable Unit Study Areas ..... . . . . . . . . . . . . . . . . .. 10

4 Layout of Industrial Sewer System in Study Area 6 21

5 Layout of Industrial Sewer System in Study Area 7 22

. 6 Layout of Industrial Sewer System in Study Area 10 23

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ALAAPAACADEMARARCAACERCLA

CFRcaecope1,3-DNBDNTDODDOTEPAEQESAESEOFFSgalGOCOHIICLIRPmmgjLmgjkgNCNCPNEPANPLO&MOUOSHAppmRARCRARIDRIRIfFSROD

LIST OF ACRONYMS AND ABBREVIATIONS

Alabama Army Ammunition PlantAlabama Administrative CodeAlabama Department of Environmental Managementapplicable or relevant and appropriate requirementClean Air ActComprehensive Environmental Response, Compensation,and Liability ActCode of Federal RegulationsContaminant of concernContaminant of potential concern1,3-dinitrobenzenedinitrotolueneDepartment of DefenseDepartment of TransportationU.5. Environmental Protection Agencyecotoxicity quotientEndangered Species ActEnvironmental Science & Engineering, Inc.degrees FahrenheitFeasibility studygallongovernment-owned/contractor-operatedhazard indexIntermediate Cleanup LevelInstallation Restoration Programmetermilligrams per litermilligrams per kilogramnitrocelluloseNational Oil and Hazardous Substances Pollution Contingency PlanNational Environmental Policy Act .National Priorities Listoperation and maintenanceOperable UnitOccupational Safety and Health Actparts per millionrisk assessmentResource Conservation and Recovery Actreference closeremedial investigationremedial investigation/feasibility study'Record of Decision

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SARATCLPtetrylTMV .2,4,6-TNTTNTTSCAUSACEUSAECUSATHAMAUSCUCL95%p,g/gVCPWESTONWWIIyd3

LIST OF ACRONYMS AND ABBREVIATIONS(continued)

Superfund Amendments and Reauthorization Act of 1986toxicity characteristic leaching procedures2,4,6-trinitrophenylmethylnitraminetoxicity, mobility or volume2,4,6-trinitrotoluenetrinitrotolueneToxic Substance Control ActU.S. Army Corps of EngineersU.S. Army Environmental Center (formerly USATHAMA)U.S. Army Toxic and Hazardous Materials AgencyUnited States Code95 percent upper confidence levelmicrograms per gramVitrified Clay PipeRoy F. Weston, Inc.World War IIcubic yard

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DECLARATION OF THE FINAL INTERIM RECORD OF DECISION

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•••••••••r••••••II

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DECLARATION OF THE FINAL INTERIM RECORD OF DECISION

SITE NAl\fE AND LOCATION

Alabama Anny Ammunition PlantArea B Soils Operable Unit - (Study Areas 6, 7, 10 and 21)P. O. Box 368Childersburg, AL 35044-0368

STATEMENT OF PURPOSE

This decision document presents the selected remedial action for the contaminated soils andsediments in Study Areas 6, 7, and 21~ and the Industrial Sewer System (ISS) in Study Areas6, 7, and 10 within Area B at the Alabama Anny Ammunition Plant (ALAAP), Childersburg,Alabama. This selected remedial action was chosen in accordance with the ComprehensiveEnvironmental Response, Compensation, and Liability Act of 1980 (CERCLA), as amended bythe Superfund Amendments and Reauthorization Act of 1986 (SARA), and, to the extentpracticable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP).

This interim remedial action is "taken to protect human health and the environmel1t fromunacceptable risks. This interim remedial action is limited to soils and sediments in Study Areas6, 7, and 21, and the Industrial Sewer System (ISS) in Study Areas 6,7, and 10 located withinArea B, herein referred to as the Area B Soils Operable Unit. With the exception of soils in thevicinity of the ISS, contaminated soils and sediments in Study Area 10 will be addressed as a.separate operable unit following completion of a sampling 'program to accurately delineate theextent of contamination.

The u.s. Environmental Protection Agency and the State of Alabama concur with the selectedremedy.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from this site, .if not addressed byimplementing the response action selected in this Final Interim Record of Decision (ROD), maypresent an imminent and substantial endangennent to public health, welfare, or the environm~nt.

DESCRIPTION OF THE SELECTED REMEDY

The Area B Soils Operable Unit addresses the principal threats from soils and sediments in StudyAreas 6, 7, and 21, and underground industrial sewer lines in Study Areas 6, 7, and 10. Thesoils and sediments and the industrial sewer lines are contaminated with explosives and lead.Each of the study areas is identified as follows:...

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(A) Soils and Sediments (Study Areas 6, 7, and 21)

The selected remedy for the Area B Soils Operable Unit consists of the following:

The scope of this ROD is limited to these study areas. Based on the current property usesurrounding Area B (hunting, logging and industrial activities) and future potential land use forArea B, the U.S. Anny has selected an Industrial Scenario for remediation of Area B. Allremedial investigations and remedial action efforts, property trdnsfers, sales or leases will berestricted to this Industrial Scenario.

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Northern TNT Manufacturing Area

Southern TNT Manufacturing Area

TetryI Manufacturing Area

Red Water Ditch

Study Area 6:

Study Area 7:

Study Area 10:

Study Area 21:

Decontaminate oversize materials by crushing or shredding and treatment in theTIS-20, or by high-pressure water washing and disposal in the backfill area.

Clear, sUlVey, and grid areas; perfonn soil and sediment sampling and analysisto delineate contamination by explosives (TNT, 1,3-dinitrobenzene, and tetryl)and lead.

For contaminated areas: excavate soils and sediments until excavation criteria aresatisfied; screen materials; transport materials to the transportable in~ineration

system (TIS-20) site in Area B; treat materials by incineration and/or stabilizationuntil treatment and disposal criteria are satisfied.

Expand the existing on-site disposal area for final placement of treated materials. '

Backfill excavated areas in Study Areas 6 and 7 and rough grade to pre-excavatedcontours; backfill Study Area 21 to the elevation of surrounding banks of the RedWater Ditch.

Close the disPosal area in accordance with the existing approved permitapplicati~nfor treated soils ("Treated Soils - Backfill Area Permit Application forthe Alabama Army Ammunition Plant Stockpile Soils Area Operable Unit",March 1993). .

Treat contaminated pr~s, sampling, and decontamination wastewaters in theTIS-20 aqueous waste treatment system; reuse water for site dust! _control and..

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process makeup.

Industrial Sewer System (Study Areas 6, 7, and 10)

• Conduct confmnatory soil and sediment sampling and analysis to ensure thatexcavation criteria have been satisfied.

• Excavated materials that contain asbestos (tiles, fragments, etc.) will be separatedduring feed preparation activities at the TIS-20 site. Details of the materialshandling procedures may be found in the Work Plan.

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Screen and transport contaminated soils and sediments to the TIS-20 site fortreatment by incineration and/or stabilization.

Remove nonencased sewer lines and manholes; transport materials to TIS-20 sitefor decontamination by high-pressure water washing or other approved methods;dispose decontaminated materials in the backfill area.

Sample and analyze soils around sewer lines and manholes for contamination;excavate as necessary to achieve excavation criteria.

Sample overlying soils to detennine compliance with excavation criteria; excavateto depth of sewer; visually inspect interior and exterior of sewer; remove grosscontamination; treat materials in TIS-20 or other approved methods andprocedures.

Locate and survey the existing vitreous clay pipe (VCP) sewer lines andmanholes .

Where sewer lines are encased in concrete: visually inspect interior; remove grosscontamination; treat materials in TIS-20 or by other approved methods andprocedures; water wash; grout/cement in place after decontamination..

Where lines are crushed or broken: visually inspect and remove grosscontamination; excavate oversize (> 2 inches) materials; transport oversizematerials to TIS-20 and decontaminate for disposal in on-site backfill.; blendundersize materials with surrounding soils using approved methods; transportmaterials to the TIS-20 for treatment by incineration and/or stabilization.

Portions (10 percent) of decontaminated VCP will be tested to ensure adequatedecontamination. Although not expected, if adequate decontamination cannot bedemonstrated using Webster's Reagent (due to porosity of pipe), a portion of thedecontaminated pipe will be crushed and analyzed for parameters outlined in theexcavation criteria. If %bster's Reagent is used, there is no npmerical

I,.II

• (B)

I

•••til·

I

•••I

..

•{;,••

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I,IIIIIIIIIIIIIIIII

quantifIable decontamination criterion. A change of color will indicate that TNTis present at concentrations above 15 ~g/cm2.

• Ifdecontamination cr;,::.~ria are exceeded, the piping will. be decontaminated again,tested, and disposed in the backfill area if criteria are satisfied. Decontaminatedpiping that fails to meet the decontamination criteria after two water-washings willbe crushed, blended with contaminated soils, treated in the TIS-20 and disposedin the on-site backfill area.

• Conduct confmnatory soil sampling around and below removed pipe to ensurethat excavation criteria are satisfied.

Excavation criteria for contaminated soils and sediments are: >647 ppm TNT, >5,000 ppmtetryl, > 1 ppm 1,3-DNB and > 500 ppm total lead. Excavation will proceed until excavationcriteria are achieved or one of the following is encountered: groundwater, bedrock, orfoundations or other major subsurface obstructions. For soils treated in the TIS-20 andstabilized, disposal criteria are: < 1 ppm TNT and below the toxicity characteristic leachingprocedure (TCLP) criteria for RCRA metals. For soils not treated in the TIS but stabilized,disposal criteria are: less than explosives excavation criteria and less than TCLP criteria formetals.

Due to the nature of contamination of soils, sediment~, ,and .the industrial sewer system byexplosive compounds, sampling, excavation, and handling procedures in the field will be dictatedby safety considerations as determined by the u.s. Anny or its designated explosives expert(s).As such, the genernl remedial ,actions .will be perfonned in accordance with the plans developedby the explosives experts.

STATUTORY DETERMINATIONS

This interim action is protective of human health and the environment, complies with Federnland State requirements that are legally applicable or relevant and appropriate to the remedialaction, and is cost-effective. This interim action is intended to fully address the statutorymandate for permanence and treatment to the maximum extent practicable. This actionconstitutes the final remedy for contaminated soils and sediments in Study Areas 6, 7 and 21,and the industrial sewer system in Study Areas 6, 7 and 10 within Area B, and addresses thestatutory preference for remedies that employ treatment that reduces toxicity, mobility, orvolume as a principal element. Subsequent actions are planned to fully address the threats posedby the conditions at other areas within this operable unit.

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FINAL lNIElUM RECORD OF DECISION

ALABAMA .ARMY AMMlJN1TION PLANT. CRJ[,DDSBUR.G, ALABAMAAREA B sons OPERABLE tlN1T(STUDY AREAS Ci, 7, 10, AND 11)

OCTOBER. D94

LieuteDaDt Col<mel B. L. MartiDCommander, Holston Army AmmUDitioD Plant,Commander. Alabama Army Ammunition "-at

-----_-.----- .~-.-.._ .. -_._-oPTIONAL FORM.. (7...80)

FAX TRANSMITTAL

s

lP.2

~.

Date

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DECISION SUMMARY

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DECISION SUMMARY

1.0 SITE NAME, LOCATION. AND DESCRIPTION

Alabama Anny Ammunition Plant (ALAAP) is located in Talladega County in east-centralAlabama, 40 miles southeast ofBinningharn and 70 miles north of Montgomery (Figure 1). Thenearest town is Childersburg, which is 4 miles south of ALAAP. This interim remedial actionis limited to soils and sediments in Study Areas 6, 7, and 21, and the industrial sewer system(ISS) in Study Areas 6, 7, and 10 located within Area B, herein referred to as the Area B SoilsOperable Unit. The boundary of Area B is shown in Figure 2. An enlarged portion of AreaB showing Study Areas 6, 7, 10, and 21 is presented in Figure 3.

1.1 Physiop-aphy

ALAAP is located in the Coosa Valley district of the Valley and Ridge physiographic province.The border between the Valley and Ridge province and the Piedmont province is south ofALAAP between Talladega and Tallaseehatchee Creeks.

1.2 Climate

Talladega County's climate is temperate. The weather during fall, winter, and spring iscontrolled by frontal systems and contlClsting air masses. Summer weather, which lasts fromMayor June until September or October, is almost subtropical because maritime tropical airprevails along the Bennuda high-pressure system.

Average daily temperatures in Talladega County are 75 degrees Fahrenheit (oF) for the high and50°F for the low. Summer high temperatures are commonly 90°F or above; occasionally,maximum temperatures exceed 100°F. Temperatures below 32°P occur approximately 60 daysper year, primarily in December and January.

Mean annual rainfall is 52 inches. The lowest average monthly ntinfall (2.2 inches) occurs inOctober, and the highest average monthly rainfall (6.4 inches) occurs in March. TalladegaCounty has two rainy seasons per year. The winter rainy season is December to April, with themajority of the rain associated with the passage of frontal systems. The .summer Iainy seasonis May through September, with the highest rainfall occurring in June and July. Summer rainsare normally convective thunderstonns.

1.3 Surface Hydroloft

The majority of the· surface ronofffrom ALAAP drains either west or southwest into the CoosaRiver. A small portion of the southern and eastern side of ALAAP drains toward TalladegaCreek, a tributary of the Coosa River. Prior to the constroction of ALAAP, the area consistedof fanns, woodlands, and wetlands. Much of the eastern half of ALAAP was poorly chained.Small natural drainways were enlarged and rerouted to provide drainage from the various

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Bon Air

Scale·0.5 0 0.5 1 Mile

94P-3385

FIGURE 1LOCATION MAP OF ALAAP

~-N-

~

8

TalladegaCounty

Sirmi 9h~-.J7

@

Montgomery

Alabama

AlAAP FS

u.s. ARMY CORPS OF ENGINEERSHUNTSVILLE DMSION

ALABAMA ARMY AMMUNmON PLANT

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-I''''

WOODED AREA

1,500o

(

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KEY-- AAAP BOUNDARY..... ,.. StUDY AREA BOUNDARIES- - DRAINAGES-----. INSTALLAtiON DIVISIONS_. - AREA A AND B BOUNDARIES

(fJ S JUDY AREA

FIGURE 2STUDVAREASATALAAP u.s. ARMY CORPS OF ENGINEERS

HUNTSVILLE DIVISIONALABAMA ARMY AMMUNITION PLANT

SOURCES: USATHAMA. ll1li ESE.

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~~.,~·A.REAB '•~ FLASHING

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KEY

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MAP Boundary .

Study Area Boundaries

Drainages

Installation Divisions

Area A and 8 Boundaries

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1Area B SoilsOperable UnitStudy Areas

1500~~~1~5~OO~iiiiiiiiiiii15ilO~O~~~15~OO1= II ; IScale In Feet

FIGURE 3AREA B SOILS OPERABLE UNITSTUDY AREAS 6, 7,10, AND 21

U.S. ARMY CORPS OF ENGINEERSHUNTSVILLE DIVISION

ALABAMA ARMY AMMUNITION PLANT

94P-3403 6130/94

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manufacturing operations.

As shown in Figure 2, two natural drainage systems conveyed surface runoff from ALAAP, westto the Coosa River. Liquid industrial wastes from the explosives manufacturing operations wereconveyed west to the Coosa River by a man-made channel (Red Water Ditch). No natural pondsexisted on ALAAP during its operation; however, two large storage lagoons were constructedto retain industrial wastes. Extensive wooded swamp and pond areas have developed in thedrainage systems at ALAAP since the beginning of demolition activities in 1913, primarily asa result of damming of drainways by beavers.

The U.S Anny Corps of Engineers has completed a wetlands delineation study at ALAAP.Based on their inspection of 12 July 1994, they concluded that a Department of the Army pennitpursuant to Section 404 of the Clean Water Act will not be required to remove contaminationfrom the man-made ditches excavated from uplands. The property is a nonwetland upland areabased upon the 1987 Wetlands Delineation Manual.

1.4 Geololic Settine

The bedrock underlying ALAAP has been mapped on a regional scale and has been identifiedas the undifferentiated Knox group of Upper Cambrian to Lower Ordovician age dolomite. Thedolomite underlying ALAAP is thick- to medium-bedded; cherty; and penetrated by numerouscavities-, joints, and fractures. The dolomite is overlain by residual soil derived from theweathering process. This soil matrix consists primarily of clay, with some silt, sand', andoccasional chert boulders, and varies in thickness from less than 3 feet to more than 80 feet~

1.5 Land Use

ALAAP is currently in an inactive caretaker status with controlled access. The only activityoccurring on ALAAP is occasional Army-supervised logging. The land surrounding ALAAPis a mixture of recreational and industrial. ALAAP is bordered on the west side by a countryclub; on the south by a paper products company; on the east by wooded, private property; andon the north by a water treatment plant. The current and future land use of the ALAAPproperty in Area A is expected to consist of hunting grounds and occasional logging of woodedareas. Area. A was auctioned and conveyed to private buyers in 1990 and is currently used forhunting grounds and occasional logging.

Based on the current property use surrounding Area B (hunting, logging and industrial activities)and future potential land use for Area B, the U.S. Anny has selected an Industrial Scenario forremediation of Area B. All remedial investigations and remedial action efforts, propertytransfers, sales or leases will be restricted to this Industrial Scenario.

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1.6 Soils

The soils at ALAAP (Areas A and B) are generally divided into three associations. Soils of theBodine-Minvale Association are found on the high ground of the eastern portion of ALAAP.This association is composed of deep, well-drained, steep, cherty, medium-textured soils derivedfrom limestone and dolomite. Most of ALAAP is covered by soils of the Decatur-Dewey­Fullerton Association, which are also deep, well-drained, loam soils derived from limestone anddolomite. The soils of the floodplains of Talladega Creek and the Coosa River have beenclassified as the Chewacla-Chenneby-McQueen Association. These are deep, nearly level,alluvial loam soils that grade from somewhat poorly drained to well-drained and are subject toflooding.

These broad-based associations represent agricultural classifications rather than engineeringdescriptions. Soil constitution at ALAAP may include three associations ranging from soilsconsisting primarily of sand and silt (with little clay) to soils comprised almost entirely of clay.

1.7 Groundwater

Potable groundwater from the dolomite aquifer of the Coosa Valley supplies the needs of thecommunities, homes, fanns, and industries around ALAAP.' 'The majority of the successfulwells draw water from the solution cracks and cavities in the dolomite. A few wells arecompleted in the residual soil; however, these wells are less productive than those drilled intothe dolomite.

1.8 Ecolopcal System

The environment at ALAAP has been disturbed three times in the past 40 years. Prior to theconstroction of the facility, the area consisted primarily of cropland and woodland. The fIrStmajor change occurred during the operational years, when much of ALAAP consisted 'ofmaintained industrial areas. In the second major change, the Anny instituted a woodlandmanagement plan, following closure of manufacturing operations, that extensively modifiedALAAP by allowing 3,411 acres of.controlled pine forest to be planted. More recently, thethird major change occurred as a result of selected remediation of soils on the site anddemolition of various areas.

Currently, many of the formerly-maintained drainages, pine plantations, and cleared areas haveundergone considemble vegetative overgrowth. Much of the planted pine has been harvested,and reforestation has occurred through natural revegetation. Damming of surface drainages bybeavers has modified the systems; drainage has become much slower, and extensive woodedswamp and shallow pond areas have developed. As a result of these changes, the majorecological systems currently consist of the following types: grassland/old field associations,upland pine forests/pine plantations, oak forests, low moist pine woods, hardwood swamps,intennittent streams, shallow ponds, and drainage ditches.

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These systems support abundant populations of aquatic and terrestrial organisms. White-taileddeer, introduced in the 1960s, have become particularly abundant, as have certain predators (thered-tailed hawk, the marsh hawk, and the bobcat).

The extensive development of shallow beaver ponds has resulted in large populations ofamphibians and aquatic reptiles. The :East Beaver Pond provides roosting for waterfowl.

2.0 Site History and Enforcement Activities

ALAAP was established on 13,233 acres of land near the junction of Talladega Creek and theCoosa River. The plant was built in 1941 and operated during World War n (WWII) as agovernment-owned/contractor-operated (GOCO) facility. ALAAP produced nitrocellulose (NC) ,single-based smokeless powder, and nitroaromatic explosives (i.e., trinitrotoluene (TNT);dinitrotoluene (DNT); and 2,4,6-trinitrophenylmethylnitramine (tetryl». Activities at ALAAPincluded the manufacture of explosives; DNT; and chemicals including sulfuric acid, aniline,N,N-dimethylaniline, and diphenylamine. Spent acids were recycled and wastes resulting fromthese operations were disposed. In August 1945, operations were tenninated at ALAAP, andthe plant was converted to standby status.

The plant was maintained in various stages of standby status until the early 1970s. In 1973, theArmy declared ALAAP excess to its needs. Since that time, several parcels of the originalproperty were sold or returned to their previous owners. In 1977, a 1,354-acre parcel was soldto Kimberly Clark, Inc. forconstrnction ofapaper products plant. Area A, encompassing 2,714acres, was auctioned in May 1990. Future land uses for these properties are expected to consistof hu~ting grounds and wooded areas for occasional logging.

In 1978, the U.S. Anny Environmental Center (USAEC) (formerly U.S. Army Toxic andHazardous Materials Agency (USATHAMA), managing the Army's Installation RestorationProgram (IRP), conducted a record search which concluded that specific areas of the facilitywere potentially contaminated by explosives and lead compounds. Additional studies at ALAAPconftmled that soils were contamjnated with explosives compounds, asbestos, and lead. Sevemlinvestigations were conducted between 1981 and 1983 to defIDe contamination further. In'1984,ALAAP was proposed for inclusion on the CERCLA (Superfund) National Priorities List (NPL).

A Remedial Investigation/Feasibility Study (RIfFS) under the Department ofDefense (DOD) IRPwas initiated in 1985 to determine the nature and extent of contamjnation at ALAAP and thealternatives available to remediate the site. For the purposes of the RIfFS, the facility wasdivided into two general areas. Area A consisted of the eastern portion of the facility and AreaB consisted of the western portion (Figure 2). The initial RI under the IRP conflI1lled theexistence of .explosives, asbestos, and lead contamination in the soil in Area A and in the soil,sediment and groundwater in Area B. The RI for Areas A and B was completed in 1986. Asa result of the fmdings of the RI, cleanup activities at Area A were conducted in 1986 and 1987,and included building decontamination and demolition, soil excavation, and stockpiling.Initially, 21,400 yd3 of contaminated· soils were excavated from Area A and stockpiled in Area

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B in two covered buildings and on a concrete slab that was subsequently covered with amembrane liner. In July 1987, ALAAP was placed on the NPL. The subsequent sequence ofevents related to Areas ,A and B are presented separately in the following paragraphs.

Area A

In 1990, EPA indicated that additional investigations needed to be conducted at Area A to ensurethat no residual contamination remained. Area A was conveyed to private buyers in August1990, with the provision that additional investigations would be perfonned.

In 1991, a supplemental RI was co~ducted to verify the effectiveness of the completed remedialactions in Area A. The supplemental RI determined that soils in Study Areas 12 and Dcontained lead and explosives at unacceptable concentnltions. The supplemental RIfFS,completed in January 1993, concluded that approximately 3,800 yd3 of lead-eontaminated soilin Study Area 12 and approximately 5 yd3 of explosives-contaminated soil· in Study Area Drequired further remediation. An Interim Record of Decision for Area A Soil Operable Unit(Study Areas 12 and D) was submitted in April 1994. Stabilization and incineration wereselected as the preferred remedial alternatives in the Interim Record of Decision for Area Asoils.

Area B

In February 1991, a Characterization Study was conducted for the Stockpile Soils excavatedfrom Area ~ and stored in Area B. The study confmned that explosives, lead, and asbestoscontaijrlnation was present above acceptable limits. In March 1991, a tornado demolished oneof the two buildings that contained Stockpiled Soils. Soils and debris from the demolishedbuilding were relocated on the concrete slab and covered with a membnme liner. A FeasibilityStudy was completed for the Stockpile Soils in October 1991. A Record of Decision for theStockpile Soils Area Opern.ble Unit was issued in December 1991 and recommended incinemtionas the preferred alternative..The incineration of Stockpile Soils commenced in May 1994 andended in August 1994.

Numerous studies have been conducted for study areas within Area B which include: SanitaryLandfill and Lead Facility (Study Area 3); Manhattan Project Area (Study Area 4); Red WaterStomge Basin (Study Area 5); Combined TNT Manufacturing Areas (Study Areas 6 and 7);Acid/Organic Manufacturing Area (Study Area 8); Aniline Sludge Basin (Study Area 9); TetrylManufacturing Area (Study Area 10); Flashing Ground (Study Area 16); the majority of thePropellant Shipping Area (Study Area 17); Blending Tower Area (Study Area 18); Lead RemeltFacility (Study Area 19); Rifle Powder Finishing Area (Study Area 20); Red Water Ditch (StudyArea 21); Demolition Landfill (Study Area 22); Storage Battery/Demolition Debris Area (StudyArea 25); Crossover Ditch (Study Area 26); and the Beaver Pond Dnrinage System (Study Area27).

A supplemental RIfFS for Area B was submitted in March 1992.

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Reports describing studies conducted at ALAAP are contained in the Administrative Record atthe Holston Anny Ammunition Plant (Kingsport, TN) and the Earle A. Rainwater MemorialLibrary (Childersburg, AL).

3.0 mGHLIGHTS'OF CO:MMUNITY PARTICIPATION

A public meeting was held in December 1991 to discuss the issues related to the preferredremedial alternative selected for the Stockpile Soils Area Operable Unit. The soils of theStockpile Soils Area Operable Unit have been successfully treated on-site by rotary kilnincineration. This Interim ROD, for treating contaminated materials in Study Areas 6, 7, 10,and 21 in Area B with similar waste characteristics, is prepared as an extension of the existingStockpile Soils Area Operable Unit remediation project.

A public notification for the Area B Soils Operable Unit public meeting and public commentperiod 'was advertised in four local newspapers, one of which was a major newspaper. Thepublic comment period began on 19 September 1994 and ended on 19 October 1994.Approximately 20 people attended a public meeting which was held on 28 September 1994 atthe Central Alabama Community College. The major concern of the public involved recentoccasions of particulate (dust) fallout from an unidentified source. The public was infonned thatthe transportable incinerator had completed remediation of the Area A Soils Operable Unit on22" August 1994 and, therefore, had not been operational in the five-week period prior to themeeting.

4.0 SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY

The Area B .Soils Operable Unit cleanup streltegy is an interim remedial action for contaminatedmaterials in Study Areas 6, 7, 10, and 21 within Area B. This interim remedial action willprotect human health and the environment from unacceptable risks caused by contaminated soilsand sediments in Study Areas 6, 7, and 21, and the industrial sewer system in Study Areas 6,7, and 10. To the extent pmctical, actions associated with this Interim ROD are consistent withthe Army's future planned activities at ALAAP.

The Remedial Investigations conducted in Area B have determined that significant and extensiveexplosives contamination is p~sent in Study Areas 6, 7, 10 and 21. The threats addressed in

. this Interim ROD are the contaminated soils and sediments in Study Areas 6, 7, and 21, and thecontaminated underground ISS in Study Areas 6, 7, and 10. These areas are contaminated withexplosives and lead. Actual or threatened release of hazardous substances from thesecontaminated soils, sediments, and ISS, if not addressed by implementation of the selectedremedy, may present a current or potential threat to the public health and the environment.

A f~a1 Remedial Investigation/Feasibility Study (RIIFS), Risk Assessment (RA), and Recordof Decision will be conducted for all Area B, including soils, sediments, groundwater, and othercontaminated media. Ongoing and future investigations by the U.S. Anny, as outlined in its SiteManagement Plan for ALAAP, will determine a fmal course of action. for the Alabama AnnyAmmunition Plant.

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s.o NATURE AND EXTENT OF CONTAMINATION

The present contamination in Study Areas 6, 7, 10, and 21 is a direct or indirect result of pastexplosives production. 'TNT manufacturing operations were conducted in Study Areas 6 and 7.

Tetryl manufacturing op~rations were conducted in Study Area 10. Wastes from explosivesproduction were disposed to the ISS in their respective areas. As a result, soils and sediments,and the industrial sewer lines became contaminated with explosives, primarily TNT and tetryl.Lead is also found in soils and sediments to a lesser extent. TNT contamination in Study Area21 (Red Water Ditch) is a result of upstream production.

The results of groundwater and surface water studies are not presented herein, as they arebeyond the scope of this Interim ROD. Groundwater at ALAAP will be addressed by the Annyas a separate operable unit.

The infonnation presented in this section is based on the following documents:

1. Remedial Investigation and Feasibility Study of the Industrial Sewer System,Alabama Army Ammunition Plant, September 1991.

2. Supplemental Remedial Investigation/Feasibility Study (RIfFS) for Area B,Alabama Army Ammunition Plant (AAAP), Draft Feasibility Study, March 1992.

The extent of contamination of soils and sediments and the ISS, are discussed in Subsections 5.1and 5.2, respectively. A summary of the nature and extent of contaminants of potential concern(COpes) in Study Areas 6, 7, 10, and 21 is presented, in Table 1.

5.1 Soils and Sediments

5.1.1 Combined TNT Manufacturio& Areas (~tudyArea 6 - Southern TNT ManufacturiDIArea and Study Area 7 - Northern TNT Manufacturinr Areal

The Combined TNT Manufacturing Areas were studied extensively during the exploratory andconfImlatory surveys (ESE, 1981; 1983). Groundwater samples were collected during the RIsurvey (ESE, 1986) for historical. comparison. Soil samples were also collected during the RIsurvey, and tested for leachable lead. Significant fmdings include:

1. As a result of DNT and TNT manufacturing activities at ALAAP, the soils of thecombined TNT Manufacturing Areas contain nitroaromatic residues. These residues aredistributed in a complex pattern within an area of approximately 78,000 square yards andextend from the ground surface to depths nmging from 3' ft to 7ft. Up to 15 percent ofthe contaminated area may contain residues at concentnltions of 1,030 ppm of TNT orgreater, while up to 2.5 percent may contain 1,280 ppm of 2,4-DNT or greater.

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Table 1Exposure Concentrations of ~ontaminantsof Potential Concern (COpes) in

ShaDow· SoU and Sediment at Stu:~y Areas 6, 7, 10, and 21 at AAAP Area B

Frequency Upper 95%Study Detected Concentration of Best Estimate Confidence ExposureArea Medium Analyte Mean Maximum Detection of the Mean Limit (UC4s) Concentration

(mglkg) (mglkg) (mglkg) (mglkg) (mglkg)

6 Soil 135TNB 9.27E-ol 1.31E+OO 4/13 4. 13E-Ql 6.00E-ol 6.00E-ol246TNT 1.48E+03 7.90E+03 14/20 1.13E+OS 1.28E+09 7.90E+0324DNT 6.13E+OO 1.60E+Ol 4/16 8.82E-Ol S.28E+OO S.28E+OO26DNT I.S3E+OO 3.30E+OO S / 17 4.42B-o1 1.5IE+OO 1.51E+OOLead 3.SSE+Ol 1.03E+02 6/6 3.SSE+Ol 6.36E+Ol 6.36E+Ol

7 Soil 135TNB 2.19E+OO 2.79E+OO 2/9 1.62E-ol 1.47E+OO 1.47E+OO13DNB 3. 18E-Ol 3. 18E-Ol 1/8 1. 14E-Ol 1.69E-Ol 1.69E-Ol246TNT 8.98B+02 4.39E+03 8 / IS 8.06B+04 1.48E+ 10 4.39E+0324DNT 1.93E+OO 5. 12B+OO 11/19 1~26E+OO 4.39E+OO 4.39E+OO26DNT 4. 19E+OO 1.61E+Ol 4/15 4.82E-Ol 1.98E+OO 1.98E+OOChromium 1.0SE+Ol 1.68E+Ol 2/2 1.0SE+Ol S.OSB+Ol 1.68E+OlCopper I.S0E+Ol 1.63E+Ol 4/4 1.S0E+Ol 1.67E+Ol 1.63E+OlNickel 9.76E+OO 1.04E+Ol 3/3 9.76E+OO 1.40E+Ol 1.04E+OlLead 1.81E+02 . 3. 15E+02 3/3 1.81E+02 3.81E+02 3.1SE+02

10 Soil Lead 9.01B+02 1.99B+03 3/3 9.01E+02 2.S8E+03 1.99E+03Tetryl 4.27E+03 1.37B+04 4/8 4.S0E+OS 7.33E+15 1.37E+04

21 Soil 13DNB 3.31E+OO 7.70E+OO 3/5 5.59E+OO 2.78E+05 7.10E+OO246TNT 7. 16B+03 2.20B+04 4/5 2.66E+07 7.32E+28 2.20E+0424DNT 4.99B-ol 6.66B-ol 2/S 4.99E-ol 1.S6E+OO 6.66E-oI26DNT 3.01E+OO 5.81E+OO 2/5 4.40E+OO 5.83E+ 16 5.87E+OO

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Table 1 (Continued)Exposure Concentrations of Contaminants of Potential Con~ern (COPes) in ShaDow·

SoU and Sediment at Study Areas 6, 7, 10, and 21 at AAAP Area B

Frequency Upper 9S%Study Detected Concentration of Best Estimate Confidence ExposureArea Medium Analyte Mean Maximum Detection of the Mean Limit (UC4s) Concentration

(mglkg) (mglkg) (mglkg) (mglkg) (mglkg)

21, Sediment 13DNB S.09E+Ol S.09E+Ol 1/23 3.34E~1 9.20E~1 9.20E~1

cont. 246TNT 7.2SE+OO 1.65E+Ol 7 /26 1.46E+OO 7.07E+OO 7.07E+OO24DNT 1. 19E+OO S.67E+OO 6/2S 2.30E-o1 4.86E~1 4.86E-ol26DNT 9.10E-ol 1.8SE+OO S114 4.95E-o1 I.S3E+OO I.S3E+OOANTRC 2.40E-ol 2.4OE-oI 1/3 1.2SE-ol 2.98E-Qt 2.40E-QlBAANTR 1.10E+OO 1.10E+OO 1 /3 6.02E-Ql 1.83E+06 1.10E+OlCHRY 7.90E-ol 7.9013-01 1/2 4.40E-ol 2.6SE+OO 7.90E-olChromium 3.38E+Ol S.03E+Ol 41'S 2.84E+Ol 4.62E+Ol 4.62E+OlCopper 1.93E+Ol 3.16E+Ol SIS 1.93E+Ol 2.94E+Ol 2.94E+OlFANT 1.60E+OO 1.60E+OO 1 / 3 1.19E+OO 7.76E+ IS 1.60E+OOHO 4.01E-{)1 4.01E-{)1 1/23 1.23E-ol 1.SOE-Ql I.S0E-61NB S.08E+Ol S.08E+Ol 2/24 2.02E+OO 7.23E+OO 7.23E+OONickel 1.74E+Ol 2.07E+Ol 8/8 1.74E+Ol 1.96E+Ol 1.96E+OlNNDPA S.OOE-6t S.OOE-ol 1/3 2.SSE-QI 6.22E-oI S.OOE-olLead S.80E+Ol 2.23E+02 26/26 S.80E+Ol 7.24E+Ol 7.24E+OlTetryl 1.28E+OO 1.28E+OO 1/22 2.22E-oI 3.17E-ol 3. 17E-ol

·Soil and sediment data from samples collected 0 to 2 feet below land surface.

Key: ANTRC - Anthracene FANT- FluorantheneBAANTR - Benzo(a)anthracene NB- NitrobenzeneCHRY- Chrysene NNPDA- N-Nitrosodiphenylamine

24DNT - 2,4-Dinitrobenzene 13STNB - 1,3,5-Trinitrobenzene26DNT- 2,6-Dinitrobenzene 246TNB - 2,4,6-Trinitrobenzene

Source: ESE.

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2. Soil samples collected during the RI survey (ESE, 1986) contained low concentrationsof leachable lead (20.7 to 94.4 jlg/L) that were below the then-applicable extractionprocedure (EP) toxicity criteria.

3. Friable and transite asbestos contamination is extensive and well mixed with soil due toplant demolition activities.

4. Currently, no groundwater is used \yithin 10,500 ft of the combined TNT ManufacturingAreas. Based on a maximum horizontal migration rate in the unconsolidated materials,contaminant migration to the point of withdrawal is not imminent.

5.1.2 Study Area 21 - Red Water Ditch

The Red Water Ditch was studied during the exploratory and RI surveys. Significant fmdingsinclude:

1. Sediments collected during the RI survey contained 0.880 ppm of TNT at the point wherethe Red Water Ditch leaves the installation. TNT was also detected where the RedWater Ditch leaves the Southern TNT Manufacturing Area (Study Area 6).

2. Low concentrations of nitroaromatic compounds (in three samples) and lead (in twosamples) were detected in the upstream surface waters during the exploratory sUlVey.The Red Water Ditch was not flowing during the RI survey. The 2,4-DNT concentrationsranged from 3.0 to 3.7 p,g/L.

3. All soil ~ples collected along the spoil banks during the RI survey contained TNT,with concentrations ranging from 0.665 to 22,200 ppm. The compounds 2,4-DNT (0.667ppm in one sample); 1,3-DNB (0.221 and 7.70 ppm); and 2,6-DNT (0.15 and 5.87 ppm)were also· detected. Individual pieces of TNT can still be found in the spoil banks.Leachable lead (64.4 and 2,733 p,g/L) was detected in two of three soil samples tested.Both values were below the then-applicable EP toxicity criteria.

4. Sediments in the Red Water Ditch are not a source for surface water contaminationmigrntion. Contaminated sediments are genenillyassociated with the surface ofthe wwngrade of the Red Water Ditch. Bank erosion during the past 50 years has covered thes~

contaminated sediments with clay to a depth of 1 to 2 ft below the current surface of theRed Water Ditch.

5. Runoff from the spoil piles and occasional discharges from contaminated industrial sewerlines present potential pathways for contaminant migration.

6. TNT contamination in the surface sediments of the Red Water Ditch is a result ofupstream: TNT production. The absence of tetryl in the surficial sediments of the RedWater Ditch at the ISS outfall from the Tetryl Manufacturing Area indicates that, while

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the ISS is contaminated, it does not appear to be discharging the contamination to thesurface drainages.

5.2 Industrial Sewer System asS)

Layouts of the sewer lines in Study Areas 6, 7, and 10 are shown in Figures 4, 5, and 6,respectively.

5.2.1 Study Area 6 - Southern TNT Manufacturin& Area

Contamination (approximately 1 ppm of TNT) was detected in one sample collected from thefurthest upgradient manhole (MH 6-16) in the E-TNT production line where the Mono-NitratingHouse feeder line meets the trunk line from the Fortifier House. Contamination was alsodetected inside _a manhole(MH 6-18) structure in one of the three samples collected where theditch from the Bi- and Tri-Nitrating House (E-TNT line) enters the system, and in a manhole(MH 6-11) sample where the line from the H-TNT production line connects to the G-TNT line.

The highest nitroaromatic concentrations (15,800 ppm of 2,4-DNT and 12,500 ppm of TNT)detected in the Southern TNT Manufacturing Area were in the shallow (6 ft) soil sample at

- manhole MH 6-3, where the surface water ditch entered the vertical clay pipe. The -samplecollected at 14 ft near the base of the manhole also contained nitroaromatic contamination (5compounds) at lower concentrations. Discoloration generally diminished with depth and mayhave been due to leaching by solvents in the wash runoff. High TNT concenmtions (1,400 ppm)were also detected in the sample (TP 6-4) collected from the ditch between the E-TNTprodu~tion line Washer House and the Red Water Ditch.

Three of the six sediment samples collected from the surface dIainage ditches containeddetectable concentrations of TNT (0.47 to 2.87 ppm). No contamination was detected in thesample collected from the Red Water Basin at the outfall of the ISS line. No other cont:am.in8ntswere detected in the sediment samples.

Both water samples collected from the ISS outfal1s contained detectable concenmtions of TNT.The sample from the outfall of the combined G- and H-TNT production lines contained 1.33ppm of TNT, while the sample from the E-TNT production line contained 198 ppm of TNT.This sample also contained 2,4-DNT; 2,6-DNT; and RDX.

Based on these results, the ISS within the Southern TNT Manufacturing Area is contaminatedwith high concentrations ofnitroaromatic compounds. These concentrations vary from productionline to production line and also within each production line. The manhole stmctures haveprobably leaked to some degree, as evidenced by contamination in the soils surrounding thestructures. The greatest soil contamination appears to be in the area where the surface ditch fromthe Bi- and Tri-Nitrating House enters the ISS.

TNT contamination in the surface sediments of the Red Water Ditch and multiple nitroaromatic

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tlSACE AAAP tSFS"f LB

r FIGURE 4 ,: II U.S. ARMY CORPS OF ~GINEE~SLAYOUT OF INDUSTRIAL SEWER SYSTEM 1;11 ~

IN STUDY AREA 6 - SOUTHERN TNT i HUNTSVILLE DMSlONMANUFACTURING AREA ;11' ALABAMA ARMY AMMUNlnON PLANTSOURCE: ESE.L..- - ;~I ----~~~-...........~

FLfWII. It Tlltl·

NIT"anNOHOUSE

o,~f1J 8"

~ UNEF 0. 12'·

MONO­------- NITRATINGHOURo ACID AND AlMa .

12" UNE E RECOVERY "GUll

FLOW~ 8". IMH6-18I~ TO REDWATER ~SIN

KEYMH - ManholeTP - Test Pit

- N~

NOT TO SCALE

NOTE:ALL PIPES ARE VITRIFIED CLAY.

1

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'JSACE AAAP ISFS H1 LB

FLOW--....

I! FLOW: ~

FlOW---..

0 1'2e & ACID I ...RECOYER" MOUU

OIOl.a Tal.NlTaATINCIMOUU,s-

FLOW---..

_ DNT NITRATING

U2 IWIATINCI I HOUlEGIWI••• MOUa 0

Ii"P7-21

KEYMH - ManholeTP - Test Pit

NOTE:ALL PIPES ARE VITRIFIED CLAY.

NOT TO SCALE_ N-....

FIGURESLAYOUT OF INDUSTRIAL SEWER SYSTEMIN STUDY AREA 7 - NORTHERN TNTMANUFACTURING AREA

u.s. ARMY CORPS OF ENGINEERSHUNTSVILLE DMSlON

ALABAMA ARMY AMMUNTION PLANTSOURCE: ESE.

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~SACE AAAP ,gS1-11' LB

;

UNI L

! :

la"- \~ U.. IC

~FLOW : \\!N \

~UNlJ

: \

\NOT TO SCALE UNI " = /

/

U!~ /"-I

FLOW,

UNI a

! ,... :- 8-

ii UNI F !Q• I=LOW

2." TI:TIm. .....111TlTl'YL N""ATIMI NOUSa ,..-aHOUlE 1002.£ UNlI

=TETnL .-A,..~ HOUII'....u: \-- ~D

t:

\FLOW UN! C ,\

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NOTE:ALL PIPES ARE VITRIFIED CLAY.

KEYMH-ManholeTP - Test Pit

FIGURE 6LAYOUT OF INDUSTRIAL SEWER SYSTEMI::U:AREA 10 - TETRYL MANUFACTURING AREA

u.s. ARMY CORPS OF ENGINEERSHUNTSVILLE DIVISION

ALABAMA ARMY AMMUNmON PLANl

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compounds in the waters discharging from the ISS indicate that the ISS in the Southern TNTManufacturing Area is continuing to discharge contamination to its surface dminages.

5.2.2 Study Area 7 • 'Northern TNT Manufacturin& Area

High concentrations (5,330 to 70,000 ppm of TNT) of contamination were de~ected in all fOUf

samples collected inside the manhole structures. A large piece (approximately 1 ft by 2 ft) ofweathered TNT was observed in m~ole MH 7-3. Contamination was detected in the twosamples collected from the upgradient manholes (MH 7-1 and MH 7-7) on the C-TNT andD-TNT production lines where the Mono-Nitrating House feeder line meets the trunk line fromthe Fortifier House. Contamination in these two manhole structures included: 5,300 ppm of TNTand 19,300 ppm of nitrocellulose in :MIl 7-1; and 70,000 ppm of TNT ~d 8,600 ppm ofnitrocellulose in MH 7-7, along with 2,4-DNT. Contamination was detected in the three manhole(MIl 7-6, MIl 7-9, and MIl 7-15) samples collected where the ditch from the Bi- andTri-Nitrating House enters the ISS.

Soil contamination was detected in the five upper-reaCh soil samples (TP 7-10, TP 7-11, TP 7-7,TP 7-4, and TP 7-2) from the four TNT production lines. The highest nitroaromaticconcentrations (79,700 ppm of TNT) detected in the Northern TNT Manufacturing Area werein the deep soil sample (9.5 ft) at manhole MIl 7-6 'where the ditch from the Bi- andTri-Nitmting House enters the vertical clay pipe. The sample collected at 3.5 ft at this samelocation also contained nitroaromatic contamination (46,100 ppm of TNT). Soils at the junctionof this ditch with the ISS line were discolored (bright putpIe) and had an odor, which did notregister on the photoionizing detector. This discoloration generally diminished with depth.

Four of the six sediment samples collected from the surface dnlinage ditches containedconcentrations of TNT (1.48 to 63.3 ppm). A detectable concentration of2,4-DNT (1.41 ppm)was also detected in one sediment sample.

No water samples were collected from the Northern TNT Manufacturing Area due to dryconditions during the field investigation.

Based on these results, the ISS within the Northern TNT Manufacturing Area is contaminatedwith high concentmtions of nitroaromatic compounds. These concentIations vary from productionline to production line and also within each production line. The manhole structures haveprobably leaked to some degree as evidenced by high concentmtions of contamination in the soilssurrounding the structures. The greatest soil contamination appears to be in the area where thesurface ditch from the Bi- and Tri-NitIating House enters the ISS.

TNT contamination in the surface sediments of the Red Water Ditch indicates that the ISS in theNorthern TNT Manufacturing Area is continuing to discharge contamination to its surfacedminages.

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5.2.3 Study Area 10 - Tetryl Manufacturinl Area

Soil contamination was detected where the wastes entered the ISS from surface ditches. Thehighest tetryl concentrations (20,900 ppm and 18,900 ppm) detected in the Tetryl ManufacturingArea were in the shallow (2 ft and 2.5 ft) soil samples at manholes MH 10-3 and MIl 10-1,where the surface ditches entered the vertical clay pipes leading to the base of the manholestructures. The samples collected near the base of the manholes at these locations containedtetryl contamination at lower concentrations. High nitrocellulose concentrations were detectedin the shallow soil samples at these two locations.

Low concentrations of TNT were detected in the two sediment samples collected from thesurface drainage and at the ISS outfall into the Red Water Ditch. No other contaminants weredetected in the sediment samples.

Based on these results, the ISS within the Tetryl Manufacturing Area is contaminated with highconcentrations of tetryl, nitrocellulose, and 1,3,5-TNB. The manhole structures have probablyleaked as evidenced by contamination in the soils surrounding the structures. The greatest soilcontamination appears to be in the area where the surface ditches enter the ISS.

6.0 SUMMARY OF SITE RISKS

The information presented in this section is based on the ItSupplemental RemedialInvestigation/Feasibility Study for Area B, Alabama Army Ammunition Plant, Baseline RiskAssessment", August 1992.·

6.1 Exposure Assessment

The human risk assessment (RA) evaluated three primary exposure scenarios for quantitativeassessment of the risks associated with potential exposure of the local population within theintended areas to site-related contaminants of concern. Based on the physical and chemicalproperties of the contaminants identified in Area B, as well as the site-specific geological,hydrogeological, and meteorological conditions, the most significant migration pathway has beendetermined to be inftltration of soil contaminants to the underlying groundwater.

The following human exposure scenarios have been addressed in the risk assessment:

• Future residential scenario.• Future industrial scenario.• Current worker or caretaker scenario.

The primary human exposure routes evaluated for the residential and industrial scenarios in theRA included:

• Exposure to contaminants as a result of ingestion of groundwater contaminatedby on-site soils and sediments.

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• Exposure to contaminants as a result of direct contact (dermal contact andincidental ingestion) with surface soil, surface water, and sediments. .

• Exposu~ to contaminants as a result of inhalation of contaminated dusts.

The main ecological exposure routes evaluated included:

• Exposure of aquatic and terrestrial animals to contaminants as a result of directcontact (dennal contact and incidental ingestion) with surface soil, surface water,sediments, and contaminated food.

• Exposure of terrestrial animals to contaminants as a result of inhalation ofcontaminated dusts.

Results of the human and ecological RA indicated that the potential noncarcinogenic' andcarcinogenic adverse impacts to human health and the environment, which are associated withfuture exposure to several study areas within Area B, range from low to high. These impactsdepend on the exPosure scenario and the study area being considered. The noncarcinogenicimpacts are indicated by a cumulative hazard index (HI) exceeding 1; a carcinogenic risk isposed if the cumulative risk exceeds 1.0E-04.

A summary of contaminants in soils and sediments that required remedial alternative screeningbased on the ecological risk assessment is presented in Table 2.

6.2 Intermediate Cleanup Levels (ICLs)

Inte~ediate Cleanup Levels (leLs) developed in the Baseline Risk Assessment for futureresidential and indusiriaI scenarios for Study Areas 6, 7, 10 and 21 are presented in Table 3.

7.0 DESCRIPTION OF REMEDIAL ALTERNATIVES

In this section, remedial alterDati~es for soils and sediments and the ISS are discus'sed separatelyas they were evaluated in various Area B feasibility studies. Soils and sediments remedialalternatives are discussed in Subsection 7.1 and ISS remedial alternatives are discussed inSubsection 7.2.

7.1 Soils and Sediments Remedial Alternatives

Several remedial alternatives were considered during the initial screening stage in the DJaftFeasibility Study for Area B submitted in March 1992. The remedial alternatives were groupedaccording to the type(s) of contaminants. The groups consisted of:

• Metals- and polyaromatic hydrocarbons (PAH)-contaminated soils and sediments.• Explosives-eontaminated soils and sediments.• Metals- and explosives-contaminated soils'and sediments.

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Table 2

Contaminants in Soils and Sediments that Required Remedial AlternativeScreening Based on the Ecological Risk Assessment

I Study Area I Contaminant of Concern I6 TNT; 2,4-DNT; 2,6-DNT

7 TNT; 2,4-DNT; 2,6-DNT; Lead

10 Tetryl; Lead

21 TNT; Lead

Source: Supplemental Remedial Investigation/Feasibility Study for Area B, Alabama ArmyAmmunition Plant, Baseline Risk Assessment, August 1992.

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Key:

Table 3

Intermediate Cleanup Levels for Soils and SedimentsConsidering Multiple Exposures

Intermediate Cleanup Levelsl

Contaminant (ppm)

Residential Industrial

TNT 34.3 647

1,3-DNB 1.Q2 1.Q2

Tetryl 696 5,000

Lead 200 500

- For each contaminant in each category, the listed ICL is the lowest ICLestablished for Study Areas 6, 7, 10 and 21.. Although the lowest ICLis listed, leLs for each study area are quite similar (e.g., for TNT, theICLs for the Residential Scenario for SUldy Area 6, 7, and 21 are 34.8ppm, 34.3 ppm and 34.7, respectively).

2 - Note that the Baseline Risk Assessment dated August 1992 includedexcavation criterion for 1,3-DNB of 0.5 ppm. The Chemical DataAcquisition Plan (CDAP) for the Stockpile Soils Area Opemble Unitoutlines the quantitation limits for metals and explosives. Table 8-2 of

. the CDAP indicates that the quantitation limit for 1,3-DNB is 1 ppm.Review of Table 6.2-2 of the Baseline Risk Assessment of August 1992indicates that the ICL for 1,3-DNB was based on the analytical detectionlimit. There' is a concern that due to potential analytical interferences,the lower limits specified in the RIlFS may not be consistentlyachievable. As such, the excavation criterion for 1,3-DNB is set at 1ppm.

NE - Not Established.

Source: Supplemental Remedial Investigation/Feasibility Study for Area B, AlabamaArmy Ammunition Plant, Baseline Risk Assessment, August 1992, Tables 6.2-1,6.2-2, and 6.2-3.

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The aggressiveness of the remedial alternatives increased in ascending order. After the initialscreening, five fmal alternatives (Alternatives lA, Ie, ID, IG, and 11) were assembled andretained for detailed ~ysis. The fmal soils and sediments remedial alternatives were thefollowing:

IA: Stabilization of Metals- and PAR-Contaminated Soils and Sediments.

Ie: Off-Site Disposal of Metals- and PAR-Contaminated Soils and Sediments.

lD: Incineration of Explosives-Contaminated Soils and Sediments.

1G: Incineration/Stabilization of Metals- and Explosives-Contaminated Soils andSediments.

11: No Action.

Brief descriptions of the soils and sediments remedial alternatives are presented in Subsections7.1.1 through 7.1.4.

7.1.1 Alternative lA: StabilizationofMetals- andPAH-Contaminated Soils and Sediments

Alternative lA includes site preparation followed by excavation of all metals- and PAH­contaminated soils and sediments. Excavated soils and sediments would be remediated using thefollowing operations:

1. . Staging of soils and. sediments prior to stabilization.2. On-site stabilization until TCLP criteria are met.3. Backfilling stabilized soils into the existing excavation.4. Landfilling of remaining stabilized material in an off-site hazardous was~ landfill.

7.1.2 Alternative Ie: Off-Site Disposal of Metals- and PAR-Contaminated Soils andSediments

Alternative 1C includes site preparation followed by the excavation of all metals- and PAH­contaminated soils and sediments. Excavated soils and sediments would be transported to theChemical Waste Management hazardous waste landfill facility for disposal.

7.1.3 A1ternative·1D: Incineration of Explosives-Contaminated Soils and Sediments

Alternative ID includes site preparation followed by excavation of all explosives-contaminatedsoils and sediments. Excavated soils and sediments would be remediated using the followingoperations:

1. Staging of soils and sediments prior to incine14tion.

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2. On-site incineration via transportable rotary kiln incinerator for explosives­contaminated material.

3. Disposal of incinerated ash in the original excavations.4. LandfJ1l.iDg of remaining stabilized material in an off-site hazardous waste landfill.

7.1.4 Alternative IG: Incineration/Stabilization of Metals- and Explosives-ContaminatedSoils and Sediments

Alternative 1G includes site preparation followed by excavation of all explosives- and metals­contaminated soils and sediments. Soils and sediments contaminated with metals and/orexplosives would be remediated using the following operations:

1. Staging of soils and sediments prior to incineration and!or stabilization.2. On-site incineration via transportable rotary kiln incinerator.3. Stabilization of soils and sediments and incinerator ash until TCLP criteria are

met.4. On-site disposal of treated and stabilized material.

7.1.5 Alternative 11 - No Action

The no-action alternative is required to be included as stipulated by CERCLA/SARA as abaseline against which other alternatives can be evaluated. Under this alternative, contaminatedsoil and sediments would remain in place in the identified study areas. The risks from thecontaminants of concern (COCs) would remain. No cost is associated with this alternative.

7.2 Industrial Sewer System Alternatives

Three remediaI alternatives were evaluated in- the detailed analysis in the RIlFS for the ISSsubmitted in September 1991. A fourth alternative was developed during the prepantion of thisinterim ROD based on site inSpections and review of archive drd.wings. The new alternative isidentified as ISS3. The ISS remedial alternatives are as follows:

ISS1: Excavation, On-Site Flashing, and Off-Site Landfilling.

ISS2: Excavation, On-Site Mobile Rotary Kiln IncinelCltion, and Off-Site Landfilling.

ISS3: Deactivation and Grouting of Concrete-Encased yep; Excavation,Decontamination or On-Site Incinemtion, and On-Site Disposal of VCP.

ISS7: No Action.

Approximately 20,000 linear feet of underground sewer lines (8 to 36 inches in diameter)currently exis~ in Study Areas 6, 7, and 10. Some of the vep is encased in concrete. Muchhas been disturbed during plant demolition activities over the years. Subsections 7.2.1 through

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7.2.3 describe the three remedial alternatives.

7.2.1 Alternative ISSl: Excavation, On-Site F1ashin~ and Off-Site LandJillin&

Alternative ISS1 (identified as Alternative 1 in the RIfFS of September 1991) involvesexcavation, on-site flashing, and off-site disposal of the contaminated sewer lines and manholesin Study Areas 6, 7, and 10. Explosives-contaminated vitrified clay pipe sewer lines, concreteencasement, and brick manholes would be flashed on-site. Flashing requires the use of a hand­held flamer to thennally decompose surface contaminants. It is anticipated that completedecomposition of all potentially energetic residues that are at, or near, the flame front can beaccomplished due to the intensity of the heat.

The explosives thennally decompose to volatile byproducts via a combination of ring-splittingand fragmentation reactions. In all cases, the reactions are exothennic. No air emissionscontrols are associated with on-site flashing. The primary byproducts of complete thennaldecomposition of explosives include nitrous oxides (N0J, carbon monoxide (CO), carbondioxide (C02), water (H20), and nitrogen gas (N2). This technique has been used successfullyin the decontamination of stroctures at several sites including the West Virginia Ordnance Worksand the ALAAP Leaseback Area.

The decontaminated materials must then be crushed and transported off-site for disposal in ahazardous waste landfill. The potentially energetic components of the hazardous waste will bedeactivated and residual materials disposed in a pennitted hazardous waste landfill.. Theestimated cost for implementation of this alternative is $4,165,000 (Feasibility Study of theIndustrial Sewer System, September 1991).

7.2.2 Alternative ISS2: Excavation. On-Site MobUe Rotary Kiln Incineration, and Off­Site Landtilling

Alternative ISS2 (identified as Alternative 2 in· the RIfFS of September 1991) involvesexcavation, on-site incineration, and off-site disposal of the contaminated sewer lines andmanholes in Study Areas 6, 7, and 10. Explosives-contaminated vitrified clay pipe sewer lines,concrete encasement, and brick manholes would be incinerated on-site using a ~obile

incinerator.

The mobile incinemtor selected for this application would consist of a rotary kiln unit with asecondary combustion chamber. The secondary combustion chamber would achieve adestroction and removal efficiency (ORE) of 99.99% for organic contaminants in the off-gas.The resulting ash and debris would then be transported off-site to a hazardous waste landfill.This requires deactivation of the energetic components of the hazardous waste and disposal ofresidual materials in a pennitted hazardous waste landfill. The estimated cost forimplementation of this alternative is $6,190,000 (Feasibility Study of the Industrial SewerSystem, September 1991). .

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7.2.3 Alternative ISS3: Deactivation and Groutin& of Concrete-Encased VCP; Excavation,Decontamination or On-Site Incineration. and On-Site Disposal of VCP

Alternative ISS3 was developed during the process of writing this Interim. ROD, based on siteinspections, discussions with U.S. Army Corps of Engineers personnel, and review of archivedrdwings. In this alternative, concrete-encased pipes and non-encased pipes are addressedseparately. A detailed description of this alternative is presented in .Section 9.0 (SelectedRemedy and Remediation Goals). A summary of remedial actions is presented in the followingpanlgnlphs.

Concrete-encased pipes will be visually inspected for gross contamination. Contaminatedmaterial will be removed and treated in the on-site incinentor, and the pipes will be grouted inplace. Where the pipes are crushed or broken, oversize material will be decontaminated anddisposed on-site in the backfill area. Undersized material «2 inches) will be blended withsurrounding soil and will be treated on-site by incineration and/or stabilization and disposed inthe on-site backfill area.

Nonencased sewer lines and manholes will be removed and transported to the incinemtor sitefor decontamination by high-pressure water washing or other .approved methods. Thedecontaminated material will be disposed in the on-site backfill area.

Contaminated soil exceeding the excavation criteria above and surrounding the VCP will betreated on-site by incineration and!or stabilization and disposed in the on-site backfill area.

7.2.4 .' Alternative ISS' - No Action

The no-action alternative is required to be included as stipulated by CERCLA/SARA as abaseline against which other alternatives can be evaluated. Under this alternative, contaminatedvep within the industrial sewer system would remain in place in the identified study areas. Therisks from the COCs would remain. No cost is associated with this alternative.

8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

8.1 Threshold Criteria

Overall Protection of Human Health and the Environment

(A) Soils and Sediments: Alternative 11 (No Action alternative) would not provide protection tohuman health or the environment. Alternatives lA and Ie address only metals- and PAH­contaminated soils and sediments. Alternative ID addresses only explosives-conraminated soilsand sediments, therefore, the potential risk from leaching lead into groundwater will remain.Alternative 1G provides the most protection to human health and the environment by permanentdestmction of all organic contaminants through incinetation, and through immobilizing lead bystabilization.

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{Bl Industrial Sewer System: Alternative ISS? (No Action alternative) would not provideprotection to human health or the environment. Alternatives ISS1, ISS2, and 1553 wouldprovide adequate prot~tion to human health and the environment by providing a pennanentsolution which includes removal and irreversible destruction of contaminants.

Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)

CAl Soils and Sediments: No federal or state chemical-specific ARARs regulate implementationof any of the alternatives. Soils will be remediated according to health-based cleanup levelsdetennined to be protective to human health and the environment. In Alternatives lA, ID andIG, stabilized materials will meet the TCLP criteria for metals. In Alternatives 1D and IG,incineration will meet < 1 ppm for TNT in treated material. Alternative II (No ActionAlternative) would not achieve the remediation levels since the contamination would not beremoved or destroyed.

(B) Industrial Sewer System: No federal or state chemical-specific ARARs regulateimplementation of any of the alternatives. Alternatives ISSl, ISS2, and ISS3 would meetexcavation and decontamination criteria upon completion of remedial actions. Alternative ISS?(No Action Alternative) would not achieve the remediation levels since the contamination wouldnot be removed or destroyed.

The following location-specific ARARs may be applicable within AAAP:

1. Within loo-year floodplain .

• 40 CFR 264. 18(b) - Facility must be designed, constructed, operated, andmaintained to avoid washout by a 1oo-year flood.

2. Within floodplain

• Executive Order 11988; 40 CFR 6, App. A: Floodplain Management - Requiresactions to avoid adverse effects, minimize floodplain destruction, restore andpreserve natural aDd beneficial values, and minimize impact of floods on humansafety, health and welfare..

3. Wetland

• Executive Order 11990; 40 CFR 6, App. A: Protection of Wetlands - Requiresaction to avoid adverse impact, minimize potential hanD, and to preserve andenhance wetlands to the extent possible.

4. Within an area affecting stream or river

• Fish and Wildlife Coordination Act [16 United States Code (USC) 661 et ~.] -

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Must take action to protect affected fish or wildlife resources, and prohibitsdiversion, channeling, or other activity that modifies a. stream or river and affectsfish or wildlife.

5. Critical habitat upon which endangered or threatened species depends

• Endangered Species Act of 1973 (16 USC 1531 et ~.); 50 CFR 402 - Requiresaction to conserve endangered or threatened species. Must not destroy or adverselymodify critical habitat.

However, none of the location-specific ARARs are expected to apply to implementation of anyof the alternatives being evaluated since all activities associated with the Area B Soils OpembleUnit remediation would be conducted in areas located away from sensitive ~nvironment (i.e.,the river, lOO-year floodplain, or critical habitat).

The following action-specific ARARs may apply to implementation of these alternatives,excluding Alternatives 11 and ISS? (No Action):

1. Clean Air Act (CAA)

• 40 CPR Part 50: National Primary and Secondary Ambient Air QualityStandards--Establishes standards for ambient air quality to protect public health andwelfare.

.~. 40 CPR ·Part 61: National Einission Standards for Hazardous Air Pollutants-Setsemission standards for designated hazardous pollutants.

2. Resource ConselVation and Recovery Act (RCRA)

• 40 CPR Part 261: Identification and Listing of Hazardous Waste - Providesguidelines for classify~gwastes as hazardous waste.

• 40 CPR Part 262: Standards Applicable to Generntors of Hazardous Waste ­. Establishes standards for generators of hazardous waste.

• 40 CPR Part 264: Standards for Owners and Opemtors of Hazardous WasteTreatment, Storage, and Disposal Facilities - Establishes minimum national standardswhich define the acceptable management of hazardous waste for owners andopemtors of facilities which treat, store, or dispose of hazardous waste.

• 40 CPR Part 266 Subpart H: Standards for Hazardous Waste Burned in Boilers andIndustrial Furnaces - Specifies standards for owners and operators of boilers andindustrial furnaces burning waste and not operating under interim status.

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3. Alabama Administrative Code (AAe)

• Chapters 13-1 through 13-7: Alabama Solid Waste Management Regulations ­Establishes minimum criteria for the processing, recycling and disposal of solidwastes and the design, location, and operation of solid waste disposal facilities.

• Chapters 335-3-1 through 335-3-14: Alabama Air Pollution Control Rules andRegulations - Sets emission standards and establishes pennitting requirements for airpollutants.

4. Code of Alabama

• Title 22, Chapter 27: Alabama Solid Waste Act - Establishes a statewide programto 'provide for the safe management of non-hazardous wastes.

• Title 22, Chapter 28: Alabama Air Pollution Control Act of 1971 - Provides for acoordinated statewide program of'air pollution prevention, abatement, and control.

• Title 22, Chapter 30: Alabama Hazardous Wast~ ~agement and Minimization Act- Establishes a statewide program to provide for the safe management of hazardous·wastes, including hazardous waste generation, ttansportation, and land disposal.

5. Alabama Department of Environmental Management (ADEM)

". Chapter 14-1: Alabama Hazardous Waste Management Regulations-Establishesstandards which defme the acceptable management of hazardous waste for ownersand operators of facilities which treat, store, or dispose of hazardous waste.

8.2 Primary Balancin& Criteria

Short-Term Effectiveness

CAl Soils and Sediments: No significant risks to the community, workers, or the envi.rQnmentare expected during the implementation of any of the soil and sediment remedial alternatives.Workers will be provided with appropriate personal protection, and safety procedures will befollowed during all phases of the remedial actions. Alternative 11 would present unacceptablerisks to human health and the environment since no remediation of the contaminated soils andsediments would occur. Therefore, this alternative would not be effective in the short term.

(B) Industrial Sewer System: Provided that there are no adverse effects associated withuncontrolled emissions resulting from flashing (Alternative ISS1), the risks to the community,workers, and the environment associated with the implementation of each of the alternatives areanticipated to be minimal. The greatest safety hazards are expected to be associated with sewerline excavation (in all alternatives), and deactivation of encased VCP (Alternative ISS3). The

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risks to the workers will be reduced by wearing appropriate personnel protection, and followingproper safety procedures. Alternatives ISSl, ISS2, and ISS3 present a risk to workers due tothe potential for explosion and exposure to contaminants during excavation. Alternative ISS7would present unacceptable risks to human health and the environment since no remediation ofthe contaminated vep would occur. Therefore, this alternative would not be effective in theshort term.

Long-Term Effectiveness and Permanence

CAl Soils and Sediments: Alternatives lA, Ie, ID, and 10 would reduce the risk associated withcontaminants. Alternatives ID and 1G would provide a permanent remedy for explosives­contaminated materials by irreversible destruction of organic contaminants via incineration.Alternative 10 will provide additional long-term protection by immobilizing leachable metals,primarily lead, by stabi1ization. Alternative II would not be effective in the long term since thecontamjnation soil and sediment would remain in place without treatment.

(Bl Industrial Sewer System: Alternatives ISSl, ISS2, and ISS3 would remove and destroy thesource of contamination in the ISS. After remediation, no signifiCant concenmtions ofcontamjnation would remain that require long-term management to ensure adequate levels ofprotection. Alternative ISS7 would not be effective in the long term since the contaminationVCP. would re~ain in place without treatment.

Reduction of Toxicity, Mobility, and Volume (TMV)

CAl Soils and Sediments: The TMV of contaminated materials will be reduced significantly ineach of the alternatives. Alternatives ID and IG would provide more reduction in volume thanAlternatives IA and Ie, since these alternatives provide permanent destmetion of explosives­contaminated materials. Alternative IG would be the most effective since it addresses all tYPesof contamjnants in soils and sediments. Although some stabilized materials will result inAlternative 1G, the mobility of the contaminants will be significantly reduced. Because theCODtaminants in soil and sediment would not be destroyed or treated under Alternative 11, TMVof the contaminants would remain unchanged.

lBl Industrial Sewer System: Alternatives ISSI, ISS2, and ISS3 would provide a high degree ofcontaminant destmetion and, therefore, a high degree of reduction of toxicity, mobility, andvolume of the contaminants in the ISS. The treatment in all three alternatives is irreversible.Because the contamjnants in VCP would not be destroyed or treated under Alternative ISS7,TMV of the contaminants would remain unchanged. .

Implementability

(Al Soils and Sediments: All alternatives are easily implementable. The equipment, personneland technologies associated with each alternative are readily available. No remedial actionwould be conducted under Alternative 11.

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(B) Industrial Sewer System: The equipment, personnel and technology are readily available forall three alternatives. No technical limitations are associated with the mobile incineration(Alternatives ISS2 and ~SS3). Implementation of the flashing alternative (lSSl), is dependentupon obtaining a pennit from EPA which allows uncontrolled emissions associated with openburning ·(flashing). Deactivation procedures for encased vep (Alternative ISS3) will beevaluated by a fmn specializing in management of energetic wastes. Procedures will beapproved by the U.S. Anny. No remedial action would be conducted under Alternative ISS7.

Cost

(A) Soils and Sediments: Soil and sediment volumes and costs were estimated in the FSsubmitted in March 1992. However, these volumes and costs are not representative of thecurrently-proposed remedial actions due to changes in study areas and remediation goals. TheBaseline Risk Assessment was revised in August 1992. The leLs established in the revised riskassessment were ~gher than those established in March 1992. New volumes were not calculatedbased on these revised leLs.

The approximate cost for proposed remedial Alternative 1G is now estimated based on thefollowing as~umptions:

(A) Volume of contaminated soils and sediments equals the volume of soil andsediment computed for the industrial scenario for Alternative 1G (from March1992 FS).

. (B) Unit ~ost = S346/yd3 based on a remedial alternative with a similar remedialapproach and a comparable volume of contaminated soil (March 1992 FS:Alternative ID, residential scenario, total cost = $12,039,913; total volume =34,761 yd3

; unit cost = S346/yd3).

The total cost of remediation of soils and sediments for the proposed alternative, based on avolume of 39,800 yd3 and a unit cost of S346/ycf3, is $13,770,800 (volume calculations arediscussed in Subsection 9.1). .

lID Industrial Sewer System: The estimated costs for Alternatives ISSl and ISS2 are $4,165,000and $6,190,000, respectively. The exact costs for Alternative ISS3 are not available at this time.However, the costs are expected to be approximately those of Alternative ISS2. Based on a totalpipe length of 20,000 ft in Study Areas 6, 7, and 10, and a unit cost of $3OO/linear ft, a totalcost of $6,000,000 is estimated at this time until detailed cost estimates are completed.

8.3 Modifyinr Criteria

ADEMIEPA Acceptance

EPA and ADEM have concurred with the choice of Alternatives 1G and ISS3.

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Community Acceptance

A public notification for the Area B Soils Operable Unit public meeting and public commentperiod was advertised in four local newspapers. The public comment period began on 19September 1994 and ended on 19 October 1994. Approximately 20 people attended a publicmeeting which was held on 28 September 1994 at the Centnll Alabama Community College.The major concern of the public involved recent occasions of particulate (dust) fallout from anunidentified source. The public was informed that the tmnsportable incinemtor had completedremediation of the Area A Soils Operable Unit on 22 August 1994 and, therefore, ·had not beenoperational in the five-week period prior to the meeting.

9.0 SELECTED REMEDY AND REMEDIATION GOALS

The complete remedy for the Area B Soils Opemble Unit consists of Alternatives IG and ISS3.A brief description of these alternatives follows:

Alternative IG: Incineration/Stabilization of Metals- and fimlosives-Contaminated Soils andSediments

• Clear, survey, and grid areas; perform soil and sediment sampling and analysisto delineate contamination by explosives (TNT, 1,3-dinitrobenzene, and tetryl)and lead.

• For contaminated areas: excavate soils and sediments until excavation criteria aresatisfied; screen materials; tmnsport materials to the tmnsportable incinerationsystem (TIS-20) site in Area B; treat materials.by incineration and/or stabilization .until treatment and disposal criteria are satisfied.

• Decontaminate oversize materials by crushing or shredding and tteatment in theTlS-20, or by high-pressure water washing and disposal in the backfill area.

• Expand thee~g on-site disposal area for final placement of treated materials.

• Backfill excavated areas in Study Areas 6 and 7 and rough gmde to pre-excavatedcontours; backfill Study Area 21 to the elevation of surrounding banks of the RedWater Ditch.

• Close .the' disposal area in accordance with the existing approved permitapplication for treated soils ("Treated Soils - Backtill Area Permit Application forthe Alabama Army Ammunition Plant Stockpile Soils Area Openble Unit",March 1993).

• Treat contaminated process, sampling, and decontamination wastewaters in theTlS-20 aqueous waste treatment system; reuse water for site dust control and

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process makeup.

• Conduct confmnatory soil and' sediment sampling and analysis to ensure thatexcavation criteria have been satisfied.

• Excavated materials that contain asbestos (tiles, fragments, etc.) will be separatedduring feed preparation activities at the TIS-20 site. Details of the materialshandling procedures may be found in the Work Plan.

Alternative ISS3: Deactivation and Grouting of Concrete-Encased VCP: Excavation, On-siteIncineration, and On-Site Di§Posal of VCP

" .•

Locate and sUIVey the existing vitreous clay pipe (VCP) sewer lines andmanholes.

Sample overlying soils to determine compliance with excavation criteria; excavateto depth of sewer; visually inspect interior and exterior of sewer; remove grosscontamination; treat materials in TIS-20 or other approved methods andprocedures.

Remove nonencased sewer lines and manholes; transport materials to TIS-20 sitefor decontamination by high-pressure water washing or other approved methods;dispose decontaminated materials in the backfill area.

Sample and analyze soils around sewer lines and manholes for contamination;excavate as necessary to achieve excavation criteria.

Screen and transport contaminated soils and sediments to the ,TIS-20 site fortreatment by incineration and/or stabilization.

Where sewer lines are encased in concrete: visually inspect interior; removegross contamination; treat materials in TIS-20 or by other approved methods andprocedures; water wash; grout!cement in place after decontamination. .

Where lines are crushed or broken: visually inspect and remove grosscontamination; excavate oversize (> 2 inches) materials; transport oversizematerials to TIS-20 and decontaminate for disposal in on-site backfill; blendundersize materials with surrounding soils using approved methods; transportmaterials to the TIS-20 for treatment by incineration and/or stabilization.

Portions (10 percent) of decontaminated VCP will be tested to ensure adequatedecontamination. Although not expected, if adequate decontamination cannot bedemonstrated using Webster's Reagent (due to porosity of pipe), a portion of thedecontaminated pipe will be crushed and analyzed for panuneters outlined in the

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excavation criteria. If Webster's Reagelit is used, there is no numericalquantifiable decontamination criterion. A change of color will indicate that TNTis present at concentrations above 15 p,g/cm2

• If decontamination criteria are exceeded, the piping will be decontaminated again,tested, and disposed in the backfill area if criteria are satisfied. Decontaminatedpiping that fails to meet the decontamination criteria after two water-washingswill be crushed, blended with contaminated soils, treated in the TIS-20 anddisposed in the on-site backfill area.

• Conduct confmnatory soil sampling around and below removed pipe to ensurethat excavation criteria are satisfied.

9.1 Basis for Selection

Alternative 1G was selected as the most appropriate remedial alternative for soils and sedimentsin Study Areas 6, 7, and 21 because it best addresses explosives and .metals (primarily lead)contaIilination and provides the most effective ovenill protection to human health and theenvironment. Incineration is the primary treatment method in Alternative 1G. Numerous othertreatment methods (such as composting, biodegradation, etc.) were evaluated in the technologyscreening stage in the FS. During the technology screening stage, these technologies wereeliminated based on their applicability to site-specific circumstances such as effectiveness of thetreatment technology to COCs, availability, implementability, etc. A complete discussion ofscreening of technologies is contained· in the Draft Feasibility Study of March 1992.

A cost comparison was perfonned in the Draft FS for three types of incinerators. They aretransportable rotary kiln incineration, slagging rotary kiln incineration, and infrared incineration.The analysis indicated that the cost of incinemtion using a rotary kiln unit is considembly lessthan the other two technologies. Currently, Stockpile Soils at ALAAP are being treated on-siteby a rotary kiln incinerator (TIS-20) with a pennit capacity of 21.26 tons/hour. The TIS-20 hasalready processed over 31,000 tons of soils contaminated with explosives, lead and other metals.Extensive stack sampling during mini-bums and the Perfonnance Test has demonstrated that theTIS-20 is capable of meeting the reference air concentrations (RACs) for lead and other metalsas dermed by the Boiler and Industrial Furnace (BIF) regulations. The reinediation of StudyAreas 6, 7, 10 and· 21 is not expected to produce soils with metals concentrations higher thanpreviously demonstrated in the Performance Test. Since the soils and sediments in Study Areas6,7, and 21 contain the same waste characteristics as the Stockpile Soils, it is appropriate to userotary kiln incinemtion as the primary treatment method. In addition to rotary kiln incinemtion,Stockpile Soils treatment also includes a soils stabilization process, prior to on-site ,disposal oftreated materials.

All of the active industrial sewer system alternatives meet the evaluation criteria to reducetoxicity, mobility, or volume. However, alternative ISS1 would result in some degree ofuncontrolled emissions which would potentially expose site workers. Alternatives ISS2 and ISS3

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are similar, since both alternatives require excavation and decontamination. Alternative ISS3does not eliminate the possibility of on-site incineration, but it does allow the option of reducingpotential cleanup costs if high-pressure water washing meets the decontamination criteria.

The volumes of contaminated soils and sediments for Alternative 1G for Study Areas 6, 7, and21 based on the Draft Feasibility Study of March 1992 are presented in Table 4. These volumesare stated herein only as a guideline, and are expected to be less than originally-estimated forthe following reasons:

• The volumes of contaminated soils and sediments shown in Table 4 are hea.lth­based risk cleanup goals derived in the Baseline Risk Assessment, conducted aspart of the Draft FS of March 1992. The Baseline Risk Assessment was revisedin August 1992 (after submission of the Draft FS) with higher cleanup goals, asshown in Table 3. These higher goals will be used in the remediation of AreaB Soils Operable Unit. The revised volumes based on these later cleanup goals.are not available.

• When the volumes were calculated in the Draft FS of March 1992, the mediasampling upon which they were based was conducted only within a relativelysmall portion of each study area of concern (Study Area 6, 7, 10, and 21), andmay not be representative of each entire area.

• The U.S. Army has elected to conduct an extensive sampling program todelineate the extent of contamination in each study area prior to remediation.Actual excavated volumes will be 'based on the results of the delineation samplingand analysis program and may change significantly from those estimated fromearlier, more limited data.

Therefore, no effort will be made at this time to recalculate new volumes based on the August1992 Baseline Risk Assessment. .

9.2 Remediation Goals

The selected alternative will meet the following remediation goals:

Excavation Cleanup Goals

The excavation cleanup goals for explosives- and lead-contaminated soils and sediments are:

Parameter

TNT1,3-DNB*

Excavation/CleanupCriteria {mlml

6471

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Table 4

Contaminated Soil and Sediment Volumes for Alternative IG

ScenarioStudy Contaminant(s)Area Residential Industrial Caretaker

(Ycr) (Yd') (ycr)

6 TNT 16,600 16,600 13,333

7 Lead 16 12 12TNT 18,148 12,963 12,9631,3,S-TNB 13

21 Lead; 1,3-DNB; TNT 10,2251,3-DNB; TNT 10,225TNT 10,225

Source: Supplemental Remedial InvestigationIFeasibility Study for Area B,Alabama Army Ammunition Plant, Draft Feasibility Study, March 1992.

Note: The above volum~ are based on the initial leLs derived during the Baseline RiskAssessment conducted in the March 1992 FS. The proposed remedial action will bebased on higher ICLs (Table 3) established in the revised Baseline Risk Assessment ofAugust 1992. Because of the higher cleanup levels, the actual volume of contaminated .material is expected to be lower than shown in Table 4. The ICLs for IndustrialScenarios for both Baseline Risk Assessments are as follows:

leLs based on March 1992 ICLs based on August 1992Baseline Risk Assessment and Baseline Risk Assessment andEPA Guidance for lead EPA Guidance for lead(Table 3 volumes are based . (Proposed Remedial Actionon these leLs) is based ~n these ICLs)

Contaminant

TNT 64.1 ppm 647 ppm1,3-DNB 0.5 ppm 0.5 ppmTetryl 1,290 ppm 5,000 ppmLead SOO ppm 500 ppm

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Parameter

TetrylLead (total)

Excavation!CleanupCriteria (ppm)

5,000500

Source: Supplemental Remedial Investigation/Feasibility Study (RIfFS) for Area B, AlabamaAnny Ammunition Plant (AAAP), Baseline Risk Assessment, August 1'992.

* Note that the Baseline Risk Assessment dated August 1992 included excavationcriterion for 1,3-DNB of 0.5 ppm. The Chemical Data Acquisition Plan (CDAP) forthe Stockpile Soils Area Operable Unit outlines the quantitation limits for metals andexplosives. Table 8-2 of the CDAP indicates that the quantitation limit for 1,3-DNBis 1 ppm. Review of Table 6.2-2 of the Baseline Risk Assessment of August 1992indicates that the ICL for 1,3-DNB was based on the analytical detection limit. Thereis a concern that due to potential analytical interferences, the lower limits specified inthe RIfFS may not be consistently achievable. As such, the excavation criterion for1,3-DNB is set at 1 ppm.

Water Treatment Criteria

The treatment criteria for wastewaters generated during remediation activities are:

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Parameter Treatment Criteria

Total Suspended Solids (TSS)Total Dissolved Solids (TDS)pH

< 50 mg/L< 1000 mg/L6 - 10

Source: Chemical Data Acquisition Plan (CDAP) for a Transportable Incineration System(TIS) at the Alabama Anny Ammunition Plant (AAAP) Stockpile Soils AreaOperable Unit, Revision No.5, 25 May 1994.

As in the case of the prior remediation of the Stockpile Soils Area Operable Unit, the rotary kilnincineration system is a net water consumer. Treated water is only used for process makeupwater and site dust control. There is nonnally no surface water discharge.

Incineration/Backfill Criteria for Treated Soil from Incinerator

Treated soil from the incinerator will be stored until analytical results indicate that the ashsatisfies the following treatment criteria for backfill:

Parameter

TNT (Total)

Arsenic (TCLP)Barium (TCLP)Cadmium (TCLP)Chromium (TCLP)Lead (TCLP)Mercury (TCLP)Silver (TCLP)Selenium (TCLP)

IncinerationlBackftllCriteria

1 ppm

5 mg/L100 mg/L1 mg/L5 mg/L5 mg/L0.2 mg/L (4 p,glg using total metals analytical method)5 mg/L1 mg/L

Source: Work Plan for a Tnmsportable Incineration System (TIS) at the Alabama AnnyAmmunition Plant (AAAP) Stockpile Soils Area Operable Unit, February 1994.

Treated material failing to meet the TCLP backfill criteria will be stabilized before disposal.Treated material failing to meet TNT incineration criteria will be reprocessed.

StabilizationIBackftll Criteria for Stabilized Material

The backfill criteria for stabilized material that is not incinerated will be the excavation cleanupcriteria for explosives and the TCLP criteria for metals, 'as follows:

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Parameter Stabilization/Backfill 'Criteria

ExplosivesTNT (Total) 647 ppm1,3-DNB* (Total) 1 ppmTetryl (Total) 5,000 ppm

Metals, Arsenic (TCLP) 5 mgfL

Barium (TCLP) 100 mgfLCadmium (TCLP) 1 mg/LChromium (TCLP) 5 mg/LLead (TCLP) 5 mg/LMercury (TCLP) 0.2 mg/L (4 p,glg using total metals analytical

method)Silver (TCLP) '5 mg/LSelenium (TCLP) 1 mg/L

Sources: (A) Baclifill criteria for explosives: Supplemental Remedial Investigation/FeasibilityStudy (RIfFS) for Area B, Alabama Anny Ammunition Plant (AAAP), Baseline RiskAssessment, August 1992..(B) Backfill criteria for metals: Work Plan for a Transportable Incineration System(TIS) at the Alabama Army Ammunition Plant (AAAP) Stockpile Soils Area OpembleUnit, February 1994.

* Note that the Baseline Risk Assessment dated August 1992 included excavationcriterion for 1,3-DNB of 0.5 ppm. The Chemical Data Acquisition Plan (CDAP) forthe Stockpile Soils Area Operable Unit outlines the quantitation limits for metals andexplosives. Table,8-2 of the CDAP indicates that the quantitation limit for 1,3-DNEis 1 ppm. Review of Table 6.2-2 of the Baseline Risk Assessment of August 1992indicates that the ICL for 1,3-DNB was based on the analytical detection limit. Thereis a concern that due to 'potential analytical interferences, the lower limits specified inthe RIfFS may not be consistently achievable. As such, the excavation criterion for1,3-DNB is set at 1 ppm.

Decontamination Criteria

Portions (10 percent) of decontaminated vep will be tested to ensure adequate decontamination.Although not expected, if adequate decontamination cannot be demonstrated using Webster'sReagent (due to porosity of pipe),' a portion of the decontaminated pipe will be crushed andanalyzed for pammeters outlined in the excavation criteria. IfWehster's Reagent is used, thereis no numerical quantifIable decontamination criterion. A change of color will indicate that TNTis present at concentrations above 15 p,g/cm2• .

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If decontamination criteria are exceeded, the piping will be decontaminated again, tested, anddisposed in the backfill area if criteria are satisfied. Decontaminated piping that fails to meetthe decontamination ~riteria after two water-washings will be crushed, blended withcontaminated soils, treated in the TIS-20 and disposed in the on-site backfill area.

10.0 STATUTORY DETERMINATIONS

The selected remedy (Alternatives IG and ISS3) satisfies the requirements under Section 121 ofCERCLA to:

• Protect human health and the environment.

• Comply with ARARs.

• Be cost-effective.

• Utilize pennanent solutions and alternative treatment technologies or resourcerecovery technologies to the maximum extent practicable.

• Satisfy the preference for treatment as a principal element.

10.1 Protection of Human Health and the Environment

The selected remedy protects human health and the environment through permanent treatmentand disposal of treated material.

During the remediation activities, adequate protection will be provided to the c~mmunity ~y

reducing the 'short-term risks posed by air emissions from the thennal treatment unit and dust,. lead, TNT, tetryl and asbestos fibers potentially generated during material handling activities.

In addition, workers will be provided with personal protection equipment during all phases ofremediation activities. Both area and personnel air sampling programs will be established tomonitor ambient and worker exposures and ensure adequate protection. Deactivation of encasedvep (or removal of potentially energetic materials for incine1Cltion) will be perfonned byqualified personnel with proper safety precautions. Although not expected, if necessary forreasons of safety, personnel will be evacuated from the immediate vicinity prior to deactivationactivities.

Long-term protection to human health and the environment will be provided by minimizingresidual risk from the contaminants and by reducing or eliminating impacts on the environment.

Controls employed in this alternative are adequate and reliable. The air pollution control systemof the incinerntor (currently operating on-site) successfully passed its Performance Test in June1994 and yielded stack emissions in accordance with regUlatory limits, protecting workers andthe community from risks associated with inhalation. There are no unacceptable short-term or

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long-term impacts on human health or the environment in this alternative.

10.2 Compliance with Applicable or Relevant and Appropriate Requirements

The selected alternatives (1 G and ISS7) comply with all ARARs. All the COCs in soils of StudyAreas 6, 7, 10 and 21 within the Area B Soil OU (i.e., explosives and lead) are expected tomeet required regulatory treatment/disposal standards prior to disposal.

No federal or state chemical-specific ARARs prevent implementation of the selected alternatives.Soils will be remediated based on health-based cleanup levels detennined to be protective tohuman health and the environment. Lead-contaminated soils will be remediated to achieve thehealth-based soil lead concentration of <500 mg/kg (based on blood-lead uptake levels inchildren). Soils contaminated with TNT will be remediated·to achieve the health-based soil TNTconcentration of < 647 mg/kg (based on the resultant risk for adult residents and the contributinghazard index (HI) due to exposure concentrntion for child residents).

No location-specific ARARs prevent the use of the selected alternative.. All activities associatedwith implementation of this alternative will be conducted away from sensitive environments (i.e.,river or tOO-year floodplain).

The following action-specific ARARs will be met with implementation of this alternative:

• Incinerator ash will be routinely tested for destruction of explosives, as required byReRA (40 CFR Part 264; Standards for Owners and Operators of Hazardous Waste

.' Treatment, Storage, and Disposal Facilities) and the State of Alabama '(AlabamaAdministrative Code Chapter 335-14-5.15(4)(a)l: Perfonnance Standards forIncinerators) .

• TCLP extract analysis on incinerator ash will be performed to ensure that metalsconcentrations meet RCRA guidelines for arsenic, barium, cadmium, chromium, lead,mercury, selenium, and silver (40 CFR Part 264; Standards for Owners and Operatorsof Hazardous Waste Treatment, Stomge, and Disposal Facilities). Incinerator ash thatdoes not pass TCLP will be solidifiedlstabilize4 prior to disposal.

• Incinerator ash and solidified/stabilized material (if required) will be disposed on-site inArea B in accordance with RCRA (40 CFR Part 264; Standards for Owners andOperators of Hazardous Waste Treatment, Storage, and Disposal Facilities) and the Stateof Alabama (Code of Alabama, Title 22, Chapter 27; Alabama Solid Waste Act andAlabama Administrative Code Chapters 13-1 through 13-7; Alabama Solid WasteManagement Regulations).

• Workers will be provided with personal protection equipment during .all phases of theselected remedy, in compliance with the OccupatioDal Safety and Health Act (OSHA) (29USC SSe 651-678). Adequate protection will be provided to the community by reducing

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risks posed by air emissions from the thermal treatment unit and reducing dust potentiallygenemted during material excavation and handling activities.

• Portions (10 percent) of decontaminated vep will be tested to ensure adequatedecontamination « 15 p,g/cm3

). Decontaminated debris will be disposed of on-site inArea B in accordance with State of Alabama regulation (Code of Alabama, Title 22,Chapter 27: Alabama Solid Waste Act and Alabama Administrative Code Chapters 13-1through 13-7: Alabama Solid Waste Management Regulations).

10.3 Cost-Effectiveness

Based on a cost comparison study conducted during the Draft FS of March 1992, tremsportablerotary kiln incineration was determined to provide ovenill effectiveness proportionate to its costs,compared to other types of incinemtors. This alternative takes advantage of the specialequipment, operators, site preparation, thermal treatment system, and regulatory approvalsalready in place for the treatment of the Area B soils.

10.4 Utilization of Permanent Solutions and Alternative Treatment Technoloaes orResource Recovea Technoloaes to the Maximum Extent Practicable

The selected remedy (Alternatives 16 and ISS3) meets the statutory requirements to utilizepermanent solutions and treatment technologies to· the maximum extent pmcticable to achieveremediation goals. The xationale for selecting~ remedy is based on the compuative analysisof the evaluati0t:t criteria. The criteria used in selecting the remedy include:

1...00&-Term. Effectiveness and Permanence: The selected remedy employsdestmction of explosives-eontaminated materials and stabilization of lead­contaminated materials. All treated materials will be disposed on-site byexpanding the existing disposal area.

Short-Term Effectiveness: The selected remedy does not involve off-sitetremsportation c;>f contaminated soils, thereby eliminating the risks due to sPi1Iageand fugitive ~missions. The community, workers, and the environment will beprotected during remedial actions by implementing appropriate protectivemeasures.

Implementability: No waiting period is involved for implementation of theselected remedy. An incinemtor and a stabilization plant are currently approvedby the regulatory agencies and are operating on-site treating soils of the StockpileSoils Area Operable Unit which have similar characteristics as the contaminatedsoils and sedimentS in the Area B Soils Operable Unit.

~: Transportable rotary kiln incinention is considerably less costly than othertypes of incinemtion.. Since an incinemtor is currently on-site, treating soils with

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similar characteristics, costs for activities such as regulatory approvals,mobilization!demobilization, etc. will be minimal for incineration of soils andsediments.

10.5 Preference for Treatment as a Principal Element

The selected interim action utilizes treatment for the contaminated soils and sediments in StudyAreas 6, 7, and 21, and the Industrial Sewer System (ISS) in Study Areas 6, 7, and 10 withinthe Area B Soils Operable Unit. Any additional required actions for Study Areas 6, 7, 10, and21 will be addressed in the fmal Decision Document for the Soils of the Area B Soils OpembleUnit.

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RESPONSIVENESS SUMl\fARY

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RESPONSIVENESS SUMMARY

1.0 OVERVIEW

The public reaction to the selected remedy is mainly acceptance. The major concern of thepublic involved recent occasions of particulate (dust) fallout from an unidentified source. Allof the public comments have been addressed, and the public appears to have no substantiveconcerns regarding implementation of the selected remedy. Continued community relationsactivities will be held to maintain public awareness of the status of remedial activities atALAAP.

2.0 BACKGROUND ON COMMUNITY INVOLVEMENT

General community interest in the ALAAP site has historically not been great. Since the sitewas declared excess to Army needs in 1973, interest has genemlly come from private groups orindustry interested in developing portions of the site. The southern part of the site (i.e., theformer nitrocellulose manufacturing area) was sold to the Kimberly Clark COlpOration in the late1970s, and a paper products plant was constmcted. In the mid-1980s, in response to interestin purchasing the eastern part of ALAAP (Area A), this section was remediated by the Armyand the contaminated soil was stoCkpiled in the western part of ALAAP (Area B), creating theStockpile Soils Area Operable Unit (OU). A ROD for treatment (i.e., incineration followed bysolidification!stabilization, if required) of the Stockpile Soils Area OU has been .signed andimplemented.

Post-excavation sampling was performed to verify the remediation efforts within Area A and twosites (Study Areas 12 and D) were subsequently identified as containing contamination a~ve

acceptable levels. A final ROD for treatment (i.e., excavation followed by stabilization) of theArea A OU was issued in April 1994, and has been subsequently implemented.

A supplemental RIlFS for Area B, prepared in March 1992, identified tetryl, lead and TNTcontamination in the old manufacturing areas. A dIaft final ROD for treatment of the Area 13Soils OU (for Study Areas 6, 7, 10 and 21) was issued in August 1994. Notice of the publiccomment period and meeting for the Area B Soil OU was placed in four local newspapers onSeptember 19, 1994. A 3Q-day public comment period extended until October 19, 1994. Apublic meeting was held on September 28, 1994 at the Central Alabama Community College,located about 5 miles from the ALAAP site. Two written public comments were received, andare attached at the end of this Responsiveness Summary.

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3.0 SUMMARY OF PUBLIC COMMENT AND AGENCY RESPONSE

3.1 Comments from Public Meetine

At the public meeting held September 28, 1994, the public was given the opportunity tocomment and ask questions about the selected remedy (Alternatives 1G and ISS3). Thefollowing is a summary of the questions!comments raised by the public andArmy/regulator/cODtnlctor responses given at the meeting, including supplemental answers(where applicable):

Ql. Aren't they already burning the soil out here? Aren't they already in the process ofdecontaminating?

Answer at meetin&: (USAEC) Yes.

Sup.plemental: WESTON has successfully treated approximately 21,000 yet ofexplosives- and metals-eontamjnated soils from Area A. Soils which failed to meet theTCLP criteria for metals are currently being stabilized before being placed in the backfillarea. All equipment and those areas not necessary to support the stabilization- activitieshave been decontaminated.

Q2. Is this the first public meeting?

Answer at meetinK: (Army) We had a public meeting over a year ago. And we're­"getting better at notifying the community on mail-outs and similar kinds of things to givethem more of a chance to know what's going on.

Answer at meetine: (USACE) It's' going to be an on-going process. This is just onephase of the cleanup out there. So you would get input into a continuing process in thecleanup of the site.

Q3. Exactly what kind of material are you going to be burning?

Answer at meetine: (wpsTON) The Alabama Army Ammunition Plant, during thesecond World War and shortly thereafter, manufactured retryl and TNT, along with otherchemicals on this particular site. The chemicals of concern (CDCs) in terms of theirexposure to the human environment and to wildlife, are TNT and tetryl (which areexplosive compounds) and lead (which is a heavy metal).

Areas 6 and 7 are the TNT manufacturing areas, and Area 10 is the tetryl manufacturingarea. The Red Water Ditch (Study Area 21) was the major dIainage for wastewaters togo off of the site. The industrial sewer system· (ISS) from the various production areasemptied into the Red Water Ditch. .

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Where there is a hit or a compound that's detected at or above the excavation level, thecleanup level, the soil will be excavated and transported to the incinerator for thermaltreatment.

Q4. Could you explain, without a lot of detail, mayPe a little bit about a Restoration AdvisoryBoard (RAB) -- what their function would be and what the end result is going to windup being?

Answer at meeting: (USAEC) Well, among other things, they review the technicaldocuments with respect to cleanup; they look at things like the Interim Record ofDecision that's on the table in the back of the room; keep up with the progress ofcleanup actions. You have an opportunity to make comments here in a public forum, butmembers of the Board will have the opportunity to make their comments early on to thedecision makers. They will also be able to report back on what they have learned tomembers of the community.

Q5. Aren't we getting into this late?

Answer at meetine: (USAEC) It's something that the Army has issued a policy on, andits starting now. It's a little bit late, but better late than never....Ifwe get -enough peoplesaying yes, we want to have a Restoration Advisory Board, then we move in thatdirection at that time.

Q6. Would one of their focuses also be to assure the completeness of the remediation project?

Answer at meeting: (Army) Absolutely. You would get to see the evolution of theproject as it progresses.

Q7. Are you monitoring what comes out of the smoke stack?

Answer at meeting: (USAEC) Yes.

Answer at meeting: (Army) Absolutely.

Answer at meeting: (ADEM) Before the State of Alabama permitted the start-up of thisincinerator, we put on very, very tough restrictions. And there has been nomalfunctions, or intermittent emissions from the plant.

Q8. Is there any kind of fallout?

Answer at meeting: (Army) No.

Q9. Is it in transparent form or other forms? What's 'happening when you bum it?

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Answer at meeting: (Army) We destroy its properties. We destroy its ability to hurt theenvironment. We're making it sterile. We're making it harmless.

Ql0. Are there any particulates being emitted from the burning process?

Answer at meetin&: (USACE) There are some. It's wen within the established EPA andADEM criteria. In fact, it's about tenfold less.

Answer at meeting: (USEPA) EPA standards on particulate emissions are very strict.We nm the incinerator through an exhaustive series of trial tests without hazardous wastein it to measure what particulate output would be.

Ql1. What would be the makeup of the particulates that are emitted?

Answer at meeting: (USACE) Carbon dioxide (CO~, •..

SUImlemental: Water vapor, oxygen, acceptable levels of trace metals.

Q12. I live in the northeastern part of Childersburg, and there appears to be fallout that seemslike coagulated mud. It's happened within the last two or three months. I've tried, ashave some of my neighbors, to get someone to come and take a look at what might befalling. The State of Alabama came out three weeks ago, but I've gotten no report. Itmay be nothing harmful, I don't know. I have some samples that I have taken, and Iwould ~e someone to look at them and see what they might be.

Answer at meeting: (USACE) The incinerator hasn't been on for over six weeks. It'sbeen in a cold status for six weeks. And when it rem, we continuously monitored thestack, plus there were monitoring stations put around the perimeter of opeIations toensure no particulates were emitted.

Answer at meetin&: (ADEM) Who was the gentleman that came out to look? Response:Carl Ferraro. Answer: I have to apologize for the Department of En~Dmenta1Management. I assure you that I will get something started tomorrow, and I'n have areport back to you at the end of the week to let you know what we're doing.

SUpjllementa1: (ADEM) The sample supplied to ADEM was analyzed and determinedto be mostly quartz (45-97%) and organic matter (2-54%) from an unknown source. Aletter addressed to the concerned citizen was issued October 6, 1994 repOrting the testresults, which has been attached at the end of the Responsiveness Summary.

Q13. Couldn't that stuff be ion particles in the atmosphere, gather enough moisture tocoagulate, then form larger particles?

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Answer at meeting: (ADEM) It is possible. But because of the requirements and theregulations that we put on this incinerator since it was classified as a hazardous waste,I would just about guarantee that it's not coming from our incinerator, simply becauseof the multiple devices that the emission goes through before it goes to the atmosphere.,It's very stringent.

Q14. When was the last date your incinerntor operated?

Answer at meetin&: (USACE) 22 August 1994.

Q15. I wonder if you can tell us if five years from now that the incinemtor wasn't hazardousto our health?

Answer at meeting: (ADEM) From a toxicological point of view, we've had a healthassessment run on this plant. We've done health and ecological risk assessments. And,to our knowledge, our restoration will eliminate any risk at that site. That's all we cansay today.

Q16. In the last days of World War n, I heard there was a project at ALAAP called HeavyWater which was the atom bomb. Are there any of those contaminants that areradioactive or anything from those experiments?

Answer at meetin&: (Army) He's talking about the Manhatten project area.

"Answer at meeting: (USAEC) We've done numerous studies on where the Manhattenproject took place and where the Heavy Water was produced. We have not foundanything that would lead us to believe that there's anything of a ndioactive natu~ orCODtaminating matter on the installation.

Answer at meetin&: (Army) There was very limited Heavy Water at this facility. I thinkthey produced about 1,300 gallons of water. DOE (Department of l3nergy), whichopemted that portion of the project, does not have a lot of information about what wenton at that time. And most of the stnlctores have been taken away. In future studies, wewill be putting more monitoring wells around that area to see if there is any impact.

Answer at meetiJ)K: (USACE) That area has been evaluated since 1973. People havebeen out, trees have been d~g up, samples have been taken, monitoring has been done.Nothing's ever been found.

Q17. In the history of th~ plant, can you tell me how many fish, foul, animal, or humans havebeen harmed by this contamination? '

Answer at meet:ine: (USAEC) I can't.

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Answer at meeting: (WESTON) I cannot answer that question.

Q18. Do you have a record of anybody or anything?

Answer at meeting: (USAEC) No, sir. Unless it's been in an explosive manner wheresome igloo blew up, I don't think so.

Q19. If not, why are we cleaning up this contamination after 45 or 50 years?

Answer at meetin&: (Army) That's been mandated by the political leadership. Theirdirection to us - it's certainly not an Army decision. It's mandated from a politicalstmcture that says to restore this property to the public domain for the use of the

\community. I mean, we couldn't say we want to put a fence around it and leave it for100 years. That's not even our decision - that's political leadership.

Q20. Do you have an estimate of the total cost of the decontamination of Study Areas 6, 7,10 and 21?

Answer at rneetin:: (USAEC) We do have a rough estimate... But we really haven't gota firm estimate yet on it.

Answer at meetin&: (Army) Believe me, we would like to spend as little as possible,because the mandated money we have to spend comes from outside our control. Wewould love to spend less, but we have a standard we have to meet for cleanup.

Answer at meetin&: (USACE) Give you a ball park, three to ten million.

Q21. How many acres are involved?

Answer at rneetin&: (WESTON) Approximately 160 acres for areas 6, 7, 10 and 21.

Q22. Is this similar like Gadsden is doing right now?

Answer at meeting: (WESTON) No. There are no chemical agents at this particularsite.

Q23. Are there any tnlcks coming in and out of that plant?

Answer at meetinK': (WEsTON) No, sir. Everything is contained within the plant.When we shut down, let's say at the end of a normal eight or a ten-hour day, thosetrocks stay in that particular area. They do not go over the road until they've beendecontaminated, and that won't happen unless the tmck breaks down and we've got totake it off-site or if we're demobilizing. All of our equipment is contained within theALAAP boundary limits. .

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Q24. Do you know how long it's going to take to clean it up?

Answer at meeting: (WESTON) If we go with the estimates that we have right now,we're probably talking in the area of about a year to a year and a half~

Q24. What's done with the material after it's burned?

Answer at meetin&: (WESTON) It's disposed in the backfill areas on-site. It is basicallyclean soil. Again the contaminants of concern are either tetryl or TNT. Both of theseare in relatively low concentrations, but they are combustible materials. So when the soilgoes through an incinemtor that has a tempetature of 1800of, plus or minus, those thingsare completely combusted. And what comes out at the tail end is basically a sanitizeddisinfected soil.

Q25. Does that destroy the lead too?

Answer at meetine: (WESTON) The lead stays with the soil. And if it passes the testsas far as the treatment criteria goes, it goes into the backfill. If it does not pass thattreatment criteria, it gets stabilized. And that basically means it gets mixed with acement or a lime-kiln type of material to make it into a solidified mass.

Q26. I was wondering that ifyou have to send this soil to another lab to be sure that it's clearof everything and that it's okay, how~ we be sure that your equipment and incinentoris doing its job as it's supposed to'1 And how can we be sure our air is not contaminated

. if you've got to send this soil to another lab to really be sure that it's clean?

Answer at meeting: (USACE) The first test is at· the site; the second test is by anindependent off-site laboratory. But there's a third test, which: is 10% of all samples Isend to the Missouri River Division, my labontory, to ron tests. And they correlate dataagainst his data here from his laboratory and his data out in the field.

Q27. But we just have one check on the stuff that comes out of the smokestack?

Answer at meeting: (WESTON) No. We do periodic tests on that incinerator. Thereis an on-line instIUment that is calibIated every single day. And those calibl3.tion records3:Te a part of what I must submit on a weekly basis to the COlpS of Engineers.

In addition to that, I didn't mention there are two independent combustion emissionmonitoring systems (CEMS). They are totally independent. One backs up the other.They both opemte 24-hours a day, so if there is a malfunction in one, the other one picksup the slack until the first one is brought back on-line.

Also, there are about 24 automatic waste feed' cut-offs. If our temperature in theincinentor gets too low, ifour residence time gets too low, ... the incinerator shuts off.

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Q28. Don't you also have ambient air monitoring equipment?

Answer at meetins: (WESTON) We have ambient air monitoring, that is correct, aroundthe perimeter of the site, in addition to the meteorological station.

Q29. Could you add one more piece of paper to that stack of paperwork you produce, that isto visit a person who has a complaint, who thinks that you may be at fault'?

Answer at meeting: (WESTON) You are welcome to come out to the incinerator at anytime, with advance notice to our site manager Mr. Barry Wright... If you call up and justtell us you want to be out there a half hour from now or whatever to have a tour of thesite -- now, there's certain areas that we can show you, but certain areas we can'tbecause they are handling contaminated material. But from the outside of the fence, it'svisually very easy to see what's going on. We're not hiding anything. The number atthe plant is (205)378-3924.

Q30. Have y'all already got buyers for the property?

Answer at meetinK: (USACB) The property has not yet been put up for sale. It won'tuntil we get it cleaned up.

3.2 Responses to Written Comments

Ll. .' Letter No.1: Dated September 29, 1994 from Ms. Laura Payne.

• Comment - I would like information on groundwater contamination at ALAAP.

Response - The current Area B Interim ROD does not address groundwatercontamination which may be present at this facility. Any information which hasbeen published regarding site investigations (including groundwatercontamination) ~t the ALAAP may be found at:

Earle A. Rainwater Memorial Library12 9th Avenue, SWChildersburg, AL 35044

or at the Holston Army Ammunition Plant located in Kingsport, TN. Ongoingand future investigations by the u.s. Army, as outlined in its Site ManagementPlan for ALAAP, will determine a fmal course of action for groundwatercontamination at the facility.

• Comment - Is there any way that the public could be supplied with someone whocould intelpret the informarion provided? \

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Response - The Army has designated Ms. Catherine Stalcup as the public affairsofficial for ALAAP. She can be reached at the following address:

u.s. Army Environmental CenterAttention: SFIM:-AEC-PA (Ms. Catherine Stalcup)Building E4461-TAberdeen Proving Ground, Maryland 21010-5401(410) 671-1268

u. A letter dated 22 September 1994 was received from Ms. Laura Olah, President ofCitizens for Safe Water Around Badger (CSWAB). Major issues and responses are asfollows:

• Comment - Alternative IG (on-site incineration) does not reduce the toxicity,mobility or volume of inorganics (such as lead).

Response - Alternative 1G includes incineration and stabilization of metals- andexplosives-eontaminated soils and sediments.

Treated materials will be tested to ensure compliance with the treatment criteriafor TNT and the toxicity chaIacteristic leachate procedure (TCLP) for metals.If required, stabilization will be conducted prior to backfill to "encapsulate" or"contain" the inorganics (specifically metals). As stated in the Feasibility Study,the mobility and toxicity of metals in soils and sediments would be reduced bysolidification!stabilization; however, the volume of contaminated soils!sedimentswould not be reduced. Solidification would increase the volume by approximately20 to 30 percent since reagents are added to the" soils/sediments. Stabilization isexpected to reduce the mobility and toxicity of meta1s-contaminated soils andsediments by preventing the leaching of metals from the final product and byeffectively bonding the contaminants to the reagents in a stabilized material.

• Comment - Incineration disperses inorganic contaminants to air, water, soil andincinerator ash. Incinerators are not safe. The direct risks of incineratorpollutants on human health are based on the probability of exposure to levels oftoxic compounds sufficient to cause disease. Incinerators produce air, water andsoil toxics through stack emissions or fugitive emissions. The uptake of these

"toxins into plants and animals and their biomagnification through the food webpresent the greatest risk to people--either through absorption,. inhalation oringestion.

• Response - Stringent stack testing was conducted on the incineration systemduring previous remediation activities at ALAAP. Three "mini-bums" wereconducted to ensure proper opemtion of the air pollution equipment. Emissionstesting was conducted while the incineIation system processed uncontaminated and

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contaminated materials. Following demoilstnltion of proper opention, aPerfonnance Test was conducted on contaminated soils spiked with maximummetals content. Emission testing was conducted to determine the concentrationsof metals and chlorine in discharge gases and to deterinine the removalefficiencies of the air pollution control equipment. Metals and chlorine stackemissions were compared to values provided· in the EPA's document entitled"Technical Implementation Document for EPA's Boiler and Industrial FurnaceRegulations" dated March 1992. Emissions of all metals (antimony, barium,lead, mercury, silver, thallium, nickel, selenium, arsenic, cadmium, chromium,and beryllium) and chlorine satisfied the limits imposed by a Tier m risk-basedanalysis. Opemtion of the incineration system .requires that maximum metalsloading does not exceed the values demonstrated during the Performance Test.To verify that the metals loading does not exceed the demonstrated maximummetals loading, samples are taken daily from each feed soil stockpile and analyzedprior to processing.An ambient air monitoring program will be conducted during excavation,screening, blending, and feed preparation activities to ensure that ambientconcentrations of respimble dust, TNT, tetryl and lead are below site-specificaction levels. Ambient air monitoring results conducted during previous activitiesat the ALAAP site indicated that no harmful concentnltions of dust, TNT,asbestos or lead were present in the on-site work areas or have migrated from thesite.

The remediation prognun is proposed to remove the high concentrations ofcontaminants currently in the food web and significantly reduce their mobility andtoxicity.

• Comment - The major pollutants associated with incineration include acids,metals, nitrogen oxides, carbon monoxide, ozone, dioxin, volatile organiccompounds (VOCs) and partially incinemted compounds (PICs). The productionof nitric acid cannot be prevented. Most toxic metals. that are present in thewaste stream are likely to remain in the combustion ash, but some likely (mercuryand chromium) are known to exit stacks despite air pollution control equipment.

Response - The compounds potentially present in trace amounts in stack gases aredirectly dependent on the contaminants in the feed material. The majorcontaminants of concern for the subject Opemble Unit include nitroaromaticcompounds (~ifica1ly, TNT, tetryl and 1,3-DNB) and lead.

During the Performance Test previously conducted at ALAAP for metals- andexplosives-eontaminated soils, stack testing was conducted for carbon dioxide,oxygen, particulate, hydrochloric acid, chlorine, explosives, metals, andhexavalent chromium. Carbon monoxide, total hydrocarbons and nitrogen oxideswere also monitored by the continuous emissions momtoring (CEM) system.

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Stack testing results indicated that emissions are well within acceptable Federaland state criteria.

The CEM system continuously monitors stack gases for carbon monoxide,oxygen, carbon dioxide, nitrous oxides and total hydrocarbons to ensure theincineration system is opernting properly at all times.

Additionally, EPA and ADEM require that the incinerator operate within stringentcriteria. The control system is provided with an automatic waste feed cutoff(AWFCO) system which will shut down feed to the incinemtor should operatingconditions exceed allowable conditions.

Regarding formation of dioxin and funm, the Federal Register dated 21 February1991 indicated that the Agency believes that the operating temperatures of theparticulate control device (baghouse) and hydrocarbon concentnltions in the fluegas play a significant role in dioxinlfunm emissions. For a given hydrocarbonconcentnltion in the flue gas, the available data suggest that the potential forelevated dioxin/furan emissions is low if the particulate matter control deviceoperates at temperatures of less than 450°F or above 750°F. The FederalRegister indicates that units with particulate matter control devices opemting attemperatures outside of the 450-750OF window are not required to determinedioxin/furan emission lates unless hydrocarbon levels are greater than 20 ppm byvolume (page 7163). The tempemture of inlet gases to the baghouse on theincineration system operates below 449°F. The AWFCO system is activated if.the temperature exceeds 449 0 F. The CEM system continuously monitors stackgases for total hydrocarbons. Furthermore, during the Performance Test, theconcentrdtion of total hydrocarbons nmged from 0.05 to 0.07 ppm by volume,well below the upper limit of 20 ppm.

The FedelCll Register also indicates that an upper limit for carbon monoxideemissions of 1()() ppm by volume (on an hourly rolling average) in the ,flue gasrepresents steady-state high efficiency combustion conditions resultblg in PICemissions that would not pose a significant risk (page 7150). The CEM systemcontinuously monitors stack gases for carbon monoxide. During operations, ifthe carbon monoxide concentrdtion exceeds 100 ppm (on an hourly rollingaverage), the AWFCO system is activated. During the Performance Test, carbonmonoxide concentrations nmged from 0.37 to 0.44 ppm by volume (corrected to7 percent oxygen), well below the limit of 100 ppm.

Comment - Alternative technologies implemented at other fedelCll facilities have,according to the u.s. Army, successfully remediated explosives-eontaminatedsoils (e.g., bioremediation, composting). Soil washing has been utilized for thetreatment ofmetals-eontaminated soils. Alternative, applicable technologies havenot been sufficiently researched nor chaneterized. .

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Response - Alternative technologies have been researched and characterized. TheFeasibility Study for Area B evaluated a number of technologies to determinetheir applicability as a source control measure for contaminants of concern.Technologies included: physical, chemical, biological, thermal, irradiation,diversion, containment, removal and disposal. During the screening process,technologies were retained or eliminated based on waste chancteristics, sitecharacteristics, the degree of technology development, perfonnance record, andinherent constroctioD, operation, and maintenance problems. Technologies thatsurvived the screening were further evaluated for threshold criteria (overdllprotection of human health and the environment and compliance with ARARs) ~

Technologies that met threshold criteria were further screened for effectiveness,implementability, and cost to reduce the number of alternatives for furtheranalysis while preserving a nmge of options. Detailed analyses were conductedon the remaining alternatives. The selected alternatives (1G and ISS3) representthe optimum remedial activities for the Study Areas.

• Comment - Precautions should be taken during excavation procedures to reduceand monitor fugitive dust which may pose significant health and environmentalrisk (e.g., application of lime, covering of ttansport troeb, wetting of roads anddisturbed soils). Air monitoring should be conducted .during the excavation andremediation process to ensure the adequate protection of workers andconsequently nearby residents, surface water and soils.

Response - An ambient air monitoring program will be 'conducted duringexcavation, screening, blending, and feed preparation activities to ensure thatambient concentrations of respirable dust, TNT, tetryl and lead are below site­specific action levels. Ambient air monitoring results conducted during previousactivities at the ALAAP site indicated that no harmful concentrations of .dust,TNT, asbestos or lead were present in the on-site work areas or mignted fromthe site.

Additionally, precautions will be taken to minimize dust emissions during siteactivities (e.g., ttansport trocks will be covered, transport roads will be moistenedwith water, etc.).

4.0 REMAINING CONCERNS

All of the public comments have been adequately addressed. The public' appears to have 'nosubstantive concerns about the implementation of the selected remedy.

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~ I ,:1_

ADEI

-ADEM_-------...............ALAIAIIA

DEPARTMENT 0' eNVIRONMENTAL MANAGEMENT.......w. Wln,,'DlndOr

Octobtlr 6.. 1994

II..~.......Mr. Bill Hicks20·' Poplar DriveChild.rAburg. AL 35044

Dear Mr. Hicks,

On August 28 t 1994 I visited your residence In res~nse to the complailt you filedconcemlng a c:lay.. like fallout. Dul1ng 11111 visit I collected two Rmptes foranalysis. The pUrpollO of this letter is to Infolm you of the ,eute of this analyet.and Other invMtlgatlons we have conducted ooncemlng your complaint.

The results of our anal~sls Indicated that the lamp_ WBre comlQ\ea of smallclumps of quaru; (45-81O~)J Qrganic matter .&Ucfl .. plant material end lrasectd~Plng8 (2-540/.) and an un1dentifled brown/amber ·colored binder (1 %). The&12. ana densfty of the ctump. Indicates that even. at ext....". conditions (wind8PMds of 20 mph and a IOUroe atack height of 160 feet or higher) thes"~iclescould only .y airbome for approxImately 'J4 to 1,'2 mila. Our inveatlga1ian findsno euoIl .ouree within that distance of your r••'denoe and thl 80urae of thisfallout is unknown at thil time., .

If VetU obaeM such fallout In the future. please feel free to contact our office. Inoraer to Mlp lOcate the 8OUroe It would be wry helpful II you could collect Mohersample and record the date and line of the fallout as well as the wind c1rec:;tionlind ,peed.. You may al80 wi'h to attempt to treae tt» fallout upwind and try todetennine the scurw,

s~~ -Carl FerraroSpecial Service. SeotlonAir DiVision

(101)1" ......,a.a7MI11

"'rslgI~;

"It&Itt.w. L.DIdri.....~.......,.,.AL"'01-1101

....Otflc..:

, '0 VuIfa.. -oact"'1nIMa,ALI sat••.,.c..) ,••ax..1 ..

......5'""

...a...~DlCI.....ALIIIN...)IU."tJ'axMHllt Thank you for your coo~ration in ttlil matt'f. If you have any question' ple..o...........,...., .el_ to contac1 me at 271-7880 in Montgomery..........L

IM'''''11_......'AlIJMIII

....... ,.....1.;-otoX.t........"ee".'AL..,...,•.

CF/et

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..

Sept. 29 t 1994

CommanderU. S. Army Environmental CenterAtTN: SFIM-AEC-BCP (Mr. Rich Isaac)Building E4480Aberdeen Proving Ground. MD 21010-5401

Dear Sir~

I was unable to attend the public hearing held Sept. 28,1994, but I have read the DECLARATION OF THE DRAFT FINALINTERIM RECORD OF DECISION .

I would like any information on GROUNDWATER CONTAMINATION atthe Alabama Army Ammunition Plant. located in Childersbur!Alabama. .

It is obvious after reading the article in the local paper,. (The Daily Home) that people do not ~ndcrstand what is goinSon. Is there any way that the public could be supplied withsomeone who coul~ interpret the information provided thepublic?

I would also like to be put on any mailing list that you haveon information about this issue.

~. ~ Nnk You, \'\

~«.v.__~~Laura PayneP. o. Box 257Childersburl, Al 3504420S-378-5718

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• ClTi~SFORS1 VAB

"S, fe Water Around Badger

E12629 Wejgand's Bay SouthMerrimac, Wisconsin 53561

Phone (608) 643-3124

-==::!I---====----=====-=-----======~---Il::E::::::====- ::a::=::==_=

..

CommanderU.S. Army Environmental CenterAnN: SFIM-AEC-BCP (~fr. Rich Isaac)Building E4480Aberdeen: Proving Ground, MD 21010-5401

September 22, 1994

HE: Draft Final.laterim Record of DeeilioD Alabama Anny Ammunition PlantChildersburg, AL August 1994

Dear Mr. Isaac:

The following is public comment on the draft final Interim Record ofDecision,..Area B Soils operable unit, Alabama Anny Ammunition Plant, Childersburg, Alabamadated August 1994.

I am President and co..founder ofCitizens for Safe Water Around Badger(CSWAB), a grassroots citizens group working to involve and empower localcommunity members in advocacy ofhuman health, cnviromnental restoration andeconomic conversion issues related to military toxies. As a community leader andaetivist~ I am familiar with many ofthc issues associated with military toxins, parti~arlyregarding the treatment and remediation ofexplosives contamiuted soils.

According to the Draft FiDal hcord ofDecision (DFROD) the prevalentcontaminants at all Study ARas (6, 7, 10 and 21) arc metals (lead), and explosives and .their degradation products (lNT, tetryl and 19 3-DB). In addition to metals andexplosives contamination: friable and transite asbestos and nitrocellulose contaminationare extensive in soils at Area 7; the industrial sewer system (ISS) within Area 6 iscontaminated with nitrocellulose, and the explosive RDX was detected at one site withintbis area.

The DFROD repo.rts vast areas ofthe Alabama AAP facility consist of surfacewaters and wedands, including creeks, swamps md pond areas. Further, beaver damshave sipificantly slowed the clrainaae and have~ced the success oflocal aquatic andterrestrial organisms including waterfowl) white-tailed deer and larger predatory species.Thest resources and biological receptors will be extremely sensitive to both the positiveand negative consequences ofremedial processes. .

As sta1cd in the: DFORD, the purpose ofremediatioD is reduce toxicity, mobilityIIld to a lesser degree, volume. Alternative 10 (oll-si. incineration) does Dot reduce I the

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toxicity~ mobility or the volume of inorganics such as lead.- a pervasive contaminant inthe soils at Alabama AAP. Incineration of lead only results in the dbpuslll ofthesecontaminants 10 the air, water, soil and resultant incinerator ash; incineration iscompletely ineffective in reducing the toxicity of lead or other .metals.

Funher~ our opposition to incineration is based on. increasing evidence thatincinerators are not safe. The direct risks ofincinerator pollutants on human health arebased on the probability ofexposure' to levels oftoxic compounds sufficient to causedisease.

Incinerators produce air~ \vater and soil taxies through stack emission or fugitiveemissions. More importantly, the uptake oftbese toxins into plants and animals and theirbiomapifiadion through the food web present the greatest risk to people ~ eitherthrough absorption, inhalation or ingestion.

The major pollutants associated with incineration include acids, metals, nitrogenoxides, carbon monoxide, ozone, dioxin, volatile organic compounds (VQC's) andpartially incinerated compounds (PIC). Sulfuric acid production can be controlled instacks with air pollution control equipment, but the production ofnitric acid camlot beprevented.. Most toxic metals that arc present in the Yt"8Ste stream are likely to remain inthe combustion ash, but some likely (mercury and chromium) are known to exit stacksdespite air pollution control equipment.

Volatile organic compounds are a large group ofcompounds~many ofwhich have.known or suspected human disease capabili~·. These compounds may OT may not becompletely destroyed in. incinerators, depending upon conditions oftemper~pressure, and oxygen levels in the incinerator flame zone. FiDall)'J partially incinerau:d·CompoUDds (PIC) are produced in the i.~cineration process and could have innumerablechemical fonnulations and health effects.

Without doub~ the most studied of these compounds is dioxin, of Vlhich the mosttoxic variation known is tettachlorclibenzodioxiD (TCDD). This compouod is regarded aspossibly the most toxic substance known. The recently...released EPA report on dioxinestablishes that dioxin causes cancert confmning the unacceptable risks to human healthcaused by hazardous waste incineration.

Further, alternative teelmologies implemented at other federal facilities have,according to the US Army, successfully remedia1ed explosives-eon1aminated soils. Forexample. field-scale demonstration projects utilizing bioremediation (compostiDg) havebeen conduct~ at Louisiana Army Ammunition Plant, Badger Army Ammunition Plantin WISCOnsin and Umatilla Depot in Oregon for the treatment ofexplosives-contamiD.tedsoils. Soil washing has been utilized at Twin Cities Anny Ammunition Plant for thetreatment ofmetals<ontamiMted soils, and characterized as a success by the Annyofficials.

These examples illustrate that alternative, applicable technologies have not beensufficiently researched nor characterized in the DFROJ;>. Given the absence ofsignificant levels ofsolvents in contaminated soils, it would appear that bioremedial andother altemative technologies could be considered and parenth~ca11y could beconsiderably cheaper than the proposed incineration processes.

Regardless of the final treatment technology chosen, steps should be taken during"excavation procedures to re4uce and monitor fugitive ~ust which may pose a significant

-1\10 ~nSOij '3~R w,.,~~ :~T m::. TT ,~

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health and environmental risk. Safeguards such as the application oflime, CQvering oftransport trucks, wetting ofroads and disturbed soils arc imperative. Air monitoringshould be conducting during the excavation and remediation process to ensure theadequate protection ofworkers and consequently Dearby residents. surface water aDdsoils.

Based on the infonnation given, I believe the DFROD is insufficient andincomplete in its assessment ofalternative, safer technologies aDd therefore P01eDtiallyplaces workers, community, biological receptors and the enviromnent at excessive aDdunnecessary risk. .

ThaDk you for the opportunity to submit comment and Jhope that the Army andappropriate regulators will reassess the conclusions ofthis report and pursue altematives'to ba23rclous waste incineration at Alabama AAP.

Sincerely,

cc: ftM. Lewis D. Walker. Secretary of .tumy for Environment, Safety and OccupationalHealth, Room ZES77, 110 Army PeDtagon, Washington, DC 20310-0110

Mr. Dan Speriosa, USEPA- Region IV, 345 Courtland St., NE. Atlanta, GA 30365Mr. C.H. Cox, Alabama Department ofEnvironmental Management, Attention:

Special Projects, 1890 AA W.L. DixonsoD Drive, Montaomery, AL 36109Ms. Cathy Hinds, Executive Director, Military Taxies Project, PO Box 845~

Sabattus, ME 04280