PB99-964303
EPA541-R99-031
1999
EPA Superfund
Record of Decision:
Lake City Army Ammunition Plant
Area 18 OU
Independence, MO
4/22/1999
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Final
Record of Decision for
Remedial Action at Area 18 Operable Unit
Lake City Army Ammunition Plant
Independence, Missouri
Prepared for
Lake City Army Ammunition Plant
FEBRUARY 1998
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Final Record of Decision Area IS Operable
Lake City Army Ammunition Plant. Independence. Missouri
MAY 2 3
TABLE OF CONTENTS
Chapter Page
1.0 DECLARATION FOR THE RECORD OF DECISION .......................... 1-1
1.1 SITE NAME AND ....... .............................. .............. 1-1
1.2 STATEMENT OF BASIS AND PURPOSE ................................ 1-1
1.3 ASSESSMENT OF THE SITE ...................... .................... 1-1
1.4 SITE DESCRIPTION .......................................... ....... 1-1
1.5 DESCRIPTION OF SELECTED REMEDY ............................... 1-2
1.6 STATUTORY DETERMINATION .................. .................... 1-2
1.7 SIGNATURE AND AGENCY CONCURRENCE ON THE REMEDY .......... 1-3
2.0 DECISION SUMMARY ..................................... ............. 2-1
2.1 SITE NAME AND LOCATION .......................................... 2-1
2.2 AREA 18 OU DESCRIPTION/HISTORY AND REGULATORY OVERSIGHT
ACTIVITIES [[[ 2-1
2.2.1 LCAAP Description/History ..................................... 2-1
2.2.2 Area 18 OU Site Description/History .............................. 2-1
2.2.3 Regulatory Oversight Activities .................................. 2-3
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION ....................... 2-3
2.4 SCOPE AND ROLE OF RESPONSE ACTION ............................ 2-4
2.5 SITE CHARACTERISTICS .................................. . ......... 2-5
2.6 SITE RISK SUMMARY ................................ ............... 2-8
2.6.1 Risk Assessment Process ....................................... 2-8
2.6.2 Data Collection and Evaluation .................................. 2-8
2.6.3 Exposure Assessment . . . . ...................................... 2-9
2.6.4 Toxicity Assessment .......................................... 2-10
2.6.5 Risk Characterization (Human Health Risks) ....................... 2-11
.2.6.6 Ecological Risk Assessment .................................... 2-12
2.6.7 Risk Assessment Conclusions ................................... 2-14
2.6.8 Remediation Goals ............. . ............................. 2-14
2.7 DESCRIPTION OF ALTERNATIVES .................................. 2-15
2.7.1 Soil Alternatives ................................. - .............. 2-16
2.8 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES ......... 2-38
2.8.1 Overall Protection of Human Health and the Environment ............ 2-39
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Final Record of Decision Area 18 Operable L'mt
Lake City Army Ammunition p'ant. independence. Missouri
2.8.2 Compliance with ARARs X40
2.8.3 Long-term Effectiveness and Permanence ^_41
2.8.4 Reduction of Toxicity, Mobility, or Volume Through Treatment . . . . .. iLp
2.8.5 Short-term Effectiveness ~ ~
2.8.6 Implementability ... '''
2-8-7 cost .'.'.".'.'.'.'.'.".'.".':::::::::::::::
2.8.8 Regulatory Acceptance
2.8.9 Community Acceptance n ,«
2.9 SELECTED ALTERNATIVE 7 ,R
2.10 STATUTORY DETERMINATIONS ...'.'.'.''.'.'.'. '. '. '. '.""'.".'.'.'.";;.".'' ['_" 7.59
2.10.1 Protection of Human Health and the Environment .. 2-53
2.10.2 Compliance with ARARs -, S4
2.10.3 Cost Effectiveness ^~-4
2.10.4 Utilization of Permanent Solutions and Alternative Treatment Technologies"to
the Extent Possible ; -> - -
2.10.5 Preference for Treatment as a Principal Element ......".. . . 2-55
2.11 DOCUMENTATION OF SIGNIFICANT CHANGES 2-56
3.0 LIST OF ACRONYMS AND ABBREVIATIONS .
Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
Figure 1
Figure 2
Figure 3
Figure 4
Figure 5
Figure 6
Figure 7
APPENDICES
Figures
Tables
Ground Water Treatment Discharge Criteria
Applicable or Relevant and Appropriate Requirements
Responsiveness Summary
LIST OF FIGURES
LCAAP Location Map
Area 18 Location Map
Area 18 Site Map
Area 18 Areas of Concern
Area! Extent of Ground Water Contamination
VOC Concentrations in Source Area Soils (Solvent Pits) - Surface to 5'
VOC Concentrations in Source Area Soils (Solvent Pits) - 5' to 12.5'
11
February 1998
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Final Record of Decision Area 18 Operable Unit
Lake dry Army Ammunition Plant. Independence, \fissouri
Table 1
Table 2
Table 3
Table 4
Table 5
Table 6
Table 7
Table 8
LIST OF TABLES
VOCs Detected in RJ Ground Water Samples
COCs in Soil
COCs in Ground Water
Exposure Groups, Exposure Routes, and Risks for Area 18
Summary of Noncarcinogenic Risks from Current Exposure Scenarios
Summary of Carcinogenic Risks from Current Exposure Scenarios
Summary of Noncarcinogenic Risks from Future Exposure Scenarios
Summary of Carcinogenic Risks from Future Exposure Scenarios
in
February 1998
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Final Record of Decision Area 18 Operabfe C 'nit
Lake City Army Ammunition Plant. Independence. Missouri
1.0 DECLARATION FOR THE RECORD OF DECISION
1.1 SITE NAME AND LOCATION
• Area 18 Operable Unit (OU), Lake City Army Ammunition Plant (LCAAP). National
Priorities List (NPL) Site.
• Independence, Jackson County, Missouri.
1.2 STATEMENT OF BASIS AND PURPOSE
This decision document describes the selected remedial action for the LC AAP Area 18 OU, in
accordance with the Comprehensive Environmental Response, Compensation, and Liability Act
of 1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization Act of
1986 (SARA), and to the extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP).
This decision is based on the contents of the Administrative Record for Area 18 OU, LCAAP.
The U. S. Environmental Protection Agency (EPA) and the Missouri Department of Natural
Resources (MDNR) concur with the selected alternative.
1.3 ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the Area 18 OU, if not addressed by
implementing the response action selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to public health, welfare, or the environment.
1.4 SITE DESCRIPTION
Three operable units have been identified at LCAAP. The three operable units are:
The Area 18 OU (the subject of this ROD) is an 88-acre area located along the northern
portion of the installation and comprises earth pits used as disposal areas.
The Northeast Comer Operable Unit (NECOU) is a 190-acre area comprising solid
waste disposal areas and burning areas. The NECOU is currently at the feasibility study
stage.
• The Installation-Wide Operable Unit (IWOU) comprises a variety of disposal areas
found throughout the facility. This OU is currently in the remedial investigation (RI)
stage.
This ROD is for the remedial action at the Area 18 OU and is the first ROD for LCAAP.
1_1 February 1998
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Final Record of Decision Area 18 Operable Lmt
Lake C/'rv Army Ammunition Plant. Independence. Missouri
1.5 DESCRIPTION OF SELECTED REMEDY
The selected alternative for the Area 18 OU. Soil Vapor Extraction and Excavation in
combination with Ground Water Extraction and Treatment, includes the following major
components:
• Soil vapor extraction using a multi-phase extraction system and treatment of extracted
ground water and vapors to address VOC (volatile organic compound)-contaminated
soil and shallow ground water hi source areas.
• Excavation and disposal of lead-contaminated soil.
• Ground water extraction and treatment.
• Institutional controls to limit future site use.
• Long-term monitoring.
The selected remedial action uses treatment to address the principal threat wastes (VOCs) in the
soil in the pits and excavation and/or containment to address low level threat wastes (lead) in the
surface soil at Area 18. The selected remedy also uses extraction and treatment to address
contaminants in the ground water. Institutional controls will be used for short-term and long-
term management and to prevent exposure to both principal and low level threat wastes and
affected ground water.
1.6 STATUTORY DETERMINATION
The selected remedy is protective of human health and the environment, complies with Federal
and State of Missouri requirements that are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. The remedy utilizes permanent solutions and alternative
treatment technologies to the maximum extent practicable for the Area 18 OU. This remedy
satisfies the statutory preference for remedies that employ treatment that reduces toxicity,
mobility, or volume as a principal element.
Because this remedy will result in hazardous substances remaining on-site above health-based
levels, a review will be'conducted within five years after commencement of remedial action to
ensure that the selected remedy continues to provide adequate protection of human health and the
environment.
1-2
February 1998
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Final Record of Decision Area IS Operable L mi
Lake Cin-Armv Ammunition Plant Independence. Missouri
1.7 SIGNATURE AND AGENCY CONCURRENCE ON THE REMEDY
Richard R. Thibodeau
Lieutenant Colonel. OD
Commander. Lake City AAP
Date
JLG/Menig
Deputy Assistant Q«ief of Staff
for Installation Management
U.S. Armv
Dennis Grams, P.E.
Regional Administrator
U.S. Environmental Protection Agency Region 7
Date
1-3
February 1998
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Final Record of Decision Area 18 Operable L'ntt
Lake City Army Ammunition Plant. Independence. Missouri
Reviewed and Concurred:
Installation Remedial Project Manager
Major Subordinate Comirjand DERP PM
Date'
79? i
Date
Installation/Major Subordinate Command
Legal Advisor
AAA — . 1 9 ? A
Date
1-4
February 1998
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Final Record of Decision Area 18 Operable Unit
Lake dry Army Ammunition Plant. Independence. Missouri
2.0 DECISION SUMMARY
2.1 SITE NAME AND LOCATION
LCAAP is a 3.935 acre facility in Jackson County, Missouri, mostly within the corporate
boundary of Independence. Missouri (Figure 1). The Area 18 OU is approximately 88 acres and
is in the north-central portion of the Installation (Figure 2). The unincorporated village of Lake
City is situated near the north central plant boundary, approximately 3,000 feet northwest of the
Area 1 SOU.
2.2 AREA 18 OU DESCRIPTION/HISTORY AND REGULATORY OVERSIGHT
ACTIVITIES
2.2.1 LCAAP Description/History
LCAAP was established in the early 1940s and was the first government-owned facility
constructed to expand small arms ammunition production. Construction at the facility began on
26 December 1940 and was completed on 11 October 1941. The Plant has operated continuously
since 1941, except for a 5-year period between World War II and the Korean Conflict. The
operating contractor from 1941 to 1985 was Remington Arms. Olin Corporation became the
operating contractor in November 1985 and continues to operate the plant on behalf of the Army.
2.2.2 Area 18 OU Site Description/History
Area 18 OU is located in the north central portion of LCAAP along the Installation boundary.
Adjacent land use includes a mix of residential, agricultural, and industrial uses. The land
surface is relatively flat across the OU. Figure 3 shows a site map of Area 18 including nearby
residences to the northwest.
The geology of Area 18 is typically river-deposited sediments that have filled an ancient river
channel (paleochannel), with finer sediments (silts and clays) in the upper layers and coarser
sediments (sands and gravels) in deeper layers. Bedrock lies below the sediments at a depth
ranging from approximately 50 feet to 90 feet below ground surface (bgs).
Surface water runoff from Area 18 generally ponds in low-lying, flat, and poorly drained fields.
Two surface water ditches, Ditches B and Bl, cross Area 18 and converge before exiting the
Installation to the north (Figure 3). At times, there may be seasonal discharge of shallow ground
water to the surface drainages.
The average depth to shallow ground water in the vicinity of Area 18 is 5 to 7 feet below ground
surface with an average seasonal fluctuation of 4 to 7 ft. The shallow ground water is not used in
the Area 18 vicinity. The primary aquifer at Area 18 (and the surrounding area) is in the sand
and gravel layers beginning at depths between 25 feet and 40 feet below ground surface. This
aquifer provides production water and drinking water to the Installation as well as drinking water
to nearby residents who have private domestic wells.
2^1 :February 1998
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Final Record of Decision Area 18 Operable L'mt
Lake City Army Ammunition Plant. Independence. Missouri
There are no buildings or structures in Area 18 except for the Area 18 ground water treatment
plant. The treatment plant was completed in 1996 and is currently operating. An extraction well
(EW-1) was also constructed in 1996 to contain ground water contamination. EW-1 is located
just north of the waste areas described below (Figure 4). A water supply well. 17-FF. is located
directly west of Area 18. It was one of 14 wells used to supply process and drinking water to the
Installation. Well 17-FF is currently connected to the ground water treatment plant and. with
well EW-1, serves to contain the VOC-contaminated ground water in the Area 18 OU.
A review of aerial photographs and historical records showed that waste disposal activities
occurred in the Area 18 OU for 20 years or more, between the early 1950s and the mid-1970s.
The following wastes were disposed of at several areas within the Area 18 OU:
Industrial Wastewater Treatment Plant (IWTP) Waste
Oil and Grease
• Solvents
• Plant Trash
• Demolition Waste
These disposal areas were covered with soil in the early 1980s. A RI was performed at the Area
18 OU hi 1993 to locate, define, and investigate potential disposal areas. Data collected during
the RI indicated that soil and ground water in this area contained contaminants consistent with
the types of wastes disposed of onsite.
Six Areas of Concern (AOCs) were identified during the Area 18 RI. The locations of the AOCs
are illustrated in Figure 4. During the RI, soil and ground water samples were collected from
each AOC and analyzed at a laboratory to determine the chemicals present. The AOCs were then
categorized based on the types of contaminants present in the soil and ground water in each area.
They are defined as follows:
• AOC 1 Solid Waste Management Unit (SWMU), encompassing a relict lagoon
identified as 57-L1-69, contaminated with VOCs.
• AOC 2 SWMU, encompassing approximately 5 relict lagoons, contaminated with
VOCs.
• AOC 3 SWMU, encompassing a relict lagoon identified as 69-L6-75, contaminated
with VOCs.
• AOC 4 Western area of surface soil (the upper 2 feet of the soil profile) containing lead
(at concentrations greater than 1,000 ppm).
• AOC 5 Eastern area of surface soil containing lead (at concentrations greater than 1,000
ppm).
2-2 February 1998
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Final Record of Decision Area 18 Operable L'nir
Lake City Army Ammunition Plant. Independence. Missouri
• AOC 6 Area containing concentrations of copper, mercury, and zinc determined to
present a human health risk through ingestion of beef from cattle that grazed at
Area 18. AOC 6 encompasses all the other five AOCs.
2.2.3 Regulatory Oversight Activities
LCAAP was proposed for listing on EPA's National Priorities List (NPL) in October 1984 with
final listing in July 1987, effective August 1987. The site is jointly regulated by the EPA and
the MDNR. The Army, EPA, and MDNR signed a Federal Facility Agreement (FFA) that
became effective November 28, 1989, which defines the procedural framework under which
LCAAP sites will be investigated and remediated, and the roles and responsibilities of the Army,
EPA. and the State of Missouri regarding CERCLA response activities at the site.
23 HIGHLIGHTS OF COMMUNITY PARTICIPATION
Community relations activities that have taken place at LCAAP to date include:
• FFA process - After preparation of the FFA by the U. S. Army, EPA. and MDNR, the
document was published for public review and comment. The FFA became effective
November 1989.
• Administrative Record - Consistent with requirements of CERCLA section 113(k), an
Administrative Record for information associated with CERCLA cleanup activities at
LCAAP was established in Building 3 at LCAAP. The Administrative Record contains
information used to support LCAAP decision-making associated with CERCLA issues.
All documents in the Administrative Record are available to the public.
• Information repositories - The Administrative Record is located at the Mid-Continent
Public Library, Blue Springs South Branch (public repository), and the West Gate
(Building 6) at LCAAP.
• Community Relations Plan (CRP) - The CRP was prepared pursuant to requirements in
the LCAAP FFA and is being actively implemented. This plan was updated in 1996.
• Restoration Advisory Board (RAB) - The RAB has been formed to facilitate public
input in the CERCLA cleanup at LCAAP, and meets bi-monthly. In addition to U.S.
Army, EPA, and State of Missouri personnel, the RAB includes community leaders and
representatives from the surrounding area.
• Mailing list- A mailing list of all interested parties in the community is maintained by
LCAAP and updated regularly.
• Fact sheet - A fact sheet describing the status of the Installation Restoration Program
(IRP) was last distributed to the mailing list addressees in November 1996.
2-3 February 1998
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Final Record of Decision Area 18 Operable L'ntt
Lake City Army Ammunition ?!am. independence. Missouri
• Proposed Plan - The Proposed Plan on this action was distributed to the mailing list
addressees for their comments.
The Remedial Investigation/Feasibility Study (RI/FS) and Proposed Plan for the LC AAP .Area
18 OL were released to the public on April 14. 1997. These documents were made available to
toe public in both the Administrative Record at the LCAAP and in the site Information
Repository noted above. The notice of availability for these documents was published in the
Independence and Blue Springs Examiner on April 12 and 13, 1997. A public — ,mpnt r ^^
was held from April 14 to May 14, 1997. In addition, a public meeting was neia on ,pm ?2
1997 where representatives from LCAAP, EPA, and MDNR were available to answer questions
and accept comments regarding the remedial action under consideration. The public was given
the opportunity to make comments on the proposed action at Area 1 8. A response to the
comments received during this period is included in the Responsiveness Summarv, which is part
or this ROD. * r
°n
u contents of Ae Administrative Record for Area 1 8 OU, in accordance
with CERCLA. as amended by SARA, and the NCP. The RI/FS reports and the Proposed Plan
tor Area 1 8 OU provide information about Area 1 8 OU and the selected remedy These
documents are available at the Information Repositories at LCAAP (West Gate, Building 6) and
the Mid-Continent Public Library, Blue Springs, South Branch.
2.4 SCOPE AND ROLE OF RESPONSE ACTION
As with many Superfund sites, the environmental problems at LCAAP are complex. As a result
the FFA parties have organized the work into three site-specific OUs. The operable units are
identified as follows:
- The Area 1 8 OU is located along the northern portion of the installation and comprises
surface impoundments used as disposal areas.
• The NECOU is a 1 90-acre area comprising solid waste disposal areas and burning areas
The NECOU is currently at the feasibility study stage.
• The IWOU comprises a variety of disposal areas located throughout the facility This OU
is currently in the RI stage.
This ROD address problems at Area 18. The primary problem at Area 18 is contaminated
ground water. The ground water contains chemicals above regulatory standards and poses a
potential threat to onsite personnel who use the ground water as well as offsite residents who
could potentially be impacted if the contaminated ground water moves offsite. The sources of
chemicals in the ground water at Area 1 8 are the pits that were used in the past to dispose of
various plant wastes including solvents and hydrocarbons. The disposal pits are contributing
chemicals to the ground water and will continue to do so unless addressed. An additional
problem at Area 1 8 is the presence of metals in the surface soil.
2-4 February 1998
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Final Record of Decision Area 18 Operable L'ntt
Lake C/rv- Army Ammunition Plant. Independence. Missouri
The Army performed an Engineering Evaluation/Cost Analysis (EE/CA) in November 1994 to
develop removal action alternatives that would contain ground water contamination at the Area
18 OU before it reached the Installation boundary. The EE/CA was conducted to expedite
response actions at Area 18. The Area 18 OU FS was conducted concurrently to develop and
evaluate remedial alternatives for both soil and ground water.
A public meeting was held in January 1995 to present the removal action alternatives developed
in the EE/CA. The preferred ground water removal action alterative identified in the Area 18 OU
EE/CA was documented in a June 1995 Action Memorandum. The removal action is a ground
water removal and treatment process and is currently operating. This removal action is
consistent with the selected ground water remedy presented in this ROD and includes the
following major components:
• Extraction of ground water from existing well 17-FF and new extraction well EW-1.
Treatment of extracted ground water using an air stripper system.
Treatment of off-gas from the air stripper using a catalytic oxidation unit.
• Discharge of the treated effluent to the Little Blue Valley Sewer District.
The remedial action for Area 18 will address ground water contamination at Area 18 using
ground water wells to extract and a treatment system to treat affected ground water. The ground
water extraction system will also prevent offsite migration of affected ground water until
treatment is completed. The selected remedial action also uses treatment to address source area
soils (disposal pits) to reduce their potential to provide a source of chemicals to the ground water.
Metals in the surface soil will be addressed by excavation, containment, and/or institutional
controls.
Combined with the response actions for the other two OUs, the selected remedy for Area 18 will
provide a comprehensive solution for environmental problems throughout LCAAP.
2.5 SITE CHARACTERISTICS
The primary sources of contamination at Area 18 are the solvent disposal pits (AOC 1. 2, and 3)
identified on Figure 4. VOCs from solvents disposed of in the pits are leaching into the ground
water resulting in chemical concentrations of VOCs in ground water at levels above Maximum'
Contaminant Levels (MCLs). Figure 5 identifies the areal extent of known ground water
contamination at Area '18. Onsite workers and nearby residents in the community of Lake City
(Figure 2) could potentially be affected by contaminants in both the soil and ground water.
In addition, lead and other metals (copper, mercury, and zinc) resulting from past disposal
activities are present in the surface soil. AOC-6 represents the area affected by metals
concentrations above remediation goals (RGs) and is identified on Figure 4. Lead was identified
in surface soil at concentrations above RGs in AOCs 4 and 5. within the larger AOC-6 area.
Other metals besides lead (copper, mercury, and zinc) are present above RGs throughout AOC-6.
2-5 February 1998
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Final Record of Decision Area 18 Operable Unit
Lake City Army Ammunition Plant. Independence. Missouri
This section describes the presence and distribution of contaminants at Area 18 resulting from
past activities.
2.5.1 Soil
VOCs were detected at concentrations above health-based risk levels and levels protective of
ground water in both surface and subsurface soil at the six AOCs in Area 18. Table 1 lists
chemicals detected in the soil for which RGs have been established as well as criteria that were
used to establish the RGs. Primary VOCs detected in soil include the solvents and solvent
related compounds 1,2-dichloroethene (1,2-DCE), toluene, trichloroethene (TCE), and
tetrachloroethene (PCE) at maximum concentrations of 934 milligrams per kilogram (mg/kg; one
mg/kg equals one part per million [ppm]), 2,000 mg/kg, 1,000 mg/kg, and 9,000 mg/kg
respectively. Table 1 lists the maximum concentrations of the chemicals detected in the soil.
More detailed information regarding these chemicals in the soil can be found in the Final Area 18
FS. VOCs in soil at Area 18 present a potential risk because they are soluble and may continue
to leach into the ground water if left in place. Also, VOCs in surface soil may volatilize into the
air, potentially affecting onsite workers. VOCs pose carcinogenic (cancer) and noncarcinogenic
(noncancer) risks under potential future land uses (see Table 1).
VOCs at concentrations above RGs (Table 1) are present in soil at AOC-1, AOC-2, and AOC-3.
VOCs present at these AOCs are consistent with the use of industrial solvents and hydrocarbon-
related chemicals at the Plant Analytical results from surface and subsurface soil samples
indicated that most of the soil contamination in AOC-1 and AOC-3 was present in the upper 12.5
feet of soil. No additional data has been collected past 12.5 feet in AOC-1 or AOC-3. At AOC-
2, contaminated soil was also present in the upper 12.5 feet in most the southern half of the AOC.
Additional data, collected after the RI, indicates contamination at depths below 12.5 feet in
AOC-2. During the FS, it was estimated that approximately 23,000 cubic yards (cy) of soil
containing VOCs above either risk-based levels or levels protective of ground water are present
in the pits hi AOCs 1,2, and 3. Figures 6 and 7 show the location and concentration of VOCs in
the soil at various depth intervals.
Metals hi the soil are not a threat to human health under current land uses, but may be a health
threat under future site use scenarios. Surface soil samples from Area 18 contained
concentrations of copper, mercury, and zinc above acceptable risk-based levels (see Table 1 and
the FS). The migration pathway that resulted in unacceptable human risk (noncancer) from
exposure to copper, mercury, and zinc was ingestion of beef from cattle that ingested metals
during grazing at Area 18. Ingestion of beef from cattle was evaluated under future land-use
scenarios.
Although specific carcinogenic and noncarcinogenic risk values are not available for lead, a
cleanup goal of 1,000 ppm was established for cleanup of lead. Surface soil samples collected at
AOC-4 and AOC-5 were found to contain lead at concentrations above 1,000 ppm. The primary
migration pathway for lead in soil is via windblown particles. In general, lead concentrations
above 1,000 ppm are confined to the upper two feet of the soil profile. During the FS, it was
2-6 February 1998
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Final Record of Decision Area 18 Operable L nit
Lake dry Army Ammunition Plant. Indeoendence. Missouri
estimated that there are approximately 4,700 cy of soil containing lead above 1.000 ppm in
AOCs 4 and 5, which are located within the larger AOC-6 area.
2.5.2 Ground Water
Three different ground water bearing units were defined under Area 18 OU. Each shows a
distinct ability to transmit (i.e., carry) water and are described as follows:
• Unit 1 (HSU1)—This unit extends from the ground surface to a depth of approximately
20 to 40 feet below the ground surface and is made up of silty clay and fine sand. HSU1
has poor ability to transmit water.
• Unit 2 (HSU2)—This unit (approximately 40 to 45 feet thick) exists from 20 to 40 feet
below the ground surface to a maximum depth of 80 to 90 ft, and is made up of medium-
grained to coarse sand and sandy gravel with layers of silty clay. HSU2 has good ability
to transmit water and is the primary aquifer of the area. An aquifer is a water-bearing
unit that can transmit sufficient water for domestic or public use. Figure 4 indicates the
approximate local ground water flow direction (with arrows) in the aquifer. These flow
directions are influenced by the pumping of extraction wells 17-FF and EW-1.
• Unit 3 (HSU3)—This unit exists below a depth of approximately 90 feet bgs and is made
up of shale and limestone layers. HSU3 has poor ability to transmit water.
Hydrologic data collected during the RI indicates there is a ground water gradient divide
(roughly along the paleochannel) near Area 18 (see Figure 5). Ground water in the western third
of Area 18 generally flows to the west, nearly parallel to the Installation boundary. In the eastern
third of the area ground water flows to the northeast toward the Installation boundary. Former
water supply well 17-FF (now used as a ground-water extraction well), located directly west of
Area 18, influences localized ground water flow by drawing ground water from Area 18 toward
the well.
Ground water samples collected from the Area 18 OU during the RI contained several VOCs.
Chemicals of concern (COCs) detected in ground water above MCLs are identified in Table 2
along with the maximum concentrations at which the chemicals were detected. Some of the
solvents may be in the form of dense non-aqueous phase liquids (DNAPLs). Figure 5 shows the
general location and size of the VOC plume at Area 18. Analytical data collected over a two-
year period indicate that VOC concentrations in ground water samples are increasing and that
contaminants may be spreading.
VOCs that leach into the ground water from the solvent pits present a potential health risk to
onsite workers under future land-use scenarios. If VOCs leach into the ground water and migrate
offsite in the future, there is a potential threat that offsite residents who use the ground water may
be affected. Based on the hydraulic gradient and ground water velocities calculated during the
RI, it is estimated that ground water beneath Area 18 traveled a distance of 1.000 feet over a two-
year period. TCE and its breakdown components typically migrate in ground water at a velocity
~ 2-7 February 1998
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Final Record of Decision Area IS Operable L'ntt
Lake City Army Ammunition Plant. Independence. Missouri
less than that of the ground water itself; however, there is the potential that contaminated ground
water could move offsite and affect offsite residents that may drink the water (e.a.. in the
community of Lake City) in the future.
2.6 SITE RISK SUMMARY
2.6.1 Risk Assessment Process
A baseline risk assessment (BLRA) was conducted during the RI to identify receptors of
concern, exposure pathways, and contaminants of concern that drive unacceptable risk to
humans. A BLRA evaluates risks under current and anticipated future land uses assuming no
remedial action is conducted. The following sections provide a summary of the BLRA
conducted for Area 18. The RI contains detailed information regarding the BLRA.
A BLRA consists of:
• Data collection and evaluation
• Exposure Assessment
• Toxicity Assessment
• Risk Characterization
The assessment of human health risks for this OU considered the following topics:
(1) COCs in soil and ground water samples.
(2) Current and future land-use conditions.
(3) Potential environmental pathways by which populations might be exposed.
(4) Estimated exposure point concentrations of COCs.
(5) Estimated intake levels of the COCs.
(6) Toxicity of the COCs.
(7) Uncertainties in the assessments of exposure, toxicity, and general risks.
2.6.2 Data Collection and Evaluation
At Area 18, soil (surface and subsurface) and ground water samples were collected and analyzed
to complete the BLRA for human and ecological receptors. Once the data was analyzed, COCs
were identified by media and a determination was made as to which COCs would be retained for
2-8 February 1998
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Final Record of Decision Area 18 Operable Unit
Lake City Army Ammunition Plant. Independence. Missouri
development of remedial action objectives (RAOs). Table 2 lists the COCs that were retained
(based on the BLRA) for RAO development and their concentrations detected in each media.
Table 3 lists the COCs that are present above MCLs (RGs for ground water) at Area 18. The
COCs at Area 18 include VOCs (primarily solvents and solvent-related compounds [TCE,
toluene. PCE. and DCE], in surface and subsurface soil. VOCs and their degradation products
(TCE. PCE. DCE. and vinyl chloride) in ground water, and metals (primarily lead) in surface
soil.
2.6.3 Exposure Assessment
Data collected during the Data Collection and Evaluation phases are used to determine the
estimated exposure point concentrations and estimated intake levels of COCs under the identified
exposure pathways.
Exposure pathways by which human populations may be exposed to the COCs in the soil and
ground water were identified during the Area 18 OU BLRA. Exposure pathways generally
consist of the following four elements:
1) A source and mechanism of release.
2) A retention or transport medium.
3) A point of potential human contact with the medium.
4) An exposure route at the contact or exposure point.
Exposure pathways identified at Area 18 in the BLRA include ingestion of contaminated ground
water, incidental ingestion of contaminated soil, dermal contact with contaminated ground water,
inhalation of VOCs from ground water and soil, inhalation of soil particles containing
contaminants, and ingestion of meat (from cattle that ingested metals while grazing at Area 18).
Both current and future land-use scenarios under which potential receptors could be exposed via
the pathways listed above were evaluated for Area 18.
Current exposure scenarios evaluated during the BLRA included both onsite and offsite
receptors. Onsite receptors include workers engaged in mowing (incidental ingestion of soil,
inhalation of soil particles, and inhalation of VOCs from soil), construction workers who
excavate soil both above and below the water table (all exposure pathways listed above except
ingestion of meat), and National Guardsmen onsite for training (incidental ingestion of soil,
inhalation of soil particles, and inhalation of VOCs from soil). Offsite receptors include
residents in Lake City who ingest contaminated ground water (as a drinking water source), have
dermal contact with contaminated ground water, and/or inhale VOCs in ground water.
Future exposure groups include industrial workers that may work onsite in the future (ingestion
of contaminated ground water, ingestion of contaminated soil, dermal contact with contaminated
soil, inhalation of soil particles containing contaminants, and inhalation of VOCs from soil) and
2^9 February 1998
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Final Record of Decision Area 18 Operable i'mr
Lake City Army Ammunition P'.ant. Indeoenaence. Missouri
offsite residents who may be exposed to contaminated ground water in the future if it moves
offsite (ingestion and dermal contact with contaminated ground water and inhalation of VOCs
from ground water).
Ecological receptors that may be exposed to contaminants (primarily in the soil) were also
evaluated during the BLRA. The ecological risk assessment is described in more detail in
Section 2.6.6.
Table 4 summarizes the exposure groups (future scenarios) and exposure routes (bv medial
evaluated for the Area 18 BLRA.
2.6.4 Toxicity Assessment
The dose-response characteristics for both noncarcinogenic and carcinogenic health effects were
quantitatively described for specific exposure routes during the BLRA. Toxicity profiles for
COCs were also compiled. Quantitative estimates which describe these relationships have been
established by the EPA and were used in the Area 18 BLRA. The following paragraphs
summarize the toxicity assessment for noncarcinogenic and carcinogenic effects of COCs at
Area 18.
Slope factors (SFs) have been developed by EPA's Carcinogenic Assessment Group for
estimating excess lifetime cancer risks associated with exposure to potentially carcinogenic
chemicals. SFs. which are expressed in units of (mg/kg-day)-', are multiplied by the estimated
intake of a potential carcinogen, in mg/kg-day, to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake level. The term "upper bound"
reflects the conservative estimate of the risks calculated from the SF. Use of this approach
makes underestimation of the actual cancer risk highly unlikely. Slope factors are derived from
the results of human epidemiological studies or chronic animal bioassays to which animal-to-
numan extrapolation and uncertainty factors have been applied.
Reference doses (RfDs) have been developed by EPA for indicating the potential for adverse
health effects from exposure to chemicals exhibiting noncarcinogenic effects. RfDs, which are
expressed in units of mg/kg-day, are estimates of lifetime daily exposure levels for humans,
including sensitive individuals. Estimated intakes of chemicals from environmental media (e.g.,
the amount of chemical ingested from contaminated drinking water) can be compared to the RfD.
RfDs are derived from human epidemiological studies or animal studies to which uncertainty
factors have been applied (e.g., to account for the use of animal data to predict effects on
humans). These uncertainty factors help ensure that the RfDs will not underestimate the
potential for adverse noncarcinogenic effects to occur.
A more detailed description of the toxicity assessment can be found in the BLRA in the Final
Area 18RI.
The RfDs and SFs for COCs for Area 18 are presented in Table 4.
2-10 February 1998
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Final Record of Decision Area ! 8 Operable L'm:
Lake City Army Ammunition Plant. Independence. Missouri
2.6.5 Risk Characterization (Human Health Risks)
The Area 18 OU RI/FS assessed the potential for unacceptable risks to humans and the
environment from being exposed to contaminants at the site. Risk characterization is a
compilation of the information included in the data collection phase, the exposure assessment.
and the toxicity assessment. The focus of this characterization was on the human health effects
that could result from direct exposure to the contaminants in soil and ground water through
contact with the skin, ingestion (such as eating), or inhalation (breathing) of soil, dust, or organic
vapors. The risks were evaluated for current workers at LCAAP, who may have reason to be in
the Area 18 OU; for National Guardsmen, who occasionally conduct maneuvers at the Area 18
OU; and for local residents (both current and future) who use the ground water (HSU2) that is
beneath both LCAAP and the community of Lake City as their drinking water source.
The risk assessment also evaluated potential unacceptable risks to persons under possible future
land-uses of the Area 18 OU. These future uses include industrial uses (manufacturing or
warehousing) and leasing parts of the area for cattle grazing (The meat from these cattle would
then be consumed by people.).
Potential carcinogenic (cancer) risks are classified by the increased probability of a person
getting cancer in his or her lifetime (i.e., excess lifetime cancer risks) from being exposed to
known or suspected cancer-causing chemicals at the site. Excess lifetime cancer risks are
determined by multiplying the intake level with the slope factor. These risks are probabilities
that are generally expressed in scientific notation (e.g., IxlQ-6). An excess lifetime cancer risk of
1 x 10-6 indicates that, as a plausible upper bound, an individual has a one in one million chance of
developing cancer over a 70-year lifetime as a result of site-related exposure to a carcinogen,
under the specific exposure conditions at a site. According to the NCP and EPA's Risk
Assessment Guidance for Superfund (EPA/540/1-89/002) the acceptable carcinogenic risk range
is between 1 x W4 and 1 x 10"*. This means there is an increased probability of one additional
case in 10,000 to one case in 1,000,000 that an individual will develop cancer above the expected
normal rate of 250,000 per 1,000,000 (or one in four). Generally, the 1x10"6 risk level is used as
the point of departure (i.e., 1x10"* is the level below which the number of increased cancer
occurrences from exposure to specific contaminants cannot be differentiated from other causes)
in determining whether remedial action should be considered. Depending upon site-specific
information, remediation may or may not be warranted if the total site risk lies within the
acceptable risk range.
Noncancef health effects were also assessed for chemicals that have effects other than causing
cancer in humans. Potential concern for noncarcinogenic effects of a single contaminant in a
single medium is expressed as the hazard quotient (HQ) (or the ratio of the estimated intake
derived from the contaminant concentration in a given medium to the contaminant's reference
dose). By adding the HQs for all contaminants within a medium or across all media to which a
given population may be reasonably exposed, the Hazard Index (HI) can be generated. The HI
provides a useful reference point for gauging the potential significance of multiple contaminant
exposures within a single medium or across media.
2-11 February 1998
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Final Record oj Dec is, c.n \>ta >
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Final Record of Decision Area 18 Operable L'ntt
Lake dry Army Ammunition Plant. Independence. Missouri
18. Toxicity Reference Values (TRV's). or numerical values quantifying the exposure
assessment for a receptor group (e.g., small mammals), were developed in a three-step process:
1) potential receptors were identified and ranked in terms of site use. trophic level, habitat and
contact use. and societal importance; 2) the exposure of the receptors to environmental media
was assessed: and 3) TRVs were developed for each route of exposure (i.e., ingestion. inhalation.
dermal contact).
The risk characterization, or HI, is computed as the ratio between the actual contaminant
concentrations, doses, and body burdens to the TRVs. If the ratio of exposure (anticipated or
measured) to the TRV (HI) is less than 1.0, no significant risk was presumed to exist for that
particular receptor(s) and contaminant(s). If the HI is in the 1 to 10 range, a small potential for
environmental risk effects exist. His greater than 10 indicate a significant potential that greater
exposures could result in risk effects, and His above 100 indicate risk effects may be expected.
Receptors at Area 18 are exposed primarily to surface soil and surface water. The baseline
ecological risk assessment concluded that there was no significant risk to aquatic receptors from
exposure to sediment or surface water. Risks were identified for small mammals (short-haired
shrew and eastern mole) and are associated with metals (some of which were not reported above
background levels) through dermal contact and ingestion of plants that take up the metals from
the soil. Risks were also identified for raptors (owls and hawks) and are associated with
consumption of mice. There are no other apparent risks to other ecological receptors such as
medium-sized mammals and-birds. There are no risks to threatened or endangered species.
The risks to small mammals (typically the short-haired shrew and eastern mole) were associated
with arsenic, copper, chromium, zinc, lead, mercury, and barium, primarily through dermal
exposure to soil and ingestion of vegetation (plants can take up significant quantities of copper
and zinc since these metals are essential nutrients). His ranged from 14.3 (lead) to 483 (copper).
However, arsenic, barium, and chromium were not reported to be above background
concentrations in many samples, whereas other metals were detected at significant concentrations
numerous times. Of this second group of metals, His were as follows: copper (HI = 483); zinc
(HI = 32); lead (HI = 14.3); mercury (HI = 17.6).
The potential risk to raptors (owls and hawks) from lead (HI = 31) and mercury (HI = 5.96)
results from the consumption of mice. Other receptors (raccoon, coyotes, other medium-sized
mammals, herons) are not at apparent risk.
In summary, the baseline ecological risk assessment indicated that in Area 18, certain
environmental receptors (specifically small mammals, raptors, chicken, and pheasant) are
potentially at risk from soil ingestion and/or ingestion of biota containing high concentrations of
metals (copper, mercury, zinc).
A detailed discussion of the ecological risk modeling, determination of COCs, ROCs,
and predicted His for metal toxicity is presented in Section 6.2 of the RI Report. Mean
background concentrations were developed for the soil of Area 18 and used in the risk
assessment to determine the background His at Area 18 for terrestrial receptors.
2^13 February 1998
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Final Record of Decision Area 18 Operable L'mt
Lake City Army Ammunition Plant. Independence. Missouri
The majority of COCs that dnve ecological risk (e.g., lead, copper, zinc, arsenic, and barium) are
co-located with COCs that drive unacceptable human health risk. The baseline ecological risk
assessment results were compared with the calculated residual risks remaining to ecological
receptors after a remedial action is taken to reduce risks to humans from exposure to chemicals in
surface soil. The "residual" risk remaining to ecological receptors will be significantly lower
after an action is taken to reduce risks to humans, since many of the same chemicals that affect
both humans and animals will be addressed at the same time. It was concluded that there would
be no adverse effects to the significant ecological receptors from the residuaJ contamination
remaining following a human health-based cleanup.
2.6.7 Risk Assessment Conclusions
A summary of the conditions at the Area 18 OU that could pose human and ecological risk
include the following:
1) Risks to nearby residents if VOCs in the ground water move offsite in the future.
2) Risks to future onsite workers from lead in the surface soil.
3) Risks to persons who eat beef from cattle that may graze (in the future) at Area 18.
4) Potential risks from metals in surface soil to small mammals and birds that live on the
land.
Actual or threatened releases of hazardous substances from this site, if not addressed by the
preferred alternative or one of the other active measures considered, may present a current or
potential threat to public health, welfare, or the environment. yv
2.6.8 Remediation Goals
Remediation Goals (RGs) for LCAAP have been established based on risk considerations (see
1 able 1). These include criteria associated with ingestion of and dermal contact with
contaminated soils by the reasonably maximum exposed individual, as well as criteria to evaluate
possible leaching of contaminants from soils to ground water at unacceptable levels. For
iu ^?;RGS WerC established at a targe* carcinogenic risk of 10*, consistent with the NCP
*?£ S^f ** RGS Sh°Uld te established for individual constituents within the risk range
pi 10 to 10 , with a preference for the most protective values. Commercial/industrial land use
is the current and reasonably anticipated future land use at the site upon which the RGs have
been based. RGs for additional constituents which may be detected at levels of concern
subsequent to the RI, such as during pre-design sampling activities, will be determined using the
method which was used to determine the RGs for constituents in Table 1. This methodology is
discussed in the Area 18 FS. K
In addition to risk-based soil RGs for protection of human health, the impact to ground water
from residual soil contamination was evaluated. The Summers model was utilized to estimate
2'14 February 1998
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Final Record of Decision Area 18 Operable Unit
Lake Cin-Army Ammunition Plant. Independence. Missouri
the level ai which contaminant concentrations in soils will produce ground water contamination
at concentrations above acceptable levels. The Summers model assumes that a percentage of
rainfall at the site will infiltrate the surface and desorb contaminants from soils, based on
equilibrium soilrwater partitioning. It is further assumed that this contaminated infiltration will
mix completely with the ground water below the site, resulting in an equilibrium ground water
concentration with all contaminants in the final mixture from the infiltration.
The Summers model was used to determine acceptable levels for VOCs in soil. The model was
not used for metals, as metals are relatively immobile in the clay soils found at the LCAAP.
Further, VOCs are the most prevalent and mobile contaminants found at the site. The site-
specific "leaching" RGs for these major contributing contaminants are presented in Table 1.
These RGs represent contaminant levels in soils that are considered protective of human health
and protective of ground water.
2.7 DESCRIPTION OF ALTERNATIVES
The area of attainment defines the area over which RGs will be achieved, and is based on the
RAOs. The area of attainment for soils at Area 18 OU corresponds to the area encompassing the
six AOCs illustrated on Figure 4. The area of attainment for ground water at Area 18 OU
corresponds to the ground water plume shown on Figure 5.
The RAOs for the Area 18 OU are:
• Prevent human contact with soil containing lead concentrations greater than 1.000
ppm.
Prohibit agricultural (e.g., grazing) and other non-industrial uses at Area 18.
Prevent future industrial workers from inhaling VOCs from surface soil.
Reduce ecological receptor risk from exposure to metals in surface soil.
Prevent ingestion and dermal contact (future workers) with onsite ground water
containing VOCs above regulatory standards.
Prevent ground water contaminated above regulatory standards from migrating off
the Installation.
• Minimize contaminant migration from soil to ground water.
A brief description of the major components of each remedial action alternative developed in the
Area 18 FS and Proposed Plan is presented below. Alternative SA-4 (Onsite
Incineration/Replacement into Excavation) was screened out in the FS prior to a detailed analysis
because of excessive cost and is not presented here. The following alternatives were evaluated in
detail in the FS and are numbered to correspond with the text in the FS Report. The selected
alternative includes a component to address contaminated soil and contaminated ground water.
For clarity, the soil and ground water alternatives are discussed separately (as in the FS and
Proposed Plan); however, it is recognized that both the selected soil alternative and the selected
ground water alternative must be implemented to meet all the remedial action objectives for the
.Area 1 SOU.
2-15 February 1998
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Final Record of Decision Area 18 Operable inn
Cay Army Ammunaion Plant. Independence. Missouri
2.7.1 Soil Alternatives
Alternative SA-7 is the selected alternative to address contaminated soil at Area 18 and is
fo™ ^SKf'SfW C°nSidered ^ addreSSm§ S0fl " ^ ' 8 « P—d
Alternative SA-7: /»-><¥/« M..IH-Ph^^ VQ.
Description
Alternative SA-7 addresses surface and subsurface soil at Area 18. Surface soil with lead
exceeding the remediation goal (RG) of 1,000 ppm will be addressed one ofrwo wav
euher excavating and disposing or covering and managing onsite, depending^ v^e'er
VOCs are collocated with the lead at levels above RGs. fhe foiling major
components make up alternative SA-7. 8 J
will be managed onsite beneath a two-foot soil cover.
In areas with soil containing VOCs at concentrations above 1 0 ppm, soil will be
left on place and a 2-foot compacted earth cover will be constructed over the
contaminated area. VOCs will be removed and treated using an MPVE system.
The following sections provide detailed description of the various components.
Treatment/Containment
18 W- T^e amount
soil to be removed and/or covered was determined based on the
potential nsk to future land users and the lead RG of 1,000 ppm. The areas of VOC
tammati in the soil to be treated were determined base'd'on the RG of 1 0 ppm The
e
™St ? m ! ^ W3S established to «*»«« risk to future workers and also to be
feTch Tth ^ 7atCr (Le" V°CS "^ S°il at co^ntrations below 10 ppm will not
leach mto the ground water at levels above cleanup criteria). Treatment and/or
containment components are as follows:
A pre-construction study to determine the extent of surface soil lead
contamination and the areas of collocated lead associated with VOCs exceeding
RGs will be performed. 5
Surface soil contaminated with lead exceeding the RG of 1 .000 ppm. in areas
where the VOC concentrations in soil are below the RG of 10 ppm, will be
2-16
February 1998
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Final Record of Decision Area 18 Operable Unit
Lake City Army Ammunition Plant. Independence. Missouri
excavated to a maximum depth of 24 inches and disposed of appropriately.
Excavated soil will be tested for Toxicity Characteristic Leaching Procedure
(TCLP) criteria to determine its ultimate disposal. Soil failing TCLP criteria will
require transportation and disposal as hazardous waste at an approved hazardous
waste facility or stabilization and disposal as special waste. Soil that meets TCLP
criteria (and other LDRs) will be disposed of as special waste in an appropriate
manner. The excavations will be backfilled using clean backfill from an onsite
source. The area containing lead above 1.000 ppm and VOCs below 10 ppm is
primarily limited to AOC-4 and potentially a small portion of AOC-5 (Figure 4).
The volume of lead-contaminated soil to be excavated is approximately 5.000 cy.
• Surface soil containing lead within the areas of VOC contamination above 10
ppm (primarily AOC-5) will be managed in-place beneath the 2-foot earth cover
constructed to enhance the MPVE system, described below. The area where
VOCs and lead are both above their respective RGs (most of AOC-5) is
approximately 12,500 square feet.
In the areas at Area 18 where VOC concentrations are above 10 ppm. including
the areas collocated with lead described above, a 2-foot compacted earth cover
will be installed and VOCs will be remediated using a technology known as
MPVE. The soil cover will be compacted to minimum of 90 percent of its
maximum dry-density as determined by standard Proctor test and will be graded to
promote positive drainage off the area. The cover will be vegetated to protect it
from erosion.
Vapor and water extracted by the MPVE system will be treated to meet discharge
criteria. The specific methods of treatment will be determined during the RD.
MPVE is a variation of soil vapor extraction (SVE) developed specifically for use in low
permeability soils, such as those present in Area 18 OU. The MPVE technology uses a very high
vacuum (up to 26 inches of mercury) applied to a series of extraction wells, causing soil vapor
and ground water to be drawn into the wells. The goal of this system is to lower the ground
water table in order to expose more soil to the air flow induced by the vacuum. Contaminants
such as chlorinated solvents and some petroleum hydrocarbons are volatilized into the air
flowing through the unsaturated zone, drawn into the wells, brought to the surface and destroyed.
The system will be installed to remove contaminant mass from the soil and shallow ground water
in the low permeability soils to a depth of approximately 30 feet bgs, in areas with VOC
concentrations above RGs. The areas containing VOCs above RGs are primarily limited to the
solvent pits located in AOCs 1, 2, and 3 (see Figure 4), a combined area of approximately 55,000
square feet. The goal of the system is to remove VOCs to concentrations below the RG of 10
ppm in these areas.
2-17 February 1998
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Final Record of Decision Area 18 Operable Unit
Lake City Army Ammunition Plant. Independence. Missouri
General Components
Excavation and disposal will address lead contaminated surface soil. Risk from
exposure to lead in the surface soil will be eliminated by removing lead-
containing soil and backfilling with clean soil. There will be no residual risk from
lead at the surface in this area. Excavated soil will be tested (TCLP) to determine
whether or not it is hazardous. If it is hazardous, soil will be disposed of at RCRA
Subtitle C facility or it will be stabilized and disposed of as special waste. For
cost estimating purposes, it is assumed that 25 percent of the excavated material
will fail TCLP testing; however, the amount of hazardous waste, if any, will not
be known until testing is complete. Soil containing lead at nonhazardous
concentrations (based on TCLP testing) will be disposed of at an approved
facility. This component of SA-7 could be readily implemented with locally
available labor and materials. Hazardous waste will require adherence to DOT
regulations and land disposal restrictions.
The MPVE system will be installed to address VOC-contaminated subsurface soil
and shallow ground water to a depth of approximately 30 feet bgs. A 2-foot earth
cover will be placed over the area to be remediated using MPVE to increase
efficiency of the system by preventing short circuiting of the soil vapor. The goal
of the MPVE system is mass removal of VOCs in the soil to concentrations below
RGs. Removal of VOCs from the soil will reduce the risk to future onsite
workers. It will also reduce the risk to future offsite residents by reducing the
source of VOCs in the ground water that could potentially move offsite in the
future if no action is taken. The residual risk from VOCs remaining in the soil
will not be known until data can be collected from the operating system over an
extended period of time. However, the results of a pilot study conducted in 1996
indicate that significant mass removal can be achieved. During the pilot study,
data collected indicate a radius of effectiveness for the vacuum system of 30 to 50
feet from an extraction well can be expected at Area 18. A 30-foot radius of
influence for each MPVE well was used to approximate the number of extraction
wells that might be needed to treat the area. For cost purposes, the area of
treatment was assumed to be 100,000 square feet. A predesign study must be
conducted to further refine the extent of contamination. Semiannual technical
reviews will be used to develop appropriate criteria for shutting down the system.
A more specific approach to the development of shutdown procedures is further
described in Section 2.9.
Along with increasing the efficiency of the MPVE system, the 2-foot earth cover
will minimize the amount of rainwater that infiltrates into the pit, reducing the
potential for the infiltration to transmit chemicals from the soil to the ground
water. The cover will also prevent direct exposure to VOCs in the surface soil
and minimize risk from exposure to lead in the surface soil in those areas where
lead is collocated with VOCs (primarily AOC-5). Since lead would remain in
place under the cover at levels above the RG, a 5-year review will be required to
2-18 February 1998
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Final Record of Decision Area 18 Operable Unit
Lake City Army Ammunition Plant. Independence. Missouri
insure that the cover continues to be protective of human health and the
environment.
Vapors collected from the MPVE system will be treated to meet applicable or
relevant and appropriate requirements (ARARs) including the Clean Air Act and
State of Missouri Air Quality Standards. A study will be conducted during the
RD to determine the specific treatment required to meet discharge criteria.
• A bench study will be conducted to determine the required ground water treatment
processes. The ground water extracted from the system will meet pre-treatment
discharge requirements established by the Little Blue Valley Sewer District
(LBVSD) in Permit No. LB-0200-LC504. The need for additional treatment will
be determined during remedial design.
Institutional controls will be implemented to restrict future uses of Area 18 to
industrial uses, preventing the use of the site for cattle grazing and other
agricultural activities, and construction of residential housing. Institutional
controls will include: (1) issuing a continuing order (by the Installation
Commander) to restrict or place limitations on access to Area 18; (2) filing a
notice in environmental and real estate records at the Installation, detailing the
restrictions of the continuing order; and (3) compliance with the provisions of
CERCLA Section 120(h)(3) and other applicable statutory requirements in the
event of property transfer. Ground water monitoring will also be required to verify
the effectiveness of the containment system; however, this can be implemented as
part of the ground water remediation option.
• This alternative can be installed within 12-18 months.
Major ARARs
• Alternative SA-7 meets the action-specific and location-specific ARARs for soil
at Area 18 OU including fugitive dust regulations, storm water management
regulations, land disposal restrictions (LDRs), and deed notations that there are in-
piace wastes managed on the property. These, and other major action-specific
ARARs are summarized in Appendix D. The Area 18 FS Report includes a
complete list of action-specific ARARs. There are no chemical-specific ARARs
for contaminants in soil. Treatment and discharge of water and vapors generated
as part of this remedy will meet appropriate standards.
Alternative SA-1: No Action
• The No Action Alternative is presented as a baseline to which other remedial
measures are compared. The National Contingency Plan (NCP) requires that the
No Action Alternative option be examined in detail during the remedial
alternatives evaluation phase. Under this alternative, no treatment or containment
2-19 • February 1998
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Final Record of Decision Area 18 Operable Unit
Lake City Army Ammunition Plant. Independence. Missouri
of any contaminated soil in the .Area 18 OU would be conducted and no
institutional controls would be placed on future land use.
Alternative SA-2: Multi-Laver Cover and Vertical Barriers
Descrition
SA~2 addresses surface soil contaminated with metals and soil contaminated
with VOCs. This alternative consists of consolidating VOC and lead-contaminated soil
within a perimeter barrier wall and beneath a reduced permeability multi-layer cover
Soils within each AOC which exceed lOpprn VOCs and soils which exceed 1.000 ppm
lead would be excavated and placed within the barrier wall. Excavated areas outside the
barrier wall would be backfilled with clean fill material. Any soils found to be TCLP
toxic for lead would be stabilized onsite before placement. The barrier wall would be
keyed into a competent layer of bedrock to minimize the flow of ground water beneath
the bamer wall. Predesign studies would be conducted to determine the most effective
material to use for the barrier wall. Ground water would be extracted to create and
maintain an inward hydraulic gradient, minimizing the release of contaminated ground
^'u^T WIthm thC barrier Walh There is approximately 2,500 cy of soil contaminated
with VOCs in AOC-1 and 4,700 cy of surface soil contaminated with lead in AOC-4 that
would be excavated and placed in AOCs-2, 3, and 5 (which is collocated with AOC-2)
Institutional controls would be used to restrict future site use. The following major
components make up alternative SA-2:
Excavating soil from AOC- 1 and placement in AOCs-2, 3, and 5.
Constructing a reduced permeability multi-layer cover over AOCs-2, 3, and 5.
Constructing a barrier wall around the combined perimeters of AOCs-2, 3 , and 5 .
Installing ground water extraction wells in the interior of the containment wall.
The following sections provide detailed descriptions of the various components.
Treatment and/or Containment Component?
Lead and VOC contamination in surface and subsurface soil was delineated during the
Area 1 8 RI. The amount of lead-contaminated soil to be removed/covered was
determined based on the potential risk to future land users and the lead RG of 1,000 ppm.
The areas of VOC contamination in the soil to be addressed were determined based on
the RG of 10 ppm. The RG for VOCs in the soils was established to address risk to
future workers and also to be protective of ground water (i.e., VOCs in the soil at
concentrations below 10 ppm will not leach into the ground water at levels above cleanup
criteria.). Treatment and/or containment components are as follows:
2'20 February 1998
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Final Record of Decision Area 18 Operable L'nit
Lake dry Army Ammunition Plant. Independence. Missouri
Approximately 2.500 cy of soil contaminated with VOCs above RGs in AOC-1
and 4.700 cy of soil containing lead above RGs from AOC-4 would be excavated
and consolidated under the areas proposed to be covered in AOC-2 and AOC-3.
Excavation and consolidation of material would occur entirely within the Area 18
OU.
Post excavation sampling would be conducted to verify that RGs were achieved in
AOC-1 and AOC-4.
• Clean backfill would be placed and compacted in the excavated areas of AOC-1
and AOC-4.
• A multi-layer cover consisting of a 24-inch thick compacted clay layer, a
geomembrane layer, and a 24-inch thick vegetative layer would be placed over the
area of consolidated. The area! extent of the cover required would be
approximately 1.9 acres. The cover would reduce the infiltration of rain water and
the subsequent leaching of contaminated material from soil. The cover would
help to prevent human and ecological receptor exposures to the lead-contaminated
soil. Prior to placement of soil beneath the multi-layer cover, the soil containing
lead would be tested using the TCLP criteria for lead. To satisfy RCRA LDR
criteria, soil failing TCLP lead testing would be stabilized onsite, so it will not
leach lead into-the ground water, prior to disposal beneath the multi-layer cover.
It is not anticipated that there would be significant quantities of soil failing the
TCLP test.
A containment wall (slurry or HDPE depending on predesign studies) would be
constructed around the combined perimeter of AOCs 2,3, and 5 (the approximate
area of the soil consolidation) to act as a vertical barrier, restricting the movement
of contaminated ground water from Area 18. For cost purposes, it was assumed a
slurry wall would be constructed. The siuny wall would be keyed into a
competent layer to prevent ground water from flowing under the wall. At Area
18, geologic conditions would require installing the slurry wall to a depth of
approximately 90 feet bgs.
• Two ground water extraction wells would be installed within the perimeter of the
barrier wall. The wells would extract ground water at a low rate (approximately 5
gallons per minute [gpm]) to create and maintain a slight inward ground water
flow within the isolated area. Extracted ground water would be managed as part
of the selected ground water alternative.
General Components
• Excavation of contaminated soil from AOCs-1, and 4 would eliminate the risk
from VOCs and lead in the soil in these respective areas. Excavation from AOCs-
2-21 February 1998
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Final Record if Decision Area IS Operable Unit
Lake City Army Ammunition °lant. /ndesc^tnce. Missouri
1 and 4 and placement in AOCs 2. 3, and 5 would be conducted entirely within
the Area 18 OU. „ '
Construction of a barrier wall and multi-layer cover would reduce risk bv
containing contaminated soil and ground water in the source area.
A predesign investigation would be performed to:
Refine and delineate the vertical and horizontal extent of lead and VOC
contamination in the surface and subsurface soil. The delineation effort
would extend to a depth of 2 feet below grade in the lead areas and 20 feet
below grade in the VOC areas.
Determine the compatibility of the vertical barrier material for use in
design of the barrier wall.
Determine the required ground water extraction rate to maintain an inward
gradient within the slurry wall.
Institutional controls similar to those described under Alternative SA-7 would be
implemented to restrict future uses of Area 18.
Excavation and consolidation of material beneath a multi-layer cover do not
impose any unusual or extraordinary conditions that would preclude
implementation of this alternative. Material excavated below the water table may
require drying prior to placement beneath the cover. Installation of slurry walls
keyed into a competent layer requires deep trenching methods and may require
special measures to ensure bank stability. The effectiveness of slurry walls in
preventing migration of VOCs in ground water requires further evaluation which
would be conducted as predesign or pilot studies. Dewatering and treatment of
the ground water contained within the slurry wall would also be required This
alternative could be implemented and the remedial action objectives for soil met
in 6-9 months. However, because of the quantity of VOCs present in soil
(estimated in the FS at 25,000 Ibs of VOCs), it is estimated that VOCs would
continue to leach into the ground water at significant concentrations for about 200
years under optimal conditions. Placement of the multi-layer cap would reduce or
eliminate infiltration and likely extend the time for chemicals to leach out of the
soil. This alternative would require that the ground water extraction wells
installed within the slurry wall containment be operated indefinitely or until
subsequent reviews indicate that there is no continued benefit to operating the
wells (i.e., no continued leaching of chemicals into ground water) Because
wastes would be managed in-place, a 5-year review of this alternative would be
required to ensure that the alternative continues to be protective of human health
and the environment.
Under this alternative, residual risks to onsite receptors from exposure to
contaminated soil would be minimal as long as the cover remained in tact.
2-22 February 1998
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Final Record of Decision Area 18 Operable L nil
Lake Citv Army Ammunition Plant. Independence. Missouri
Continued operation of the ground water extraction wells within the barrier wall
would be required to prevent migration of ground water above MCLs.
Major ARARs
* Alternative SA-2 meets the action-specific and location-specific ARARs for soil
at the Area 18 OU including fugitive dust regulations, storm water management
regulations, land disposal restrictions (LDRs), and deed notations that there are in-
piace wastes managed on the property. These, and other major action-specific
ARARs are summarized in Appendix D. The Area 18 FS Report includes a
complete list of action-specific ARARs. There are no chemical-specific ARARs
for contaminants in soil.
Alternative SA-3: Onsite Low Temperature Thermal Desorption
Description
Alternative SA-3 addresses surface soil contaminated with metals and soil contaminated
with VOCs. This alternative includes excavating soil contaminated with lead in excess of
1,000 ppm and VOCs in excess of 10 ppm. including VOC-contarninated soil below the
water table, from each of the AOCs. When necessary, the excavations would be
dewatered so that excavation can continue below the water table. Excavated soil
containing VOCs above RGs would be treated onsite using a process called Low
Temperature Thermal Desorption (LTTD). Surface soil containing lead above RGs
would be tested and stabilized onsite, if necessary. Excavated areas below the water table
would be backfilled with clean fill material. Once the excavations are backfilled to an
elevation above the water table, treated soil and surface soil containing lead above the RG
of 1,000 ppm would be consolidated in the excavations where VOC-contaminated soil
was removed. The final 2-foot of fill in all excavated areas would consist of a 2-foot
earth cover as described in Alternative SA-7. The following major components make up
alternative SA-3:
Excavating VOC-contaminated soil from AOCs-1, 2, 3, and 5.
• Excavating lead-contaminated surface soil from AOCs-4 and 5.
Dewatering the excavations where necessary and treating the water if required.
• Treating VOC-contaminated soil using LTTD.
Backfilling excavations below the water table with clean fill material.
Consolidating LTTD-treated soil and soil containing lead in the excavations
above the water table.
2-23 ' February 1998
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Final Record of Decision Area 18 Operable Unit
Lake City Army Ammunition Plant. Independence. Missouri
Constructing a 2-foot thick earth cover over excavations.
The following sections provide detailed descriptions of the various components.
Treatment and Engineering Component?
The volume of soil contaminated with VOCs above RGs is approximately 23.000
cy and is located in AOCs-1, 2, 3, and 5. Soil would be excavated to a depth of
20 feet in AOC-1, the southern half of AOCs-2, and AOC-3 and to a depth of 3
feet in the northern half of AOC-2 and most of AOC-5. Post excavation sampling
would be conducted to verify that residual VOCs in the soil are at concentrations
below RGs in the excavated areas.
Ground water entering the excavation during excavation (estimated at 60 gpm)
would be collected and treated at the existing Area 18 treatment plant to meet
discharge criteria for the existing treatment plant. If necessary, additional
pretreatment of the water would be conducted prior to discharging to the Area 18
treatment plant so that discharge requirements are met.
Excavated soil containing VOCs would be treated onsite using LTTD. LTTD is a
process designed to remove organic contaminants from excavated soil and sludge
by using air, heat, and/or mechanical agitation. The removed contaminants are
then collected and treated. Treated soil would be tested to verify that RGs and
TCLP limits are met prior to placing material back into the excavations.
That portion of the excavation that lies below the depth of the typical water table
(approximately 7 feet bgs) would be backfilled with clean material.
Soil treated using LTTD would be placed back into the excavations at depths
above the water table.
The upper 2 feet of soil in AOCs-4 and 5 (approximately 4,700 cy and 1,200 cy
respectively) containing lead concentrations greater than 1,000 ppm and meeting
RCRA LDR criteria (as described under Alternative SA-2), would be excavated
and consolidated in the areas of AOCs-1,2, and 3 where VOC-contaminated soil
was excavated. Material exceeding LDR criteria for metals would be stabilized
onsite prior to placing the final 2-foot cover.
A 2-foot earth cover would be constructed over the area containing the
consolidated waste. The cover would be graded for positive drainage and
vegetated to minimize infiltration and erosion.
2-24 February 1998
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Final Record of Decision Area 18 Operable Lnit
Lake City Army Ammunition Plant. Independence. Missouri
General Component^
Excavation of soil containing VOCs above RGs, including that below the water
table, and treatment of the soil by LTTD would eliminate unacceptable risk from
VOCs in the soil. Remaining VOC concentrations would also be protective of the
ground water.
Excavation and consolidation beneath a 2-foot earth, cover of surface soil with
lead concentrations above RGs would eliminate risk from exposure to surface soil
containing lead. Excavation and consolidation of material would be conducted
entirely within the Area 18 OU.
A predesign investigation would be performed to refine and delineate the vertical
and horizontal extent of lead and VOC contamination in the surface and
subsurface soil, obtain design data, and to classify the waste.
Institutional controls as those described under Alternative SA-2 would be
implemented.
Implementation of an LTTD system requires the services of specialized vendors,
but these vendors are readily available. It would be necessary for the LTTD
system to comply with the substantive requirements of the Clean Air Act and
State of Missouri Air Quality Standards. Because this would be an onsite
CERCLA response action, administrative permits otherwise necessary would not
be required. Excavation below the water table would require dewatering and
potentially treating the water if chemical concentrations are above discharge
criteria. It may also be necessary to shore the sidewalls of the excavation to
maintain slope stability. This alternative could be implemented and remedial
objectives met within 15 months. Because wastes would be managed in-place, a
5-year review of this alternative would be required to ensure that the alternative
continues to be protective of human health and the environment.
Major ARARg
The major ARARs for Alternative SA-3 are the same as those described in
Alternative SA-2. In addition, emissions from the LTTD unit would be treated to
comply with Clean Air Act requirement and Missouri Air Quality Standards.
These, and other major action-specific ARARs are summarized in Appendix D.
Alternative SA-3 would meet RGs for soil.
Alternative SA-4: Qnsite Incineration
This Alternative was screened from further consideration in Chapter 3 of the FS7 which
defines and screens initial alternatives prior to detailed evaluation. It will not be
discussed further in this document.
2-25 February 1998
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Final Record of Decision Area IS Operable L'mt
Lake City Army Ammunition Plant. Independence. Missouri
Alterative SA-5: Excavation and Qffsite Treafment and ni«pn««i
Description
^ VOCs SW 1^ SUrfaCe-f " C0ntaminated ^ me<^ *>d soil contaminated
with V DCs. This alternative is similar to Alternative SA-3 except that excavated soil
contaminated with lead in excess of LOGO ppm and VOCs in excess of 10 ppm would be
SA-T: """^ **** ***»' ^ f°I1OWing maJOr C°mp°nent' make ™
Excavating soil containing VOCs above 1 0 ppm from AOCs- 1 . 2. 3. and 5 .
Excavating surface soil containing lead above 1 ,000 ppm from AOCs-4 and 5.
Dewateririg the excavations where necessary and treating the water if required.
Offsite disposal of excavated soil.
Backfilling excavations with clean fill material.
The following sections provide detailed descriptions of the various components.
Treatment and Enciphering Cni^pnpp^c
This alternative is similar to SA-3 with the exception that the VOC-contaminated
soU (above 10 ppm) from AOC-1, AOC-2, and AOC-3 and lead contaminated soil
(above 1,000 ppm) from AOC-4 and AOC-5 would be excavated and disposed at
a KCKA-penrutted facility instead of being treated onsite.
Excavated material would be tested to make a determination of applicable RCRA
waste codes for purposes of identifying appropriate offsite disposal facilities.
Approximately 23,000 cy of uncontaminated fill would be used to fill the
excavation.
General C!
There would be no residual unacceptable risk from either lead or VOCs in the soil
since soil contaminated above RGs would be excavated and disposed of offsite.
A predesign investigation would be performed to refine and delineate the vertical
and horizontal extent of lead and VOC contamination in the surface and
subsurface soiL obtain design data, and classify the waste.
2-26 Februarv 1998
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Final Record of Decision Area 18 Operable Unit
Lake dry Army Ammunition Plant. Independence. Missouri
Institutional controls similar to those described under Alternative SA-2 would be
implemented.
Material removed from the site would require disposal in RCRA Subtitle C
(hazardous waste) or Subtitle D (solid waste) facilities. Deep excavation would
be required as under Alternative SA-3. This alternative could be implemented
and remedial objectives met within 2-4 months.
Maior ARARs
The major ARARs for this alternative are similar to the ones for Alternative SA-3.
LDRs and transportation of hazardous wastes are two ARARs to be met under this
alternative. These and other major action-specific ARARs are summarized in
Appendix D. Alternative SA-5 would meet RGs for soil.
Alternative SA-6: Excavation and Ex-Situ T andfarming
Description
Alternative SA-6 addresses surface soil contaminated with metals and soil contaminated
with VOCs. This alternative is similar to Alternative SA-3 except for the technology
used to treat VOC-contaminated soil. Under Alternative SA-6, soil containing VOCs
above RGs would be excavated and treated onsite using landfarming technology. The
volume of material to be treated under Alternative SA-6 is the same as that under
Alternative SA-3. As in Alternative SA-3, treated soil would be returned to the
excavation once RGs have been met. Lead contaminated soil (above 1,000 ppm) in
AOC-4 and AOC-5 would be excavated and consolidated in AOCs 1, 2. and 3. The final
2-foot of fill in ail excavated areas would consist of a 2-foot earth cover as described in
Alternative SA-7. The following major components make up alternative SA-5:
Excavating soil containing VOCs above 10 ppm from AOCs-1, 2, 3, and 5.
Excavating surface soil containing lead above 1,000 ppm from AOCs-4 and 5.
• Dewatering the excavations where necessary and treating the water if required.
Landfarming soil containing VOCs above RGs.
Backfilling excavations below the water table with clean fill material.
• Place soil treated using landfarming back into the excavations at depths above the
water table.
Consolidate soil containing lead above 1,000 ppm excavated from AOCs-4 and 5
(approximately 4,700 cy and 1,200 cy respectively) in AOCs 1, 2, and 3. Material
~ ~~ 2-27 February 1998
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Final Record of Decision Area IS Operable Unit
Lake City Army Ammunition f'ant. Independence. Missouri
exceeding TCLP requirements for lead would be stabilized onsite prior to placing
the final 2-foot cover.
Construct a 2-foot earth cover over the area containing the consolidated waste.
Grade the cover for positive drainage and vegetate the cover to minimize
infiltration and erosion.
The following sections provide detailed descriptions of the various components.
Treatment Components
This alternative is similar to SA-3 (i.e., volume of material to be treated is the
same) with the exception that the VOC-contaminated soil from AOC-1, AOC-2,
and AOC-3 would be treated using landfarming technology instead of LTTD and
then would be returned to the excavation. Landfarming consists of applying
affected material to a plot of land at controlled rates, mixing it with the surface
soil, and allowing the physical, chemical, and biological systems that exist
naturally in the soil to reduce chemical concentration through volatilization,
desorption, degradation, and immobilization of the chemicals. Measures would
be taken to optimize the remediation timeframe for landfarming. These measures
would include aeration, pH adjustment, nutrient addition, moisture control, and/or
mixing. A significant portion of the VOCs ^ .... so" raid volatilize into the air,
resulting in media transfer. To reduce exposure risks, it may be nece^.
collect and treat volatilized VOCs. Landfarming pilot studies have been
conducted on the contaminated soils at the Area 18 OU (Landfarming Treatability
Pilot Study Report Areas 17 and 18 Operable Unit. Bums & McDonnell, 1997).
Results of the studies indicate that landfarming would be effective in treating the
source area soils to levels consistent with site RGs. Because of the media transfer.
there are two options associated with this alternative:
Option 1: Landfarming of Contaminated Soil Without Air Controls
Landfarming would be performed outdoors and would not include constructed air
controls. VOC emissions would be monitored and controlled by the rate of
application and tilling of the contaminated soil.
Option 2: Landfarming of Contaminated Soil With Air Controls
This option would include the collection, treatment, and destruction of vapors
generated during landfarming. Landfarming would be performed in a closed
structure under this option.
Treated soil would be placed back into the excavations.
2-28 February 1998
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Final Record of Decision Area IS Operable L'nit
Lake City-.Army Ammunition Plant. Independence. Missouri
• Lead contaminated soil (above 1.000 ppm) in AOCs-4 and 5 would be excavated
and consolidated in AOCs 1. 2, and 3.
• A 2-foot earth cover would be constructed over the area containing the
consolidated waste, graded for positive drainage, and vegetated.
General Components
Excavation of soil containing VOCs above RGs, including that below the water
table, and treatment of the soil by landfarming would eliminate unacceptable risk
from VOCs in the soil. Remaining VOC concentrations would also be protective
of the ground water.
• Excavation and consolidation beneath a 2-foot earth cover of surface soil with
lead concentrations above RGs would eliminate risk from exposure to surface soil
containing lead. Excavation and consolidation of material would be conducted
entirely within the Area 18 OU.
• A predesign investigation would be performed to refine and delineate the vertical
and horizontal extent of lead and VOC contamination in the surface and
subsurface soil, obtain design data, and classify the waste.
• Institutional controls similar to those described under Alternative SA-2 would be
implemented.
• Implementation of this alternative would require construction of a landfarming
treatment pad and may require construction of a building if it is determined that
air emission requirements are not being met. However, it is anticipated that
controlled application of material to the landfarm would prevent air emission
regulations from being exceeded. This alternative could be implemented and
remedial objectives met within 24 months.
Major ARARs
• ARARs for this alternative are the same as under Alternative SA-3. Major action-
specific and location-specific ARARs are summarized in Appendix D.
Alternative SA-6 would meet RGs for soil.
Alternative SA-8: Selective Excavation/Treatment or Disposal
Description
Alternative SA-8 is a combination of components of the other alternatives. All the
aspects of Alternative SA-8 have been described under previous alternatives. This
alternative consists of excavation of the same areas as described in Alternative SA-5. The
! 2-29February 1998
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Final Record of Decision Area 18 Operable Unit
Lake City Army Ammunition Plant. Independence. Missouri
only difference relative to the areas of excavation is that soil containing VOCs above RGs
in AOCs-1. 2. and 3 would be excavated only to the depth of the water'table VOCs in
the soil below the water table would be left in place and addressed by the around water
treatment component of the selected remedies. Four options were considered to treat '
excavated soil containing VOCs; LTTD, landfarming without air controls. landfarmine
with air controls, and offsite treatment and disposal. Soil containing lead above RGs ~
would either be excavated and consolidated or disposed of offsite. The major
components that make up alternative SA-8 have been previously described in
Alternatives SA-2 through SA-7. Only significant differences will be discussed in the
following sections.
Treatment and Engineering Components
Excavation of VOC contaminated soil at AOC-1, AOC-2, and AOC-3 under this
alternative is similar to that under Alternative SA-5, except that excavation would
be conducted to remove only the VOC-contaminated soil above the water table
Surface soil containing lead above the RG of 1,000 ppm from AOC-4 and AOC-5
would be excavated as described under Alternative SA-5. Alternative SA-8
includes excavation of approximately 10,000 cy of soil contaminated with VOCs
(above the water table only, estimated at 7 feet below grade) and excavation of
approximately 4,700 cy of soil contaminated with lead.
Four treatment options under Alternative SA-8 to address the excavated soil
include:
Option 1: LTTD treatment of VOC contaminated soil and consolidation of
lead contaminated soil as described hi Alternative SA-3.
Option 2a: Landfarming, without air controls, of VOC contaminated soil and
consolidation of lead contaminated soil as described in Alternative
SA-6.
Option 2b: Landfarming, with air controls, of VOC contaminated soil and
consolidation of lead contaminated soil as described in Alternative
SA-6.
Option 3: Offsite treatment and disposal as described in Alternative SA-5.
General Component.*;
Some residual risk from VOCs in the soil below the ground water table would
remain. The selected ground water alternative would have to be implemented to
address contaminants in the soil below the ground water table and ground water
containing chemicals above MCLs.
2'30 February 1998
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Final Record of Decision Area IS Operable L'nit
Lake City Army Ammunition Plant. Independence. Missouri
A predesign investigation would be performed to refine and delineate the vertical
and horizontal extent of lead and VOC contamination in the surface and
subsurface soil above the water table, obtain design data, and classify the waste.
Institutional controls similar to those described under Alternative SA-2 would be
implemented.
Implementation considerations of this alternative are similar to those previously
described in Alternatives SA-2 through SA-8, depending on the option selected.
Alternative SA-8 would meet the RGs for the soil above the water table. The
remaining VOCs below the ground water table would be treated by the selected
ground water remediation alternative that would be used in conjunction with this
soil remedial alternative.
Major ARARs
• The major ARARs are as described in the previous alternatives. Major action-
specific and location specific ARARs are summarized in Appendix D.
2.7.2 Ground Water Alternatives
Alternative GW-4 is the selected alternative to address contaminated ground water at Area 18
and is described first. Additional alternatives considered for addressing ground water at Area 18
are presented following the description of GW-4.
Alterative GW-4; Extraction Weils (One Deep and Four Shallow! Air Stripping/Catalytic
Oxidation/Discharge
Description
Alternative GW-4 addresses contaminated ground water at Area 18. Contaminated
ground water will be removed using extraction wells and/or extraction trenches. Both
new and existing weils will be used. Wells will be installed near the plant boundary to
prevent offsite movement of ground water contaminated above MCLs. Wells and/or
trenches will also be installed in or near the source area to address contaminated ground
water that could continue to move from the source if no action is taken. Extracted ground
water will be treated using an existing onsite air stripper equipped with catalytic
oxidation offgas treatment. The treatment plant was constructed in accordance with the
June 1995 Action Memorandum for a Removal Action and is currently operating. It was
designed with excess capacity so that additional waste streams can be added.
Pretreatment of ground water will be conducted if necessary to meet LBVSD
requirements. The following major components make up Alternative GW-4:
Continued use of extraction well EW-1 which was installed as part of the 1995
removal action to contain ground water onsite.
2-31 " February 1998
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Final Record nf Decision Area IS Ooerable Unit
Lake dry Army Ammnniiion . -lent. Independence. Missouri
Operation of existing water supply well 17-FF as a ground water extraction well
for remediation. Well 17-FF will no longer be used as a water supply well.
Installation of four shallow extraction wells or extraction trenches in the vicinity
of the source area.
Treatment of extracted ground water using the existing Area 18 air stripper.
Treatment of offgasses from the air stripper using catalytic oxidation to destroy
VOCs.
Discharge of treated ground water to the LBVSD. Ground water will be treated to
meet LBVSD discharge requirements.
Treatment and/or Containment Components
Ground water contamination was delineated during the Area 18 RI. Ground water
modeling was conducted as part of the RI to predict how fast and in what directions
contaminants in the ground water at Area 18 could move. Results of the ground water
modeling were used to help determine the proposed locations of extraction wells and/or
trenches. Ground water from these wells and/or trenches will be treated to meet the
LBVSD discharge requirements of Permit No. LB-0200-LC504. Appendix C lists the
discharge requirements described in the permit. Treatment components are as follows:
Continued operation of EW-1 which was installed as part of the removal action.
The location of EW-1 is shown on Figure 5. It is estimated that EW-1 will
initially be pumped at approximately 380 gpm; however, the rate will be adjusted
so that containment of contaminated ground water within LCAAP boundaries can
be achieved at the lowest extraction rate possible. Operation of this well, along
with continued operation of well 17-FF (described below) will prevent the offsite
movement of contaminated ground water.
Continued operation of well 17-FF for ground water remediation. The well will
no longer be used as a water supply well. It is estimated that 17-FF will initially
be pumped at approximately 90 gpm; however, the rate may be adjusted so that
containment of contaminated ground water within LCAAP boundaries can be
achieved at the lowest extraction rate possible.
Installation of ground water extraction wells or ground water extraction trenches
in the shallow aquifer in the vicinity of the source area to recover additional VOC
mass in soil left in place below the water table. The installation of shallow
wells/trenches will allow removal of more contaminant mass in the shallow
aquifer in a shorter time frame. For cost purposes, it is assumed that four wells
will be installed in the source area.
2-32 February 1998
.k.
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Final Record of Decision Area 18 Operable Unit
Lake City-Army Ammunition Plant. Independence. Missouri
Extracted ground water will be treated using an onsite air stripping unit equipped
with catalytic oxidation off-gas treatment to destroy VOCs removed from the
ground water. The treatment plant was constructed in accordance with the June
1995 Action Memorandum and associated design specifications. Extraction and
treatment of ground water will be continued until RGs are achieved.
Treated ground water will be discharged to the LBVSD. Treated ground water
will meet LBVSD discharge requirements.
General Components
Extraction wells EW-1 and 17-FF will address current and potential future risk
associated with VOCs in the ground water. These wells will operate in
combination to prevent contaminated ground water from moving offsite.
Prevention of offsite migration will eliminate future risk to offsite receptors who
use the ground water as their source of drinking water. The operating rates of the
wells will be adjusted to the lowest extraction rate that will contain contaminated
ground water onsite. This will minimize the amount of water that will be treated
•at any one time and will reduce the potential for smearing contaminants between
the NECOU and Area 18. The wells will be operated until RGs are achieved.
The wells and/or trenches installed in the source area will remove additional VOC
mass at the source, reducing the amount of contamination leaving the source area
and allowing a faster cleanup of the ground water. The location, depths, and
pumping rates of the wells or trenches in the source area will be determined
during remedial design. For cost purposes, it is estimated that four additional
wells will be installed and will produce an estimated 50 gpm of ground water to
be treated. The number of wells and pumping rates will be refined during
remedial design.
Air stripping will remove VOCs from the ground water. The existing Area 18
treatment plant will be used to treat the water removed by the wells and/or
trenches. Catalytic oxidation will destroy VOCs in the offgas.
Institutional controls will be implemented to restrict future uses of the site to
industrial uses and to prevent the use of untreated ground water extracted onsite.
Institutional controls will include: (1) issuing a continuing order (by the
Installation Commander) to restrict or place limitations on installation of any new
ground water wells on LCAAP property; (2) filing a notice in environmental and
real estate records at the Installation, detailing the restrictions of the continuing
order and ground water well restrictions; and (3) compliance with the provisions
of CERCLA Section 120(h)(3) or other applicable statutory requirements in the
event of property transfer.
• Long-term ground water monitoring for VOCs, to detect potential movement of
contaminants in the ground water and to determine the effectiveness of the
~~~ 2^33 February 1998
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Final Record of [Vision Area 18 Operable Unit
Lake dry Army Ammitnim n Plant. Independence. Missouri
alternative will be implemented. Monitoring will be conducted at a frequency
sufficient to verify that contaminants above MCLs are not moving beyond the
Installation boundary. As part of the long term ground water monitoring, 12 new
monitoring wells have been installed within and at the edge of the VOC plume (4
each in HSU1. HSU2-intermediate, and HSU2-deep). Installation of additional
monitoring wells and monitoring of existing wells, which may include off-Post
residential wells, for VOCs may be required to monitor system performance. This
will be specified as a component of the long-term ground water monitoring plan
developed during remedial design.
Monitoring of the treatment system effluent will continue to be conducted to
verify effectiveness of treatment. Weekly monitoring of the effluent is currently
conducted as part of the LBVSD pretreatment requirements.
The ground water remediation system will be operated until RGs have been met
for four consecutive quarters. Once this occurs, the ground water extraction
system will be shut down and the ground water will be monitored for four
additional quarters to verify the effectiveness of the treatment.
This alternative can be installed and in operation within 12-18 months; however,
based on ground water modeling, it may take in excess of 50 years to achieve
MCLs hi onsite ground water. Ground water containing contaminants above
MCLs will be contained onsite.
Maior ARARs.
This alternative will meet chemical-specific ARARs for ground water, specifically
MCLs established under the Safe Drinking Water Act and State of Missouri
ground water quality standards will be met at the Installation boundary. Ground
water modeling conducted during the FS indicated that ground water treatment
may require in excess of 50 years to achieve MCLs. Ground water containing
contaminants above MCLs will be contained onsite. Ah- emissions from the
stripper and catalytic oxidation unit will meet Clean Air Act and State of Missouri
Air Quality Standards. Major action-specific and location specific ARARs are
summarized in Appendix D. This alternative will meet RGs for ground water at
Area 18.
Alternative GW-1: No Action
The No Action Alternative is presented as a baseline to which other remedial
measures are compared. The National Contingency Plan (NCP) requires that the
No Action Alternative option be examined in detail during the remedial
alternatives evaluation phase. Under this alternative, no treatment or containment
of contaminated ground water would be conducted and no institutional controls
would be placed on future ground water use.
2-34 February 1998
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Final Record of Decision Area 18 Operable L'nit
Lake City Army Ammunition Plant. Independence. Missouri
Alternative GW-2: Limited Ground Water Extraction/Ground Water Monitoring/Point-
of-Use Treatment
Description
Alternative GW-2 addresses contaminated ground water at Area 18. Contaminated
ground water would be removed from the ground water using existing water supply well
17-FF. As with Alternative GW-4, removed ground water would be treated using the
existing Area 18 air stripper equipped with catalytic oxidation offgas treatment. Point-of-
use treatment would be used for offsite residents if, in the future, it is determined that
ground water contaminants have moved offsite and are contaminating offsite resident's
drinking water. At the present time, there is no indication that ground water
contamination from Area 18 has moved beyond the Installation boundary. The following
major components make Alternative GW-2:
Continued use of production well 17 FF to contain ground water onsite.
• Treatment of extracted ground water using the existing Area 18 air stripper.
• Treatment of offgasses from the air stripper using catalytic oxidation to destroy
VOCs.
Implementing a point-of-use treatment system, as necessary, if future offsite
resident's drinking water wells become contaminated with ground water
contaminants from Area 18.
Discharge of treated ground water to the LBVSD. Ground water would be treated
to meet LBVSD discharge requirements.
Treatment and Engineering Components
Continue operation of well 17-FF for use in ground water remediation; however,
the well would no longer be used as a water supply well. It is estimated that 17-
FF would initially be pumped at approximately 90 gpm; however, the rate would
be adjusted to optimize the ratio of contaminant extraction to ground water
extraction. Continued operation of well 17-FF would reduce the offsite
movement of contaminated ground water; however, ground water modeling
conducted during the FS indicates that operation of well 17-FF alone likely would
not totally prevent offsite movement of contaminated ground water.
The existing Area 18 treatment plant would be used to treat extracted ground
water as described under Alternative GW-4.
2-35 February 1998
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Final Record of Decision Area 18 Operable Unit
Lake City Army Ammunition Plant. Independence. Missouri
General Components
Extraction well 17-FF would address current and potential future risk associated
with VOCs in the ground water; however, operation of well 17-FF alone would
likely not prevent the offsite migration of contaminated ground water. "Therefore.
there would be some residual risk from remaining VOCs in the ground
The operating rate of the well would be adjusted to minimize the amount of water
treated at any one time and reduce the potential for smearing contaminants
between the NECOU and Area 18. The well would be operated until RGs are
achieved or until no further benefit can be achieved by operation of this well
alone, at which time a review of the remedy would be required.
• The same institutional controls would be implemented as under Alternative
GW-4.
Monitoring would be conducted at a frequency sufficient to verify that
contaminants above RGs are not migrating beyond the Installation boundary.
Monitoring of intermediate and deep wells along the boundary and off-Post for
VOCs, explosives, and metals to detect potential offsite migration of
contaminants in ground water. Specific locations for monitoring ground water
would be determined during the remedial design.
• If VOC contamination in ground water is detected in off-Post wells, a point-ci-u^e
treatment program would be implemented for offsite consumers who use ground
water extracted from those areas potentially impacted by contaminants from Area
18. Off-Post residential wells requiring point-of-use treatment (e.g., a single
point-of-use air stripping unit) would be outfitted as required.
• Implement a point-of-use treatment system monitoring plan to verify the
effectiveness of the systems and ensure effectiveness of the point-of-use treatment
system(s). Sampling for VOCs would be conducted on a quarterly basis or other
interval sufficient to verify that the point-of-use treatment systems remain
effective.
This alternative could be implemented using standard methods and equipment that
are readily available. Existing ground water wells could be used to detect
potential contaminant migration. Offsite point-of-use treatment systems are
readily available. Successful implementation would be evaluated and monitored
with an effective operations and maintenance (O&M) program of the system to
ensure consumed ground water is below MCLs.
Major ARARs
This alternative would not meet chemical-specific ARARs for ground water,
specifically MCLs established under the Safe Drinking Water Act and State of
2-36February 1998
-------
Final Record of Decision Area 18 Operable L'nir
Lake City Army Ammunition Plant. Independence. Missouri
Missouri ground water quality standards. Ground water modeling conducted
during the FS indicated that chemicals in the ground water will remain above
MCLs and continue to migrate both on-Post and off-Post under the existing
pumping scenario. Major action-specific and location specific ARARs are
summarized in Appendix D.
Alternative GW-3; Extraction Wells/Air Stripping/Catalytic Oxidation/Discharge
Description
Alternative GW-3 is the same as that for GW-4 (above), except that the shallow ground
water wells in the source area have been deleted. The containment wells (17-FF and EW-
1) would be used to intercept contaminants as they move from the source areas. The
components of this alternative have been implemented in accordance with the June 1995
Action Memorandum.
Treatment and Engineering Components
Continued operation of EW-1 as described in Alternative GW-4.
• Continue operation of well 17-FF for use in ground water remediation as
described in Alternative GW-4.
Treatment of extracted ground water as described in Alternative GW-4.
Discharge of treated ground water as described in Alternative GW-4.
General Component^
Risk from exposure to VOCs in the ground water would be eliminated by
removing and treating contaminated ground water before it moves offsite. The
remediation time for this alternative would be longer than for Alternative GW-4
since no source area wells/trenches would be used.
• Institutional controls as described in Alternative GW-4 would be implemented.
Long-term ground water monitoring for VOCs, to detect potential movement of
contaminants in the ground water and to determine the effectiveness of the
alternative would be implemented. The same as described in Alternative GW-4.
Monitoring and shutdown of the treatment system as described in Alternative
GW-4.
2-37 February 1998
-------
Final Record of Decision Area 18 Operable Unit
Lake City Army Ammunition Plant, inaependence. Vfissouri
Maior ARARs
This alternative would meet chemical-specific ARARs for ground water.
specifically MCLs established under the Safe Drinking Water Act and State of
Missouri ground water quality standards would be met at the Installation
boundary. Ground water modeling conducted during the FS indicated that ground
water treatment may require in excess of 50 years to achieve MCLs; ground water
containing contaminants above MCLs would be contained onsite. Air emissions
from the stripper and catalytic oxidation unit would meet Clean Air Act and State
of Missouri Air Quality Standards. Major action-specific and location specific
ARARs are summarized in Appendix D. This alternative would meet RGs for
ground water at Area 18.
2.8 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The RAOs for the Area 18 OU as established in the Area 18 FS are:
Prevent human contact with soil with lead concentration greater than 1,000 ppm.
Prohibit agricultural (e.g., cattle grazing) and other non-industrial uses at Area 18.
Prevent future industrial workers from inhaling VOCs from surface soil.
Reduce ecological receptor risk from exposure to metals in surface soil.
Prevent ingestion and dermal contact (future workers) with onsite ground water
above regulatory standards.
Prevent ground water contaminated above regulatory standards from migrating off
the Installation.
Minimize contaminant migration from soil to ground water.
Pursuant to Section 300.430(e)(9)(iii) of the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), the remedial action to be implemented should be selected based upon
consideration of nine evaluation criteria. These criteria are as follows:
Threshold Criteria
1. Overall protection of human health and environment.
2. Compliance with applicable or relevant and appropriate requirements (ARARs).
Primary Balancing Criteria
3. Long-term effectiveness and permanence.
4. Reduction of toxicity, mobility, or volume of contamination.
5. Short-term effectiveness.
6. Implementability.
7. Cost.
2-38 February 1998
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Final Record of Decision Area /•? Operadie C nil
Lake City Army Ammunition Plant. Independence. Missouri
Modifying Criteria
8. State acceptance.
9. Community acceptance.
The following sections provide a brief review and comparison of the remedial alternatives
according to EPA's evaluation criteria.
2.8.1 Overall Protection of Human Health and the Environment
This criterion considers whether a remedy provides adequate protection and describes how risks
are mitigated through treatment, engineering, or institutional controls.
Soil
Alternative SA-1 does nothing to reduce risk levels associated with exposure to VOCs and
metals in soil at Area 18. Alternative SA-2 would contain VOC and lead-contaminated soil.
eliminating exposure to human and ecological receptors; however, since the waste is managed in-
place and waste is present below the water table, SA-2 does not provide the level of protection
that other alternatives do. Alternatives SA-3, 5, and 6 provide a similar level of protection of
human health and the environment through removal and treatment of contaminated soil, with
each alternative utilizing excavation and ex-situ treatment of contaminants. SA-5 specifies
offsite management of wastes. The selected Alternative, SA-7, utilizes an in situ MPVE system
to extract contaminants from soil with an onsite treatment system to treat extracted vapors and
ground water. Pilot study tests have shown that Alternative SA-7 may be able to extract
contaminants in soils from greater depths below the surface than can practically be attained with
the other alternatives involving excavation and ex-situ treatment. Alternatives SA-2 through SA-
8 all significantly reduce ecological risks from exposure to contaminants in surface soil. All
alternatives except SA-1 use institutional controls to prevent cattle grazing (and other agricultural
uses) and to restrict land use to uses compatible with the alternatives.
In conjunction with selected ground water Alternative, GW-4, Alternative SA-7 provides the
potential for the highest degree of source removal among the soil alternatives considered and will
achieve RGsi
Ground Water
Alternative GW-1 is the No Action Alternative and does not provide protection of human health
and the environment. Alternative GW-2 would reduce the quantity of contaminated ground
water in the dissolved phased by continued operation of existing well 17-FF. Alternative GW-2
does not provide for containment of the Area 18 ground water plume and would allow
contaminated ground water at levels exceeding MCLs to migrate beyond the LCAAP boundary.
Alternative GW-2 does not provide for remediation of the plume onsite to levels below MCLs.
Alternatives GW-3 and GW-4 both provide protection by extracting and treating ground water so
that MCLs can be met at the Installation boundary. Alternative GW-3 provides for containment
2-39 February 1998
-------
Final flee -.rd of Decision Area IB Operable Unit
Lake City Army Arnmur..!, .^:^m. Independence. Missour,
of the existing Area 18 ground water contaminant plume within its existing limits but does not
attempt to address shallow ground water in proximity to sources. In addkfonTo con^ ntem
2.8.2 Compliance with ARARs
Alternatives are evaluated under this criterion to assess compliance with ARARs
requirements mclude cleanup standards, standards of control and other subs^ve envent,
Relevant and appropriate requirements address problems or situations sufficientlv similar to
those encountered at a CERCLA site that their use is well suited to the environmenTaS
technical factors at a particular site. The determination of "relevant and appr^e" emohasizes
appropriateness of the requirement to a sit, ARARs
Chemical-Specific ARARs are health or risk-based numerical values or
methodologies which, when applied to site-specific conditions, result in
establishment of the amount or concentration that may be found in, or safely
discharged to, the environment. i,w*uciy
Location-Specific ARARs restrict the concentratic- ^hazardous substances or
the conduct of activities solely because they are in specific locatioi ...... *. as flood
plains, wetlands, historic places, and sensitive ecosystems or habitats.
"SPeCifiC ARAR? ** mUally technol°gy or" activity-based requirements or
itations on actions taken with respect to hazardous wastes.
A summary evaluation of Federal and State ARARs pertinent to this remedial action is provided
Soil
6Stablished for soil a< Area 18.
^ ""^ ^ Altemative SA'2 ^Hzes containment rather than
t •**.»»* would remain in-place
a1ta,T a?16Ved- AItemative S A'2 "q«i« ground water control as pan of
w teTt^ble ££?? ^ water MCLs since waste is managed in place and is present below
emSt; ^ H £ SA'3' 5' ^ 6 WOUld acWeVe Soil RGs to a de?th of 15 feet bgs.
alternatives use different treatment methods to achieve the RGs. Alternative SA-8 is similar
2-40 February 1998
-------
Final Record of Decision Area 18 Operable Unit
Lake City Army Ammunition Plant. Independence, Missouri
to Alternatives SA-3. 5. and 6, except that RGs are achieved only for soils above the water table.
which is approximately 7 feet bgs. Alternative SA-7 has the potential to achieve soil RGs to a
depth of nearly 30 feet bgs, and thus has the potential to remove a large amount of contaminant
mass from the soil. Technical review of the selected alternative will be conducted as specified in
Section 2.9 to determine the systems compliance with RGs.
Action and location-specific ARARs are similar for most of the alternatives. Appendix D lists
the action and location-specific ARARs for the various alternatives. Major action-specific
ARARs would include storm water management and Clean Air Act Amendments. Major
location-specific ARARs would include consideration of wetlands and floodplain management
requirements.
Ground Water
Alternatives GW-1 and GW-2 would not meet MCLs or State Ground Water Quality Standards
at the Installation boundary and would not prevent ground water contaminated with chemicals
above MCLs from moving beyond the Installation boundary. Alternatives GW-3. and GW-4
meet MCLs at the Installation boundary by preventing the movement of contaminated ground
water offsite. Under Alternatives GW-2, GW-3, and GW-4, extracted ground water would be
pre-treated to meet discharge requirements of the LBVSD. GW-3 and GW-4 would provide
containment of the existing plume and, in conjunction with the selected soil alternative, SA-7,
will ultimately remediate the-aquifer to MCLs within the Area 18 OU. If, due to site conditions
or technical limitations, it is not practical to remediate onsite ground water to levels below MCLs
a Technical Impractibility waiver could be evaluated.
2.83 Long-term Effectiveness and Permanence
This criterion considers the long-term effectiveness of alternatives in maintaining protection of
human health and the environment after response action objectives have been met.
Soil
All the alternatives, other than the No Action alternative, provide long-term effectiveness in
reducing potential risks associated with the soil. SA-2 is a less permanent solution than the other
alternatives because wastes are managed in-place, thus SA-2 would rely on effective operations
and maintenance of the containment system. Alternatives SA-3, SA-8 (Options 1 and 2b), and
selected Alternative SA-7 use destructive technologies to treat VOCs removed from the soil.
SA-7 incorporates an innovative technology and its ability to extract VOCs may vary according
to site geology. However, pilot studies at LCAAP have indicated effective mass removal for this
technology. Contaminated soil would be disposed of offsite (in a RCRA permitted facility)
under Alternatives SA-5 and SA-8 (Option 4) and may or may not be treated prior to disposal
depending on the classification of the soil (i.e., hazardous or nonhazardous) and the facility
requirements. Alternatives SA-6 and SA-8 (Options 2a) use media transfer to remediate
contaminated soil. Under Alternative SA-8, contaminated soil would be left below the water
table to be addressed by the selected ground water alternative.
" February 1998
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Final Record of Decision Area 18 Operable Unit
Lake City Army Ammunition rlam Independence. Missouri
Ground Water
Alternative GW-1 would not provide long-term effectiveness in reducing the potential for
movement of VOCs or meeting MCLs. GW-2 reduces the amount of contamination in around
water through extraction and treatment: however, the reduction is not sufficient to meet MCLs
within the plume, or to contain the plume within LCAAP boundaries. Both Alternatives GW-3
and GW-4 are effective in the long-term and provide permanent remedies for ground water at
Area 18. Each alternative would require intensive operations and maintenance. The selected
Alternative, GW-4, will incorporate a higher mass removal rate of contaminants in eround water
by specifying extraction wells in source areas. These are not included in other ground water
alternatives, and are expected to provide for remediation of the contaminant plume in a shorter
time than GW-3. A review (within 5-years) of the remedial alternative will be conducted to
evaluate the effectiveness and ability of the alternative to remediate the ground water to levels
below MCLs.
2.8.4 Reduction of Toxicity, Mobility, or Volume Through Treatment
This criterion considers the anticipated performance of specific treatment technologies an
alternative may employ.
Soil
Alternative SA-1 would not reduce toxicity, mobility, or volume of waste. Alternative SA-2
would use containment rather than treatment to address contaminants in the soil; therefore,
toxicity and volume of material would not be reduced. However, mobility of both the
contaminants in the soil (cover) and the ground water (barrier wall and extraction wells) would
be minimized. Alternatives SA-3, SA-8 (Option 1), and selected Alternative SA-7 all would
reduce the toxicity, mobility, volume, of contaminants through permanent, destructive treatment
Under Alternatives SA-6 and SA-8 (Option 2a), VOCs would be transferred from the soil to the
air and would not be treated. Contaminated soil under Alternative SA-5 would be disposed of
offsite. Under Alternative SA-8, contaminated soil would be left below the water table to be
addressed by the selected ground water alternative. Alternative SA-7 will offer the potential for
the largest permanent reduction in contaminant mass, as contaminant recovery from the soil
column may extend to 30 feet below grade. This is not practical for the excavation/ex situ
treatment alternatives considered. As stated in CERCLA §121(b), onsite treatment is preferred
relative to offsite disposal, containment, and media transfer.
Ground Water
Alternative GW-1 would not reduce toxicity, mobility, or volume of contaminated ground water
Alternatives GW-2, GW-3, and selected Alternative GW-4 would reduce the toxicity, mobility,
and volume of contaminated ground water through extraction and treatment. Selected
Alternative GW-4 will provide the highest level of reduction by incorporating source area ground
water extraction wells into the alternative.
2-42 February 1998
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Final Record of Decision Area 18 Operable L 'mi
Lake City Army Ammunition Plant. Independence. Missouri
2.8.5 Short-term Effectiveness
This criterion considers the effectiveness of alternatives in maintaining protection of human
health and the environment during the construction of a remedy until remedial response
objectives have been met.
Soil
All alternatives other than the No Action alternative have the potential to expose onsite workers
and nearby persons to fugitive dust and incidental VOC emissions during construction, especially
during activities such as excavation and consolidation of contaminated material. Alternatives
SA-2 and SA-7 would pose less exposure risk of this type because excavation of VOC-
contaminated soil would not be required. Alternatives SA-3, 6, 7, and 8 (Option 1, 2a. and 2b)
would require air emission monitoring to ensure that VOC emissions would remain within
acceptable levels. Personal protective equipment and engineering controls could be use to
mitigate potential worker exposures. Overall, selected Alternative SA-7 will provide the highest
level of short-term effectiveness because VOC-contaminated soil will be addressed in situ and
will not cause significant releases to the atmosphere during handling. Alternatives SA-2 and SA-
5 would require 6-9 months to install. SA-3 and SA-7 would require 12-18 months, and SA-6
would require 24 months to .install. The implementation time of Alternative SA-8 would vary
according to the treatment technology selected, but would require less time than other
alternatives specifying similar treatment approaches.
Ground Water
The No Action Alternative and Alternative GW-2 would not present short-term risk to workers
or nearby residents from construction activities since no new remedial measures would be
constructed or installed. However, GW-2 would not prevent ground water containing chemicals
above MCLs from moving off-Post. In general, short term threats associated with the
implementation of alternatives GW-3 and GW-4 would be similar and would be addressed by the
use of appropriate personal protective equipment for construction personnel. It is not anticipated
that LC AAP workers or nearby residents would be exposed to site related contaminants during
construction of either of these alternatives.
2.8.6 Impiementability
This criterion considers the administrative and technical feasibility of implementing the
alternatives and the availability of necessary goods and services for implementation of the
response action.
Soil
There are no implementability concerns for Alternative SA-1. Alternative SA-2 would require a
predesign study to determine compatibility of the barrier wall material and contaminants in the
soil. SA-2 would be difficult to implement because the depth of the barrier wall required (90-
2-43 February 1998
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Final Record of Decision Area IS Operable L'nit
Lake dry Army Ammunition Plant. Independence. Missouri
100 feet) is beyond the depth where standard construction methods can be used. Alternatives
SA-3. 6. and 7 and the associated options under Alternative SA-8 would require treatability
studies to determine optimum operational parameters. Alternative SA-3 could be the most
difficult of these alternatives to implement due to administrative issues in siting an LTTD
treatment unit. Alternative SA-6 may require air controls that would make it more difficult to
implement. Alternative SA-5 would require hauling waste offsite and complying with DOT
requirements. Selected Alternative SA-7 will require phasing during implementation for the
removal of lead, cover placement, and MPVE installation.
Ground Water
Institutional controls would be implemented for all alternatives other than No Action. There
would be no active measures to implement under alternatives GW-1 and GW-? Alternatives
GW-3 and GW-4 would be equally implementable, the only difference being the installation of
shallow wells and/or trenches as part of GW-4. The ground water treatment plant, a significant
element of both GW-3 and GW-4 is already constructed and operational.
2.8.7 Cost
This criterion considers the capital and O&M costs associated with each of the alternatives
Costs were developed using Means Building Cost Index, vendor estimates, and contractor
experience. Alternatives are evaluated for cost in terms of both capital costs and long-term
O&M costs necessary to insure continued effectiveness of the alternatives. Capital costs include
the sum of the direct capital costs (materials and labor) and indirect capital costs (engineering
licenses, permits). Long-term O&M costs include labor, materials, energy, equipment
replacement, disposal, and sampling necessary to ensure the future effectiveness of the
alternative.
The objective of the cost analysis is to evaluate each of the alternatives based on their ability to
protect human health and the environment for additional costs that may be incurred. Costs vary
between the alternatives as a result of differences in the amount of materials and the level of
effort required for each alternative. The least costly alternatives for both soil and ground water
alternatives are the No Action alternatives.
The following cost tables provide a summary of expected costs for soil and ground water
alternatives. The detailed cost basis is provided in the FS and Administrative Record. As
summarized in Section 2.11, Documentation of Significant Changes, the costs for the selected
soil alternative increased from those presented in the Proposed Plan. The cost increase is a result
of FFA parties agreeing on lead management protocol for Area 18 and a decision to install the
vapor extraction system to deeper soil depths. The cost increase is offset by the enhancement of
mass removal at deeper soil depths (30 feet as opposed to 10 feet bgs) and keeps the selected
alternative competitive when compared to other options.
2~44 February 1998
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Final Record of Decision Area fS Operable L 'nil
Lake City Army Ammunition Plant. Independence. Missouri
Alternative SA-I (No Action)
Total Capital Costs
30- Year Present Value for Annual Costs
Annual Cost = SO
Years = 30
Discount Rate = 5%
TOTAL 30- Year Present Value
SO
SO
so
Alternative SA-2 (Multi-Layer Cover and Vertical Barriers)
Total Capital Costs
30- Year Present Value for Annual Costs
Annual Cost = SI 22,000
Years = 30
Discount Rate = 5%
TOTAL 30- Year Present Value
Alternative SA-3 (Onsite Low Temperature Thermal Desorption)
Total Capital Costs
30- Year Present Value for Annual Costs
Annual Cost = S5,000
Years = 30
Discount Rate = 5%
TOTAL 30- Year Present Value
54.250,000
SI, 875. 000
56,125,000
$10,130,000
577,000
510,210,000
2-45
February 1998
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Final Record of Decision Area !8 Operable Unit
Lake City Arrm.'Ammwti.cx P'inc. Indf.-f-. i^nce.'Missouri
Alternative SA-S (Excavation and Offsite Treatment and Disposal)
Total Capital Costs
S25.700.000
30-Year Present Value for Annual Costs
S5.000
Years = 30
Discount Rate = 5%
TOTAL 30-Year Present Value
S77.000
525,780,000
Alternative SA-6 (Excavation and Ex-Stiu Landfarming)
Total Capital Costs Option 1
Option 2
S4,690,000
S9.040.000
30-Year Present Value for Annual Costs (same for Option 1 and 2)
Annual Cost = 55,000
Years = 30
Discount Rate = 5%
TOTAL 30-Year Present Value Option 1
Option 2
Alternative SA-7 (Soil Vapor Extraction and Treatment)
577,000
$4,770,000
$9,120,000
Total Capital Costs
$3.210,000
30-Year Present Value for Annual Costs (same for Option 1 and 2)
Annual Cost for Cover Portion = $4,600
Years = 30
Annual Cost for MPVE System = $647,500
Years = 5
Discount Rate = 5%
$2,874.000
TOTAL 30-Year Present Value
56,084,000
Alternative SA-8 (Selective Excavation/Treatment or Disposal)
Total Capital Costs Option 1
Option 2a
Option 2b
Option 3
$4,150,000
51,920.000
$5,490,000
$10,690.000
30-Year Present Value for Annual Costs (same for all options)
Annual Cost = $5,000
Years = 30
Discount Rate = 5%
$77,000
TOTAL 30-Year Present Value Option 1
Option 2a
Option 2b
Option 3
$4427,000
$1,997,000
$5,567,000
$10,767,000
2-46
February 1998
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Final Record of Decision Area 18 Operable Unit
Lake City Army Ammunition Plant. Independence. Missouri
Ground Water
Alternative GW-I (No Action)
Total Capital Costs
30- Year Present Value for Annual Costs
Annual Cost = SO
Years = 30
Discount Rate = 5%
TOTAL 30-Year Present Value
SO
SO
so
Alternative GW- 2 (Limited Ground Water Extraction/Ground Water Monitoring/Point-of-Use
Treatment)
Total Capital Costs
30- Year Present Value for Annual Costs
Annual Cost = S 1 19,300
Years = 30
Discount Rate = 5%
TOTAL 30- Year Present Value
$12.000
SI, 834,000
51,846,000
Alternative GW-3 (Extraction Wells/Air Stripping/Catalytic Oxidation/Discharge)
Total Capital Costs
30- Year Present Value for Annual Costs
Annual Cost - Years 1 -5= $636,000
Annual Cost - Years 6-30=5580,000
Years = 30
Discount Rate = 5%
TOTAL 30- Year Present Value
$3,637,000
$1,474,000
512,800,000
Alternative GW-4 (Extraction Wells (One Deep and Four Shallow) Air Stripping/Catalytic
Oxidation/Discharge)
Total Capital Costs
30- Year Present Value for Annual Costs
Annual Cost = $691,500
Years = 30
Discount Rate = 5%
TOTAL 30- Year Present Value
S4.01 1.000
$10,622,000
514,630,000
2-47
February 1998
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Final Record of Decision Area 18 Operable L'mt
Lake City Army Ammunition Plant. Independence. Missouri
2.8.8 Regulatory Acceptance
This criterion considers the support agencies preferences or concerns about the alternatives.
EPA and the State concur with the selected remedy, SA-7 and GW-4. as evidenced by their
review comments and acceptance of the RI/FS and Proposed Plan.
2.8.9 Community Acceptance
Comments offered by the public were used to assess whether the proposed alternative was
acceptable to the community. The Army received no written comments during the public
comment period of 14 April 1997 through 14 May 1997. Questions were posed to the Army
regarding the selected remedy during the public meeting held on 22 April 1997. There were no
objections to the selected remedial alternative expressed at the meeting. Questions about the
remedy posed during the public meeting appeared to be satisfactorily addressed during the
meeting. The questions and concerns of the community are discussed in the Responsiveness
Summary, which is Appendix E of the ROD. Based on the nature of the public response, the
remedy described in the Proposed Plan is acceptable to the community.
2.9 SELECTED ALTERNATIVE
Based on the requirements of CERCLA, comparative analysis using the nine criteria, public
comments, and in consultation with EPA and the State, the Army has determined that the
selected alternative for the Area 18 OU is Soil Alternative SA-7 (Soil Vapor Extraction and
Treatment) in combination with Ground Water Alternative GW-4 (Ground Water Extraction and
Treatment). The selected remedies meet the RAOs for the Area 18 OU which are:
Prevent human contact with soil with lead concentration greater than 1,000 ppm.
• Prohibit agricultural (e.g., cattle grazing) and other non-industrial uses at Area 18.
Prevent future industrial workers from inhaling VOCs from surface soil.
Reduce ecological receptor risk from exposure to metals in surface soil.
• Prevent ingestion and dermal contact (future workers) with onsite ground water
above regulatory standards.
• Prevent ground water contaminated above regulatory standards from migrating off
the Installation.
• Minimize contaminant migration from soil to ground water.
The selected remedies meet these objectives through a combination of treatment of principal
threat wastes, excavation or containment of low-level threat wastes, and institutional controls
restricting land and ground water use.
Major components of Alternative SA-7 for Soil are:
• In areas where surface soil lead concentrations are above 1 ?000 ppm and VOCs
are present in the soil at concentrations below the RG of 10 ppm, soil will be
2-48
February 1998
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Final Record of Decision Area 18 Operable Unit
Lake dry- Army Ammunition Plant. Independence. Missouri
excavated to a maximum depth of 2 feet and disposed of in an approved
repository.
Installation of a 24-inch thick vegetated soil cover over soil containing VOCs at
concentrations exceeding 10 ppm.
Install an in situ MPVE system to remove VOC mass from the soil that exceeds
RGs and minimize exposure to VOC contamination in the surface soils.
Onsite treatment of vapor extracted from the MPVE wells using thermal/catalytic
oxidation, a vapor phase carbon adsorption unit, or other technology determined
during remedial design.
Onsite treatment of ground water extracted from the system and discharged at
levels meeting LBVSD discharge limitations.
Restore any excavations to grade to promote positive drainage.
Institutional controls.
Long-term monitoring.
Cost to implement SA-7: Capital Cost of $3,210,000 (based on estimate provided
by US ACE) and O&M Cost of $674,500 per year for 5 years (the maximum
expected duration of MPVE) for the MPVE system and $71,000 per year for 30
years for maintenance of the cover. Estimated total 30-year present worth cost is
$6,084,000.
and Earth Cover over Lead and VOC-contaminated Soil
Surface soil (0-2 feet) containing lead above cleanup levels (1,000 ppm) will be excavated and
disposed of in an approved repository unless it is collocated in an area with VOCs present in the
surface soil above the 10 ppm VOC RG. In the areas where lead is collocated with VOCs
exceeding RGs and MPVE will be implemented, lead above 1,000 ppm will be managed onsite
beneath a 2-foot soil cover as described below. Excavated areas will be restored to grade. A
predesign study will further refine the lead-contaminated areas to be excavated.
Areas with VOCs exceeding 10 ppm will be remediated using a MPVE system. Prior to
installation of the system, a 2-foot vegetated soil cover will be placed over these areas to enhance
performance of the MPVE system by minimizing potential short circuiting of soil vapors. The
soil cover will also eliminate exposure to lead in surface soils that is collocated with VOCs
exceeding 10 ppm.
2-49 February 1998
-------
Final Record of Decision Area 18 Operable L'mt
Lake City Army Ammunition Plan:. Independence. Missouri
MPVE
MPVE will be implemented in all areas where VOCs in soil exceeds the RG of 10 ppm. The
MPVE system is a multi-phase system that will extract contaminant vapors from the soil as well
as ground water from the pore spaces of the contaminated soil. A key element of the multi-phase
system is the extraction of shallow ground water to depress the water table and allow extraction
of vapor phase contaminants from soils to a greater depth. A pre-remedial design evaluation
acceptable to the Army, EPA, and State of Missouri will be performed to determine the final
number and location of extraction wells required to remediate the soil. Based on the results of
the predesign study, multi-phase SVE wells will be located to remove vapors and shallow ground
water contaminated with VOCs.
SVE technology is both an innovative and presumptive in situ remedial technology for treatment
of VOC-contammated soil. Closure criteria are difficult to establish before full-scale operation
of the system is implemented. Although pilot testing of the system suggests rapid mass removal
a monitoring program must be developed and implemented during the remedia! ctionto
evaluate long-term removal rates. An O&M plan will be developed for operation of the SVE
system consistent with the FFA terms. The O&M program will include development of standard
operating procedures (SOPs) to provide for monitoring, inspections, repairs, and system
shutdown. It will be subject to the approval of the FFA parties and the data will be used by the
FFA parties as a decision point for terminating or continuing operation of the system.
Semiannual technical reviews will accommodate the development of appropriate criteria for
measuring performance and shutting down the system. SVE system performance data will be
made available to the FFA parties for evaluation at a minimum of six months after the system
begins operation. Criteria will include, but not be limited to, evaluation of mass recovery rates
cost-effectiveness, and reduction of soil contamination levels. System operation will be
determined based on the evaluation of these criteria. As full-scale performance data is collected
information on physical limitations of the site and the benefits of this mass removal system will '
be better developed and used to determine continued operation of the system. System
enhancements (e.g., soil fracturing or horizontal well installation) will be evaluated prior to
system shut down. Termination of the system will occur only with the approval of the FFA
parties.
Treatment of Extracted Vapors and Pound Water
Vapors removed by the MPVE system will be treated to meet ARARs. Extracted ground water
will be treated to meet LBVSD pre-treatment discharge limitations.
Institutional Controls and Monitoring
Institutional controls will be implemented to restrict future uses of the site to industrial uses,
preventing the use of the site for cattle grazing, other agricultural activities, and construction of
residential housing. Institutional controls would include: (1) issuing a continuing order to restrict
2-50 February 1998
-------
Final Record of Decision Area fS Opera&fe C'ntl
Lake City Army Ammunition Plant. Independence. Missouri
onsite worker access to contaminated soil: (2) filing a notice to the deed detailing the restrictions
of the continuing order; and (3) a covenant to the deed in the event of property transfer.
Monitoring of the treatment systems will be conducted to ensure that treatment goals are being
met and that air emissions do not exceed acceptable levels.
Major components of the Ground Water Alternative are:
Continued operation of a ground water extraction well (EW-1) in HSU2. This
well was installed as a component of the 1995 removal action.
Continued operation of well 17-FF for use in ground water remediation.
Installation of shallow ground water extraction wells or ground water extraction
trenches in the vicinity of the source area. For cost purposes, it is estimated that
four shallow extraction wells will be required; however, the final number will be
determined during remedial design
• Onsite treatment of extracted ground water using an air stripping unit equipped
with catalytic oxidation off-gas treatment. This treatment plant has been
constructed as a part of the removal action and is currently operational.
Discharge of treated ground water to the LBVSD at levels at or below established
limits. The current limits are presented in Appendix C.
• Quarterly monitoring of the treatment system effluent.
Institutional controls.
Long-term ground water monitoring for VOCs to evaluate the performance of the
ground water remediation system. Monitoring will be conducted to evaluate
possible plume migration beyond its currently understood boundaries, and to
evaluate remediation of the plume within the area known to be contaminated.
Cost to implement GW-4: Capital Cost of $4,011,000 and O&M Cost of $691,500
per year for 30 years. Estimated total 30-year present worth cost is $14,630,000.
Ground Water Extraction. Treatment, and Discharge
Ground water will be removed using system components implemented as part of the removal
action at Area 18. EW-1 is expected to be operated at approximately 380 gprn, 17-FF at 90 gpm,
and the four shallow wells at an aggregate rate of 50 gpm. Actual pumping rates will be
Determined using capture zone data once the system is operational. The system will be adjusted
to operate so the minimum amount of ground water can be removed and treated while still
2-51 February 1998
-------
Final Record uf Decision Area IS Operable I' nit
Lake dry Army Ammunition Flam. Independence. Missouri
containing the VOC plume within the Installation boundary. Well I7-FF will no longer be used
as a water supply well and will solely be used for ground water remediation.
Removed ground water will be treated using an onsite air stripper equipped with off *as
T^rf pSfflg a ^^u °Xidati°n Unit' Treat£d «I*und water ^ be discharged to the
LB VSD. Effluent from the treatment system is currently monitored weekly to insure that
treatment goals are being met. Effluent monitoring will continue at intervals sufficient to
determine if treatment goals are being met. Ground water will be extracted and treated so RGs
(MCLs) will be met at the Installation boundary. MCLs may be met throughout Area 18
however, due to site conditions and technical limitations it may not be practical to meet MCLs
onsite, particularly in the tight soils in the source area.
Institution^ Contrnk
to nr i" ^ !mPlemented to restric< figure uses of the site to industrial uses and
o prevent the use of untreated ground water extracted from contaminated areas within Area *T
£S5S£ T^ S WiU indUde: h(1 } ISSUing a C°ntinUing °rder <*** Installation Co^ndt)
to restrict or place limitations on the installation of any new ground water supply wells- (2) filing
a notice m environmental and real estate records at the Installation, detailing Ae restriciions of
rtC~i:^ T20^d "T We" r^011* "ld (3) —P'^-with the provSoi
framfer ' " aPPIicable statutorv requirements in the event of property
Long-term Monitoring
A long-term monitoring program will be developed and implemented as a component of the
miff 3CT 1S f,UuJeCt t0 aPPr°Val °f ^ EPA «* ™MR' Contaminant concentrations
o dlteSTe X \ m°nii°red t0 6ValUate ^ effectivene^ <>f ^ remediation svstem and
o determine if contaminants in the ground water are migrating beyond the capture zone of the
remediation system. If ,t» determined that contaminants in the ground water are moving offsite
modifications to ihe remediation system will be implemented to ensure effective plume
containment within LCAAP boundaries.
revie^.wjI1|be conduc*d to evaluate the effectiveness of the remediation system.
RGs and the remedial alternative will be reevaluated at that time to ensure that the system is
L UV?y ^ effidently " P08^16' Long-teim monitoring will continue until
of Missouri Ground-Water Quality Standards and Federal MCLs are met.
2.10 STATUTORY DETERMINATIONS
In accordance with the statutory requirements of Section 121 of CERCLA. remedial actions that
are selected are required to:
Protect human health and the environment
2-52 February 1998
-------
Final Record of Decision Area }3 Operable L wr
Lake Cin-Army Ammunition Plant. Independence. Missouri
Comply with applicable or relevant and appropriate requirements (ARARs)
Be cost effective
Use permanent solutions and alternative treatment technologies to the maximum
extent practicable
Satisfy the preference for treatment that reduces contaminant toxicity. mobility, or
volume as a principal element
The manner in which the Area 18 remedial action satisfies the above requirements is discussed in
the following sections.
The selected remedy will be reviewed, at a minimum, every five years as specified in CERCLA
121(c) because hazardous substances will remain on-site after the remedy is implemented.
2.10.1 Protection of Human Health and the Environment
Soil
The selected remedy addresses health and environmental issues that were identified in the Area
18 OU RI and Baseline Risk-Assessment. Specifically, the soil vapor extraction and treatment
alternative:
Eliminates exposure to lead (above 1 ,000 ppm) and other metals and VOCs in the
surface soil by excavating, disposing, and/or constructing a cover over these soils.
Reduces the volume of VOCs in the subsurface soil which may ultimately migrate
to ground water.
Uses institutional controls to prevent agricultural and other non-industrial uses of
the site.
The selected soil remedy will meet remedial action objectives for soil and reduce and maintain'
cumulative risk within the 10" to 1Q-* risk range.
Ground Water
The selected remedy addresses health and environmental issues that were identified in the Area
18 OU RI and Baseline Risk Assessment. Specifically, the ground water extraction and
treatment alternative:
Reduces potential exposures to off-Post receptors by containing contaminated
ground water at levels exceeding MCLs within LC AAP boundaries.
2-53 February 1998
-------
Final Record of Decision Area 18 Operable Unit
Lake City Army Ammunition Plant. Independence. Missouri
Reduces risk by reducing the concentration of contaminants in the ground water to
levels below MCLs.
Prevents the use of untreated, contaminated ground water extracted from within
LCAAP boundaries.
Provides for long-term monitoring of ground water to identify potential future
risks associated with the Area 18 OU and to monitor the effectiveness of the
remedial action.
The selected ground water remedy will meet remedial action goals for ground water a^ - '
and maintain cumulative risk within the 1 Q-* to 1 0'6 risk range.
2.10.2 Compliance with ARARs
There are no chemical-specific ARARs for soil; however, RGs have been established for clean
up of soils in the Area 18 OU. Soil RGs are based on levels protective of ground water as
calculated using EPA's SUMMERS model and will be evaluated during technical reviews as to
their appropriateness. Alternative SA-7 will achieve significant mass reduction of VOCs in the
soil Action and location-specific ARARs will be met, including Clean Air Act and State air
quality requirements.
Alternative GW-4 will meet Safe Drinking Water Act MCLs and State Ground Water Quality
Standards at the Installation boundary and may meet MCLs in the vicinity of the source area
Uttgas emissions from air strippers will be treated to meet requirements of the Clean Air Act and
state air quality requirements. Action and location-specific ARARs will be met.
Additional information about ARAR compliance is contained in Section 2.8.2.
2.10.3 Cost Effectiveness
The selected remedy has been determined to provide overall effectiveness in reducing human
health risks relative to their costs.
Soil
The 30-year net present worth of Alternative SA-7 is $6,084,000. The estimated cost of the
selected remedy is similar to other alternatives, but achieves the best balance of risk reduction
and contaminant mass removal.
Ground
The net present worth of Alternative GW-4 is $14,630,000. The estimated costs of the selected
ground water remedy exceed the estimated costs associated with Alternative GW-3 by
2-54 February 1998
-------
Final Record of Decision Area IS Operable L nil
Lake City Army Ammunition Plant. Independence. Missouri
approximately SI.800.000: however. Alternative GW-4 provides for greater contaminant mass
removal and an anticipated shorter remediation time frame.
2.10.4 Utilization of Permanent Solutions and Alternative Treatment Technologies to the
Extent Possible
The selected remedy meets the statutory requirement to utilize permanent solutions and treatment
technologies to the maximum extent practical for the Area 18 OU. EPA has designated MPVE
(a variation of SVE) as a presumptive remedy for removal of VOCs in soil. Ground water
extraction and treatment systems have proven effective in remediating and containing
contaminated ground water. The selected remedy provides the best balance of tradeoffs among
alternatives which are both protective and ARAR-compliant relative to the five primary
balancing criteria: long-term effectiveness and permanence; reduction of toxicity, mobility, or
volume of contamination; short-term effectiveness; implementability; and cost. Section 2.8
provides a comparative analysis of these criteria relative to each alternative.
The use of MPVE, soil covers, and ground water extraction and containment provide the best
balance of contamination removal and cost effectiveness while maximizing reduction in site
risks.
The State accepts the selected remedy and has been involved with the RI and remedy selection
process. Concerns regarding the development of the alternatives were identified by the State and
have been adequately addressed.
Anticipated community concerns were addressed during the development of alternatives. During
the public comment period, the community did not identify any additional concerns for the
selected remedies.
A five-year review of the selected remedy will be performed since the selected remedy will
require an extended time frame to meet cleanup goals. The review will be conducted no less
often than every five years after commencement of the remedial action to insure that the remedy
continues to provide adequate protection of human health and the environment. During this
review, RGs and the selected alternative will be reevaluated to ensure that they remain
protective, provide a significant reduction in contamination, are cost effective, and are achievable
in a reasonable time frame.
2.10.5 Preference for Treatment as a Principal Element
The selected remedies for soil and ground water both provide treatment as their principal
element. Alternative SA-7 uses treatment and/or containment to address the principal threat
wastes (VOCs) in the soil in the surface impoundments, and excavation and/or containment to
address low level threat wastes (lead) in the surface soil at Area 18. GW-4 uses extraction and
treatment to address contaminants in the ground water. Institutional controls will be used for
short-term and long-term management of Area 18 to prevent exposure to principal and low level
threat wastes and to affected ground water.
2^55 February 1998
-------
Final Record of Decision Area 18 Operable Unit
Lake City Army Ammunition Plant. Independence. Missouri
2.11 DOCUMENTATION OF SIGNIFICANT CHANGES
The selected action is the same as the preferred alternative presented in the Proposed Plan for the
Area 18 OU remedial action. There have been changes relative to the Proposed Plan regarding
the handling of lead contaminated surface soil and the costs associated with the selected"
alternative.
The FFA parties agreed to a lead management protocol for Area 18 that specifically describes
how lead-contaminated soil and soil contaminated with both lead and VOCs will be addressed bv
the remedial action. The preferred alternative in the Proposed Plan indicates that lead
concentrations in surface soils greater than 1,000 ppm would be addressed by a soil cover and/or
excavauon/stabilization and disposal as appropriate. As discussed in the description of the
selected soil alternative, SA-7, lead-contaminated soil (0-2 ft) in excess of 1.000 ppm will be
excavated and disposed in an appropriate repository or managed under a soil cover if it is
collocated with soil containing VOCs in excess of 10 ppm.
The costs for the selected soil alternative increased from those presented in the Proposed Plan
The cost increase is a result of the modified lead management strategy and also by a decision to
install the vapor extraction system to greater soil depths. The capital cost for SA-7 was
estimated to be approximately $1.5 million in the proposed plan. The estimate of cost for SA-7
in this ROD is approximately $6.0 million. The cost increase is offset by the enhancement in
mass removal at greater soil depths (30 feet as opposed to 10 feet bgs). The increase in
performance keeps the selected alternative competitive when compared to other alternatives
2~56 February 1998
-------
Emal Record of Decision Area !8 Operable Lnit
Lake Cirv Army Ammunition Plant. Indeoendence. Missouri
AOC:
ARARs:
BLRA:
CERCLA:
COC:
DCE:
DNAPL:
EPA:
FFA:
GW:
HI:
HQ:
IRP:
IWOU:
IWTP:
LBVSD:
LCAAP:
LDR:
LTTD:
MCL:
MDNR:
ue/L:
mg/L:
MPVE:
NCP:
NECOU:
NPL:
O&M:
OU:
PCE:
ppm:
RAO:
RCRA:
RfD:
3.0 LIST OF ACRONYMS AND ABBREVIATIONS
Area of Concern
Applicable or Relevant and Appropriate Requirements
Baseline Risk Assessment
Comprehensive Environmental Response. Compensation and Liability Act
Chemical of Concern
Dichloroethene
Dense Non-Aqueous Phase Liquid
Environmental Protection Agency
Federal Facility Agreement
Ground Water
Hazard Index
Hazard Quotient
Installation Restoration Program
Installation-Wide Operable Unit
Industrial Wastewater Treatment Plant
Little Blue Valley Sewer District
Lake City Army Ammunition Plant
Land Disposal Restrictions
Low Temperature Thermal Desorption
Maximum Contaminant Level
Missouri Department of Natural Resources
Micrograms per liter
Milligrams per liter
Multi-Phase Vapor Extraction
National Oil and Hazardous Substances Contingency Plan
Northeast Corner Operable Unit
National Priorities List
Operations and Maintenance
Operable Unit
Perchloroethylene; liquids used in degreasing or paint removal.
Parts per million by weight
Remedial Action Objective
Resource Conservation and Recovery Act
Reference Dose
3-1
February 1998
-------
Final Record of Frisian Area 18 Operable L'ntt
Lake City Army Ammunition ,~,JW. Independence. Missouri
RG:
RI/FS:
RME:
ROD:
SA:
SARA:
SACM:
SF:
SVE:
SVOC:
TCA:
TCE:
TCLP:
VOC:
Remediation Goal
Remedial InvestigatioaTeasibility Study-
Reasonable Maximum Exposure
Record of Decision
Soil Alternative
Superfund Amendments and Reauthorization Act
Superfund Accelerated Cleanup Model
Slope Factor
Soil Vapor Extraction
Semivolatile Organic Compound
1.1,1,-tetrachloroethane
Trichloroethylene
Toxicity Characteristic Leaching Procedure
Volatile Organic Compound
3-2
February 1998
-------
Final Record of Decision Area 18 Operable Lnn
Lake dry Army Ammunition Plant. Independence, \fissourt
APPENDIX A
FIGURES
February 1998
-------
-------
I
JOWA _
MISSOURI
TO DES MOINES. IA
197 Ml.
NEBRASKA
KANSAS
KANSAS crrr. KS
KANSAS CITY, MO
INDEPENDENCE
N
TO TOPEKA, KS
61 Ml.
LAKE CITY
ARMY
AMMUNITION
PLANT
TO ST. LOUIS. MO
257 Ml.
TO SPRINGFIELD. MO
170 Ml.
— m
z^*
EA ENGINEERING.
SCIENCE. AND
TECHNOLOGY. INC.
DEPARTMENT OF THE ARMY
LCAAP
LAKE CHY, MISSOURI
REGIONAL LOCATION MAP
LCAAP - AREA 18 OU
UGR
GAT
DESIGNED BY
JDK
DRAWN fff
PMS
CHECKED BY
JDK
SCALE
NONE
DATE
DEC 97
PROJECT NO
60984.01
FIGURE NO.
t
-------
p/77 mrrrmnrtrn irirn mrn mrn
(HI HIIHIIIIIIIIIIIIIIIIIIIIIIIIII III
'//'tl IIII n H n n a H H H 11 a H H H ff //I
\lllllliiiiiiiiiiiiiiiih
LEGEND
/77-/ri
//>y^ COMMUNITY OF LAKE CIIY RESIDENCE
FK5URE.2 AREA 18 LOCATION MAP
-------
DRAWING NAME: f \PROJ\6D9840' \FlGURES\1 S-STC
DATE:27/1*^199T TIME'S:.!" DRAWN °":Ss
2]
O
c
^D
m
00
C/)
m
>
"D
-------
AOC 3 (SOLVENT PIT)
AOC 5 (LEAD CONTAMINATION)
AOC 2 (SOLVENT PIT)
AOC 0 (METALS CONTAMINATION)
AOC 4 (LEAD CONTAMINATION)
AOC 1 (SOLVENT PIT)
ta-udi^:
*/a->6 I °'«-
SHALLOW WELL
INTERMEDIATE WELL
DEEP WELL
BEDROCK WELL
AREA OF CONCERN
(AOC)
GROUND WATER
FLOW DIRECTION
AREA 18 BOUNDARY
DITCH
FIGURE 4 AREA 18 OU AREAS OF CONCERN
-------
H.UUC-
sour
FIGURE 5 AREAL EXTENT OF GROUND WATER CONTAMINAIION
-------
TOTAL VOJUUE Of SOB. • «0 **'
«CS OF COKTHMHtt f 24 to
CONCOffRWC* * 18 uj/g
SURFACE SOIL
CL 0-0.5'
VOUME OF CONlMMttTQ) SO*. * 2184 j
WSS OF CDMTWMUHr1it2S84 k
MMCE CONCOflRfinON * 1122 ug/j
TEST BORINGS
CL 0.5'-2.5'
VOUJHE OF OOmUMHOED SOL • 1300 ft'
HOS OF CONIAMNWr • 37M b
AWtMC CONCOniMTION » 825 u«/«
SUM OF TOTAL CHLORlNATEOl COMPOUNDS (ug/9):
TEST BORINGS
CL 2^'-5.0'
300'
-1'
300'
NO SIClNinCANT DATA HAS SEEN
COLLECTED BELOW 13 FEET BGS
DEPARTMENT OF THE ARMY
LCAAP
3CAL£
1" = 300'
VOC CONCENTRATIONS IN SOURCE AREA
SOILS (SOLVENT PITS) - SURFACE TO 5
WTE
DEC 97
|="iOj£cr MO
12422.08
-------
VOtUC OF CONTAUNnH) SOL • 1544 yd'
MASS OF COMMINMff • 2156 to
AVERMC CONCBnKATION « 465 09/9
TEST BORINGS
CL 5.0'-7.5'
VOLUME OF CONTMBWH) SOL • 1805 yd*
IMSS OF COOTMilMNT * 4312 »
AVERAGE CONCENnWIUN * 7M ug/g
TEST BORINGS
CL 7.5'-10.0'
voujic OF COMMWMCD SOL « uos
MASS OF COMMMWr « 300 b
MWOE COHCOfflMnON • 83 ug/g
SUM OF TOTAL CHUORWATED COMPOUNDS (ug/g):
1-10
10-100
100-1000
1000-10000
TEST BORINGS
a 10.0'-12.5*
3001
iOO'
AddHiono) 2050 lb«. at 12.5-15.0
in ptt 57-L1-69
SCALE
NO SIGNIFICANT DATA HAS SEEN
COLLECTED BELOW 13 FEET BGS
SC EN^C
A NI D
DEPARTMENT OF THE ARMY
LCAAP
VX CONCENTRATIONS IN SOURCE AREA
SOILS (SOLVENT PITS) - 5' TO 12.5'
PROJECT UGfi
TER
JESIGHEu 3V
RJK
DRAWN 'BY
PMS
>ECKE3 BY
KW
SCALE
r
300'
DEC 97
=3!XECT SO
12422.08
-------
-------
Final Record of Decision Area 18 Operable L'nn
Lake City Army Ammunition Plant. Independence. Missouri
APPENDIX B
TABLES
February 1998
-------
-------
TABLE 1 COCs AND REMEDIATION GOALS FOR AREA 18 SOIL
Compound
Copper
Mercury
Zinc
Lead
1.2-DCE
Toluene
PCI-
TCE
1'AIIs
Vinyl
Chloride
Benzene
1,1-DCE
Notes.
Detection
Limit
(rag/kg)
2.7
0.050
2.4
1.2
1.20
0.005
0.005
0.005
5.0
0.010
0.005
0.005
Maximum
Detection
Concentration
(trig/kg)
18,000
7.3
7,200
1,600
934
2,000
1,000
9,000
20. 1"°'
4.9
0.003
ND
Maximum
Background
Concentration
(mg/kg)
30.7
<0.l
99.5
39.5
NA
NA
NA
NA
NA
NA
NA
NA
Protection of
Groundwater Soil
Tmrorl
Concentration
(mg/kg)
-',,' . .-_ — ...
NA
NA
NA
—
2.06
ISO
1.09
0.4
660
0.01
0.25
0.3
===================:
Protection of
tiumin Iflcftlil)
(mg/kg)
-
58I"»
0.09'"
148.5'"
2,728
NA
NA
784
273l"'/27.3<"/l76«>
NA
NA""
NA<">
NA
===== '
=====
Missouri
ASL$">
(mg/kg)
-
17
5600
240
560/1, 100'"
11,000
380
260
.
-
170
8.3
i
•
TBC Criterlf
Other
Remedial
Criteria
Imp/fta?)
20'"
.
2.I78|5>
.
20,000'"
I0<"
60"'
.
-
_
10
=t
..
1
EPA
Region 3/9
(mg/kg)
=====
310/610
_
_
IO..OOO/390
200,000/280
55/0.65
260/34
-/-
1 5/0.2
99/4.6
4 8/0 1 2
-
1
Remediation
Goals
(mg/kg)
========
581
0.09
1485
1,000'*'
10
180
10
10
660
10
99
10 H
,ii
I. Ingesiion of beef from cattle pastured in Area 18. 5. Sec Lead Leachabilily from Soil discussion in FS. 9 Cis/trans isomcrs
3' I0< cancel ri* t IJlE* inChCS' **** °" MDNR recommcndalions I0- To(at PAIh less than KU, lUi calculated based «„ Siimmas
J. 10 cancer risk. 7. Withdrawn. Model
(II|B|)' 8- Pr°P°sed in ***** R^ster. Friday, July 27, 1990. II. These compounds were no. detected in surface soil
., • i » t • *» • *
risks were calculated for these compounds.
f \PROJ\60WOI\POOI.\ROD\DFT FNUTABI.I-SMABLEI WTO
3 May I9»5
-------
TABLE 2 VOCS DETECTED IN RI GROUND WATER SAMPLES
18-4 (Shallow)
18*8 (bedrock/deep)
18-9 (bedrock/deep)
18-11 (deep)
18-12 (Intermediate)
18-13 (deep)
18-14 (Intermediate)
18-15 (shallow)
18-16 (deep)
(34)/(2.000)
(150)/(66)
(95)/(8,000)
(7.000)/(8.000)
1(9.2)
/(58)
(20)/
(35)/(94)
42/(200)
19/
/(2.000)
4,000)/(4.000)
22/
(130)/
5.5/
/(14)
/(68)
4/
2.7/(42)
/2.1
19
/23
-/(15)/-
18-17 (deep)
71K1.361/-/1.0
18-24 (shallow)
17-FF
[vinyl chloride 44-370 ntJL over 4-year
period (see Appendix 4-D of Rl (EA 1995)1
22-3 (deep)
[12DCE ND-330 uglL over 4-ycar period)
16-14 (Intermediate)
16-15 (shallow)
0.92
(a) Delimiters indicate firsl/second/third round (if applicable).
() Indicates above MCL.
[ | Indicates duplicate sample.
Units of measure:
H-\PH(>J\6OTJ«mPOOIAROD\DFT_FNI.VrABlESVTABUJ.WPO
-------
TABLE 3 COGS AND REMEDIATION GOALS FOR AREA 18 GROUND WATER
Compound
1,2-DCE**1
Manganese
Arsenk
Vinyl cnloride
1,1-DCE
Benzene
PCE
TCE
Maximum Concentration
Detected Otg/L)
4,000
2.740
16.8
8,000
35
42
8.1
68
Remediation Goal
70
NA
50
2
7
5
5
5
Rationale
MCLb
MCL
MCL
MCL
MCL
MCL
MCL
(a) Both cis and trans isomers.
(b) Safe Drinking Water Act Maximum Contaminant Level.
F:*ROJ\6098401\POOL\ROrftDFT_FNL\TABLES\TABLE3.WPD
-------
TABLE 4 EXPOSURE GROUPS, EXPOSURE ROUTES, AND RISKS FOR AREA 18""
Total Exposure Point Exposure Pathway Chemicals of Potential
Concern"1'
Current Lake City 1 . Ingeslion of VOCs
Residents'1' Ground-Water acetone
benzene
chlorobcnzene
chloroform
chloromethane
1,1-DCE
TCE
xylenes (total)
Explosives
HMX
RDX
1,3,5-Trinitrobenzene
Inorganics
arsenic
barium
beryllium
cadmium
chromium
copper
lead
mercury
zinc
PATHWAY TOTAL
Noncancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
3.0 E-04
3.0 E-05
2.9 E-05 •
1.7 E-05
9.0 E-05
3.1 E-05
2.4 E-05
6.5 E-05
4.7 E-05
2.2 E-05
7.3 E-06
3. 9 E-05
2.9 E-03
2.0 E-05
9.2 E-05
2.2 E-04
7.8 E-04
1.5 E-04
3.1 E-06
3.9 E-03
Cancer Noncancer
Cancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
NA
1.3 E-05
NA
7.6 E-06
3.9 E-05
1.3 E-05
1.0 E-05
NA
NA
9.6 E-06
NA
1.7 E-05
NA
8.7 E-06
4.0 E-05
9.4 E-04
NA
6.3 E-05
NA
NA
SF
(mg/kg-day )-|
NA
2.9 E-02
NA
6.1 E-03
1.3 E-02
6.0 E-OI
I.I E-02
NA
NA
I.I E-OI
NA
1.8 E fOO
NA
4.3 EiOO
NA
NA
NA
NA
NA
NA
Risk
(CDI x SF)
NA
4 F-07
NA
5E-08
5E-07
8 E-06
1 E-07
NA
NA
1 E-06
NA
3 E-05
NA
4 E-05
NA
NA
NA
8 E-05
KID
(mg/kg-day)
1 H-0 1
NA
2 E-02
1 E-02
NA
9 E-03
1 E-OI
2EtOO
5 E-02
3 E-03
5 E-05
3 E-04
7 E-02
5 E-03
5 E-04
5 E-01
4 E-02
NA
'3 E-04
3 E-OI
1 liixard Index
(CDI / Rfd)
3 E-01
1 E-03
2 E-03
3 E-03
2 E-04
3 E-05
9 F-U4
7 E-03
1 E-OI
1 !•' 01
4 K-02
4 E-03
2 E-OI
2 I- -04
2 l-'-02
1 l'-02
1 E-02
6 E-OI
-------
TABLE 4 (CONTINUED)
- Cancer
Chemicals of Potential
Total Exposure Point Exposure Pathway Concern
2. Dermal Contact VOCs
with Ground acetone
Water benzene
chlorobenzene
chloroform
chloromethane
I.I -DCE
TCE
xylenes (total)
Explosives
HMX
RDX
1,3,5-Trinitrobenzene
Inorganics
arsenic
barium
beryllium
cadmium
chromium
copper
lead
mercury
zinc
PATHWAY TOTAL
Noncancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
—
4.0 E-06
9.7 E-06
1.3 E-06
2.0 E-06
3.5 E-06
3.5 E-06
4.0 E-05
—
—
—
7.7 E-08
5.7 E-06
4.1 E-08
I.8E-07
8.8 E-07
1.6 E-06
I.I E-09
6.3 E-09
5.7 E-06
Cancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
NA
1.7 E-06
NA
5.7 E-07
8.5 E-07
1.5 E-06
1.5 E-06
NA
NA
...
NA
3.3 E-08
NA
1.8 E-08
7.9 E-08
3.8 E-07
NA
5.0E-IO
NA
NA
SI-
(mg/kg-day )-l
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1.8 El 00
NA
4.3 E+00
NA
NA
NA
NA
NA
NA
Risk
(CDI x SF)
NA
5 E-08
NA
4 E-09
1 E-08
9 E-07
2 E-08
NA
NA
„
NA
2 E-06
NA
7 E-07
_„
..
NA
..
NA
NA
3 E-06
Noncancer
KID
(mg/kg-day)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
3 R-04
7 E-02
5E-03
5 E-04
5 Ii-03
4 E-02
NA
3 E-04
3P. -01
Hazard Index
(CDI /RID)
5 E-04
1 E-04
4 E-04
3 E-05
2 E-05
3 E-04
8 E-04
8 E-05
4 E-03
2 E-04
6 E-05
3 E-04
2 E-05
7 E-03
-------
TABLE 4 (CONTINUED)
Tolal Exposure Point
_______________ _ _
— . . _
Noncancer
Chronic Daily
Chemicals of Potential |t,i<.k_ ir>™\
'omt Exposure Pathway Concern ,
3. Inhalation of VQCq
VOCs from acetone
Ground Water benzene
chlorobenzene
chloroform
chloromethane
1,1-DCE
TCE
xylenes (total)
Explosives
HMX
RDX
1 ,3,5-Trinitrobenzene
Inorganics
arsenic
barium
beryllium
cadmium
chromium
copper
lead
mercury
zinc
PATHWAY TOTAL
iii*Mnw I^LXI i
9.0 E-05
I.I E-05
9.6 E-06
5.7 E-06
3.9 E-05
I.I E-05
7.3 E-06
2.2 E-05
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
— — — — i
TOTAL FOR CURRENT LAKE CITY RESIDENTS
Cancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
"•
NA
4.8 E-06
NA
2.4 E-06
1.7 E-05
4.6 E-06
3.1 E-06
NA
NA
*"
NA
NA
NONE
NONE
NONE
NONE
NA
NONE
NA
NA
— — — — ________
— ~
Cancer
SF
(mg/kg-day}-l
_
NA
2.9 E-02
NA
8.1 E-02
6.3 E-03
I.2E-IOO
6.0 E-03
NA
NA
NA
NA
5.0EHOI
NA
8.4 E+00
6.1 E+00
4.1 ElOl
NA
NA
NA
NA
Risk
(CDI x SF)
•^~~~~~— ~~ —
NA
1 I--07
NA
2 E-07
1 E-07
6 E-06
2 E-08
NA
NA
NONE
NA
NONI;
NA
NONE
NONE
NONE
NA
NONI;
NA
NA
6 E-06
9 E-05
___ _
Noncancer
KID
(mg/kg-day)
—
1 E-01
NA
5.5 E-03
1 E-02
NA
9 E-03
2.9E-01
2 E+00
5 E-02
3 E-03
5 E-05
3 'E-04
I.-IP.-04
5 E-03
5E-04
5.5 E-07
4 E-02
NA
8.6 E-05
3 I--OI
— — -
— — — — ——_-_«_
Hazard Index
(CDI/RfD)
-- •
9 E-04
2 I-MH
6 li-04
1 I--03
3 R-03
1 E-05
NONI-:
NONE
NONI:
NON1-
NONIi
NONE
NONE
NONE
NONE
NONI;
NONI-
NONE
— -— • -
7 E-03
.•
6E-OI
-------
TABLE 4 (CONTINUED)
Cancer
Chemicals of Potential
Total Exposure Point Exposure Pathway Concern
Current Lake City 1. digestion of Explosives
Well C Residents'" Ground- Water HMX
RDX
Inorganics
arsenic
barium
beryllium
copper
lead
zinc
PATHWAY TOTAL
2. Dermal Contact Explosives
with Ground HMX
Water RDX
Inorganics
arsenic
barium
beryllium
copper
lead
zinc
PATH WAY TOTAL
Noncancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
7.2 E-05 '
3.6 E-05
4.9 E-05
5.0 E-03
3.0 E-05
1.3 E-03
I.5E-04
5.4 E-03
—
...
9.8 E-08
9.9 E-06
6.0 E-08
2.6 E-06
I.2E-09
6.5 E-06
Cancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
NA
1,6 E-05
2. IE-OS
NA .
1.3 E-05
NA
6.6 E-05
NA
NA
...
4.2 E-08
NA
2.6 E-08
NA
5.3 E -10
NA
SF
(ing/kg-day)-!
NA
I.IE-OI
1.8E-IOO
NA
4.3 E^O
NA
NA
NA
NA
NA
I.8EIOO
NA
4.3 Ei 00
NA
NA
NA
Risk
(CI)lxSI-1)
NA
2.6 E-06
4.5 E-05
NA
6 E-05
NA
..
NA
9 E-05
NA'
..
2 E-06
NA
1 E-06
NA
—
NA
3 K-06
Noncancer
KID
(mg/kg-dny)
5E-02
3 B-03
3 E-04
7E-02
5 K-03
4E-02
NA
3E -01
NA
NA
3 E-04
7 E-02
5 E-03
4 E-02
NA
31: -01
llu/uid Index
« 1)1 /RID)
1 E-03
1 E-02
2E-OI
7 E-02
6 E-03
3 E-02
..
2 E-02
3E-OI
..
..
4 P.-04
1 E-03
1 l-!-04
1 E-04
._
3 l;-05
2 l-:-03
-------
TABLE 4 (CONTINUED)
Total Exposure Point
Exposure Pathway
3. Inhalation of
VOCs from
Ground Water
PATHWAY TOTAL
Chemicals of Potential
Concern
Explosive^
HMX
RDX
Inorganic;
arsenic
barium
beryllium
cadmium
lead
zinc
TOTAL FOR CURRENT LAKE CITY WEL
Noncancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
NONE '
NONE
NONE
NONE
NONE
NONE
NONE
NONE
L C RESIDENTS
Cancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
NA
NONE
NA
NONE
NA
NONE
NA
Cancer
SF
(mg/kg-day)- 1
NA
NA
5.0 EH) 1
NA
8.4 E+00
6.1 E+00
NA
NA
Risk
(CDI x SF)
NA
NONE
NONE
NA
NONE
NA
NONE
NA
0
1 E-04
Npnfanrer
HID
(mg/kg-day)
5E-02
3E-03
3E-04
I.4E-04
5 E-03
5E-04
NA
3E-OI
1 la/ard Index
(CDI / RfU)
•"•
NONE
NONE
NONIi
NONE
NONK
NONE
NONE
NONE
0
3E-OI
-------
TABLE 4 (CONTINUED)
Noncancer
Chronic Daily
Chemicals of Potential Intake (CDI)
Total Exposure Point Exposure Pathway Concern (mR/kfi-day)
Future Off-Post 1 . Ingeslion of VQCs
Residents Ground-Water 1,2-DCE
'ICE
vinyl chloride
PATH WAY TOTAL
2. Dermal Contact VQCs
with Ground 1,2-DCE
Water TCE
vinyl chloride
PATHWAY TOTAL
3. Inhalation of VQCs
VOCsfrom 1,2-DCE
Ground Water TCE
vinyl chloride
PATH WAY TOTAL
TOTAL FOR FUTURE OFF-POST RESIDENTS
2.2 E-03 '
2.5 E-04
3.9 E-03
1,6 E-04
3.6 E-05
1.6 E-04
7.6 E-04
7.6 E-05
1.6 E-03
Cancer
Cancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
NA
I.I E-04
1.7 E-03
NA
1.5 E-05
6.9 E-05
NA
3.3 E-05
6.7 E-04
SF
(mg/kg-day )-l
NA
I.IE-02
1.9 E 100
NA
NA
NA
NA
6.0 F.-03
3.0E-OI
Risk
(CDI x SF)
NA
1 R-06
3 E-03
3 E-03
NA
.-07
. E-04
1 E-04
NA
I ti-07
2 K-04
? • 04
j.i
Noncniicer
KflJ Hazard Index
(mg/kg-day) (CDI /RID)
1 E-OI 2I--OI
IK-OI 2F.-03
NA
2I--OI
NA 2T
NA 41
NA
21
1 l:-02 g J
2.9 -03 .1 h
NA
1 1
31
-02
-04
-02
-02
-02
•01
-01
-------
TABLE 4 (CONTINUED)
Cancer N'lncam-'T
Chemicals of Potential
Total Exposure Point Exposure Pathway Concern
Mowers 1 . Soil Ingeslion VOCs
chloroform
l,l-dichloroelhane(l,l-
DCA)
cis-l,2-DCE
ethylbenzene
melhylethyl ketone
(MEK)
methyl isobutyl
ketone(MIBK)
PCE
toluene
1,1,1-lricliloroetliane
TCE
xylenes (total)
Base/Neutral and A.yjd.
Exlractab, |e Compounds.
bis(2-
elhylhexyOphthalate
di-n-buiyl phthalatc
fluoranthene
Inorganics
barium
cadmium
chromium
copper
lead
mercury
silver
zinc
PATH WAY TOTAL
Noncancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
NONE '
NONE
1.2 E-07
NONE
NONE
NONE
1.1 E-07
3.2 E-07
NONE
5.4 E-07
NONE
8.5 E-07
2.3 E-07
2.3 E-07
2.4 E-05
I.I E-07
6.4 E-06
2.1 E-04
3.8 E-05
1.4 E-07
8.0 E-08
9.4 E-05
Cancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
NONE
NONE
NA
NA
NA
NA
NA
NA
NA
1.9 E-07
NA
3.0 E-07
NA
NA
NA
4.1 E-08
2.3 E-06
NA
1.4 E-05
NA
NA
NA
SF
(mg/kg-day )-l
6.1 E-03
NA
NA
NA
NA
NA
5.2E-02
NA
NA
1.1 E-02
NA
1.4 E-02
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Itisk
(CDI x SI-)
NONE
NONE
NA
NA
NA
NA
NA
NA
NA
2 Ii-0<>
NA
4 E-09
NA
NA
NA
..
NA
NA
NA
NA
6 l-.-O'J
KfD
(mg/kg-dny)
1 E-02
IE-01
1 E-02
1 E-OI
6 E-OI
5 E-02
1 E-02
2E-01
0 E-02
1 E-OI
2E-IUO
2 li-02
1 E-OI
4 li-02
7 li-02
i r.-o3
5 E-03
4 li-02
NA
3 E-04
5 l-i-03
3 E-OI
1 laznrd Index
(CDI / KID)
NONE
NONE
1 E-05
NONE
NONE
NONE
1 E-05
NONE
5 li-06
NONE
4 li-05
2 E-06
6 li-06
3 E-04
2 lr.-04
6 E-06
5 1-1-03
5 li-04
2L-05
3 E-04
71-1-0)
-------
TABLE 4 (CONTINUED)
Chemicals of Potential
Tolal Exposure Point Exposure Pathway Concern
2. Inhalation of VQQ
Soil Particulales chloroform
1,1-DCA
cis-l,2-DCB
ethybenzene
methyleihyl ketone
(MEK)
MIBK
PCE
toluene
1,1,1-lrichloroethanc
TCE
xylenes (total)
Base/Neutral and Acid
Extractable Cornnpund.;
bis(2-
elhylhexyOphthalate
di-n-butyl phthalate
fluoranthene
Inorganics
barium
cadmium
chromium
copper
lead
mercury
silver
zinc
PATHWAY TOTAL
•
Noncancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
NONE '
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
2.1 E-07
5.5 E-08
5.5 E-08
6.0 E-06
2.8 E-08
1.6 E-06
5.2 E-05
9.2 E-06
3.5 E-08
2.0 E-08
2.3 E-05
Cancer
Cancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
NONE
NONE
NA
NA
NA
NA
NA
NA
NA
NONE
NA
7.4 E-08
NA
NA
NA
9.9 E-09
5.6 E-07
NA
3.3 E-06
NA
NA
NA
SF
(mg/kg-day )-l
8.IE-025
NA
NA
NA
NA
NA
2.0 E-03
NA
NA
6.0 E-03
NA
NA
NA
NA
NA
6.1 EiOO
4.1 I->OI
NA
NA
NA
NA
NA
Risk
(CDI x SF)
NONE
NONE
NA
NA
NA
NA
NA
NA
NA
NONF.
NA
1 E-09
NA
NA
NA
6 E-08
2 E-05
NA
NA
NA
NA
2 li-05
Noncancer
RID
(mg/kg-day)
NA
1.4 E-07
NA
1 EiOO
1 EiOO
2.2 E-02
NA
4E-OI
NA
1 E-02
NA
NA
NA
NA
I.4E-04
NA
5.5 E-07
NA
NA
.) I--04
NA
NA
.-- __
1 lazard Index
(CDI / RID)
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
1 E-05
5 E-07
1 E-06
4 E-02
6 E-05
1 E-03
4 1 MM
4 E-06
8 E-05
1 '• H __
4 E-02
-------
tAUU-4(C'ONTINUi;i))
Chemicals ofPolential
Total Exposure Point Exposure Pathway Concern
3. Inhalation of VOCs
VOCs from Soil chloroform
1,1-DCA
cis-l,2-DCE
ethybenzene
MEK.
MIBK
PCE
loluerte
1,1,1-trichloroethanc
TCE
xylenes (tolal)
Base/Neutral and Acid
Extraclables (BNAs)
bis(2-
ethylhexyl)phthalate
di-n-butyl phthalate
fluoranthene
Inorganics
barium
cadmium
chromium
copper
lead
mercury
silver
zinc
PATH WAY TOTAL
TOTAL FOR MOWERS
Noncanccr
Chronic Daily
Intake (CDI)
(mg/kg-day)
4.3 E-07 '
3.4 E-08
2.8 E-05
5.6 E-06
1.3 E-06
2.2 E-07
2.5 E-04
1.3 E-04
5.6 E-07
6.3 E-04
2.4 E-05
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
LiUlCcr Nun,' ni'-ri
Cancer
Chronic Daily
Intake (CDI)
(nig/kg-day)
1.5 E-07
. 1.2 E-08
NA
NA
NA
NA
NA
NA
NA
2.3 E-04
NA
NONE
NA
NA
NA
NONE
NONE
NA
NONE
NA
NA
NA
SF
li"l!/kg-day)-l
8.1 E-02
NA
NA
NA
NA
NA
2.0 E-03
NA
NA
6.0 E-03
NA
• NA
NA
NA
NA
6.1 E+00
4.1 EtOI
NA
NA
NA
NA
NA
Risk
(CUI x SF)
IE-08
NA
NA
NA
NA
NA
•NA
NA
1 E-OG
NA
NONE
NA
NA
NA
NONE
NONE
NA
NONE
NA
NA
NA
1 li-06
2 E-05
RID
img/kg-day)
1 E-02
1.4 E-07
1 E-02
2.9 E-OI
2.9 E-OI
2.2 E-02
1 E-02
1.1 E-OI
9 E-02
2/J E-03
2 El 00
2E-02
1 E-OI
4 I--02
1.4 IMM
5.5 E-07
4 E-02
NA
8.5 l-:-05
5 E-03
3 E-OI
1 lii/ard Index
(CDI /RID)
4 E-05
2 E-OI
3 E-03
2 E-05
5 F-06
1 !•'-() 5
1 F-02
1 E-03
6 E-06
2E-OI
1 E-05
NONE
NONE
NONE
NONI-"
NONF
NONF
NONF
NONE
NONF
NONF
5 E-OI
5 E-OI
-------
TABJ.E 4 (CONTINUED)
Cancer
Chemicals of Potential
Total Exposure Point Exposure Pathway Concern
Future Construction 1. Ingestionof VOCs,
Workers Ground water carbon tetrachloride
chloroform
1,1 -DCA
1,1-DCE
l,2-DCE(cis and trans)
ethylbrnzene
melhylene chloride
MEK
MIBK
PCE
toluene
1,1,1-lrichloroethane
TCE
vinyl chloride
xylenes
BNAs
bis(2-
elhylhexyljphthalale
chrysene
di-n-butyl phthalate
fluoranthene
phcNAnthrene
1 ,2,4-trichlorobenzene
Explosives
1,3-dinitrobenzene
2,6-dinilrotoluene
RDX
1,3,5-lrinitrobenzene
2,4,6-lrinilroIolucne
Noncancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
I.OE-07 '
3.3 E-08
NONE
4.0 E-08
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
8.7 E-08
NONE
I.8E-07
NONE
NONE
NONE
NONE
NONE
NONE
2.1 E-08
NONE
NONE
Cancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
7.2 E-09
2.3 E-09
NONE
2.8 E-09
NA
NA
NONE
NA
NA
NA
NA
NA
NONE
6.2 E-09
NA
NONE'
1.3 E-08
NA
NA
NA
NA
NA
NONE
1.5 E-09
NA
NONE
SF
(mg/kg-day )-l
1.3E-OI
6.IE-03
NA
6.0 E-OI
NA
NA
7.5 E-03 .
NA
NA
5.2 E-02
NA
NA
I.I E-02
1.9 E 1 00
NA
1 .4 E-02
2.9 E-02
NA
NA
NA
NA
NA
6.8E-OI
I.IE-OI
NA
3.0 E-02
Risk
(CDI x SI')
9E-IO
IE-II
NONE
2 E-09
NA
NA
NONE
NA
NA
NA
NA
NA
NONE
1 E-08
NA
NONE
4 E-IO
NA
NA
NA
NA
NA
NONE
2 E-IO
NA
NONE
Noncancer
RID
(mg/kg-day)
7 E-03
1 E-02
1 Ei 00
9 E-03
1 I--OI
1 1:100
6 E-02
5E-OI
5 I--01
1 E-OI
2E-IOO
9 E-OI
1 E-OI
NA
4 lit 00
2 E-02
NA
1 El 00
4 E-OI
NA
1 E-02
1 I; -03
NA
3 E-03
5 E -04
5 I--04
Iliizard Index
(CDI /KID)
1 E-05
3 E-06
NONI-
4 1-1-06
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONK
NONE
NONI;
NONE
7 E-06
NONK
NONE
10
-------
TABU- 4 (CONTINUED)
Noncancer
Chronic Daily
^ , Chemicals of Potential intake rrrm
Total Exposure Point Exposure Pathway Concern (mgSay)
1. digestion of
Ground water
(Cont.)
Inorganics (dissolved)
antimony
arsenic
barium
beryllium
cadmium
chromium
copper
lead
mercury
nickel
selenium
silver
zinc
Inorganics iMill)
arsenic
barium
beryllium
cadmium
chromium
copper
lead
mercury
nickel
selenium
silver
zinc
7.7 E-07
5.1 E-08
3.3 E-06
NONE
NONE
NONE
9.7 E-08
4.4 E-08
NONE
2.IE-07
4.3 E-08
NONE
3.4 E-06
I.9E-07
6.8 E-06
I.2E-08
5.8 E-08
3.8 E-07
3.8 E-07
158 E-07
NONE
4.5 E-07
3.4 E-08
6.9 E-08
4.6 E-06
Cancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
NA
3.6 E-09
NA
NONE
NONE
NONE
NA
3.1 E-09
NA
NA
NA
NA
NA
1.3 E-08
NA
8.5E-IO
4.2 E-09
2.7 E-08
NA
I.I E-08
NA
NA
NA
NA
NA
Cancer
SF
(mg/kg-day)-l
NA
I.8E4GO
NA
4.3 E+00
NA
NA
NA
NA
NA
NA
NA
NA
NA
1.8 E tOO
NA
4.3 R tOO
NA
NA
NA
NA
NA
NA
NA
NA
NA
PA PH WAY TOTAL (using dissolved metals cone.)
PATHWAY TOTAL (using total metals cone.) ~
Risk
(CDI x SI-')
NA
7 E-0'>
NA
NONF.
NONE
NONE
NA
NA
NA
NA
NA
NA
2 E-08
NA
4 E-09
NA
NA
NA
NA
NA
NA
- --
2 I--08
._
4 f-:-()»
Nnncnncer
RID Hazard Index
(mg/kg-day) (CDI/Rfl))
4C-04
3 E-04
7 E-02
5 E-03
5 E-04
2E-02
4 E-02
NA
3 E-04
2 E-02
5 E-OJ
5 E-03
2E-OI
) !• -04
7 E-02
5 E-03
5 E-04
2 1--02
4 l-:-02
NA
3 E-04
2 E-02
5 E-0.1
5 E-03
2E-OI
1
2 E-03
2 E-04
5 E-05
NONI:
NONE
NONE
2 E-06
NONE
1 E-05
y li-06
NONE
2 l:-05
(> li-04
1 E-04
2 f-:-()6
1 E-04
4 E-07
1 E-05
NONE
2 !•- 05
7 I--06
1 I--05
2 I--05
2li-(H
— ™
') li-04
-------
TABLE 4 (CONTINUED)
Cancer
Chemicals of Potential
Total Exposure Point Exposure Pathway Concern
2. Ingestionof VOCs
Soil carbon tetrachloride
chloroform
1,1-DCA
1,1 -DCE
1,2-DCE (cis and trans)
ethylbenzene
methylene chloride
MEK
MIBK
PCE
toluene
1,1,1-Irichloroethane
TCE
vinyl chloride
xylenes
BNAs
bis(2-
elhylhexy!)phthalate
chrysene
di-n-butyl phlhalate
fluoranthene
pheNAnthrene
1 ,2,4-trichlorobenzene
Explosives
1,3-dinifrobenzene
2,6-dinitrololuene
RDX
1,3,5-lrinilrobenzene
2,4,6-lrinilrotoluene
Noncancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
NONE '
4.5 E- 10
NONE
NONE
8.5 E-06
2.9 E-06
1.6 E-06
NONE
NONE
I.3E-05
2.3 E-05
NONE
9,7 E-05
I.I E-07
NONE
2.4 E-06
NONE
5.6 E-07
4.0 E-07
4.2 E-07
1.4 E-06
5.6 E-08
1.0 E-07
5.8 E-07
I.I E-06
1.0 E-07
Cancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
NONE
3.2E-II
NONE
NONE
NA
NA
I.I E-07
NA
NA
NA
NA
NA
6.9 E-06
7.9 E-09
NA
1.7 E-07
NONE
NA
NA
NA
NA
NA
7.2 E-09
4.1 E-08
NA
7.2 E-09
SF
(mg/kg-day)- 1
I.3E-OI
6.1 E-03
NA
6.0E-OI
NA
NA
7.5 E-03
NA
NA
5.2 E-02
NA
NA
I.I E-02
I.9E+00
NA
1.4 E-02
2.9 E-02
NA
NA
NA
NA
NA
6.8E-OI
I.I E-OI
NA
3.0 E-02
Risk
(CDI x Sl:)
NONE
2E-I3
NONE
NONE
NA
NA
9E-IO
NA
NA
NA
NA
NA
8 E-08
2 E-08
NA
2 E-09
NONE
NA
NA
NA
NA
NA
5 E-09
5 K-09
NA
2E-IO
Honcancer
KID
(mg/kg-day)
7 E-03
1 E-02
1 E 1 00
9 E-03
1 E-OI
lEiOO
6 E-02
5 E-OI
5 E-OI
IE-01
2E+00
9 E-OI
1 E-OI
NA
4KIOO
2 K-02
NA
1 KiOO
4I:.-OI
NA
1 E -02
1 E -03
NA
3 E-03
5 1- -04
5 K-04
Hazard Index
(CDI / RfD)
NONE
5 E-08
NONE
NONE
9 E-05
3 E-06
3 E-05
NONE
NONE
1 F,-04
1 E-05
NONE
1 E-03
NONE
NONE
NONE
NONI;
NONE
NONE
NONE
6 1 -05
5 1 -OS
2 1 -04
2 I -01
2 1 -0-1
12
-------
TABU- 4 (C'ONTINUIiD)
Chemicals of Potential
Total Exposure Point Exposure Pathway Concern
2. Ingestionof Inorganips (dissolved]
Soil (Cont.) antimony
arsenic
barium
beryllium
cadmium
chromium
copper
lead
mercury
nickel
selenium
silver
zinc
Inorganics doiaj)
arsenic
barium
beryllium
cadmium
chromium
copper
lead
mercury
nickel
selenium
silver
zinc
PATHWAY TOTAL (using dissolved metals)
PATHWAY TOTAL (using lolal metals)
Noncancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
NONE '
8.3 E-07
5.0 E-05
9.6 E-07
1.8 E-07
1,2 E-05
2.2 E-04
5.3 E-05
1.6 E-07
4.3 E-06
NONE
1.3 E-07
1.3 E-04
8.3 E-07
5.0 E-05
9.6 E-07
1.8 E-07
1.2 E-05
2.2 E-04
5.3 E-05
1.6 E-07
4.3 E-06
NONE
1.3 E-07
1.3 E-04
-
Cancer M
Cancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
NA
5.9 E-08
NA
6.8 E-08
1.3 E-08
8.3 E-07
NA
3.8 E-06
NA
NA
NA
NA
NA
5.9 E-08
NA
6.8 E- 10
1.3 E-08
8.3 E-07
NA
3.8 E-06
NA
NA
NA
NA
NA
(mg/kg-day )-l
NA
I.SEiOO
NA
4.3 E-<00
NA
NA
NA
NA
:NA
NA
NA
NA
NA
I.8E+00
NA
4.3 Ei 00
NA
NA
NA
NA
NA
NA
NA
NA
NA
Risk
(CDI x SI-)
NA
IE-07
NA
3 E:07
NA
NA
NA
NA
NA
NA
1 E-07
NA
4 K-09
NA
NA
NA
NA
NA
NA
5 K-07
5 K-07
KID
(nig/ky-day)
.
4 K-04
3 K-04
7 K-02
5 E-03
5 E-04
4 K-02
NA
3 E-04
2 K-02
5 K-03
5 K-03
2E-OI
3 E-04
7 E-02
5 K-03
5 K-04
7 I-.II7
4 K-02
NA
3 K-04
2 K-02
5 K-03
5 K-03
2K-OI
•••i
IliU.ird Index
(CDI/ltf!))
i — . .
NONE
3 E-03
7 K-04
2 K-04
4 K-04
5 K-03
5 K-04
2 K-04
NONE
6 K-04
3 K-03
7 K-04
2 E-04
4 K-04
1 I-.-05
5 K-03
5 K-04
2 K-04
NONE
3 K-05
6 K-04
..—
o I: ()">
..— .
2 K-02
-------
TABLE 4 (CONTINUED)
Chemicals of Potential
Total Exposure Point Exposure Pathway Concern
3. Dermal Contact VOCs
wilh Ground carbon telrachloride
Water chloroform
1,1-DCA
1,1 -DCE
l,2-DCE(cis and trans)
elhylbenzene
methylene chloride
MEK
MIBK
PCE
toluene
1,1,1-lrichloroelhane
TCE
vinyl chloride
xylenes
bis(2-
eihylhexyl)phthalale
chrysene
di-n-butyl phlhalate
fluoranlliene
pheNAnlhrene
1 ,2,4-lrichlorobenzene
Explosives
1 ,3-dinitrobenzene
2,6-dinilrotoluene
RDX
1 ,3,5-lrinitrobenzene
2,4,6-trinilrotoluene
Noncancer
Chronic Daily
Intake (COI)
(mg/kg-day)
7.3 E-07 '
8.9 E-08
NONE
1.9 E-07
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
1.8 E-07
NONE
NONE
7.0 E-05
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
Cancer
Cancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
5.2 E-08
6.4 E-09
NONE
1.3 E-08
NA
NA
NONE
NA
NA
NA
NA
NA
NONE
1.3 E-08
NA
NONI:
5.0E-06
NA
NA
NA
NA
NA
NONE
NA
NONE
sr
(mg/kg-day )-l
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Risk
(CUI x SI-')
7 E-09
4E-II
NONE
8 E-09
NA
NA
NONE
NA
NA
NA
NA
NA
NONE
2 E-08
NA
NONI:
1 F:.-07
NA
NA
NA
NA
NA
NONL
NA
NONL
Noncancer
RID
(rng/kg-day)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Hazard Index
(CDI/RfD)
1 E-04
9C-06
NONE
2 E-05
NONE
NONE
NONE
NONI;
NONI;
NONI;
NONE
NONE
NONE
NONE
NONI;
NONE
NONI;
NONE
NONE
NONI;
NONE
"
NONI-
14
-------
. TABLE 4 (CONTINUED)
"
Chemicals of Potential
I otal Exposure Point Exposure Pathway Concern
3. Dermal Contact Inorganics (dissolved.:)
with Ground antimony
Water (Cont.) arsenic
barium
beryllium
cadmium
chromium
copper
lead
mercury
nickel
selenium
silver
zinc
Inorganics (Infajj
arsenic
barium
beryllium
cadmium
chromium
copper
lead
mercury
nickel
selenium
silver
zinc
PATHWAY TOTAL (using dissolved metals)
PATHWAY TOTAL (using total metals)
Noneancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
2.0 E-07
1.3 E-08
8.7 E-07
NONE
NONE
NONE
2.5 E-08
4.5E-1I
NONE
5.3 E-09
I.I E-08
NONE
5.4 E-07
4.9 E-08
I.8E-06
3.1 E-09
1.5 E-08
2.0 E-07
1.0 E-07
I.6E-IO
NONE
1.2 E-08
8.8 E-09
I.I E-08
7.2 E-07
••— ••••—•^ i^ M«MM
— — •— — — ^_Mta_
Cancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
NA
9.4 E- 10
NA
NONE
NONE
NONE
NA
3.2E-I2
NA
NA
NA
NA
NA
9.4E-IO
NA
NONE
NONE
NONE
NA
3.2 E- 12
NA
NA
NA
NA
NA
•-
Cancer
SF
(mg/kg-day )-l
NA
I.8E+00
NA
4.3E<00
NA
NA
NA
NA
NA
NA
NA
NA
NA
I.8EIOO
NA
4.3 El 00
NA
NA
NA
NA
NA
NA
NA
NA
NA
Itisk
(CDI x SF)
NA
2 E-09
NA
NONE
NONE
NONE
NA
NA
NA
NA
NA
NA
7 E-09
NA
9 E-09
NA
NA
NA
NA
NA
NA
2 K-U7
2 E-07
NoilrnnriT
RID
(mg/kg-day)
4 li-04
3 li-04
7 E-02
5 E-03
5 E-04
2 E-02
4 E-02
NA
3 E-04
2 E-02
5 E-03
5 F-03
3 E-04
7 li-02
5 li-0.1
5 li-04
2 l; IP
A I--02
MA
3 E-04
2 ii-02
5 1,0.1
5 li-0.1
2r--()l
•
. — »
1 la/ard Index
(f'DI/Rfl))
5 E-03
5E-05
1 li-04
NONE
NONK
NONE
1 E-06
NONE
3 E-Ort
2E-05
NONI;
"1 li-06
2 li-04
3 li-04
6 r.-o&
1 li-04
5 1-.-05
4 li-06
NONIi
(> 1 -()(>
21-05
2 I -05
*> 1 -06
• . — .
-------
TABLE 4 (CONTINUED)
Cancer
Noncancer
Chronic Daily
Chemicals of Potential Intake (CDI)
Total Exposure I'oiiit Exposure Pathway Concern (mg/kg-day)
4. Inhalation of VOCs
VOCs from Water carbon tetrachloride
chloroform
1,1-DCA
1,1 -DCE
l,2-DCE(cisandlraiis)
elhylbenzene
methylene chloride
MEK
MIBK
PCE
toluene
1,1,1-trichloroclhane
TCE
vinyl chloride
xylenes
BNAs.
bis(2-
elhylhexyl)phthalate
chrysene
di-n-butyl phlhalale
fluoranthene
pheNAnthrene
1 ,2,4-lrichlorobenzene
Explosives
1 ,3-dinitrobenzene
2,6-dinitrotoluene '
RDX
1 ,3,5-trinilrobenzene
2,4,6-trinilrotoluene
4.0 E-04 '
I.5E-04
NONE
2.0 E-04
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
5.5 E-04
NONE
NONE
2.4 E-05
NONE
NONE
NONE
NONE
NONE
NONE
...
NONE
NONE
Cancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
2.9 I--05
I.I E-05
NONE
1.4 E-05
NA
NA
NONE
NA
NA
NA
NA
NA
NONE
3.9 E-05
NA
NONE
I.7E-06
NA
NA
NA
NA
NA
NONE
...
NA
NONE
SI'
(mg/kg-day)- 1
5.3 E-02
8.IE-02
NA
1.2 E tOO
NA
NA
I.6E-03
NA
NA
2.0 E-03
NA
NA
6.0 E-03
3.0E-OI
NA
NA
2.4 E-02
NA
NA
NA
NA
NA
NA
NA
NA
NA
Risk
(CI)lxSI-)
2 l:-06
9E-07
NONE
2 E-05
NA
NA
NONE
NA
NA
NA
NA
NA
NONE
1 E-05
NA
NONE
4 1--08
NA
NA
NA
NA
NA
NONE
-
NA
NONE
Noncancer
KID
(mg/kg-day)
7 h-03
1 1.-02
1 .4 H-07
9 E-03
1 E-OI
2E-OI
8.6 E-OI
2.9 E-OI
2.2 e -01
1 E-OI
5.7 E-OI
9 E-OI
2.9 I--02
NA
4EIOO
2 l-:-02
NA
1 I-IOO
4 E-OI
NA
2.5 L-03
1 1 -03
NA
3L-03
5 1 -04
51 -04
1 l:r/ard Index
(CDI/KflJ)
6 t-02
1 E-02
NONE
2E-02
NONE
NONE
NONE
NONE
NONH
NONE
NONE
NONE
NONE
„
NONE
NONE
..
NONII
NONE
NONE
NONE
NONE
NONIi
NONE
NONE
NONE
-------
TABUS 4 (CONTINUED)
._ ._ Chemicals of Potential
Total Exposure Point Exposure Pathway Concern
4. Inhalation of Inorganics (dissolved)
VOCs from Water antimony
(I'onl.) arsenic
barium
beryllium
cadmium
chromium
copper
lead
mercury
nickel
selenium
silver
zinc
Inorganics iuna)j
arsenic
barium
beryllium
cadmium
chromium
copper
lead
mercury
nickel
selenium
silver
zinc
PATHWAY TOTAL (using dissolved metals)
PATH WAY TOTAL (using tola! metals)
Noncancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
NONE '
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
dancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
NA
NONE
NA
NONE
NONE
NONE
NA
NONE
NA
NA
NA
NA
NA
NONE
NA
NONE
NONE
NONE
NA
NONE
NA
NA
NA
NA
NA
.
Cancer
— "• ,,..,..
N()ML'iini*f>r
SF
(rmj/kg-day)-l
NA
5.0EIUI
8.4 El 00
6.1 EtOO
4.IEIOI
NA
NA
NA
NA
NA
NA
NA
5.0E10I
NA
8.4 EiOQ
6.1 ElOO
4.1 E+OI
NA
NA
NA
NA
NA
NA
NA
Risk
(CDI x Sl:)
NA
NONI;
NA
NONE
NONE
NONE
NA
NONE
NA
NA
NA
NA
NA
NONE
NA
NONI;
NONE
NONI-:
NA
NONI;
NA
NA
NA
NA
— - — -
3 E-05
.1 E-05
RID
(mg/kg-day)
—
4 E-(M
3 E-04
I.4E-04
5 ls-03
5 E-04
5.5 I--07
4E-02
NA
8.6 E-05
2 E-02
5 I--0.1
5 E-OJ
2E-OI
3 E-04
1.4 E-04
5 E-0.1
5 E-04
5.5 E-07
4 I--02
NA
8.6 E-05.
2 E-02
5 E-OJ
5 I-.-03
2 E-OI
'~ - . .
lla/ard Index
(CDI/Rfl))
—
NONI;
NONI;
NONI;
NONE
NONE
NONE
NONE
NONI;
NONE
NONE
NONE
NONI;
NONE
NONE
NONI;
NONI;
NONI;
NONI;
NONI;
NONE
NONI;
NONE
NONI;
NONE
KJ/\KI|,'
;
(> l:-0 2
— — —
-------
TABLE 4 (CONTINUED)
Cancer
Chemicals of Polenlial
Total Exposure Point Exposure Pathway Concern
5. Inhalation of VQCs
Soil ('articulates carbon tetrachloride
chloroform •
I.I-DCA
1,1-DCE
l,2-DCE(cis and Irans)
elhylbenzene
methylene chloride
MEK
M1BK
PCE
toluene
1,1,1-trichloroethane
TCE
vinyl chloride
xylenes
BNAs
bis(2-
elhylhexyOphihalalc
chrysene
di-n-butyl phthalate
fluoranlhene
pheNAnthrene
1 ,2,4-trichlorobenzene
Explosives
1 ,3-dinitrobenzene
2,6-dinilrololuene
RDX
1 ,3,5-lrinitrobenzenc
2,4,6-lrinitrotolucne
Noncancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
NONE '
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
5.4 E-06
NONE
1.3 E-06
9.0 E-07
9.5 E-07
3.1 E-06
1.3 E-07
2.3 E-07
1.3 E-06
2.6 E-07
2.3 E-07
Cancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
NONE
NONE
NONE
NONE
NA
NA
NONE
NA
NA
NA
NA
NA
NONE
NONE
NA
3.8 E-07
NONE
NA
NA
NA
NA
NA
I.6E-08
9.3 E-08
NA
1.6 E-08
SF
(mg/kg-day)- 1
5.3 E-02
8.IE-02
NA
I.2E+00
NA
NA
I.6E-03
NA
NA
2.0 E-03
NA
NA
6.0 E-03
3.0 E-OI
NA
NA
2.4 E-02
NA
NA
NA
NA
NA
NA
NA
NA
NA
Risk
(CDI x SF)
NONI:
NONE
NONE
NONI;
NA
NA
NONI;
NA
NA
NA
NA
NA
NONE
NONI:
NA
5 E-09
NONE
NA
NA
NA
NA
NA
1 1--08
1 li-08
NA
5I;.-IO
• Noncancer
RID
(mg/kg-day)
7 l-:-03
1 li-02
I.4E-07
9 E-03
1 E-OI
2 I- -01
8.6I--OI
2.9 E-OI
2.2 e -01
1 E-01
5. 7 E-OI
9E-OI
2.9 l>02
NA
4EIOO
2 E-02
NA
1 EMM)
4I--OI
NA
2.5 li-03
1 li-03
NA
3 E-03
5 E-04
5 F.-04
1 liizard Index
(CDI/RfD)
NONE
NONE
NONIv
NONE-
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONI-
NONE
NONK
NONE
3 E-04
NONI-
1 E-06
2 E-06
1 Ii-01
1 l:-04
1 lv-04
4 li-04
5 l:-0.)
5 !-!-04
18
-------
TAULli4(C'ONTINUl:D)
Total Exposure Point
Exposure Pathway
5. Inhalation of
Soil Participates
(Com.)
Chemicals of Potential
Concern
Inorganics {diss. flllECf f^oiiL'iniL'cr
SI-
(mg/kg-day )-l
NA
5.0E+OI
NA
8.4 El 00
6.1 E+00
4.1 ElOl
NA
NA
NA
NA
NA
NA
NA
5'.OE+OI
NA
8.4 E 100
6.1 EiOO
4.1 E+OI
NA
NA
NA
NA
NA
NA
NA
PA Til WAY TOTAL (using dissolved metals)
PATHWAY TOTAL
(using total metals)
Risk
(C'DI x Sl:)
NA
7 E-06
NA
1 E-06
2R-07
8 Ii-05
NA
NA
NA
NA
NA
NA
7 E-06
NA
1 E-06
2 E-07
8 E-05
NA
NA
MA
NA
NA
NA
8 Ii-05
8 E-05
ItlU
(mg/kg-(l;iy)
4 E-04
3E-04
1.4 E-04
5 E-03
5 E-04
5 5 F-07
4E-02
NA
8.6 E-05
2 I--02
5 E-03
5 E-03
2E-OI
3 E-04
1 .4 E-04
5 L-03
51- -04
5 5 |.-.07
4 l;-02
NA
8.6 E-05
5 K-0»
S K.fH
2 I--OI
1 la/ard Index
(CDI/RtD)
NONI;
6 E-03
8E-OI
4 E-04
8 E-04
1 I--02
4 E-03
5 E-04
NONI-:
6 I--05
1 .E-03
6 E-03
8E-OI
4 l>04
8 l-:-04
1 I--02
4 I--03
NONI-:
i I-.-05
• —
8 l-'-oi
— -*«•
8 i:-o i
19
-------
TABLE 4 (CONTINUED)
Cancer
Chemicals of Potential
Total Exposure Point Exposure Pathway Concern
6. Inhalation of VOCjj
VOCs from Soil carbon tetrachloride
chloroform
1,1-DCA
1,1 -DCE
l,2-DCE(cis and trans)
elhylbenzene
methylene chloride
MEK
MIBK
PCE
toluene
1,1,1-trichloroelhane
TCE
vinyl chloride
xylenes
SNA;;
bis(2-
ethylhexyl)phlhalate
chryscne
di-n-butyl phthalate
fluoranthene
pheNAnthrene
1 ,2,4-lrichtorobenzene
Explosives
1,3-dinitrobenzene
2,6-dinitrololuene
RDX
1-,3,5-trinitrobenzene
2,4,6-lrinitrotoluene
Noncancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
NONE
2.4 E-06
I.9E.-07
NONE
I.6E-04
3.1 E-05
NONE
7.2 E-06
1.2 E-06
I.4E-03
7.2 E-04
3.1 E-06
3.5 E-03
NONE
1.3 E-04
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
Cancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
NONE
I.7E-07
I.3E-08
NONE
NA
NA
NONE
NA
NA
NA
NA
NA
2.5 E-04
NONE
NA
NONE
NONE
NA
NA
NA
NA
NA
NONE
NONE
NA
NONE
SP
(mg/kg-day )-l
5.3 E-02
8.IE-02
NA
I.2E+00
NA
NA
1.6 E-03
NA
NA
2.0 E-03
NA
NA
6.0 E-03
3.0E-OI
NA
NA
2.4 E-02
NA
NA
NA
NA
NA
NA
NA
NA
NA
Risk
(CDI x SF)
NONE
IE-08
—
NONE
NONE
NA
NONE
NA
NA
NA
NA
NA
2 E-06
NONE
NA
NONI-;
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
,ONE
Noncancer
KPD
(mg/kg-day)
7 E-03
IE-02
I.4E-07
9 E-03
1 E-OI
2E-OI
8.6 E-OI
2.9 E-OI
2.2 e -01
1 E-OI
5. 7 E-OI
9 E-OI
2.9 E-02
NA
4L100
2 1 -02
NA
1 I <00
41-01
NA
2.5 E-03
1 E-03
NA
3 E-03
5 E-04
5 I--04
1 la/ard Index
(CDI/RIU)
NONE
2 E-04
1 EiOO
NONE
2 E-03
1 E-04
NONE
2 i-05
5 --05
1 E-02
1 -:-03
3 i-06
1 --OI
NONE
3 E-05
NONE
NONE
NONE
NONE
NONE
NONI-:
NONE
NONE
NONE
NONE
NONE
-------
TABLE 4 (CONTINUED)
"•
Chemicals ofl'otenlial
Total Exposure I'oinl Exposure Pathway Concern
6. Inhalation of Inorganics (di«»lv<.,lj
VOCs from Soil antimony
(Com.) arsenic
barium
beryllium
cadmium
chromium
copper
lead
mercury
nickel
selenium
silver
zinc
Inorganics (total)
arsenic
barium
beryllium
cadmium
chromium
copper
lead
mercury
nickel
selenium
silver
zinc
PATHWAY TOTAL (using dissolved metals)
PATIIWA V T/ITAI •/..„:.._.... i . • i
« _____
Noncaiiccr
Chronic Daily
Intake (GDI)
(mg/kg-day)
NONE
NONE
NONE
NONIi
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
Cancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
NA
NONE
NA
NONE
NONE
NONE
NA
NONE
NA
NA
NA
NA
NA
NONE
NA
NONE
NONE
NONE
NA
NONE
NA
NA
NA
NA
NA
11
Cancer
SF
(nig/kg-day)-! (
• • — .
NA
50E10I
8.4 El 00
6.1 EK)0
4.1 EiOl
NA
NA
NA
NA
NA
NA
NA
5.0EIOI
NA
8.4 EI 00
6. IE tOO
4.1 K 101
NA
NA
NA
NA
— •"•*••' I..— — __
— . _
Risk
— ^—— ^— — __
NA
NONE
NA
NONI;
NONE
NONE
NA
NA
NA
NA
NA
NA
NA
NONE
NA
NONE
NONE
NONE
NA
NONE
NA
NA
NA
NA
NA
2 E-06
*
NllMl
KID
4 I;-(M
1 1--04
1 4IM14
5 E-03
5 E-04
5.5 H-07
4 J--02
NA
8.6 I--05
2 E-02
5 !•-().}
5 E-03
2E-OI
3 E-04
5 E-03
5 i;-04
5.5 I--07
4 I--02
NA
8.6i;-()5
2 E-02
5 i;-03
5 E-03
9 I* t\t
— ^— «™^— -_-^_-________
,'iincer
1 lazard Index
\\. \)\ 1 KID)
NONE
NONI;
NONI;
NONI;
NONE
NONI;
NONI;
NONI;
NONI;
NONI;
NONI;
NONE
NONI;
NONE
NONE
NONI;
NONE
NONI;
NONE
NONE
NONE
NONE
NONE
NONE
NONI;
_
i !•: i no
-------
TABLE 4 (CONTINUED)
.. . Nuncaiifcr
Noncancer Cancer
Chronic Daily Chronic Daily
(CDI/RID)
TOTAL FOR FUTURE CONSTRUCTION WORKERS (using dissolved melals)
2(i(00
TOTAL FOR FUTURE CONSTRUCTION WORKERS (using total metals) , E.04
2EIOO
-------
TABLH 4 (CONTlNUIiD)
Chemicals of Potential
Total Exposure Point Exposure Pathway Concern
NAlioNAl |. Ingestionof VOCj
Guardsmen Soil chloroform
I.I -DCA
cis-l,2-DCE
elhylbenzene
MEK
MIBK
PCE
toluene
l.U-trichloroelliane
TCE
xylenes (total)
BNAs
bis(2-
elhylliexyl)phihalale
di-n-butyl phlhalate
fluoranlhcne
Inorganics
barium
cadmium
chromium
copper
lead
mercury
. silver
zinc
D ATI III/ AV Tr\T A i
Noncancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
NONE '
NONE
2.3 E-07
NONE
NONE
NONE
2.3 E-07
6.5 E-07
NONE
I.I E-06
NONE
1 .7 E-06
4.5 E-07
4.5 E-07
4.9 E-05
2.3 E-07
1.3 E-05
4.3 E-04
7.5 E-05
2.8 E-07
1.6 E-07
1.9 E-04
Cancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
NONE
NONE
NA
NA
NA
NA
NA
NA
NA
1.5 E-07
NA
2.4 E-07
NA
NA
NA
3.2 E-08
1.8 E-06
NA
1.1 E-05
NA
NA
NA
• i
Cancer
SF
(mg/kg-day )-l (C
6.IE-03
NA
NA
NA
NA
NA
5.2 E-02
NA
NA
I.I E-02
NA
1.4 E-02
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
—
. _ Noiirniirrr
Risk
DI X SI')
NONE
NONE
NA
NA
NA
NA
NA
NA
NA
2 E-09
NA
3 li-09
NA
NA
NA
NA
NA
NA
NA
RID
(ing/kg-day)
IE-02
1 E-OI
1 E-02
IE-01
6E-OI
5 E-02
1 E-02
2 E-OI
9 E-02
1 E-OI
2KIOO
2 E-02
4 i-02
7 :-02
--UJ
4 '-02
NA
j I--04
3 i-:-oi
1 lazard Index
(CDI/Rfl))
NONE
NONE
2 E-05
NONE
NONE
NONE
2 E-05
3 E-06
NONE
i i;-os
NONI:
8 li-05
4 E-06
1 E-05
7 li-04
5 I-.-04
1 I-.-05
I.-02
.M -04
<> E-04
23
-------
TABLH 4 (CONTINUHD)
Chemicals of Potential
Total Exposure Point Exposure Pathway Concern
2. inhalation of VQCs
Soil Participates chloroform
I.I-DCA
cis-l,2-DCE
ethylbenzene
MEK
MIBK
PCE
toluene
1,1,1-trichloroethane
TCE
xylenes (total)
bis(2-
elhylhexyOphlhalale
di-n-butyl phlhalate
fluoranlhene
Inorganic;
barium
cadmium
chromium
copper
lead
mercury
silver
zinc
PATHWAY TOTAL
Noncancer
Chronic Daily
Intake (GDI)
(mg/kg-day)
NONE '
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
7.5 E-07
2.0 E-07
2.0 E-07
2.2 E-05
1.0 E-07
5.7 E-06
I.9E-04
3.4 E-05
1.3 E-07
7.2 E-08
8.4 E-05
Cancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
NONE
NONE
NA
NA
NA
NA
NA
NA
NA
NONE
NA
I.I E-07
NA
NA
NA
1.4 E-08
8.1 E-07
NA
4.8 E-06
NA
NA
NA
Cam
SI-
(mg/kg-day )-l
8.1 E-02
NA
NA
NA
NA
NA
2.0 E-03
NA
NA
6.0 E-3
NA
NA
NA
NA
NA
6.1 EiOO
4.1 EtOI
NA
NA
NA
NA
NA
;er
Risk
(CDI x Sl:)
NONE
NONE
NA
NA
NA
NA '
NA
NA
NA
NONE
NA
2 E-O'J
NA
NA
NA
9 E-08
3 E-05
NA
NA
NA
NA
3 E-05
RID
(mg/kg-day)
1 E-02
1. 4 E-07
1 E-02
2.9 E-OI
2.9 E-OI
2,2 E-02
1 E-02
I.I E-OI
9 E-02
2.9 E-03
2E+00
2 1 -02
1 1 -01
4 1 -02
l.'l 1: 04
5 E-04
5.5 E-07
4 E-02
NA
8.6 E-05
5 li-0 1
3I--UI
Ihuard Index
(CDI /RID)
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONI-:
NONE
NONE
NONE
4 E-05
2- E-06
5 E-06
2 1- 01
2 E-04
5 E-0.1
1 E-03
1 E-05
2 E-OI
24
-------
TABLE 4 (CONTINUED)
Toial Exposure Point
Chemicals of Potential
Exposure Pathway Concern
3. Inhalation of VOCs
VOCs from Soil chloroform
1,1-DCA
cis-l,2-DCE
eihylbenzene
MEK
MIBK
PCE
toluene
1,1,1-trichloroelhane
TCE
xylenes (total)
BNAs
bis{2-
ethylhexyljphlhalate
di-n-butyl phthalate
lluoranlhene
Inorganfc;
barium
cadmium
chromium
copper
lead
mercury
silver
zinc
'ATHWAY TOTAL
• —
'OTAL FOR NATIONAL GUARDSMEN
— — ==^_ _ =____«__-^__
Noncanccr
Chronic Daily
Intake (CDI)
(mg/kg-day)
1.4 E-06
I.I E-07
9.4 E-05
1.9 E-05
4.4 E-06
7.2 E-07
8.3 E-04
4.3 E-04
19 E-06
2.1 E-03
7.8 E-05
NONI:
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
— • _
i^— — — __ • __ „
Cancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
i.
2.1 E-07
I.6E-08
NA
NA
NA
NA
NA
NA
NA
3.0 E-04
NA
NONE
NA
NA
NA
NONli
NONE
NA
NONE
NA
NA
NA
"' '
^— —
. Cancer
(mg/kg-day)- 1
— .
8.1 E-02
NA
NA
NA
NA
NA
2.0 E-03
Kl A
NA
NA
6.0 E-3
NA
NA
NA
NA
Kl A
NA
6.1 Ei 00
4.1 ElOl
NA
NA
NA
NA
NA
-
Risk
(CDI x SI-')
2 E-08
NA
NA
NA
NA
NA
NA
NA
2 E-06
NA
NONE
NA
NA
NA
NONI;
NONI;
NA
NONI;
NA
NA
NA
—
2 i- -06
• • — . ~— .
4 E-05
• —
Noncqnecr
Rfl) llnzard Index
(mg/kg-day) (CDI /RID)
. —
1 E-02
1.4 E-07
1 E-02
2.9E-OI
2.9E-OI
2.2 E-02
1 t-02
I.I 1- -01
9 E-02
2.<; I--03
21-100
2 l>02
1 E-OI
4R-02
5 E-04
5 5 IC-07
•\ E-02
NA
K.<> P.-05
3E-OI
~
™— _
1 I--04
8 E-OI
9 !•-() 1
6 E-05
2 i;-05
3 E-05
8 E-02
•1 E-04
2 E-05
2 l-:-()2
4 E-05
NONI;
NONE
NONE
NONI;
NONI;
NONI;
NONI;
NONI;
NONI;
NONI;
NONI;
— •
— • — . — •—.
2 l-'ilin
-------
TABLE 4 (CONTINUED)
Canter
Chemicals of Potential
Total Exposure Point Exposure Pathway Concern
Meat Eaters 1. Ingestionof VQCs
Meat cis-l,2-DCE
PCE
toluene
TCE
BNAs
bis(2-
ethylhexyl)phlhalaie
di-n-bulyl phthalate
fluoranlhene
Inorganics
barium
cadmium
chromium
copper
lead
mercury
silver
zinc
PATHWAY TOTAL
TOTAL FOR MEAT EATERS
Noncancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
2.6 E-08 '
I.5E-07
9.1 E-08
6.4 E-08
2.3 E-06
I.5E-05
3.3 E-06
2.3 E-05
1.6 E-06
2.2 E-04
I.3E-02
7.0 E-05
1.1 E-03
6.4 E-06
5.9 E-02
Cancer
Chronic Daily
Intake (CDI)
(mg/kg-day)
NA
NA
NA
2. 7 E-08
9.9 E-07
NA
NA
NA
7.0 E-07
9.3 E-05
NA
3.0 E-05
NA
NA
NA
SF
(mg/kg-day )-l
NA
5.2 E-02
NA
1.1 E-02
1.4 E-02
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Risk
(CDI x SI-)
NA
NA
NA
3E-10
1 E-08
NA
NA
NA
..
..
NA
__
NA
NA
NA
1 E-08
i i;-o8
Noncancer
KID
(mg/kg-day)
1 1--02
1 E-02
2E-OI
1 E-01
2 E-02
1 E-OI
4 E-02
7 li-02
1 E-03
5 E-03
4 E-02
NA
3 E-04
, 2 E-02
3 li-OI
Hazard Index
(CIM/Kfl))
3 i-:-oo
2 I--05
5 E-07
6 t--07
1 1-:-04
1 l:-04
81--05
3 P.-04
3 E-03
2 I--04
3 E-01
,_
4EtOO
1 E-03
2F.-OI
4 I- H)()
4 lit 00
(a) Based on the Area 18 Rl.
(b) Chemicals of potential concern (COPCs) include chemicals that were carried through the risk analysis. COPCs may or may not become COCs as their concentrations,
potential exposure scenarios, etc. are analyzed during the human health risk assessment.
(c) Based on an average of residential wells that were determined to be in the flow path of Area 18 ground water.
(d) Based only on the well resulting in maximum risk (Well C)to Lake City residents. This was done to address concerns that combined observations of all wells did no
assess the maximum potential risk to Lake City residents. Refer to the Area IS Rl for detailed discussion regarding this topic.
-------
-------
Final Record of Decision Area IS Operable L'nu
Lake Cin Armv Ammunition Plant. Independence, \ftssoun
APPENDIX C
GROUND WATER TREATMENT DISCHARGE CRITERIA
Februarv 1998
-------
-------
Permit No. LB-Q200-LC504
PART 1 - Effluent Limitations Continued:
J. During the period of February 21, 1997 to February 20, 2000 wastes containing
any of the following substances in solution or in suspension in concentrations
exceeding the maximum permissible concentration shall not be discharged through
Outfall 003 to the District's system. Repeated or willful violation of these maximum
limits shall be deemed sufficient to warrant enforcement action.
Daily
Maximum
Parameter mg/l
pH 5 to 10.5 SI
1,1-Dichlcroethane 0.026
1.1-Dichloroethene 0.035
1,2-Dichlorcethene • 0.400
1,1,1-Trichlcroethane 0.900-
Benzene 0.043
Carbon Tetrachloride 0.044
Chloroform 0.009
Ethyl Benzene 0.007
, Methylene Chloride 0.030
Methylisobutyl Ketone 0.002
Toluene 0.110
Tn'chloroethene 0.680
Vinyl Chloride 0.250
Bis(2-Ethy!hexyl)Phtha!ate 0.360
Chrysene 0.066
Di-N-Octyl Phthalate 0.013
2,4-Dinitrotoluene O.CC6
HMX 0.002
Nitrobenzene 0.013
RDX 0.005
Antimony 0.078
Arsenic 0.030
Barium 0.856
Beryllium 0.010
Cadmium 0.200
Chromium 1.00O
Copper 3.000
Lead 1.500
Nickel 1.000
Selenium 0.034
Silver 0.100
Zinc 5.000
-------
TABLE 7 SUMMARY OF NONCARCINOGENIC RISKS (His) FROM FUTURE EXPOSURE SCENARIOS
Exposure Groups
UMUI|UM^UMM4l
Future
Workers
Commercial/Industrial
WorJwrs
(Total Metals)
Chronic
11
7x10°
>,, - Residents
> -.josj;, ' "''
MMftftfiftftqftf
(a) Risk due to total metals is 1 x 10*'.
(b) Noncancer risk without chromium is Hazard Index (HI)
-------
TABLE 8 SUMMARY OF CARCINOGENIC RISKS FROM FUTURE EXPOSURE SCENARIOS
Future
Commercial/Industrial
Workers
(Tofa! Metals)
(a) Risk is the same for total and dissolved metals.
(b) Cancer risk without chromium for this exposure group is 1 x 10s.
F:\PROJ\609840l\POOL\ROD\DFT FNL\TABLES\TABLE8.WPD
-------
TABLE 5 SUMMARY OF NONCARCINOGENIC RISKS (His) FROM CURRENT EXPOSURE SCENARIOS
(a) See discussion on Inhalation risks driven by chromium.
(b) Noncancer risk without chromium is Hazard Index (HI) < 1.
F:\PROJ\60984W\I-OOUROD\DFT_FNl.\TABLbSVTABI.E5.WPD
-------
TABLE 6 SUMMARY OF CARCINOGENIC RISKS FROM CURRENT EXPOSURE SCENARIOS
F:\PROJ\609840I\POOL\ROD\DFT FNIATABLE6.WPD
-------
e Opium ,
lu, 2;i, J;i, mil)
IIV.SD)
Discharge Option 111
II), 2I>, 31), only
(Discharge lu Ditch It)
33 DSC I2M-U/0
•IDCIK.lOi S
•HUTU §§301.302, 306, >07
10 CSK 20-7 0)1
I OCSR 20-6.010
10 CSR 20-7 015
Applicable
Applicable
("lean W.itci Act (CWA)
ruisuanl to (Ins alternative and disi barge opium, uiniaminaied
ground \\aler uill be extracted anil Healed in llic A KM IK
iieainienl phuil prior to being discharged io ilie I inle Hlue V,ille>
Sewer Disliicl (1.IWSD) Ilie CWA requires lh.il ilie discharge
comply with I IJVSI) pielieatmeni piogram (ieneial
prelreulinenl legululions ure loculed at 40 CI R 10 ] -III ( I |<
-10J 5 intliulei general and specific puiliilniioiis on diMhaiyei to
I'D I Wi I (ii lliisdistbaige option, the disi liaise \\nnld lie
regulated under permit tfl.H 02(10 I.(\S(|-| DibUiaiiie
ret|iiirenienls nl ibis perinil are included in Appendix (' Since the
dibtlmige is oll-silc and is legulalcd pnibiianl to a pciinil, it is mil
considered un AKAR. bul is a compliance rci|iiuemcni
I'mstiant to this allernutive and dihcbaige upturn, umt.miinaii-d
ground water will be extracted and Healed in the AIC.I 18
treatment plant prior Io being discharged to Ditch II onsiic
Onsile discharges must meet the substantive retiiiiicinenls nl tin.-
CWA NI'IMiS program Applicable discharge ciileiia undci the
NI'DLS piogram are found in -10 U Ks 301, 302. 306, iiiul ](I7
Construction of a second outfall from the air slrippei would
require adherence to substantive requirements of the current m
place NPDES Permit pursuant to Missouri Clean Watei Law 110
CSR 20-6.010(1) J. Any modification to a sewer system or walei
contamination source or point source would require adherence lu
substantive requirements of 10 CSR 20-6 10!(•!). .10 CSR 20-
7015 regulates the limits for various pollutants which are
discharged to (he various waters of (he Stale of Missouri.
( MY OIK UMI NmlNAI (iWAKARDOC
-------
Discharge Option «3
1C ,2< ,3C, only
(Discharge through Underground
Inji-i lion)
IOCSR20-6
Applicable
The injection ofha/ardous wastes fiuiu (T.KCI.A silos into wells
must meet the substantive lequiremeiits of the Sale Dunking
Water Act (SI)WA) Underground Injection Control (UIC)
hograii) I Inderground injection wells are divided into 5 dilleieiit
classes, standards and criteria depend on the classification ol (he
well Ol the 5 classes, Class I, IV and V wells aie most likely to
be involved \vilh CliKCl.A actions {CI.KCI.A Compliance With
Oihei Laws Manual Interim final, 1988 ) the specific
reqiiiiemcnls can only be identified after the well classifications
are deleimmed Missouri regulates the conslmUioii and opeialmi1
of sucli wells under 10 CSK 2()-f> Substantive refinements ol Id
C'SH 20-6 must be leviewed to identify AKAKs If undetL'iound
injection is selected, these requirement* would be addiessed m tin.-
KD/KA which is subject to review according to piovisions ol the
I-1-A
( 'MY IMH IIMI.NIS-HNAI l.W AKAR IMIC
-------
-------
1-'
DhSnUMION 01- KI-MI-.DIAI. Al. I liUNA IIVHS AND SUMMARY ()l AC I ION -SIM-CII 1C AKAKs
REMEDIAL ALTERNATIVE
DESCRIPTION
ACTION-SPECIFIC ARARs
ARAR STATUS
COMMENTS
S()llKCi:-AKI:A Al II-KNA'IIV|-:S
Allci native SA I: No Action
Alttin.ilni: SA 2: ( unlainmtnt -
( appinu ami Vertical Harriers
• l.toiion ami sciliinciu conliol aiul
slorniwjlcr management
• Insiiillalion of'u cap
• Insiallalion ol a veihcal barrier
• Kcvegel.iliou ot llie cap
N_A
•10 CI l< 26>l, Snli|i,ni K
IOCSK 10-6 170
NA
Kdcvanl ,uul
Appiopn.ilc
Applicable
Hit; lagiiiHis al Area 18 aic suilaec uiipoiciuliiiciiis AKAUs .110
llic bame as iliscusscd iiiiilt-r Alicinalivc SA-7
l-'ugilive (lust emissions may he produced during itihlall.iluMi til
the cap. ARARs regarding fugitive dust emissions aic the same a,
described under Alternative SA-7
MY IHXPUMl.NIS'IINAl SOU. ARAR IXK'
-------
Alleimiihc W J: Kxca\alion nilh
Onsiic 'I luTinal Treatment,
lU'pliuemeiil unit 2-ft. C'uvcr
• I.fusion and sediment control and
stormwiilcr management provisions
• Selective excavation of muclivc
waste lagoons
• Collection of"ground water
infillialing into the excavation and
onsile trealineni
• Set up of low temperature Iliermul
shipping facility onsile
• 'liealnienl of excavated materials and
backfill onsile
• Installation of 2-fl. cover
• Kcvegclulion of disturbed urea
40 (TK 264^111^111 K
IOCSR25-7264(2)(K)
IOCSR 106.170
I DCS It 20-6.200
4(HTI<§264, Subpail X
4U(TK§265373
through 265 381
Relevant and
Appropriate
Applicable
Applicable-
Applicable
Ilic lagoons at Aiea 18 are surface impoundments AKARs aie
the same as discussed undei Alternative SA-7
l-'iigilive dust emissions may be produced dm ing m :.illation of
the cover AKARs regarding fugitive dust emissions uie tlie same
as desctibed under Alternative- SA 7.
ARARs regaidmg storm water managemem aie ihe same .is
described under Alternative SA-7
I be low lempeiatuie Iliermul liealnienl unit is classified a-, a
miscellaneous treatment unit under KCKA and -10 (TK |',nl 2
-------
SA-3 (Continued)
IOn:R§264.Suhpaill.
10 CSR 25-726-t(2)(l )
40 CFR §261
40 CFR § 264
40 C! R § 268
Applicable
Applicable
If ihe contaminated soil is determined to he ha/ardous and is
staged in piles before lieaimcnl, the Army is deleimincd lit be .1
large quantity generator, and the excavated soil lem.mis in lliis
area lor more than 90 days, Ilien llie remediation area is defined .is
a waste pile llie Stale of Missouri at 10 CSR 25-7 264(2 )(l )
incorporates by reference and sets foclh standards which modily
or add to llie federal requirements for waste piles in 40 C'l K I'.til
2fa4, Subpart I.. In order to be exempted from the waste pile
requirements in 40 CI-K § 264, Subpart I, which Missouri
incorporates by reference; 40 CI;K Tail 264, Subpuii I , which
Missoun incorporates by reference; ami 10 CSR 25-7.2(>4(2)(l.),
ihe waste pile must meet the following requirements, liquids or
materials containing free liquids' are not placed in the pile, llie pile
is protected from surface water run-on by the structure or in some
other manner, the pile is designed and operated to control
dispersal of the waste by wind, where necessary, by means other
than welling; the pile will not generate leachale through ^
decomposition or other reactions; and llie pile musi be at U-.isl icn
feel above Ihe historical high groundwater table II llie wasle pile
cannot meel ihe above slated requirements for exemption, then ihe
design and operating requirements and closure and post closure
requirements will provide ARARs.
ARARs under RCRA relate to disposal of waste mateiials
excavated from the site during construction and implementation
of the remedial alternative, where the soil exhibits ha/aidotis
characteristics (i.e., the TCl.P test exceeds regulatory levels)
Soil that is excavated will be (esled to determine if it is a KCKA
hazardous wasle. 40 CFR Part 261 lists Ihe maximum
concentration of contaminants for the toxicity characteristic basal
on TCl.P testing. Chemicals found in the soil at Area 18 and the
corresponding regulatory limits for the loxicily characteristic are
mercury (0.2 rng/L); lead (5.0 mg/L), PCI: (0.7 mg/l.); Ifl- (0 5
ing/l-); tolal cresol (200 mg/l.); vinyl chloride (0.2 mg/l.);
benzene (Q.S mg/l.); and I.I DCI-: (0.7mg'l )
MY IKKtlMUNISvHNAl SOU-AKAR IXK
-------
SA-3 (Continued)
1
Still thill is excavated will he tested lo determine it it is a RCRA
ha/ardous waste Ifil is and the hazardous soil is disposed of
onsile, I.DRs (-10 CFR 268) would be applicable Also, if the
waste is dcleiniined lo be lia/ardous, ItCKA sloiage rct|iiiieinciitt
under 40 (TK 264 would be applicable.
Because the contaminated soil will be excavated, Healed in a
sepaiate unit, and replaced in the excavation as backfill.
placement will occur Placement must comply with 1 l)l<
treatment slandaids found in 40 CH< 268 lla/aiduu-, soils aie
generally subject lo (he I.DK tiealment standards that appl) lo tlu-
lij/.iuluus wastes with which the soils aie contaminated
'freulmenl standards for listed wastes and lur wastes exhibiting
the loxicily characteristic ute puhlislied in 40 (TK § 268 40 Soil
containing a specific wasle can be land disposed as King .is the
concentration of the waste in the soil is below (he specified
treatment standard. The procedures for obtaining a tiealability
variance aie described al 40 (TK § 268 4-1 II ha/aid«ms. malei i.il
generated during construction ol the Aiea 18 icmetly will he
subject lo applicable provisions ol lU'KA foi dispns.il .is a
ha^.udous waste
Sediments and/or sludge lemovcd fiom llic Aica IK lic.iiinciil
system during ••operation and spent catalyst from the i,n,il>iic
oxidalitin unit will have to be deposed olaccouhng ID -II) ( 1 K
268 if ihey exhibit ha/ardous chaiaclerislics IT the FChklii.iK li,nii
the licatmcnt unit are determined to be haiaulous waste ami \\ill
be disposed of onsile, the LDKs will be applicable 1 DKs leqniic
thai RCRA hazardous wastes be Healed to protective level',
'specified in 40 (TR 268 prioi lo land disposal
I 'MYIXHIIMINIS'IWAI SOU ARARJXK'
-------
\lUinali\t-SA 5: I.\ca\alioir
Olfsile Ircalmenl and Disposal
• I nisiiui and sediment conliol and
sloimuaK'i manatjemenl piovislons
• Si-U-ilive i-\i.asalion nl mailive
\\asle layoons
• Collection ul giotmd ualer
iulillraliiiL' inlo Ihe excavation and
onsile neaimeiil
• 'lianspoilalion ol excavated maleiial
nllsile I'm uealment and disposal
• Hack filling of excavated areas with
clean (ill, regiailing, revegelalion
•10 Cl K 26-1, Suhpail K
K1CSK 25 7 2M(2)(K)
IOC SK 10 6 1711
IOCSK 20 62(10
•10 C'l K § 264
Uclcv.iui and
Appiopiiiile
Apphcahle
Applicable
Applic*al>le
I lie Ligiiuns .il Aiea IK aie iinlaie impimiidnienls AKAK1. aie
the same as discussed tinder Alternative. SA-7
J-iigilive dust emissions may lie pindiaeil dtniiii; cxiavatinii
AKAHs legauhng lugilive dust emissions aie llie same
-------
SA-6 Option l/SA-8 Option 2a
'.and Funning
• I iind limning ol cimlaininaled soil
willioi.laircoiiin.ly Land farming I KK'SR 10-6 170
option will be
i.fd in an tipe.i area without
any air control byi.em
Ixcava.cVOC.con.annna.edsoil f IOCSK 20-6 200
i'> J depth of apj)iox 20 li
»|Mt-ad2|| will layci oil Hie saml
\\ilh irc.iiL-il M)il
Relevant and
Appropiiate
I«CSK25-726J(2)(K)
SC. 7.|()|. 70.12
an Air Aci (('A A)
KM 'IK §50
IOCSK 10-6010
IOCSK 10-6060
n-ercury, and vinyl chloride. ,0 fSR .0-6
would be conducted «o be
and the envir and would
b
is subjec. ,0 approval according
40CFR§264.Subpart
10 CSR 25-7.264(2X1.)
ARARs regarding .he use o
cs ,„ iaKe extaval . ,„
'"<
< MY IXH (IMtNIVHNAl Mill ARAR IHX'
6
•
-------
SA-6 Option I /SA-8 Option 2a
(Continued)
SA-6 Option 2/SA-Hi Option 21)
I.and I-a nil in 14
• Land larming ol the contaminated
soil with air conliols This will
include collodion and ireaiinenl of
vapois generated during land
(mining Land fanning under this
n|i(ii)ii will be peiloimed in a
closed blmcluie
• Lxcavale VoC-tonlaminaled soil
ID a depth of approx. 20 ft.
• li.nklill \\nli liciticd soil
•IO(TK§26I
40 Cl R § 264
40C1K§268
40 (TK 264, Subparl K
IOCSK 2S-7.264(-')(K)
IOCSK 10-6.170
IOCSK 20-6.200
40C!-R§264.IIOI
40CFR§264.II02
Ap|)licubk
Relcvanl anil
Applicable
Applicable
Applicable
Although llie ireaiinenl processes ate dilleienl under Allem.ilives
SA-3 and SA-6 Option I/SA 8 Option 2a, these ARARs for the two
alternatives are similar. Refer to Alternative SA 3 lor a desuiplion
of RCRA ARARs.
The lagoons at Area 18 aie surface impoundments ARARs aic the
same as discussed under Alternative SA-7
l-'ugiiive dust emissions may be pioduced during excavation
ARARs regarding fugitive dust emissions aie the same as descnbed
under Alternative SA-7.
ARARs legaiding storm water management aie llie s.ime .is
descnbed undci Alleinalive SA 7
Pursuant to this remedial alternative, the land farming leilmolngy
will be performed using air controls. If the method of controlling
air emissions is classified as a containment building under RCRA,
the design and operating requirements at 40 CFR § 264.1101 and
the closure and post-closure care requirements at 40 Cl K §
264.1102 are ARARs. The Stale of Missouri has no equivalent
provisions to 40 CFR § 264.1101, Design and Operating Standard:,
for Containment Buildings, and 40 CFR § 264.1102, Closure and
Post-closure Care.
( MY UOCUMbNIVHNAI SOU ARAR UOC
-------
SA-6 Option 2/SA-8 Option 2b
Land Farming (continued)
42U.S.C.740I-7642
•jo cm § so
IOCSR 10-6010
10 CSR 10-6 060
40CTR§6I
10 CSR 10-6.080
40 CFR §261
•)0 CFR § 264
40 Cm § 268
Applicable
Relevant and
Appropriate
Applicable
Clean Air Act (CAA)
I lie lancllarming operation would be subject to the ait pollution
control standards of the Clean Air Act. Emissions from the
landfarming vapor treatment unit will meet (he applicable federal
and Mate criteria under the standards of the Clean Air Act 40 CI'K
50 specifies Ambient Air Quality Standards for sullur dioxide,
carbon monoxide, ozone, nitrogen dioxide, paniculate mallei, and
lead that are protective of public health. 10 CSR-6.010, Ambient
Air Quality Standards, has (he same requirements as 40 CI-K 50 and
adds ambient air quality standards for hydiogen stilfule and sulfuric
acid 40 CFK 61 establishes emissions standard; for benzene,
beryllium, mercury, and vinyl chloride. 10 CSR 10 6 080 adopts
the requirements of 40 CFR 61 for these constituents. Ben/ene,
beryllium, mercury, and vinyl chloride may he presenl at Aiea 18
10 CSK 106 060 establishes Ju nnnunin levels I'm o/one emission-,
of 40 Ions per year and vinyl chloride emissions of I tun per year
The iale of landfarming would be conducled lo he protective of
human health and the environment and would meet (lie .ipplu able
emission stand.uds. Opeialing parameters would he listed m (lie
RD/KA woikpl.m which is subject lo appioval iiciuulmg in I I A
provisions.
AKAKs under KCKA relate lo disposal of waste mulciiaK uxcav.iud
from the site during constniction and iinplenienlulion ol llie
remedial alternative, where (he soil exhibits ha/aidous
characteristics (i.e., the TCI.I' lest exceeds regulatory levels) Soil
thai is excavated will be tested lo determine if it is a KCKA
hazardous wasle. 40 CFR Part 261 lists the maximum concentration
of contaminants for the loxicily characteristic based on TC1.P
testing. Chemicals found in the soil at Area 18 and (he
corresponding regulatory limits for the loxicily characteristic are:
mercury (0.2 mg/L); lead (5.0 mg/l.), PCI: (0 7 mg/l.); TCI-i (0.5
mg/|.); total cresol (200 mg/L); vinyl chloride (0.2 mg/l.); ben/ene
(0.5 mg/l.); and I, I DCK (0.7 mg/l.)
C MVDIK IIMI.NISHNAI SOU AKAR DOC
-------
SA-6 OpliDii 2/SA-8 Option 21)
l.und Farming (continued)
C MY I)(H UMI.NIS-HNAI SOIL ARAR DOC
Since the contaminated soil will be disposed of ollsile, I.DRs .ne not
AKARs (although transporters and disposal facilities must comply
with applicable RCRA regulations under 40 CTR 264 and 40 (TK
268) However, if the svaste is determined to be ha/aulons, KCKA
storage requirements under 40 C.TR 264 would be applicable
Because the contaminated soil will be excavated, treated in a
separate unit, and replaced in the excavation as backfill, placement
will occur Placement must comply with I OR lie.unieiil bltiiulaids
found in 40 ('I K 268 lla/ardons soils are generally .subject to the
I.DR treatment slandaids that apply to the ha/aulous wastes with
which the soils .ire contaminated 'treatment si.uul.cnl-> lot listed
wastes and for wastes exhibiting the loxicily chai.ick'iisln. .lie
published in 40 CTR § 268 40 Soils continuing a specific waste i.m
be land disposed as long as (he concenli.ilion of the waste in (he soil
is below the specified treatment standard. I he procedmes lui
obtaining a treatability variance are descnbed at 40 CTK § 268 44
If hazardous, material generated during construction of the Aiea IK
remedy will be subject to applicable provisions ol RCRA I'm
disposal as a ha/ardous waste. Also, sediments aiul/oi sludge
removed from the Area 18 treatment system during operation and
spent catalyst from the catalytic oxidation unit will have to he
disposed of according to 40 CTR 268 if they exhibit lu/,minus
characteristics. If the residuals from the treatment unit are
determined to be hazardous waste and will be disposed ol onsile, the
LDRs will be applicable. LDRs require that RCRA ha/aidous
wastes be treated to protective levels specified in 40 (TR 268 pi 101
to land disposal.
-------
SA-7 Iii-Sitii Soil Vapor Kxlrucliiiii
and I iralnicnl
• Soil vapor exli action using a
multi-phase extraction system
urn! treatment of extracted
ground water and vapors to
addiess VOC (volatile
organic compoinul)-
cotituininaled soil and
shallow ground water in
souice areas.
• lixeavation and disposal of
lead-conlaniinuled soil.
• (iiotind water extraction and
treatment.
Institutional controls to limit
future site use.
• I.ong-tenn monitoring.
•IIHTK26I. SulipjilK
lOCSR25-726-l(2)(K)
42U.SC 7-101-7642
40 CFK § 50
IOCSR 10-6010
IOCSR 10-6.060
40CTR§6I
IOCSK 10-6.080
IOCSR 10-6.170
IOCSK 20-6.200
Relevant and
Appropriate
Applicable •
Relevant and
Appropriate
Applicable
Applicable
I he lagoons .it Aiea 18 ate sin due impuiinihncnls 1 lie Si.nc ul
Mibsoini at 10 C'SR 25-7 20-I{2)(K) muiipoiates liy lelueiuc .in,I
sets forth standards which modify or add to the ledei.il
requirements for surface impoundments in 40 (TK Part 2(>4,
Subpart K. The closure and post-closure requirements in 40 C'l-'R
§ 264, Subpart K and 10 CSR 25-7,264(2)(K) are relevant and
appropriate.
Clean Air Acl(CAA)
Puisuant to this alternative, extruded giound walei and vapors
will be treated at the Area 18 licalment plant CAA leqiiiicmcnis
for this remedial alternative aie the same as described uiulci
Alternative GW-3/GW-4. Refer to Alternative UW-J/GW-l l.u
discussion.
!:ugitive dust emissions may be produced from the excavation
activities The Stale of Missouri at IOCSR 10 6 170 lesincis
persons from causing or allowing fugitive pailiuil.tie matin to p>
beyond the premises where such mailer originates I he
limitations on the quantities as well as exceptions to the nilc ;uc
described in detail at 10 CSR 10-6 170
•I he requirements of 10 CSR 20-6 200 apply to all pcisons ulm
disturb land that may result in a storm water point source I he
regulations require that best Management 1'iactices (DMI's) for
controlling stonn water runoff, erosion, and sediment tiaiisport
must be employed. BMPs include actions such as the use of
stabilized construction entrances and roads, silt fences, dikes,
sediment retention ponds, erosion control nials/hlaiiktis, aiul/m
planting vegetation. The types and locations of sediment ami
erosion control measures will be determined during remedial
design and will be addressed in the conMiuciion work plan or
remedial design documents. Vegetative stabili/alion pioicdtites,
practices, and standards will be consistent with U'AAP standards
and MDNR requirements.
I -MY IXXmifcNISM INAI. SOU. ARAR I)OC
10
-------
SA-7 lu-Silii Soil Vapor Extraction
and Treatment (continued)
42USC300(g)
4<)CIR§ Nl
10 CSR 60
33 USC 1251-1376
40CI-K401 5
IOCSR23-4010
10 CSR 23-4.060
10 CSR 23-4 070
Relevant and
Appropriate
Applicable
Safe Drinking Water Act (SDWA)
Requirements of the SDWA aie llie same as under Allcmaiivc
|eil to revii/u
according to l-'f-'A provisions
11
( .MYIMHIJMLNISHNAI SOU. ARAR IKK'
-------
SA-7 ((Oiiliiiiii-il)
•ioriu§2oi
40 (IK §2d 1
401TR§268
Applicable
I in the Aic.i 18 iciiieiliiiiiiui. AKAKs under KCKA lel.ilc In
disposal of waste nialciials excavated liiini lite site dniini/,
construction and implementation of the remedi.il altername.
where (lie soil exhibits hazardous characteristics (i e . (he I (.'I I*
lest exceeds regulatoiy levels) 40 CTR Pail 261 lisis the
niaxiiniini concentration of coiiliiininunts for the toxicity
cliuracleriMic based on 'I ('II' testing Chemtculs Ibund in the snil
at Area 18 and the corresponding regulutoiy limits foi (lie toxicil>
cliiiracleiislic uie: nieiciny (0 2 ing/I.), lead (5 (I ing/1 ),!'('!•(() /
ii)g/l.), TCL (0.5 mg/l.), total ciesol (200 ing/L), vinyl diloiulc
(0.2 mg/l.); ben/ene (0 5 mg/l.), and I.I DC'I- (0 7 nig/I.) S(.il
thiil is excavated will be tested to dckiimnc if n i-> ,i ItCKA
hazardous waste If it is and the li.i/mduus soil is disposed ul
onsile, I.DRs (40 Cl R 268) would be applicable Hdclciinined In
be lia/ardous, conlaniinaled niedi.i geneialed dining uinsimiiinii
of the Aiea 18 remedy will be subject to applicable |)iuvhiuiii ul
RCRA lot disposal as a lia/.nduiis w.ible AKn, .si-iliinenl. .iihl m
sludge rcniDved from die Area 18 licalnicnl syilcni diniiu1
opcialum and spent catalyst finin Ihc catalytic ouil.iimn uiui \s ill
have to be disposed ul actoidmg to -10 ('I l< 2iiK il llu^ cxluliil
ba/aidiuis characteristics
12
I MY DIM IIMINISIINAI SOU AKAK 1MK.'
-------
SA-8 Selective Excavation and
Treatment Option I
• Selective exciivulioii with trcalineiu by
iim temperature llicimal dcsorption
(I II'D)
40 C.TR 264, Snbpart K
IOCSR25-7264(2)(K)
IOCSK 106.170
IOCSR20-<)200
40lTR§264,Subpail X
40 Cl R §§ 265 373
through 265.381
40 ITR § 264, Subpail I.
10 CSR 25-7264(2)(l.)
40CI-R§261
40 Cl R § 264
40 CFR § 268
Relevant and
Appropriate
Applicable
Applicable
Applicable
Applicable
Applicable
I lie lagoons at Area 18 aie surface impoundment:) AKAKs arc
the same as discussed under Alternative SA-7
Fugitive dust emissions may be produced duimg installation ol
the cover. AltARs regarding fugitive dust emissions aie the same
as descubed under Alternative SA-7.
rcgiiulmg sloim water management aie the ->.imc ,r>
described under Alleinative SA-7.
AKARs legaidmg tbe l.'l I'D unit aie the same a^ do>uibcd
Alternative SA-3.
ARARs regarding the use of piles to stage excavated maleiial.s ,iu
the same as described under Alternative SA-3.
These RCRA ARARs are the same as described under Allcmaluc
SA-3.
I MY IKK IIMIN1S IINAl SOU ARARIXX:
13
-------
SA-8 Selective Excavation and
Trculincnl Option 3
• Soil will lie excavated and lianspuiled
off-site for Itculiiiciil iiiul disposal
40 CFR 264. Subpart K
IOCSR25-7264(2){K)
IOCSR 10-6.170
IOCSR 20-6.200
40 CFR §261
40 CFR § 264
Relevant and
Appropiiale
Applicable
Applicable
Applicable
The lagoons ut Area 18 ure surface impoundments ARARs uic
(lie same as discussed under Alternative SA-7
Fugitive dust emissions may be produced dining excavation
ARARs regarding fugitive .dust emissions are the same as
described under Alternative SA-7
ARARs regarding storm water management are the same as
described under Alternative SA-7.
'Ihese RCRA ARARs are the same as described under Alternative
SA-5
Notes Ucciiuse the Stale of Missouri has received RCRA base aiilhoiiialion for certain parts of the RCRA Hazardous and Solid Waste Amendments (IISWA) of I9K I ID
administer and enforce the RCRA hazardous waste management programs in lieu of the federal program, the State hazardous waste regulations svill provide AKAK:> In
addition, (lie Stale of Missouri in many instances incorporates by reference the federal hazardous requirements and sets forth Slate requirements which modify or add in the
federal ict|niicmenls and the Slate has modified or added to the federal regulations, the federal citation lius also been provided in lite action-specific AKAKr, l.ihlc
14
( MY IKK IIMI N1SHNAI SOU AKAK IKK.
-------
''• Final Record of Decision Area IS Operable L'nit
Lake City Army Ammunition Plant. Independence. Missouri
APPENDIX D
APPLICABLE
OR
RELEVANT AND APPROPRIATE REQUIREMENTS
February 1998
-------
-------
Action-Specific ARARs
-------
-------
DHSCKINION oi KI:MI;I)IAI. AI.TI-:UNATIVI-.S AND SUMMARY oi- ACTION-SPI-CII-IC: AKAK-,
HKMKDIAL ALTERNATIVE
DESCRIPTION
(iKOUND WAII-K Al.ll.KNAIIVI.S
Allti nali\e l onsile air
stripping lower
•' Continued discharge of treated
\\aler to onsile water treatment pi.ml
• (imniul \\ ater monitoring for the
next 3D >ears
• Deed restrictions loi giotnul wulei
usage
• lieulinent nl contaminated ground
\\aler before use by ollsile users
ACTION-SPECIFIC ARARs
NA
42 I ISC 300(1)
IOCSR60
» USC 1251-1376
40 CT'K§ 403.5
40 Cl R § 264 Subpart X
ARAR STATUS
NA
Kelevant and
Appropriate
Applicable
Relevant and
Appropriate
COMMENTS
Ground water AKAKs aie descubed under the disuus.iion ol
Alternatives (iW-3/GW-4 below AKAKs related to drschar^c ol
treated giound water are discussed tiiuler the various tlisLli.uge
items listed under Alternatives (iW-3/(iW-t
S.ite Dunking Water Act (SDWA)and Stale Dunking Water
Regulations
AKAKs are the same as discussed under Alternatives (iW H AV
4.
Clean Water Act (CWA) and Slate Suilace Water (,>ualii)
Regulations
ARARs fur discharge of treated ground water aie the same as
discussed under Alternatives (iW-3/(iW-4, Option III.
The thermal oxidation unit used to treat the collected vapors is a
miscellaneous treatment unit under RCKA AKAKs aie the same
as described under Alternatives (iW-MiW--l
( VMYIKHUMLNISUINAI UW ARAR IKK.'
-------
Allcraulhc (,'\V-2 (Continued)
42 USC 7401-76-12
•10 CTK § 50
IOCSK 10-6 010
IOCSK 10-6 OWI
•H)CIK§6I
IOCSK 10-6080
•40CIK§26I
•40 ('IK §268
Applicable
Kelevunl itiul
Appropriate
Applicable
Clean Ail At! (CAA)
I lie operation ol (he Area 18 .Hi Miipper ih MibjeU In the .111
pnlliituiu cunliiil Mandaids ol Ihe Clean Ail Act as deM.nbed
under Alicm.iiivcs (iW-3/(i\\'--l
•10 C'l-R I'jrl 261 liils llic niiixiiiiuiil coiicenliiiliou ol
contaminants foi the loxicily ch.ii.icieiishc based on III I'
testing, lithe residuals from the liealmcnl unit are tlclciiniiicd in
be hazardous waste and will be disposed of OIIMIC, I he I I )!<•> \\ ill
be applicable I.DKb require that KCKA lia/aidous wastes be
treated to protective levels specified in -10 U K 268 pilot lo l.uul
disposal
( MYUOLUMtNlSJ-INAI (iWAKARtHK;
-------
Alternative <;\V-J/<;\V-4: Kxliaction
Wells/Air Stripping/Catalytic
Oxidalioii/Discliaite to I'OTW
• lifii.dl.iiinn nl (Jioiiiul water
cMiaUKm wells iiiul associated
piping
• Inslall.iiiim til .111 snipping lower
• I'lovide process piping lor
discharge loPOIW
• (iiound \\alei monilunng
42 USC 30()(g)
40CIK§ l-ll
IOCSK60
3) USC 1251-1)76
IOCSR 23-4 0)0
IOCSR23-4060
10 CSK 23-4 070
Relevant and
Appiopiiale
Applicable
Sale I)i inking Water Act (SI)WA)
40 CI-R 141 establishes MCI s lot specific coiil.iminiints in puhlu
drinking \viiler 40 ('IK 141 also piuvides MCI (is which aie sel
ut levels i»f unknown or anticipated adverse health eflecls with
and adequate margin of safely MCl.s ami MCI (is aie generall)
applicable under SDWA tu the quality nidi inking water ill (he
point of distribution for consumption 1 hey are consideied
relevant and uppropiiale to giomulwulei that may be used lui
drinking 10 CSR 60 requires (hut all giound water used loi
di inking water is to be treated to drinking walei sland.nds 1 he
Lake City aquifer is a drinking water aquifer and is used by
l.CAAP as a water supply.
Clean Water Act (CWA)
CWA icquiiemenlsare discussed nndei ihe disUi.uge opiums
listed below
As a pail of this lemedial alleinalive, exlraclmn wells will lie
constructed. The substantive requirements of the Rules ol the
Missouri Department of Naluial Resources, Division ot (ieologj
and Land Survey, Chapters 1 through 6 apply to all wells at
I.CAAI*. Extraction wells used in site remediation are legulaied
by Chapter 4, tilled "Moniloiing Well Construclion Code," and
are included in the definition of "monitoring wells " Among oiliei
things, the Chapter 4 rules sel foiih cnleiia l»r Ihe geneial
protection of ground water quality and resources -Ciiieii.i lot die
placement ol wells is specified in IOCSR23 -40(0 Kit SR j )
4.060 specifies construction slandaids However, acuiidmg In 10
CSK 23-4 060, the slandaids for consliuctiun ol UMI.KIIOII wells
is determined on a case-by-case basis by the division 1 hese
details will be provided in the RD/RA woikplan subjcu to icvieu
according to 1 FA provisions.
I MY IMRIIMhNISvUNAI. liW AKAR 1HK'
-------
Allci native <;\V-J/(,\V-4 (C'uitliiiiivJ)
•12 USC 7-101-76-12
•10 (I k§50
10 CSK 10-6010
IOCSK 10-6060
-10 ( IK §61
10 CSK 10-6080
Applicable
Applicable
Relevant and
A|i|>ropiiale
I lie thermal oxidation unit used to treat the colleued vapors is
classified as a miscellaneous iiealmenl unit under KCKA and -III
n K I'.ul 261 10 CSK 2S-7 26-1. Standards lot Oxvuers and
Opei,tl nt Hazardous Waste liealmcnl, Storage and Disposal
Facilities, is llie stale rule that coiresponds to •]() H K 1'ail 26-t.
Standards lor Owners and Operators of llasardons Waste
I rcattnent. Storage and Disposal Facilities I Ire State of Missoin i
does not have any provisions pertaining to miscellaneous
treatment units. 40 Cl-'R 264, Suhpart X sets forth design,
operational, and monitoring requirements for miscellaneous
treatment units to ensuie operations are protective ol human
health and the environment It also references requiiemenls ul -III
CI K 2d I Subpails I iliiinigh (> and AA ihioinjli ('(' I lie desiyn.
opcialmg, and nionitoiing paiamcleis ul llic lie.ilnicni mill s\ ill In-
spetilicd in (he KD/KA woikpLui xvliKli is snlijcU in ,ip|iui\.il
aiioidtng to II A provisions
Clean Air Act(CAA)
'I he opeiation of the Area 18 an sirippei is sul>|ci.l ID the ,m
pollution control standards ot the Clean Ail Act I he icleasc »l
otf-gas by the Area 18 ait stripping unit is introduced lo a
catalytic oxidation unit which destroys VOCs imparted in the
vapor phase. 'I he emission fiom the catalytic oxid.iinm unit u ill
meet the applicable federal and stale ciileria under (he standard-,
of the Clean Air Act. 40 CT'K 50 specifies Ambient An (Juulil)
Standards for sulfur dioxide, caibon monoxide, o/one, nitrogen
dioxide, paniculate matter, and lead that are protective of public
health. 10 CSR-6.010, Ambient Air Quality Slandaids, has the
same requirements as 40 CFK 50 and adds ambient air quality
standards fur hydrogen sulftde and sulfuric acid 40 CI K 61
establishes emissions' standards for benzene, beryllium, mercury,
and vinyl chloride. 10 CSK 10-6 080 adopts the requirements ol
40 CI-K 61 for these constituents Ben/ene, beryllium, niercmy,
and vinyl chloride may be present at Area 18. 10 CSK 10-6 Odd
establishes Je minimus levels for o/one emissions of 40 Ions per
year and vinyl chloride emissions of ! (on per year.
NU^H
HIIMINISMNAI (iWAHAKIXK;
-------
AlfiTiialtM- (,\V J/(.W 4 (Continued)
•IO(TK§ 261 I01J
40 (IK §261
•IOCIK§2(>8
Applicable
Applicable
I lie Opel.lllOII Ol'llle AUM I 8 illl Sllippei IS Mll>|eil Id the
iei|uiieinenis id -10 (IK ->6l KIJ2, wlni.li iconics lli.u ihc im.il
organic emissions from .ill piocess vents be reduced to below 1 I
Ions per yu.ii oi be reduced by "S peiteni b> weight I lie ledei.il
siandaid is nioie stringent Ih.in ilic MIWHIII il.nutanl lot cinibsiuii
linillb iiiulei IIK'SK 10-6 100, llieref'oie, the ledei.il M.ind.iid liu
opcialum ol lite dii siiijiper vsoiiltl be jpplk.ihle
l-or the Aiea 18 lemedialiun, AKAKs undei Kl'KA lelale lo
disposal ol w.isle inalciiah excavated I'riiin lliu iilc duinii;
coiiblriiLlion and iinpleiiienlulion oldie icineili.il .ilicm.ilivc,
where the waste inalcnals exhibit lia/ardous cliuiaLlciislus (i c ,
the 'ICI.P test exceeds regulatory levels) -JO C'l-'K I'ait 2M lists
the maximum concentration of contaminants for the loxiciiy
characteristic based on TCl.l' testing. Chemicals found in the soil
at Area 18 and the corresponding regulatory limits lot (he loxiciiy
characteristic are: mercury (0 2 mg/L); lead (5 0 mg/l), l'( I (0 7
mg/l.); TCI: (0.5 mg/l.); total cresol (200 mg/l.); vinyl clilmule
(02 mg/l.); benzene (0.5 mg/l.); and 1,1 DCIi (0 7 my I ) Soil
that is excavated will be tested lo determine if it is
-------
V T
-------
Location-Specific ARARs
f
-------
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LOCATION-SPECIFIC APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS FOR LAKE CITY ARMY
AMMUNITION PLANT(a)
Citallon
Wilhin area affecting stream or
river—and—presence of fish or wildlife
resources
Must lake action to protect fish or wildlife
resources; prohibits diversion, channeling, or
other activity that modifies a stream or river
and affects fish or wildlife.
Federal agencies should consult with the Fish
and Wildlife Service and State personnel to
develop protective measures for affected
wildlife.
Presence of fish and wildlife resources;
action by Federal agencies resulting in
(he control or structural modification of a
natural stream or body of water.
Offsite response actions.
Fisli and Wildlife Coordination
Acl(16USC66!etseq);
40CFR6.302(g)(l994)
Presence of wetlands as defined in
Executive Order 11990 §7(c) and
40 CFR § 6, Appendix A § 40) (1994)
Whenever possible, actions must avoid or
minimize adverse impacts on wetlands and
act to preserve and enhance their natural
and beneficial values. New construction in
wetlands areas should be particularly
avoided unless there are no practicable
alternatives.
Wetlands protection considerations shall be
incorporated into planning, regulating, and
decision-making processes.
Action which involves:
• Acquiring, managing, and disposing
of lands and facilities.
• Providing Federally undertaken
finances, or assisted construction and
improvements.
• Conducting Federal activities and
programs affecting land use.
• Executive Order 11990
• 40 CFR §6.302(a) (1994)
• 40 CFR § 6, Appendix A
(1994)
Presence of wetlands as defined in
40 CFR § 230.3(1) (1994) and 33 CFR
§ 328.3(b)("
* Action must be taken to avoid degradation
or destruction of wetlands to the extent
possible. Discharges for which there are
practicable alternatives with less adverse
impacts or those which would cause or
contribute to significant degradation are
prohibited.
• If adverse impacts are unavoidable, action
must be taken to enhance, restore, or
create alternative wetlands.
Action involving discharge of dredge or
fill material into wetlands.
Clean Water Act § 404
(33 USC§ 1344(1991
40 CFR §230 (1994)
33 CFR § 320 330("
(a) Adapted from EPA (1994).
(b) There are no comparable State requirements.
-------
Elfiadolains
Within 100-year floodplain
Within "lowland and relatively flat
areas adjoining inland and coastal
waters and other flood prone areas
such as offshore islands, including at
a minimum, thai area subject to a one
percent or greater chance of flooding
in any given year." (Executive Order
11988 § 6"> and 40 CFR 6, Appendix
A § 4(d)J
• Treatment, storage or disposal facility
• RCRA' - defined listed or characteristic
hazardous waste (40 CFR 261) -or-
RCRA-permitted facility
i
• Action which involves:
- acquiring, managing, and disposing of
lands and facilities
- providing federally undertaken.
financed, or assisted construction and
improvements
- conducting federal activities and
programs affecting land use
• Facilily must be designed.
constructed, operated and maintained
to prevent washout of any hazardous
waste by 100 year flood
Action shall be taken to reduce the
risk of flood loss, minimize the
impact of floods on human safety,
health and welfare, and restore and
preserve the natural and beneficial
values of floodplains.
The potential effects of actions in
floodplains shall be evaluated and
consideration of flood hazards and
floodplain management ensured.
If action is taken in floodplains,
alternatives to avoid adverse effects,
incompatible development, and
minimize potential harm shall be
Citation
40 CFR 264.18(b)
Executive Order 11988
40CFR6.302(b)
40 CFR 6 (Appendix A)
(a) Adapted from EPA (1994).
(b) There are no comparable Slate requirements.
-------
Additional ARARs Provided by the State of Missouri for the
Selected Remedy
-------
-------
TABLE 1: CHEMICAL-SPECIFIC REQUIREMENTS
Chemical
Maximum Concentration Allowed
Medium
Reason Why Requirement is an
ARAR
Regulatory Citation
lead*
1.5 micrograms per cubic meter using method
specified in 10 GSR 10-6.040(4)(G); Calendar
quarter arithmetic mean not to be exceeded
ambient
air
Provides the regulatory maximum
allowable level of lead in ambient air
for protection of public health and
welfare.
fAALs:
for lead 0.36 micrograms per cubic meter (24
hour averaging time); for lead acetate 0.01
micrograms per cubic meter (24 hr. avg. time);
for lead compounds 2.00 micrograms per cubic
meter (8 hr avg. time)
AALs are calculated for acceptable
fenceline concentrations for
protection of public health and
welfare.
10 CSR 10-6.010, "Ambient Air
Quality Standards."
10 CSR 10-6 040, "Reference
Methods."
N/A
particulate
matter 10
micron* (PM,0)
50 micrograms per cubic meter annual arithmetic
mean; method as specified In 10 CSR 10-
6.040(4)(J)
150 micrograms per cubic meter 24-hour
average concentration as determined 10 CSR
10-6.040(4)(K)
ambient
air
Provides the regulatory maximum
allowable level of particulate matter
for protection of public health and
welfare.
10 CSR 10-6.010, "Ambient Air
Quality Standards."
10 CSR 10-6.040, "Reference
Methods."
Others
See attached list of AAL's
ambient
air
AAL's are calculated for acceptable
fenceline concentration for protection
of public health and welfare.
Refer to list
•Lead and particulate matter are two of eight pollutants for which ambient air quality standards have been promulgated in this section of the slate rule The other
six are: sulfur dioxide, carbon monoxide, photochemical oxidants (ozone), nitrogen dioxide, hydrogen sulfide and sulfuric acid.
fA current list of draft AAL's (Acceptable Ambient Levels) is attached. AAL's in this list were developed by the Mo Dept of Health MDOH/MDNR taken from an
existing standard, or adjusted for ambient exposure from an existing standard as indicated In the "Source" column. The AAL's in this list refer to acceptable
fenceline concentrations.
-------
,^, ?„„junsooon of'^^ ^toStiftT^*"«»«*»**"*»•.City
air pollution regulations which apply to this area are Chapte 2! "A?SCfrnSSi R ? Q 9f,ed 'OCal a9encleS-) In general, the sections of the
SST,?' 2* QUBllli!Slandard8'Definitions' Sarrtp^g £ IJISSS^^SSS^ ^X?™? Cily Melrop0liian Area-"and
Missouri. The preceding table, TABLE 1, and the followlna table TABLE ?«H«mntio * ,u" Contro1 Re9"'aHons for the Entire State of
chapters. Additionally, TABLE 1 lists some non^dlhSH^ •"*•«• "H-hn. from these two
^^"•M^MMHIIIiaAB
Action subject to Requirement
Existence of visible emissions"
Existence of odors
Open burning
Particulate emissions leaving
property of origin0
Emission of air contaminants
Requirement
TABLE 3: ACTION SPECIFIC REQUIREMENTS
Specifies the maximum allowable
shade or opacity of visible air
contaminant emissions
Restricts the emission of
excessive odorous matter
• —
Restricts open burning of refuse,
trade wastes, etc.
Restricts the emission of
participate matter to the ambient
air beyond the premises of origin.
(This applies not only to the
operation itself, but also to the
construction and use of the non-
public access roads on site
. __
Jpon request, any source shall
complete, or have completed,
ests of emissions or. at the
option of the agency, make the
source available for tests of
emissions.
•••mMUB^^^
Reason Why Requirement Is an
ARAR
, " i«-
Limits visible emissions at the
site, (from excavation, access
roads, etc.), thereby limiting the
release of contaminants into the
ambient air
—
Protects the surrounding property
owners from excessive odors
— ,
Prevents release of ambient air
contaminants from open burning
Restricts paniculate emissions
from the site (from excavation,
access roads, etc.) to the
property of origin, thereby
protecting the surrounding
property from contamination
Provides data necessary to
determine if engineering controls
used for the operation are
preventing the release of air
contaminants into the ambient air
Regulatory Citation
10 CSR 10-2.060, "Restriction of
Emission of Visible Air
Contaminants"
10 CSR 10-2.070, "Restriction of
Emission of Odors"
- —
10 CSR 10-2.100. "Open Burning
Restrictions"
10 CSR 10-6.170,'Restriction of
Particulate Matter to the Ambient
Air Beyond the Premises of
Origin"
10 CSR 10-6.180. "Measurement
of Emissions of Air
Contaminants"
^ Ai,
Con,rol Pro9ram
-------
Summary and Recommendations; ;
These tables listing ARARs are based on the information provided in the Draft ROD. The major
components of the project that are of concern to the Air Program are soil vapor extraction (Multi-Phase
Vacuum System - MPVE) and treatment of vapors, excavation and consolidation of lead-contaminated
soil, earth cover to address surface soils, and ground water treatment (air stripping/catalytic oxidation).
The following state rules are not listed as ARARs for the reasons given:
10 CSR 10-6.070, "New Source Performance Regulations.' which establishes acceptable design
and performance criteria for specific source categories construction new or modified emission
sources.
10 CSR 10-6.075, "Maximum Achievable Control Technology Regulations," which establish
emission control technology, performance criteria and work practices for specific source
categories that emit or have the potential to emit hazardous air pollutants.
10 CSR 10-6.080, "Emission Standards for Hazardous Air Pollutants," establishes emission
standards and performance criteria for specific source categories emitting hazardous air
pollutants.
10 CSR 10-6.240, "Asbestos Abatement Projects - Registration, Notification and Performance
Requirements," and 10 CSR 10-6.250, 'Asbestos Abatement Projects - Certification, Accreditation
and Business Exemption Requirements,* which regulate tile handling and disposal of asbestos
containing materials.
The regulations allow for a prescribed amount of visible emissions. However, due to the nature of the
contaminants, it is recommended that no visible emissions be allowed from the excavation and handling
of the contaminated materials.
Ambient Air Quality Standards for lead and particulate matter (as well as sulfur dioxide, carbon monoxide,
photochemical oxidants (ozone), nitrogen dioxide, hydrogen sutfide, and sulfuric acid) are codified in the
state regulations. The "acceptable ambient levels* are not codified specifically. However, health-based
AALs exist for many of the chemicals present at this site. The AAL's are used in the permitting process.
(Current list attached.)
Many of the chemicals present are also categorized as hazardous air pollutants (HAPs). The de minimis
level of HAPs is 10 tons/year for any single HAP or 25 tons/year for any combination of two or more HAPs.
(De minimis levels are used to determine the level of regulatory review. They do not represent
determined 'safe* levels.)
The concentration of air contaminants at the fenceline should remain below the Acceptable
Ambient Levels provided in the attached list Adequate modeling/monitoring of the ambient air for
air contaminants should be implemented to determine if engineering controls are sufficient to
protect public health and the environment
This is a Superfund project and therefore is not required to obtain an actual permit, but is required to meet
the substantive requirements of the state rules. Missouri State Rules, 10 CSR 10-6.060, "Construction
Permits Required,* and 10 CSR 10-6.065, 'Operating Permits Required.* provide a mechanism for the
state to review sources of air pollution and determine if they are in compliance with the air pollution control
requirements, AAL's, laws and guidances. Adherence to the AAL's and performance of adequate
monitoring to determine this should be considered the substantive requirements of these two rules.
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-------
October 20, 1997
ADDENDUM
Please be aware of the data that this report does not present:
1. The report does not contain the CAS Numbers for nickel
refinery dust dipropylene glycol methyl ether acetate, and
tripropylene glycol methyl ether.
2. The report incorrectly lists the asbestos AAL units as
ug/m , rather than the correct units, fibers/mL.
3' AALSreP°rt dOSS n0t liSt thS followinS Pollutants' 1-hour
• Bromine (CAS# 7726-95-6), 0.33 mg/m3 .
• Dichloroethyl ether (CAS# 111-44-4), 0.287 mg/m3
• Dime thy lamine (CAS# 124-40-3), 49 ug/m3.
• Hydrogen Cyanide (CAS# 74-90-8), 11 mg/m3.
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-------
-fl
Monday, October 20, 1997
DRAFT ACCEPTABLE AMBIENT LEVELS FOR MISSOURI
(•AAL CONCENTRATION * ug/m3|
i'aga 1
Chanical
ACBPHATB
ACBTALDBHYDB
ACBTAHIDB
ACETIC ACID
ACETOUS
ACBTONITRILH
ACBTOPHENONB
ACBTYLAMINOPLUORIHB , ( 2 - I
ACETYLENE
ACROLEIN
ACRYLAMIDB
ACRYLIC ACID
ACRYLONITRILB
ALACHLOR
ALAR
ALDICARB
ALDICARB 6ULPONB
ALDRIN
ALLY
ALLYL ALCOHOL
ALLYL CHLORIDE
ALUMINUM
ALUMINUM OXIDB
ALUMINUM PHOSPHIDE
AHDRO
AMBTRYM
ANINO-2-MBTHYLANTHRAO.UINONB, 11-)
AHIHOANTHRAQUINONB, [2-1
AHINOAZOBBNZBNB, [4-|
AMINOBIPHENYL, |4-)
AMITRAZ
AMMONIA
AMMONIUM NITRATE (SOLUTIOHl
AMMONIUM SULPAHATB
AMMONIUM SULPATE (SOLUTION)
AMILINB
ANISIDINB HYDROCHLORIDE, (ORTHO-1
ANI8IIIIMB, (ORTHO-I
ANISIDINB, [PARA- )
ANTHRACENE
ANTIMONY
ANTIMONY COMPOUNDS
APOLLO
ARSENIC (INORGANIC!
ARSBNIC COMPOUNDS (INORGANIC * ARSINEI
ASBESTOS
ASBESTOS, AMOSITB
ASBESTOS, CHRYSOTILB
ASBESTOS, CROCIDOLITH
ASBESTOS, OTHER FORMS
ASSURE
ASULAM
ATRAZINB
AURAHINB
AZOBBNZRNB
BARIUM
CAS 1
30560-19-1
75-07-0
60-35-5
«4-19-1
67-64-1
75-05-8
98-86-2
53-96-3
74-86-2
107-01-t
79-06-1
79-10-7
107-13-1
15973-60-)
1596-S4-5
116-06-3
1646-88-4
309-00-2
742J3-64-6
107-11-6
107-05-1
742S-90-5
1344-21-1
20659-73-8
67485-29-4
8)4-12-9
S2-38-0
117-79-3
50-09-3
92-67-1
33089-61-1
7654-41-7
$484-52-2
7773-06-0
7783-20-2
62-53-3
134-29-2
90-04-0
104-94-9
120-12-7
7440-36-0
20-00-8
74115-24-S
7140-38-2
20-01-9
1332-21-4
1332-21-4
1332-21-4
1332-21-4
1332-21-4
76578-14-8
3337-71-1
1912-24-9
492-80-1
103-33-3
7440-3»-3
»-HR AAL*
333.33000
933.33000
0.04400
O.OS330
80.00000
0.00200
66.67000
0.53300
133.33000
1.78000
26.67000
133.33000
6.67000
6.67000
0.02670
66.67000
6.67000
8-HR AAL Sourc*
ACOIH TLV
ACOIH TLV
ACQIH TLV
ACOIH TLV
ACOIH TLV
Unit Rink Factor
ACOIH TLV
ACUIH TLV
ACOIH TLV
ACOIH TLV
ACOIH TLV
ACGIH TLV
ACOIH TLV
ACOIH TLV •
ACOIH TLV 1
ACOIH TLV
ACOIH TLV
24 -HR AAL*
2.00000
160.54000
0.40000
100.00000
0.20000
1.00000
0.00050
0.00004
0.00004
0 00004
0.00004
0.00004
24-HR AAL Sourc.
Haavachuattta DEP
HoBSOcllusotto DEP
MaaaAChusatts DBF
Haaaachu>atta DBP
Haaaachuaatta DBP
Miaaouri DOH
Haasachuoatta DBP
Mia ouri DOK
Mia ouri DOH
(la ouri DOH
Mia ouri DOH
Mia ouri DOH
Annual AAL*
0.500000
160.S4000D
0.010000
100.000000
0.100000
1.000000
O.OOU200
0.000004
0.000004
0.000004
0.000004
Annual AAL Sourca
Massachusetts DBP
Mnasachusettu UBP
Maasachusdt ts DBP
KaBaachuoet ta IJEP
Hasuaclmuettu !)HP
Mauuachustttta DKP
Maiiuachusatta D[>P
U3iiB(:)iua
-------
ttonday. Oetobtr 20, 1997
WATT ACC8PTABLI AHHCNT LEVELS TOR MISSOURI
(•AAL COHCIHTRATIOH . U0/«3J
Pag. 1
AW,' I 24-HR AAL Sourc.
Annual AAL» I Annual AAL 3ourc»
BARIUH COMPOUNDS
BARIUM CYAHIDB
BAYLBTON
BATTHKOID
BBKMN
BBNOHYL
8BHTAZON
BKNZIAI ANTHRACENE
BBNZAL CHLORIDE
BBNZALDBHYDB
BENZAHI02
BENZENE
BENZIDIIJS
«.«7000lACOIR TLV
>.19000lACOIH TLV
2S.S7000 ACOIH TLV
0.170000 HUiourl DOH
BH1ZO (B) PLUORANTHBH8
BBNZO (K) PIUORAHTHEHB
BBHZOIC ACID
BBNZOTSICHLOR1DB
BBNZOVL CHLORIDE
BENZOn. PEROXIDB
BNZ1L CHLORIDE
JBRYLLIUM
BRKLLIUM COMPOUNDS
IDRIN
IPHBNTHRIH
IFH04IL, (1,1-1
IS (2-CHLORO-l-HBTHVLBTHyt) BTHBR
IS (2-HTHYLHBXYt,) ADIPATB
ISIACETATOITBTRAHYDROXYTRI-LBAD
13 (CHLOROimiyL) BTHBR
IS (OHtXJROKBTHifL) BTHBR
ISPHBNOL A
ORON
ROHIHB
KOHOCHLOROHBTHANB
BROMODICHLOROMBTHANB
ROKOFORM
ROKOH2THANB
BROHOXYNIL
ROHOXYNIL OCTAHOATB
UTADIBNB, (1,3-)
UWI, ACRYLATE
ALCOHOL, (N-l
UTYL ALCOHOL, [3BC-
UTYL ALCOHOL. ITBRT-]
BBNZYL PHTHALATB
JTYLATB
TYLBNE OXIDB, [1.2-|
/TYLPHTHALVL BUTYLGLYCOLATB
0.16000
1.60000
l.COOOO
Ml««ourl DOH
HL.ourl DOH
Hiuouri DOH
0.017000
0.170000
0.170000
Hluoouri DOH
Hlnoouri DOH
HlsDonri DOH
ACOIH TLV
ACOIH TLV
HauoacliuuettB UBP
H««««chu«.tt. DBF
H>«««chua*tta DBP
naanachusetts DBP
Mi..ouri DNR & DOH
Hlooouri DNR t DOH
Nl»ouri DNR t DOH
14,000.00000
0.88900
tflsaoui 1 DNR ti DOH
ACOIH TLV
ACOIH TLV
S.2SOOO Ha»«ochu.«tts CBp
1.20000lH«»«ochunattii DBP
412.24000 Ha«.ochu»ett» DEP
•.066.70000
4,000.00000
ACOIH TLV
ACOIH TLV
WMIUH
UJHIUH COMPOUNDS
,LCIUH CHROMATB (ANHYDROUS)
LCJUH CYANAHIDB
LCIUH CYAHIOB
PROLACTAH
Massachusetta UEP
0.00300 Haaaachua*tt« DBP
0.000100lHa3»aclm.«tti) !)
0.08890
118.02000
13.33000
ACOIH TLV
ACOIH TLV
ACGIH TLV
-------
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a * •
* • •
4*9
US
O O O
a « «
II
XX X X
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o o a
o r- o
-4 O •-•
00 O
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a. o o.
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a a
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Jm m
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ill
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23333
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w A< *• «j «* S
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J* « * *
322S-Z
: : : :
xxxxxx
ooo
O rt O
o a o o 2 o
*•» O • 1-t O O
ow«»ooo
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888!
II I
3S I
m
O O O O
0*2 g
11 1
o o « r-
.a 1 I
30 g pj g —
J JtfQ^-UJXJ
O >-3 >-=>So-J
t^esa-zsz^xxg
§ai a
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a. O «(•
§x a a S
02 •*
3 n M M"Z n n § oo t
: i-. •-. > o 5 3 ca 2 i
•> -J* X X
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-------
Hondiy. Oclolxr JO, 1997
DKW ACCBPTABLS AKBIBfT L8VXL3 POR HISSWRI
(•AM, COHCmmiOH - uy/al)
P.O. 4
Ch.alc.l
COPPER CYAHIDK "~
CRBOSOTB
CRBBIDINK. IPARA-I
CRSSOL, IKBTA-I
CRBCOL. [ORHIO-1
CRSSOL, (PARA- ]
CRSBOLB IMIXBD ISOHERSI
CROTONALDBHIDB
CUHBNB
CUHUIH BYDROPBROXIDg
CUPPBRRO!)
CYAMZIHS
CYANIDE COHPOVNDS
CYANIDB-PRSB
CYANOOBH
CYAHOOHN EROHIDB
CYCLOHBXANB
CYCLOHBXANON1!
CYCLOHEXYLAHINE
CYHAL03HRIN/KARATB
CVPERKBTHRIN
CYROHAZINB
DACTHAL
DALAPON, SODIUM SALT
DAHITOL
DDB
DDT [P, P • -DICHLORODIPIIBNYLTRICHLOROB
DECABROKODIPHBNYL BTHBR
DBKBTON
DIO-BTHYLHEXYLI PHTHALATE, IDIHP)
DXALLATB
DIAHIHOJWISOLB SULPATB, (2,4-)
DIAMINOAHISOLB, [2,4-1
DIAMIHODIPIIBWYL BTHBR, (4,4>-)
DIAMINOTOLUBNB (MIXED ISOHBRS]
DIAMIHOTOLUBNB, [2,4-1
DIAZOHBTOAHB
DIBENZ (A, H ) ANTHRACBHB
DIBENZOPURAN
DIBROXO-3-CHLOROPROPAMB. [1,2-1
DIBROHOBEHZBtm, [1,4-1
filBROKOCHLOROMBTHANB
DIBROHOBTHAHB, [1,2-1
DIBUTYL PHTHALATB
1ICAHBA
DICHLOROBBHZEU3 (HIXBD ISOHBRS)
DICHLOROBBN2KHB, (1,2-1
DICHLOROBBHZBNB , [1,3-]
DICHLOROSRHZE1I8, (1.4-]
DICHLOROBBNZIDBNB, [3,3-1
DICHLORODIPLUOROHETHANB
DICHLORODIPMBNYL DICHLOROBTHANB, (F,P
DICHLORODIPHBHYL WCHLOROETHYLENB, [P
DICHLOROBTHANB, [1.1-]
DICHLOROBTHANB, (1,2-j
DICHtOROBTHYLBNB, {!,!-]
CAS 1
544-93.
8001-58-
120-71-
108-39-
95-41-
10«-44-
1319-77-
123-73-
•0-15-
135-20-
21725-46-
20-09-
57-1J-
460-19-
SOC-CI-
108-94-
104-91-
68085-85-
52315-07-8
1861-32-
75-99-0
39515-41-8
72-55-9
50-29-3
1163-19-5
8065-48-3
117-11-'
2303-16-'
39156-41-7
(15-05-4
101-80-4
25376-45-8
95-80-7
334-88-3
53-70-3
132-64-9
96-12-8
106-37-6
134-48-1
106-93-4
84-74-2
1918-00-9
25321-22-6
95-50-1
541-73-1
10(-«-7
91-94-1
75-71-6
72-54-8
72-55-9
75-34-3
107-06-J
75-35-4
8-HR AAL«
229.4800
293.3000
293.3000
293.3000
80.0000
St. 6700
(6.6700
2(6.6700
66.6700
1,333.33000
533.33000
0.10000
0.26700
0.07100
13.33000
53.33000
66. 000. 00000
2.160.00000
ACOIH TLV •
ACOIII TLV
ACOIH TLV
ACOIII TLV
ACOIH TLV
ACOIH TLV •
ACOIH TLV •
ACOIK TLV
ACOIH TLV
ACOIH TLV
ACOIH TLV
Unit Riik p«ctor
ACOIH TLV
COIH TLV
COIH TLV
COIH TLV «
HCOIH TLV
JOIH TLV
24-HR AAL
24.0500
580.0000
280.820(
1.36000
0.16.000
81.74000
18.00000
1] .01000
1.08000
24-HR AAL Sourc*
HI* Mauri DOH
H«M*chu»tta DBP
Ml««ourl DOH
a«»«chu»«ec< DEP
i*»ouri DOH
.«.chu..U. DEP
MMMWMiimHB
Annual AAL4
12.020U
280.82000
0. 770000
0.017000
81.740000
o. laoooo
0 . 040000
0.020000
| Annual AAL Souic*
HaaoachuaattB DEI1
MaB0*clvuaattit DBP
Hiaaourl DOH
aaflAdhusolts PBP
BaoacJitlseLta DBP
Asaat-tiuset La l»g|i
asuacliusetttf 13Kp
-------
•f/
Monday, October 20, 1997
DRAFT ACCEPTABLE AMBIENT LEVELS FOR MISSOURI
I'AAL CONCENTRATION - ug/r»3|
Paga 5
DICHLOROBTHYLBNB, [TRANS-1,2-]
DICHLOROKBTHANB
DICHLOROPHBNOL, [2,4-]
DICHLOROFHENOXY ACffTIC ACID, [2,1-]
DICHLOROPHBNOXY! BITTRIC ACID, |4-|2,4
DICHLOROFROPANB, (1,2-)
DICHLOROPROF8NB. (1,3-1
DICHLORVOS
DICOPOL
DIBLDRIN
DIBroXYBUTANB
DIBTHANOLAHIMB
DIBTHYL FHTHALATE
DIRTHYL SULPATB
DIBTHYLAMINB
DIBTHYLBNR QLYCOL HONOBUTYL BTHBR
DIFENZOQUAT
DIPLUBEHZURON
DII80FROFYL HBTHYLPHOSPHOHATB
DIHBTHIPIN
DIMETHOATB
DIHETHOXIBENZIDINE, [3,3-]
DIMETHYL BBNZIDINB, (3,3-)
DIMETHYL CARBAHOYL CHLORIDE
DIMETHYL PORHAMIDB
DIMETHYL HYDRAZIUB, [1,1-]
DIMETHYL PHEHOL, [2,4-]
DIMETHYL FHTUALATB
DIMETHYL BULPATB
DIMtTHYL TBRBPHTKALATB
DIMlTHYLAHINa
DIHITHYLAHINOAZOBBMZBNB, |4-)
DIKlTHYLAHILim, (N-M-1
DIHBTHYLFHBNOL. [2,6-]
DIMBTHYLPHBHOL, [3,4-1
DINITRO-0-CR8SOL, [4,6-]
DINITRO-0-CYCLOHBXYL PHENOL, (4,6-)
DIHITROBENZENE. (KKTA-J
DINITROPHBNOL, [2,4-]
DIHITROTOLVENB, [2,4-]
DIHITROTOLUBHB, [2,6-]'
DINOSED
DIOCTYL PHTHALATE, [N-|
DIOXANB, [1,4-]
DIOXIHfl
DIFHBNAMID
DIPHHHYLAMIHE
DIPHBIYLHYDRAZIHB, [1.2-1
DIFHBNYLMBTHANB OIISOCYANATB, [4,4-1
DIFROFYLBNB CLYCOt METHYL BTHBR
DIPROPYUZNB CLYCOL HBTHYL BTHBR ACBTA1
DIQUAT
DISULFOTOH
DIURON
DODINE
156-60-
7S-OS-2
120-93-2
94-75-7
84-82-6
78-OT-S
S4J-75-«
62-7J-7
115-32-2
60-57-1
1464-53-5
111-42-2
(4-66-2
64-17-5
109-89-7
112-14-5
43222-49-6
35367-3S-5
1445-75-6
55290-44-7
60-51-5
119-90-4
119-93-7
79-44-7
68-13-2
57-14-7
105-67-9
131-11-3
77-7B-1
120-61-6
124-40-1
60-11-7
121-61-7
576-26-1
95-65-8
514-52-1
131-89-5
99-65-0
51-2S-S
121-14-2
606-20-2
88-85-7
117-14-0
123-91-1
TFO
957-51-7
122-39-4
122-66-7
101-61-8
34590-94-8
85-00-7
298-04-4
130-54-1
2439-10-3
10,533.3300
1.7800
65.6700
0.1780
0.0440
0.17780
0.08890
133.33000
2.67000
13.33000
2.67000
0.26700
20.00000
0.04500
2.66700
1.33100
1.33000
1.79000
8-HR AAL Souro
ACOIH TLV
ACOIH TLV
ACOIH TLV
ACOIH TLV
ACOIH TLV
(
ACOIH TLV
ACOIH TLV
ACGIH TLV
ACOIH TLV
ACOIH TLV
ACOIH TLV
ACOIH TLV
ACOIH TLV
nit Rl>k Pictor
ACOIH TLV
COIH TLV
COIH TLV
COIH TLV
24-HR AAL*
215.6200
20.0000
0.9000
31.0000
80.00000
8.13000
450.00000
6.00000
40.00000
43.00000
24.49000
2 72000
5,500.00000
5,500.00000
24-HR AAL Sourc.
Ha«Mchua«tt« DBF
Hl*>ouri DOH
Haaaachu«*tt* DBF
Mioouri DNR t DOH
Hliiouri DOH
HM*achu>att* DBF
Mi«ouri DOH
iaflBachUBOtfcfl DBp
Miaaouri DOH
HlHouri DNR L DOH
iaBaachuaaCta DBP
h t^ npp
isaourl DOH
iiaouri DON
Annual AAL*
107.B1000
0 ,24000
0.05000
4.07000
3 .000000
40.000000
0.240000
,
'
Annual AAL Source
Ha»»achuB«tto PEP
H&aaachus«tt* DBP
HASwachusfttts DEP
Hluaourl DHR t DOH
HaauAchuuotta DEP
*B«achufl«ctfl DEP
-------
Hominy, October 20, 1997
[WAIT ACCEPTABLE AMBIENT LEVELS FOR MISSOURI
{•ML CONCENTRATION * ug/nj)
rag*
Chanlcal
BHDOIWLPAH
B1IDOTHXLL
E1IDRIU
KPICHLOROIIYDRIN
EPN [BTIIYL P-HITBOPHBHYL PHEHYLPHOS
BPUILOH-HEXACHLOROCYCLOIIBXAHB
BPTC (S-BT1IYL DIPROPYLTHIOCARBAHATB
BTHANOL
BTH8PKOH
BTHION
BTHOXYBTHANOL, [2-|
BTHYL ACBTATS
BTIIYL ACRYLATB
BTHYL BENZENE
ETHYL CHLORIDE
ETHYL CHLOROFORHATB
BTHYL ETHER
BTHYLRNB
ETHYLENB CLYCOL
BTHVLBNB IHINB [AZIRZOXUS]
ETH»LBNB OXIDB
BTHILBNB THIOUREA
BTHYLSNIOIAHINB
BTHYLPHrHALYt BTHYLOLYCOLATB
EXPRESS
PENAHIPHOS
FLUOHBTOROH
PLUORIPB
PLUORIHB (SOLUBLE PLUORIDB)
FLURIDONB
PLUVALIHATB
POLPBT
POHBSAFBM
PONOPOS
PORMALOBHYDE
PORHIC ACID
POSBTYL-AL
PURAN
FURFURAL
FURMBCYCLOX
GASOLINE VAPORS
OLWOSIHATB-AHHONIUH
CLYCIDYALDBHYDS
GLYCOL BTHBR IKTHYLBNB OLYCOL ETHERS]
E*YCOL BTHBR (DIBTHYLBNB GLYCOL BH1BRS
OLYCHOSATB
HARMONY
IIBPTACHLOR
HEPTACHLOR BPOXIDB
HBXABROHOBEHZBNB
IIBXACHLOROBBNZBMB
HBXACHLOROBUTADIBNB
HBXACHLOHOCYCLOHBXANB, (AlPHA-l
HEIUCHLOROCYCLOHBXANB, JBBTA-)
IIEXACHLOBOCVCLOHEXAUB, (DBLTA-)
CAS 1
TO
ns-at-
145-73-
73-20-
106-89-
2104-«t-
4105-10-
759-94-
$4-17-
1(672-17-1
553-12-
110-BO-
141-7d-
140-98-
100-41-4
75-00-3
541-41-3
60-29—
74-15-1
107-21-
151-56-4
75-21-
96-45-
107-15-3
•4-72-0
101200-4d-<
22224-92-6
2164-17-2
16984-46-!
77(2-41-4
59756-60-4
69409-94-5
133-07-3
72178-02-0
944-22-9
so-oo-0
64-18-6
39148-24-8
110-00-i
98-01-1
£0568-05-0
6006-61-9
77182-92-2
765-34-4
20-10-0
20—10-0
1071-83-6
79277-27-3
76-44-8
1024-57-3
87-82-1
118-74-1
87-€8-3
319-84-6
319-85-7
319-86-8
8-HA AAL*
0.0171
0.0178
6.6700
0.0200
5.3300
353.3300
0.17800
333.33000
1.33000
26.67000
1.33000
120.00000
106,67000
12,000.00000
0.00380
0.45000
0.00560
0.01900
0.02000
8-HR AAL Vourc
ACOIH TLV
ACGIH TLV
ACOIH TLV
Unit Hl.fc P.cto
ACOIH TLV
ACOtll TLV
ACOIH TLV
ACOIH TLV
ACOIH TLV
ACOIH TLV
COIH TLV
COIH TLV
COIH TLV
COIH TLV
nib Rl»)c Puctor
nit Ri«k Factor
nit Risk P«ctor
nit Ri.fc p.cter
nit Ritlc Factor
24 -HR AAL
8.0000
51.2400
391.8400
0.5600
360.0000
717.5500
329.8000
.14.5000
0.2430
6,80000
0.80000
0.40000
3.00000
450.00000
0.14000
24-HR AAL Bourc.
Hiliouri DOH
HBiflftchUB*tta DEP
Ha»aehuiDtt* DBP
H..»«cliu«.tt. DBP
Illiourl DOH
1a««achuaatta DBP
Haiaachuaatta DBP
taaaachuaatta DBP
Hlaaourl DOH
Haaaachu«atta DBP
Hlneourl DOH
aaaachuaattB DBP
aaaachUMttm DKP
l.uouri DOH
«aaachue«tta DBP
Annual AAL
^^•••••NMMI
0.08000
51.24000
391.84000
0.28000
300.00000
358.78000
164.90000
34 . 5000C
6.800000
0.080000
0.020000
2.00UOUO
0.001000
Annual AAL Sourca
Hamachuaatta DBP
Hapaachuaatta DBP
Haaaachuaatta UBP
^aaaachuaatta DBP
Haaaochuaatta DBP
Maaaachuaatta DEP
laaoachuaatta DBP
.
Maaaachuatttta DEP
Maesachuaotta DBP
aseachuaatta DEP
asaachusatta DBP
-------
Monday, October 20, 1991
DRAFT ACCEPTABLE AMBIENT LEVELS FOR HISSOURI
CAM. CONCENTRATION - U9/»3|
Pago 7
HBXACHLOROCYCLOPBNTADIHNB
HEXACHLORODIBBNZO-P-DIOXIN (MIXTURE)
HBXACHLOROBTHANB
HBXACHLORONAPHTHALANB
H8XACHLOROPHBNB
HBXAHYDRO- 1,3, 5-TBINITRO-l , 3 , 5-TRIAZI
HBXAKBTHYLBNE, -1, 6-DI1SOCYANATH
HBXAHBTHYLPHOSPHORAHIDH
HBXANE, |N-]
HBXANONB, [2-]
HBXAZINONB
HYDRAZINB
HYDRAZINB SULFATE
HYDROOBN DBOHIDH
HYDROOBN CHLORIDE
HYDROGEN CYANIDE
HYDROOBN FLUORIDE
HYDROdBN SULPIDB
HYDROQUINONE
IHAZALIL
IHAZAQUIN
INDBNOU,2,3CD|PYRBNB .
IPRODIONE
ISOAHYL ACETATE
ISOBUTYL ACBTATB
ISOBUTYL ALCOHOL
ISOBUTYRALDBHYDB
I80FHORONB
I90PROPALIH
IBOPROPYI. ACETATE
IBOPROPYL ALCOHOL
ISOXABBN
LACTOFBU
LAMINAR (R) HO DRY FILM PHOTOPOLYHB
LEAD
LEAD ACETATE
LEAD COMPOUNDS
LEAD SUBACBTATB
LINDANB [OAHKA-HBXACHLOROCYCLOHBXANS
LINUROH
LIQUID ALKALIIIB STRIP 733
LOHDAX
KACU DBF 70 A
HACU DBP 70C
HACU DIZBR 9279 PROCESS
MACUBLACK LT 9282
HALATHION
MALEIC ANHYDRIDE
HALEIC HYDRAZIDH
MANBB
HAHGA1JB3H
HANCANBSB COMPOUNDS
HCPP
HBLAMIHB
MEPigUAT CHLORIDE
77-«7-
19408-7<-
<7-72-
1335-17-
70-10-
131-93-
82J-OC-
680-31-
110-54-
S9i-7»-
51235-04-
302-01-
10034-93-2
10035-10-6
7647-01-0
74-90-8
7644-39-3
7783-06-4
123-31-9
35554-44-0
81335-37-7
193-39-5
36714-19-7
133-92-2
110-19-0
78-13-1
71-14-2
7I-J9-1
33930-53-0
108-21-4
67-63-0
82558-50-7
77501-63-4
TFJ
7439-93-1
301-04-2
20-11-1
13335-32-6
58-89-9
330-55-1
TP3
83055-99-6
TF4
TP5
TP«
TJ7
121-75-5
101-31-6
123-33-1
12427-38-2
7439-9C-5
20-12-2
91-85-J
108-78-1
24307-2C-4
0.0000
2.6700
26.67000
3,066.70000
333.33000
13,066.70000
2.00000
1.78000
0.89000
13.33000
Unit RUk P»cto
ACOIH TLV
ACOIH TLV
ACOIH TLW
ACOIH TLV
ACOIH TLV
C01H TLV *
COIH TLV
COIN TLV
COIH TLV *
o.ooeo
0.5300
4,200.0000
.10.8800
0.0070
5.0000
7.0000
12.0000
0.6800
0.90000
1.60000
144.76000
193.77000
360.00000
283.81000
0.35700
0.00(80
0.14000
0.14000
0.27000
24-HR AAL Sourc*
Ma»«chuB«ttM DBP
Hn>*nchu»tb» DBF
Hiiiourl OHR L DOII
Hu»«cbu>*tb« DBP
Hai»«chu»«tta DBP
H«n«chu«»tt. DBF
M*B>fccltul4tt> DBF
Mi*«ouri DNR b DOH
H««««chu«»tt« DBP
HlNourl DOH
Mi.«ourl DOH
(n««Kchua*cta DBP
(•••*chu«*tt« DBF
Hi««ourl DOH
Ha«Bachu>«tt« DBF
Himouri DOH
[n«*achua«tt* DEP
[ftaaachuastt* DBP
M«»*Kchua«ttfl DBP
•••achuaatta DBF
0.00600
0.25000
420.00000
10.68000
0.00200
5.00000
7 00000
3.00000
0.34000
0.90000
0. 170000
144.760000
193.770000
41.220000
283.810000
0.070000
0.010000
0.003000
0.140000
Maaaachuaatta DBF
Haaaachuaotts DBP
Hloiiouri DNR <. DOII
Haaaachuoatte DBP
Maaiachuaatta DBP
Maaaaclmaatta DBP
Mlaaouri DNR ft DOH
^aaaachuaatta DBF
MaaaachuBatfca DEP
Hiono.Jtl DOH
laeaachuoattv DBP
Maaaachuaatta DBP
Haaaachuaatta DBP
taa*achua«tta DBP
Kaaaachuaattfl DBP
Maaaachuaotta DBP
Hasaachuoatta DBP
aaaachuaatta DBP
-------
Honday. Octobar 20. 1997
DRAW ACCBJTABIB AHBIBwr UVSU K>* HICCOURI
C'AAL C01ICEHTKATIOH • ug/n))
Pa«* I
Chamical
MERCURY IBLBHBirrAL)
HBRCUBY COMPOUNDS [ALXYL I A«YL|
HBRCURY COHPOUHDS IIHOROANIC)
HBRPHO3
HBRPH03 OXIDE [BUTYL PHOBPKOHO TRITH
HBTALAXYL
HETHACRYLOHITRILB
H3THAHIDOPH03
HEDIANOL
HBTHIDATIIIOH
H8THOHYL
HBTHOXYCHLOR
H8THOXYBTHANOL, (2-]
HBTHYL ACRYLATB
HBTHJL CHLORIDE
HBTHYL CHLOROCARBOHATB
METHYL BTHYL KBTOHB
HBTHYL HYDRAZINB
HBTHYL IODIDE
HBTHYL ISOBUTYL KBTONB
HBTHYL ISOCYANATB
HBTHYL KBRCAPTAN
HBTKYL MERCURY
HBTHYL HBTHACRYLATE
HBTHYL PARATHION
HBTHYL TBRT-BUTYL ETHER
HBTHYL- 4-CHLOROPHENOXYI BUTYRIC ACID,
HBTHYL-4-CHLOROPHENOXYACBTIC ACID, [2-
HBTHYLBMB Brs(2-CHLOROANILINE) , [4,4-
HETHYLBNB BIB|H,N-DIHET1IYL)BBNZBNAHIN1
HBTKYLENB BROMIDE
HBTKYLBHHDIMIILINB, [4,4-)
HBTOLACIILOR
HBTRIBUZIH
HICHLUt'S KBTONB
MINERAL FIBERS
HIRBX
HOLINATB
HOLYBDBNUM
HOLYBDBHUM TRIOXIDH
USTARD GAS
NALBD
NAPHTHALENE
APHTHYLAHINS, [ALPHA-]
HAPHTHYLAHINB! IBBTA-J
NICKBL
ICKEL CARBONYL
ICKSL COMPOUNDS
NICKEL OXIDB
ICKBL RB71HBRY DUST
IICXEL SUBSULPIDB
NITRAPYRIN
NITRATE
NITRIC ACID
NITRIC OXIDE
NITRITE
CAS 1
7439-97-
20-13-
20-13-
150-50-
78-48-
57137-19-
126-98-
10265-92-
950-37-
16752-77-
73-43-
108-46-
96-33-
74-B7-
79-22-
7«-93-3
60-34-4
74-88-4
108-10-1
624-13-9
74-93-1
22967-93-6
80-62-6
298-00-0
1634-04-4
94-81-5
94-74-6
101-14-4
101-61-1
74-95-3
101-77-9
51218-45-2
21087-64-9
90-94-1
TC14
23(5-85-5
2212-67-1
7439-98-7
1313-27-5
505-60-2
300-76-S
91—20—3
134-32-7
7440-02-0
13463-39-3
20-14-4
1313-99-1
12035-72-2
1929-12-4
14797-55-0
7697-37-2
0102-43-9
4797-65-0
8-HR AAL'
40.0000
33,3300
133.3000
0.06220
1.77800
0.66700
13.33000
2.67000
0.03910
10.67000
66.67000
66.67000
66.67000
40.00000
0.06200
1.33000
0.02100
133.33000
66.67000
400.00000
8-HR AAL Sourc
ACOIH TLV
ACQIH TLV
ACOIK TLV
ACOIH TLV
ACOIH TLV
ACOIH TLV
ACOIH TLV
ACOIH TLV
ICOIH TLV
COIH TLV
COIH TLV
COIH TLV
COIH TLV
CQIH TLV
COIH TLV
COIH TLV •
nit Ri«k Factor
COIH TLV
COIH TLV
COIH TLV
0.1400
0.0030
0.1400
600.0000
3.0000
9.5700
105.0000
360.0000
64.00000
0.00300
22.27000
15.70000
0.27000
0.27000
0.04200
24-HR AAL Sourc*
Hai«achu»«tl« DEP
Haaaachuaattl DEP
Haaaachuaatta DEP
Hi»ourl DOH
flaaaachuaatta DBP
Haaaacbuaatta DBP
Hlaaourl DOH
Hlaaourl DOH
Hlaaourl DOH
Haaaachuaatta DBP
Haaaachuaatta DBP
iaaouri DOH
aa.achua.tt. DEP
laaaachuaalls DBP
laaourl DOH
Annual AAL
0.0700
0,0014
0.0100
7.13000
2.00000
4.79000
10.00000
55.70000
0.001400
22.270000
14. 250000
0. 160000
0.010000
Annual AAL Sourc*
HaaaachuiattB DSP
Huaaacltuiatta DEP
Haaiachuaatta DBP
Haaiachuaatta DKP
Kaaaachuaatta DBP
Haoaachunetta DBP
Haseachuagtta DEP
Haaattchuaatta DEP
laaaacluieetto Db'p
Haoaachugetts UEP
.
a DEP
EP
-------
Monday, October 20, 199V
DHAiT ACCBPTABLB Miaitttt1 LBVBLS VOR MISSOURI
(•AAL CONCENTRATION - Ug/l*3|
Chemical
NITHO-0-ANISIDINB, IS- I
NITROBSNZBNB
NITROBIPHENYL, ]4-|
HITROPEII
IIITROOE1I DIOXIbB
NITROGEN BUSTARD
NITROCLYCBRIN
limOPHBNOL, [3-1
NITROPIIBNOL, |4-|
NITROPROPAMH. [2-1
NITHOSO-DI-N-BlrTYLAMINB. |H-|
NITROSO-N-BTHYLURBA, [N-l
HITROSO-H-HETHYLBTHYUAHIHB, [H-|
NITROSO-N-HBTHYLURBA. |N-|
NITROSODI-N-PROPYLAWNB, III-]
HITROSODIHTllAtlOLAHINB, |N-|
tllTROflODIBTIIYLAHIHB. (ll-|
NmOSODIHBTHYLAMHH, [M-]
HITROflODIPHKNYUHIHB, |N-]
NITROSODIPJimLAHINB, (PARA-)
NmOSOKBTHYLVttttLAHINB, [II- 1
HITROSOHORPHOLINB, [H-l
NITROSONORHICOTINB, [II -|
IIITROSOPIPBRIDIHB, (N-|
H1TROSOPYRROLID1NB* (N-)
NORPLURAZON
NTA (NITRILOTRIACSTIC ACID)
NUSTAR
OCTABROHODIPUENYL BTHBR
OCTACHLORONAPTHALEHB
OCTAHYDRO-l.l.S^-TBTRANITRO-l.l.S^-1:
OCTAH8, [N-j
ORYZALIN
OSMIUM THTHOX1DB
OXABIAZON
OXAMYL
OXYPLUDRPBM
PACLOBUTRAZOL
PARAQUAT
PWIATHIOH
PCD (POLYCIILOKINATBD UIPHBNYLS)
PBN01HUTIIALIN
PENTABROHODIPIIBMYL BT1IBR
PENTACIILOROtlEllZUIIU
PEMTACIILOROMITROOEJIZBHU
PENTACHLOROPIIBtJOL
PHMTAJIB
PERMETIIRIH
PBROXYACBTIC ACID
PHEIIOL
HIEIIVI. HBBCIIRIC ACBTATB
PMBIIYLUNBDIAHINB, [HBTA-]
PIIEKYLENBDIAMINB. (PARA-)
PHENYLPIieNOL, [}-|
PIIOSALODB
PHOSCEMB
CAB 1
99-54-
88-95-
91-93-
19)6-75-
10102-44-
51-75-
55-O-
11-75-
100-03-
79-46-
934-16-
759-71-1
10595-95-
684-93-
631-S4-
111S-54-
55-11-5
62-75-9
16-30-J
156-10-5
4549-40-0
59-19-3
165*3-55-1
100-7S-4
930-55-3
37114-D-3
139-11-9
15509-19-9
32536-52-0
2334-13-1
2691-41-0
111-65-
190*1-11-)
20116-13-0
19666-10-9
311)5-33-0
13874-03-)
76711-63-0
1910-43-5
56-31-2
1316-14-)
40417-43-1
125)4-11-9
601-93-5
12-61-
109-66-
52645-51-
79-21-
101-95-
62-11-
101-45-3
106-50-3
90-43-7
2)10-11-0
75-44-5
1-HR AAL'
4.00000
6.32000
0.00620
0.00021
0.00070
0.01600
1.1)000
19,333. 11000
0.02670
0.26700
0.01780
14,400.00000
0.02670
0.01780
0.01710
5.31000
1-HR AAL Bourc.
ACOIH TLV
ACOIH TLV
Unit Ri*k P.ctor
1
"~
Unit Rl«k P«otor
Unit Ri«V r.ctor
Unit RUk P«ntot
ACOIH TLV
ACOIH TLV
ACOIK TLV
ACOIH TLV
ACOIH TLV
ACOIH TLV
ACOIH TLV
ACOIH TLV
ACOIH TLV
ACOIH TLV
24-HR AAL*
13.68000
0.27197
0.00)01)
1.20000
0. 50000
45.00000
24-HR AAL Bourn
H»»«ahu>ttt< OBP
MAAQB
HaMftchucattB DBP
Hlllaourl DHH 1. 0011
Ml»ouri DOH
Hl««ouri DDH
Aniiunl AAL'
6.140000
100.000000
0.00050U
0 0100UO
9.500000
Annukl AAL Saute*
H«»«echu«.tt. tlBP
NAAQS
H«»0«chu»«tL« DBP
""" U"e
Hi*aourl 1X311
-------
Hond.y, October 20, 1997
DRAFT ACCBPTABUI AX«I«NT 18VSL3 TOR MISSOURI
C'AAL COHCDRRATIOH - ug/«3)
t»g. 10
chMlcal
PHOSPHIDE
PHOSPHORIC ACID
PHOSPHOROUS IYELLOH OR HHITEI
PHTKALIC AHHYDRIDB
PICLORAH
PICRIC ACID
PIRIHIPIIOB-HBTHYL
POLYCYLIC OROANIC HATTER
POTABIIUH CYANIDE
POTASEIUH SILVBR CYANIDE
PROCHLORAZ
PROHSTOH
PROHBTRYH
PRONAHIDB
PROPACHLOR
PROPANE SULTONB, (1,3-1
PROPANIL
PROPAZINB
PROPHAH
PROPICONA20LB
PROPIOLACTOHB. [BBTA-J
PROPIONALCBHYDB
PROPOXUR (»AYOON1
PROPYL ALCOHOL
PROPYLBNB
PROPYLBNE OXIDE
PROPYLDUIHINB, [1,2-]
PYDRIM
PYRIDINB
QUINALPHOS
UINOLINB
UINONB
RADIONUCLIDBS {INCLUDING RADON)
RADIUM 226,228
RADON 222
RBSHBTHRIN
RBSORC1NOL
ROTBNON8
SACCHARIN
SAPROLB
SAVEY
ELBNIOUS ACID
ZLBNIUM
SELENIUM COMPOUNDS
SELENIUM SULPIDB
SELENOUREA
SBTHOXYDIH
SILVBR
SILVBR COMPOUNDS
SILVER CIANIDB
SIHAIINB
SODIUM ACIPLUORPBN
SODIUM AZIDB
SODIUM CYANIDE
SODIUM DIBTHYLDITHIOCARBAMATg
CAS 1
732-11-
7803-51-
7664-38-
7723-14-
19H-02-
88-89-
29232-93-
TPJ
151-50-
506-61-
67747-09-
1610-18-
7287-19-
23950-58-
1911-16-
1120-71-
709-98-J
139-40-2
132-42-9
60207-90-
57-57-»
123-38-6
114-26-1
71-23-1
115-07-1
75-56-
51630-58-
110-86-1
13593-03-8
91-22-5
106-51-4
TP16
7440-14-4
14859-67-7
10453-86-8
108-46-3
83-79-4
81-07-2
94-59-7
78587-05-0
7783-00-8
7782-49-2
20-16-6
7446-34-6
630-10-4
4051-80-2
7440-22-4
20-17-7
506-64-9
122-34-9
2476-59-9
6628-22-8
143-33-9
148-18-5
A-HR AAL*
5.3300
1.3300
1.7100
1.3300
166.8600
0.24(0
0.26670
6.67000
0.8890
200.00000
0.07100
0.88900
4.36000
1.33000
0.13000
0.16500
4.00000
125.58000
B-HR AAL Soure
ACGIII TLV
ACCIH TLV
ACCIH TLV
ACOIH TLV
ACQJH TLV
ACOIH TLV*
.
ACOIH TLV
AC01EI TLV
ACOIH TLV
ACOIH TLV
COIH TLV
COIN TLV
COIH TLV
COIH TLV
CGIH TLV*
COIH TLV
COIH TLV
GIH TLV*
24-HR AAL
••MHMMBBM
24.000
1.6500
0.1600
133.63000
6.00000
12.24000
0.54000
0.54000
0.54000
24-HR AAL 3ourc«
Hl.iourl DOII
H<>l«chu»tt< DBP
Mlaaourl DON
H»««chu««tt. DBP
H«»»«chu««tt. DBP
a«««ohuiotta DEP
la«««chu«.tt« DBP
•Bl«chu».tt« DBP
Annuil AAL
0.2700
0.82000
0.01700
133.630000
0.300000
3 .060001
0.541)000
0.05000D
Annual AAL Sourc* |
Hmachuifttta DBP
H«l»chu»tto DBP
HUoouri DOII
4 i
«0Bachue*tts DEC 1
avsachuaet t» DBf I
; .
-------
Monday, October 20, 1997
DRAFT ACCEPTABLE AMBIENT LEVELS FOR MISSOURI
(*AAL CONCENTRATION • ug/m3»
Pags 11
SODIUM SULPATH (SOLUTION)
SOLDER FLUSH 909
STRYCHNINE
STYRBNB
STYRBNB OXIDE
SULPURIC ACID
SUPER SOLDER STRIP 380?
SYSTHANE
TBBUTHIURON
TBDLAK FVF FILM
TBRBACIL
TBRBUTRYN
TBKBFHTHALIC ACID
TBTFACHLORO-l.J-DIPLUOROBTHANB, [1.1,:
TBTRACHLOROBENZEME, [1, 2, 4,5-1
TBTPACHLORODIBBNZO-P-DIOXIlt, [2,3,7,8-
TBTHACHLOROHTHANB, [1,1,1,2-)
TBTRACHLOROBTHAHB, [1,1,3,2-j
THTRACHLOROBTHYLENIl
TBTMCHLOROFHBNOL, [2,3,4,6-)
TBTRACHLOROVINPHOS
TBTRABTHYL LEAD
TETRABTHYLDITHIOPYROPKOSPKATB
TBTRAHYBROFURAN
THALLIC OXID8
THALLIUM
THALLIUM [I) SULPATB
THALLIUM AC8TATB
THALLIUM CARBONATE
THALLIUM CHLORIDE
THALLIUM CONFOUNDS
THALLIUM NITRATE
THALLIUM SELEN1TB
THBRH-CHBK £117 (BARIUM SALTS)
THIOACBTAHIDB
THI08BHCARB
THIODIANILINB, (4, 4'-)
THIOFHAHATE-MBTHYL
THIOURBA
THIRAM
THORIUM DIOXIDE
TITANIUM OXIDE
TITANIUM TETRACHLORIDE
TOIUBMB
TOLUENB DIISOCYANATS. [2,4-1
TOLUBNK DIIBOCYAMATE, [2,6-]
TOLUIDIHB UYDROCHLORIDB, (ORTHO-1
TOLUIDINB, [ORTHO-]
TOXAPHBNB
TRIALLATB
TRIAZIQUONB
TRI8ROMOBENZEHB, [1,2.4-1
TRIBUTYLTIH OXIDE
TRICHLORPON
TRICHLOHO-1,2,2-TRIFLUOROBTHANB, (1,1,
7757-83-
TP
57-24-
100-43-
96-09-
7654-93-
TP
88671-89-
34014-ia-
TF10
5902-51-2
ees-so-o
100-JI-O
76-12-0
95-94-3
1746-01-6
630-20-C
79-J4-5
U7-H-4
58-SO-J
961-U-5
7B-00-2
3C»-24-5
109-99-9
1314-35-5
7440-28-0
7446-U-6
563-68-J
6S33-73-9
7791-12-0
20-H-l
10101-45-1
12039-S2-0
TP11
62-55-5
29249-77-$
139-6S-1
23564-05-8
62-56-6
137-26-8
1314-20-1
13463-67-7
7S50-45-0
108-86-3
S84-94-9
91-06-7
636-21-5
95-53-1
8001-35-2
2303-17-5
68-76-1
615-54-3
56-35-1
52-61-6
76-13-1
2.0000
1.33000
1.49000
.33000
.65000
.72000
.53000
,56000
.33000
.74000
.85000
0.88900
0.86900
0,53300
0.08890
101,333.00000
ACOIH TLV
ACOIH TI.V* '
ACaiH TLV*
ACOIH TLV
ACOIH TLV*
ACOIH TLV
ACOIH TLV*
ACOIH TLV*
ACOIH TLV
ACOIH TLV
ACOIH TLV*
COIH TLV
COIH TLV*
COIH TLV
COIH TLV
COIH TLV
200.0000
2.7200
1,133.3300
18.6700
2.0000
0.01644
160.35000
400.00000
0.10000
2.38000
24-HR AAL Source
Hi. .our! DOH
Ha»«nchu««tt» DBF
MA»actiUH«tt* DBF
H«««ftchu*«tti DBF
Ml. .our 1 DOH
Adju.t.d L««d NAAQS
^••••chu.vtta DBF
luourl DOH
AflB«ChU.*tt. DSP
a«i«chu*«tta DBF
2.00000
2.72000
566.67000
0.02000
0.020000
6.000000
80.100000
20.000000
D. 100000
0.170000
Maasachvia.tts DBF
Maoaachvievtte DBF
Ma.oachuaett a DBF
Haaaachuaatta DBF
Maaaachuaabta DBF
Adju.tad Land NAAQS
Maaaachuaatta DBF
faaaachUBtttta DBF
laaaachuaatta DBF
aasachuaatta UEF
-------
Konday. Octob.r 20. 1)97
DRAFT ACCSCTABLB AHBIEUT LIVIUS FOR MISSOURI
(•AM. COIKBITRATIOH .
P«g« 12
TMCHLOROSTHAHI. |l.I,l-J
TRICHLOROBTHAHB, (1.1,2-1
TRICWLOROBTKYUHE
TRICHLOROPLUOKOHETHAHE
TRICIIWROPHKHOL, (2,4,5-1
TRICHLOROPHEMOL, (2,4,6-)
TRICHLOROPHBNOXlflPROPIOHIC ACID, (2- (I
TRICH'LOROPHBNOXYACBTIC ACID, (2,4,5-1
TRICHLOROPItOPAHB. [1,1,3-)
TOICMLOROPHOPANB. [1,2,3-]
TRIDIfllANI
TRIBTllYLJOilllB
TRIFLURALIII
TRIHETHYLBBNZEMB. [1,2,4-]
TRIHBTHYLPBHTANB, [2,2,4-1
TRINIWOBENZENB, [1,3,5-1
TRINITROTOLUENE, [2,4,6-]
TRIPROPYLBNB OLYCOL METHYL BTIIBR
TRIE (2, 3-DIBROKOPROPYL) PHOSPHATB
TYPE 301 STAINLESS STB8L
URANIUM (NATURAL)
URBTHANB [ETHYL CARBAHATE]
VANADIUM (PUHB OR DUST)
VANADIUM PSNTOXIDB
VERHAH
VINCLOZOHH
VIHYL ACBTATB
VINYL BROHIOB
VINYL CHLORIDE
WARFARIN
XXLBNB, (HBTA-)
XYLKNB, [ORTHO-I
XYLSNB, (PARA-)
XYLBNBS (HIXBD IBOMBRS)
:YLIDIHE, [2,6-1
ZINC (PUHB OR DUST)
ZINC COMPOUNDS
ZINC CYANIDE
ZINC PHOSPHIDE
ZINC/ZINC OXIDK
ZINSD
71-55-
79-00-
79-01-
75-69-
95-95-4
II-OC-:
91-72-1
93-7C-5
591-77-6
5B131-OI-:
121-44-1
1512-09-1
95-63-6
540-84-1
99-35-4
111-96-7
126-72-7
TP12
7440-61-1
51-79-6
7440-62-2
1314-63-1
1929-77-7
50471-44-1
108-05-4
593-60-2
75-01-4
11-81-2
101-31-3
95-47-6
106-42-3
1330-20-7
17-62-7
7440-66-6
20-19-9
557-21-1
1314-84-7
1314-13-2
12122-67-7
995.6000
1.7000
4,000.00000
1,666.70000
0.01190
2.67000
3.56000
0.26670
133.30000
133.33000
150.42000
66,67000
ACOIH TLV
ACOIK TLV
ACOIH TLV
ACOIH TLV
ACGIH TLV
ACOIH TLV
ACOIH TLV
ACOIH TLV
ACOIH TLV
ACOIH TLV
COIH TLV
COIH TLV
4.500.0000
14.1400
64.3000
1 , 6000
1 .00000
73.00000
3,336.00000
3,200.00000
0.27000
0.14000
30.00000
3.47000
250,00000
250.00000
250.00000
250.00000
Hlaaourl DON
K«aa«chuaatta DBP
Hlaaourl DNR I DOH
Maaiachuaatt* DBP
HaaiAchuaatta OBP
Hlaaourl DNR L DOH
Hlaaourl DNR t, DOH
Hlaaouri DOH
4«iachuattt> DBP
(•••a.chu>«tt* 0BP
H««««chua»tt« DSP
Ha»enchuoatta DBP
Hlaaouri DOH
Hlaaouri DOH
Hinourl DOH
Hlaaouri DOH
1.031.37000
0.06000
0.610100
0.160000
0.700000
0.270000
0.03000C
8. 000000
0.310000
11.800000
11.800000
11.800000
11.800000
Haaaachua*tt« DEP
Haaakchuaatta DEP
Haaa.cKua.et. UKC
Maaaachuevtto DBP
Maaaachuaatto DBP
taapochuaat ta DBP
laBaachuaatt a DBP
1aa0achua«tta DBP
Haaaachuaatta DBP
Haaaachu»«tta DBP
-------
Miscellaneous ARARs
-------
-------
MISCELLANEOUS ARARs(a)
Code of State Regulations
10CSR 10-2.060
10CSR 10-2.070
10CSR 10-2. 100
10 CSR 10-6.010
10CSR 10-6.040
10 CSR 10-6. 170
10 CSR 10-6. 180
10 CSR 20-6
10 CSR 20-6.200
10 CSR 20-7.0 15
10 CSR 20-7.031
10 CSR 23-4.010(1)
10 CSR 23-4.4060 (4)
10 CSR 23-6.060
10 CSR 25-6.263 (2)
10 CSR 25-7.264 (2)(G)3 '
10 CSR 25-7.264 (2)(G)4
10 CSR 25-7.264 (2)(K)
10 CSR 25-7.264 (2)(L)
10 CSR 60-4.030
10 CSR 60-4.040
10 CSR 80-2.020 (l)(a)
10 CSR 80-2.020 (9)(a)l
10 CSR 80-2.020 (9)(a)5
10 CSR 80-2.020 (9)(b)
40 CSR Part 122
Revised Statutes of Missouri
260.200(4) RSMO
260.200(34) RSMO
260.210. 1(1) RSMO
Code of Federal Regulations
40 CFR 263
40 CFR 264.1 16
40 CFR 264.1 18
40 CFR 264.228
40 CFR 264.600
40 CFR 264. 11 01
40 CFR 264. 11 02
40 CFR 265.373-381
40 CFR 403.5
Comprehensive Environmental Response,
Compensation and Liability Act
CERCLA 121(d)(2)A
CERCLA 121(d)(3)
Federal Regulations
FR 47982, 48047 (Revised 40 CFR 268.40)
(a) Note that some of these notations may have been stated earlier.
-------
-------
Final Record of Decision Area IS Operable Unit
Lake City Army Ammunition Plant. Independence. Missouri
APPENDIX E
RESPONSIVENESS SUMMARY
February 1998
-------
-------
Final Record of Decision Area 18 Operable L'nu
Lake dry Army Ammunition Plant. Independence. Missouri
Responsiveness Summary
Remedial Action at Area 18 Operable Unit
Lake City Army Ammunition Plant, Independence, Missouri
1. Overview
The United States Army established a public comment period from April 14 to May 14. 1997 for
interested parties to review and comment on remedial alternatives considered and described in
the Proposed Plan for the Area Eighteen Operable (.Area 18 OU). The Proposed Plan was
prepared by the Army in cooperation with the U. S. Environmental Protection Agency (EPA) and
the Missouri Department of Natural Resources (MDNR).
The Army also held a public meeting at 7:00 p.m. on April 22, 1997 at the Roger T. Sermon
Center in Independence, Missouri to outline the proposed remedy to reduce risk and control
potential hazards at the Area 18 OU.
The Responsiveness Summary provides a summary of comments and questions received from
the community at the public meeting and during the public comment period as well as the
Army's responses to public comments.
The Responsiveness Summary is organized into the following sections:
• Background on Community Involvement
Summary of Comments and Questions Received During the Public Comment
Period and Army Responses
• Remaining Concerns
The selected alternative for the Area 18 OU, Soil Vapor Extraction and Treatment in
combination with Ground Water Extraction and Treatment, includes the following major
components:
Soil vapor extraction and treatment using a multi-phase extraction system and
treatment of vapors.
• Ground water extraction and treatment.
• Institutional controls and long-term monitoring.
2. Background on Community Involvement
In August 1987, LCAAP was listed on the EPA's National Priorities List (NPL). A Federal
Facilities Agreement (FFA) was signed by the Army, EPA, and the State and went into effect on
E-l February 1998
-------
Final Record of Decision Area 18 Operable Unit
Lake City Army Ammunition Plant. Independence. Missouri
November 28, 1989. The FFA establishes a procedural framework and schedule for developing
implementing, and monitoring appropriate response actions for LCAAP.
Community relations activities that have taken place at LCAAP to date include:
FFA process - After preparation of the FFA by the U. S. .Army. EPA and
MDNR, the document was published for comment. The FFA became effective
November 1989.
Administrative Record - An Administrative Record for information was
established in Building 3 at LCAAP. The Administrative Record contains
information used to support Army decision-making. All the documents in the
Administrative Record are available to the public.
Information repositories - An Administrative Record outline is located at the
Mid-Continent City Library, Blue Springs Branch (public repository) and at the
west entrance to the Plant (Building 6).
Community Relations Plan (CRP) - The CRP was prepared and has been
accepted by EPA and the State of Missouri and is being implemented. This plan
was updated in 1996.
Restoration Advisory Board (RAB) - The RAB has been formed to facilitate
public input in the cleanup and meets quarterly. In addition to Army, EPA and
Missouri oversight personnel, the RAB includes community leaders and local
representatives from the surrounding area.
Mailing list - A mailing list of all interested parties in the community is
maintained by LCAAP and updated regularly.
Fact sheet - A fact sheet describing the status of the IRP at LCAAP was last
distributed to the mailing list addressees in November 1996.
Proposed Plan - The Proposed Plan on this action was distributed to the mailing
list addressees for their comments.
The Proposed Plan for this remedial action was distributed to the mailing list addressees for their
comments, and additional copies of the Proposed Plan were available at the April 22. 1997 public
meeting. A transcript of comments, questions and responses provided during the public meeting
was prepared. r 6
E-2
February 1998
-------
Final Record of Decision Area 18 Operable L'nit
Lake City Army Ammunition Plant. Independence. Missouri
3. Summary of Comments and Questions Received During the Public Comment Period
and Army Responses
Part I - Summary and Response to Local Community Concerns
In review of the written transcript of the public meeting, there were no community objections to
the proposed remedial action indicated. No written comments were received during the public
comment period.
The majority of the comments received during the public meeting were in the form of questions
about the remedial investigation findings and the remedial action (i.e., what would be done, how
it would be done, and what effects the action might have). Representatives of the Aimy were
available to provide answers to the questions and also provided an overview presentation during
the meeting to describe the proposed actions.
Part II - Comprehensive Response to Specific Technical, Legal and
Miscellaneous Questions
There were no community objections to the proposed remedial action and there were no
comments or questions from the public as a result of the April 22, 1997 public meeting.
4. Remaining Concerns
Based on review of the transcript of the oral comments received during the public meeting, there
are no outstanding issues or remaining concerns associated with implementation of the proposed
remedial action.
E-3 Febnnr.- \998
-------
-------
DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs
REMEDIAL ALTERNATIVE
DESCRIPTION
ACTION-SPECIFIC ARARs
ARAR STATUS
COMMENTS
SOURCE-AREA Al.THRNATIVES
Alternative SA-1: No Action
NA
NA
Alternative SA-2: Containment--
Capping and Vertical Barriers
• Erosion and sediment control and
stormwatcr management provisions
• Installation of a cap
• Installation of a vertical barrier
• Revcgelalion of Ihecap
I. 40 CFR 264.228
IOCSR25-7.264{2)(K)
I. Potentially
Applicable
The contaminated area will probably be classified as a suiface
impoundment. The Slate of Missouri at IOCSR 25-
7.264(2)(K) incorporates by reference and sets I'oiih standards
which modify or add to the federal requirements foi surface
impoundments in 40 CFR Part 264. SubpartK. If the
contaminated area is classified as a surface impoundment, then
Ihe closure and post-closure requirements in 40 CFR § 264.228
and IOCSR 25-7.264(2)(K) are applicable.
2. IOCSR 10.6.170
2. Applicable
2. Fugitive dust emissions may be produced from the excavation
activities. The Stale of Missouri at IOCSR 10 6.170 restricts
persons from causing or allowing fugitive paniculate matter lo
go beyond the premises where such matter originates. The
limitations on the quantities as well as exceptions to the ink- aie
described in detail at IOCSR 10-6.170(1995).
3. IOCSR 20-6.200
3. Applicable
3. The pertinent requirements for storm wafer disehaiges thai aie
cited at 10 CSR 20-6.200 Storm Water Regulation will provide
ARARs for excavation activities.
Notes; Because the State of Missouri has received RCRA base authorization for certain parts of the RCRA Hamdotis and Solid Waste Amendments (I ISWA) of 1984
to administer and enforce the RCRA ha/ardous waste management programs in lieu of the federal program, the Slate hazardous waste regulations will provide AK ARs
In addition. Ihe Slate of Missouri in many instances incorporates by reference Ihe federal ha/ardous requirements and sels forth Stale requi.emenis which modify «'„
add lo Ihe federal requirements and the Stale has modified or udded lo the federal regulations, (he federal citation has also been provided in the action-.vpccilic ARARs
l:\l>K()]\6(W840IVI>(H)l.\ROI>\l)ITJ:NI.VACT.AKAKTbl.
-------
DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARAR.S (Continued)
REMEDIAL ALTERNATIVE
DESCRIPTION
SA-2 (Continued)
ACTION-SPECIFIC ARARs
4. 59 Federal Register 47982.
48047, September 9,1994
(cffeclive December 19,
1994) lobe codified in (he
Code of Federal Regulations
as revised 40 CFR § 268.48
ARAR STATUS
4. Applicable
COMMENTS
4. Because the contaminated soil will be excavated and treated in
a separate unit, when the soil is used as backfill, placement will
occur. As a result, land disposal restrictions will he triggered.
Hazardous soils are generally subject to Hie I.DR treatment
standards that apply to the ha/.ardous wastes with which the
soils are contaminated (59 FR 47982, 47986, September 9,
1994). Waste codes must first be identified for each listed and
characteristic ba/ardous waste. To discern the I.DR liealmenl
standards for listed wastes and for wastes exhibiting the toxieily
characteristic, refer to the table titled "Treatment Standards for
Hazardous Wastes" published in 59 l-'ederal RegiMer 47982.
48047, September 9, 1994, (effective December 19, 1994) to
be codified in the Code of Federal Regulations as revised 40
CFR § 268.40, using the identified waste code. The right hand
column of this table, for non-wastcwatcr, i.c, soil, lists the
treatment standard applied to each specific waste code. Soils
containing a specific waste can be land disposed as long as ihe
concentration of the waste in the soil is below the specified
treatment standard. However, because contaminated soils are
considered by EPA to be significantly different in llu-ir
trealability characteristics from Ihe wastes that have been
evaluated in establishing the BOAT standards, contaminated
soils will generally qualify for a treatability variance undei 40
CFR § 268.44 (59 FR 47982, 47987). The procedures for
obtaining a treatability variance are described at 40 CFR ROJ\609H40I\1>OOI AROI}\DIT_FNIMCT_ARAR TBI.
•f?
-------
DESCRnmON OP RUMBDUL ALTERNATIVES AND SUMMARY O, AC
REMEDIAL ALTERNATIVE
DESCRIPTION
~"~~^~— — — — — — — — — — ___^__
SA-2 (Continued)
======================
ACTION-SPECIFIC ARARs
— . — _
5. iOCSR 25-7.264(2)(6)3
IOCSR 25-7.264(2)(6)4
40CFR§264.II6
40CFR§264.II9
— — ...
A RAR STATUS
5. Applicable
1
^ AHAK., ,O, ........ „,
COMMENTS
As a pan of (his remedial alicrnalivc. institutional controls will
be employed. 40 C.KR § 300.430(a)( I ,(iii)(D) slalcs „,„,
U A expects lo use msliluiionul controls such as water use and
deed rcslr.ctions to supplement engineering conltols as
appropriate for short- and long-tern, management to preveni ,„
limit exposure (o ha/.ardous suhslances, pollutants or
40 r r'iri!^''; Sli"C °TMlSMU'ri illi;'"l'<>ra,es hy rele.cncc
40 C.f-.R. §(, 264.116 and 264.119 and adds addition,!
requirements. The State of Missouri stales at IOCSR 25-
7_264(2)(G)3 (hat in addhioi, to the requirements in 40 C I- R (51
264.116 when an owner/operator certifies a closure which did'
nol result in the removal of wastes to background levels the
owner/operator shall record a notation on an instrumenllvhich
is normally examined during title search that in pe.pciuily will
notify any polential purchaser ol the properly that (he huul IMS
rlS «°3 '" managC ha/ilrdl)us waslt- Also, pursuant,«, 10
CSR 25-7.264(2X0)4, the notation shall be rceo.ded will, the
recorder(s) of deeds in all counties in which (he facility8!*
located.
l-.U'ROJ\50<)840IU'00|.\R()l)\l)Krj-TMI.\AtT.ARARTHI.
-------
DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Continued)
REMEDIAL ALTERNATIVE
DESCRIPTION
Alternative SA- 3: Excavation with
Onsite Thermal Treatment,
Replacement and 2-fl. Cover
• Erosion and sediment control and
stormwalcr management provisions
• Selective excavation of inactive
waste lagoons
• Collection of ground water
infiltrating into the excavation and
onsile treatment
• Set up of low temperature thermal
shipping facility onsile
• Treatment of excavated materials and
backfill onsitc
• Installation of 2-ft. cap
• Revcgctalion of disturbed area
• Ground water monitoring
ACTION-SPECIFIC ARARs
I. 10 CSR 10-6.170
2. 10 CSR 20-6.200
ARAR STATUS
1. Applicable
2. Applicable
I.
COMMENTS
Fugitive dust emissions may he produced from the excavation
activities. The State of Missouri at 10 CSR I0-6.l7t)rcstiicls
persons from causing or allowing fugitive paniculate mailer to
go beyond (lie premises where such mailer originates. The
limitations on the quantities as well as exceptions to the mle aic
described in detail at 10 CSR 10-6.170 (IW5).
2. The pertinent requirements for storm water discharges thai are
cited at 10 CSR 20-6.200 Storm Water Regulation will provide
ARARs for excavation activities.
I- U'R()J\6098^0IVl'OOI.\ROI)U)IT_fNL\ACT ARAR TIM.
-------
DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Continued)
REMEDIAL ALTERNATIVE
DESCRIPTION
ACTION-SPECIFIC ARARs
ARAR STATUS
COMMENTS
SA-3 (Continued)
3. 4<)Cr-R§264.6()()
40 CFR§§ 265.373
through 265.381
3 Potentially
Applicable
3. It appears liiai the thermal treatment unit will he classified us a
miscellaneous treatment unit. 10 CSK 25-7.264 Standards foi
Owners ami Operators ol' Hazardous Waste Treatment, Storage
and Disposal Facilities is the stale rule that corresponds to 10
CT'R Part 264 Standards lor Owners and Operators of
Hazardous Waste Treatment, Storage and Disposal Facilities.
The Slate of Missouri does not have any provisions pertaining
to miscellaneous treatment units. Therefore, if the (heimal
treatment process takes place in a miscellaneous treatment unit,
then the requirements in 40 CI;R § 264.600 would provide
ARARs. Also, the thermal treatment requirements of 40 CTR
265.373-381 may be relevant and appropriate if the excavated
soil is to be treated in a device other than an enclosed device
using controlled flame combustion, unless 40 CFR 265.1
provides otherwise.
4. IOCSR25-7264(2)(L)\
4. Potentially
Applicable
If the contaminated soil is staged in piles before treatment, ihe
Army is determined to be a large quantity generator, and the
excavated soil remains in this area for more than 90 days, (lien
the State of Missouri may define the remediation area as a
waste pile. The Stale ol Missouri at lOC'SR 25-7.264(2)(l.)
incorporates by reference and sets forth standards which
modify or add to the federal Requirements for waste piles in 40
CFR Part 264, Subparl L.
!• \1'K()J\WW8')III\1'OOL.\R()1>U)I-T.WI.\ALT ARAR Till.
-------
DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARAR.S (Cominuc,
bminucd)
REMEDIAL ALTERNATIVE
DESCRIPTION
SA-3 (Continued)
ACTION-SPECIFIC ARARs
ARAR STATUS
COMMENTS
In order lc> he exempted from the waste pile requirements in 40
CI;R § 264.251, wliich Missouri incorpoiaics by reference; 40
CI;R Pan 264. Subparl F. which Missouri incorporates by
reference; and IOCSR 25-7.264(2)(L)2.K, the waste pile muM
meet the following requirements: liquids or materials
containing free liquids are not place in the pile; the pile is
protected from surface water run-on by the sliucluie or in some
other manner; the pile is designed and operated to control
dispersal of the waste by wind, where necessary, by means
other than wetting; the pile will not generate Icachale through
decomposition or other reactions; and the pile mu.sl he at least
ten feet above the historical high groundwaler table. If the
remediation pad upon which the soil is placed is classified by
the State as a waste pile and cannot meet the above stated
requirements for exemption, then the design and opeiating
requirements and closure and post-closure requirements will
provide ARARs. In addition, if the remediation pad is
classified as a waste pile, then the excavated soil will need to
meet land disposal restrictions prior to placement in the waste
pile
l:\PR()J\6(»8^)l\J'(K)l.\ft()l)\J)Kr I-NIAACT.ARAR TBI.
-------
DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Continued)
REMEDIAL ALTERNATIVE
DESCRIPTION
ACTION-SPECIFIC ARARs
ARAR STATUS
COMMENTS
SA-3 (Continued)
5. 59 Federal Register 47982,
48047, September 9, 1994,
(effective December 19,
1994) to be codified in the
Code of Federal Regulations
as revised 40 CFR § 268.40
5. Applicable
5. Backfilling with the treated soil may be a part of this lemedial
alternative. Because the contaminated soil will be excavated
and treated in a separate unit, when the soil is used as backfill,
placement will occur. As a result, (he land disposal restrictions
will be triggered. Hazardous soils are generally subject to Ihe
LDR treatment standards that apply to ihe ha/.aidous wastes
with which Ihe soils arc contaminated (59 I-'R 47982, 47986,
September 9, 1994). Waste codes must fust be identified for
each listed and characteristic hazardous waste. To discern Ihe
I.DR treatment standards for listed wastes and for wastes
exhibiting the toxicity characteristic, refer to the table titled
"Treatment Standards for Hazardous Wastes" published in 59
Federal Register 47982, 48047, September 9, 1994, (effective
December 19, 1994) to be codified in the Code of f;edeial
Regulations as revised 40 CFR § 268.40, using the identified
waste code. The right hand column of this table, for non-
wastewater, i.e, soil, lists Ihe treatment standard applied to each
specific waste code. Soils containing a specific waste can be
land disposed as long as the conccntiation of the waste in Ihe
soil is below the specified treatment standard. However,
because contaminated soils are considered by HP A to be
significantly different in their Irealability characteiislics from
the wastes that have been evaluated in establishing the UDAT
standards, contaminated soils will generally qualify lor a
Irealability variance under 40 CFR § 268.44 (59 I-'R 47982,
47987). The procedures for obtaining a treatability variance
are described at 40 CFR § 26K.44
l:\HR()j\6U9S40l\l'()OI.\R()U\l)Fr. I-NIAACT.ARAR TBI,
-------
DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Continued)
REMEDIAL ALTERNATIVE
ACTION-SPECIFIC ARARs
SA-3 (Continued)
6. 10CSR25-7.264(2)(K)
40 CFR § 264.228
7. IOCSR 25-7.264(2)(6)3
10CSR 25-7.264(2)(6)4
40 CFR §264.116
40 CFR §264.119
6. Potentially
Applicable
7. Applicable
6. The contaminated area will probably be classified as a .surface
impoundment. The Stale of Missouri al 10 CSR 25-
7.264(2)(K) incorporates by reference and sets forth standaids
which modify or add to the federal requirements for surface
impoundments in 40 CFR Part 264, Subpart K. II the
contaminated area is classified as a surface impoundment, llicn
the closure and post-closure requirements in 40 CFR § 264 228
and 10 CSR 25-7.264(2)(K) arc applicable.
7. As a part of this remedial alternative, institutional controls will
be employed. 40 C.F.R. § 3()0.430(a)( I )(iii)(D) states Hint
EPA expects to use institutional controls such as water use and
deed restrictions to supplement engineering controls as
appropriate for short- and long-term management to prevent or
limit exposure to hazardous substances, pollutants, or
contaminants. The Slate of Missouri incorporates by reference
40 C.F.R. §§ 264.116 and 264.119 and adds additional
requirements. The State of Missouri slates al 10 CSR 25-
7.264(2)(G)3 that in addition to the requirements in 40 C.F.R. §
264.116, when an owner/operator certifies a closure which did
not result in the removal of wastes to background levels, the
owner/operator shall record a notation on an instrument which
is normally examined during title search lhal-in perpetuity will
notify any potential purchaser of the properly that the land has
been used to manage hazardous waste. Also, pursuant to If)
CSR 25-7.264(2)(G)4, the notation shall he recorded with the
recordcr(s) of deeds in all counties in which the facility is
located.
KVmM\609840l\KX)l.\ROO\OITJttl.\ACT_ARAR.TBI.
-------
DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Continued)
REMEDIAL ALTERNATIVE
DESCRIPTION
ACTION-SPECIFIC ARARs
ARARSTATUS
COMMENTS
Alternative SA-5: Excavation with
Oflsite Treatment and Disposal
• Hrosion and sediment control and
slormwaler management provisions
• Selective excavation of inactive
waste lagoons
• Collection of giuuud water
infiltrating into the excavation and
onsitc treatment
• Transportation of excavated material
off si le for treatment and disposal
• Backfilling of excavated areas vvilli
clean Fill, rcgrading, rcvcgetalion
• Ground water monitoring
I. IOCSR 10-6.170
I. Applicable
2. IOCSR 25-6.263(2)
40 CFR Part 263
CERCLA§
2. Applicable
I. Fugitive dust emissions may be produced from the excavation
activities. Tlic Slate of Missouri at IOCSR 10 6.170 restricts
persons from causing or allowing fugitive paniculate mallet to
go beyond the premises where such mallei originates. The
limitations on the quantities as well us exceptions to the uile aie
described in detail at IOCSR 10-6.170 (1995).
2. II) CSR 25-6.263 Standards for Tianspoilers of llii/.aidntis
Waste incorporates 40 CI;R I'art 263 by reference and sets
forth additional state requirements. 10 CSR 25 6.263(2)
provides that a hazardous wasie transporter shall comply wiili
the requirements of this Missouri section in addition 10 the
federal transporter requirements. Slate and federal transpoi tei
requirements such as manifest and packaging requirements will
provide ARARs. Also, facilities used for off-site disposal ate
required by C'ERCLA § I2l(d)(3) lo be in compliance with nil
pertinent RCRA requirements (have a RCRA permit or inleiim
status and have any releases from Solid Waste Management
Units being controlled by corrective action).
3. IOCSR25-7.264(2)(K)
40 CFR §264.228
3. Potentially
Applicable
3. The contaminated area will probably be classified as a suilace
impoundment. The Stale of Missouri at 10 CSK 25-
7.264(2)(K) incorporates by reference and sets I'oilh standards
which modify or add to (lie federal requirements for surface
impoundments in 40 CFR Pan 264, Subpart K. If the
contaminated urea is classified as u suilace impoundment, then
the closure and post-closure requirements in 40 CT'R § 264.228
and 10 CSR 25-7.264(2)(K) arc applicable.
ARARTBI.
-------
DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Continued)
REMEDIAL ALTERNATIVE
DESCRIPTION
ACTION-SPECIFIC ARARs
ARAR STATUS
COMMENTS
SA-5 (Continued)
4. 10 CSR 25-7.264(2)(6)3
IOCSR25-7.264(2)(6)4
40CTR§264.II6
40CFR§264.II9
4. Applicable
4. As u part of this remedial alternative, inslitulional controls will
lie employed. 40C.F.R. § 3lH).43(>(a)(l)(iii)(l>) slates linn
Hl'A expects to use instiluliinial controls such as water use anil
deed restrictions to supplement engineering controls as
appropriate for short- and long-term management to prevent or
limit exposure to hazardous substances, pollutants, or
contaminants. The Stale of Missouri incorporates by icl'eicncc
40 C.F.R. §§ 264.116 and 264.119 and adds additional
requirements. The Slate of Missouri stales at 10 CSR 25-
7.264(2)(G)3 that in addition to the requirements in 40 C.F.R. §
264.116, when an owner/operator certifies a closure which did
nol result in the removal of wastes to background levels, the
owner/operator shall record a notation on an insliunicm which
is normally examined during title search thai in pcipcluily will
notify any potential purchaser of the property that the land has
been used to manage ha/.ardous waste. Also, pursuant to 10
CSR 25-7.264(2)(G)4, the notation shall tie recoidcd with the
rccorder(s) of deeds in all counties in which the facility is
located.
I- U>R\UFr_FNL\ALT_ARAR THI.
10
-------
DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Continued)
REMEDIAL ALTERNATIVE
DESCRIPTION
SA-6 Option l/SA-8 Option 2a
Land Farming
• l.aiul farming of contaminated soil
without air controls. Land farming
under (his option will he performed
in mi open area without any air
control system.
• Excavate soil to 20 I'l.
• Construct a remediation pad (hat will
consist of a liner and sand. Piping
wilt be installed in the sand to collect
run-off. • Spread 2 ft. soil layer on
the sand.
• Backfill with treated soil.
ACTION-SPECIFIC ARARs
1. IOCSR 10-6.170
2. IOCSR 20-6.200
AR A R STATUS
1. Applicable
2. Applicable
COMMENTS
1. Fugitive dust emissions may be produced from the excavation
activities. The Stale of Missouri HI IOCSR l()-d. 170 restricts
pei sons from causing or allowing fugitive paniculate matter to
go beyond the premises where such mallei oiigmales. The
limitations on (lie quantities as well as exceptions to ihc rule me
described in detail al IOCSR 10-6.170 (IW)
2. The pertinent requirements for storm water discharges thai are
cited al IOCSR 20-6.200 Storm Water Regulation will provide
ARARs for excavation activities. ___
!• M'K(>)\609B4l)l«'OOI.W)!>U>IT_HNI.\ACT_ARAR TBI.
II
-------
DESCRIPTION OH REMHDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Conlmuecl)
COMMENTS
REMEDIAL ALTERNATIVE
DESCRIPTION
SA-6 Option 1 /SA-8 Option 2a
(Continued)
ACTION-SPECIFIC ARARs
3. Missouri Title V Pcrmil
Program
IUCSR 10-6.010
ARARSTATUS
3. TBC Guidance
Potentially
Applicable
3. The Clean Air Act Amendments of 1990 added (he Tillc V
Program which establishes a fedeial operating periuii program
for numerous sources of air pollution. The CAA Amendments
require Missouri lo umdify its operating permit piogiam lor
sources of air pollutants to meet the requirements of Title V by
November 15, 1993. According to a personal communication
with h'ric Giroir of the Missouri Aii Polliiiion Com ml Progiam.
Missouri has submitted to EPA (heir Title V Permit Piogiam
and expect it to he accepted by the end of I9l)5. Missouri is
currently operating on an interim program. Until the Mksumi
rule is approved by EPA, it provides only TIK? guidance.
Missouri has adopted the National Ambient Aii Quality
Standards (NAAQS) and enforces them through permits.
These Missouri standards are published at 10 CSR 10 6.010
(1994), Ambient Air Quality Standards. If emissions exceed
regulated levels, then the Air Pollution Control Program may
require Air Pollution Dispersanl Modeling lo be conducted.
Based on results of the modeling, some loim ol air pollution
control may be required. [Personal communication with K.
Jjuven (314) 751-48171. In addition. Missouri's Aii
I \l'K<)J«i<»IMOI\l'0<>l.WC)|«U|.T. I-NIAACT AKAk TBI.
12
-------
DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Continued)
=====
ARAR STATUS COMMENTS
REMEDIAL ALTERNATIVE
DESCRIPTION
SA-6 Option 1 /SA-8 Option 2a
(Continued)
ACTION-SPECIFIC ARARs
Pollution Control Program utili/.cs "acceptable ambient levels,"
(AALs), which have not been promulgated and apply only lor
construction permits. These levels represent the concentration
of a contaminant that is not to be exceeded at (he fence line.
[Personal communication with Li. Oiioir (314) 751 4817.|
All emission points at a Supcilund site would be uin.sideied
one stationary source for purpose of determining applicability
of "Prevention of Significant Deterioration" (I'SD) Review.
I.CAAP does not appear to be a "major source" pursuant to 40
CFR § 52.2l(b)(l)(i)(a) (I'J94). liven though I.CAAP site
could be designated a major source pursuant to 40 CI;R §
52.2l(b)(l)0)(b) (1994) if the combined emission points at.
LCAAP emit (or have the potential to emit) 250 or moie tons
of any regulated pollutant a year, it is unlikely that this would
occur.
Although LCAAP would not he required under CliRCLA to
obtain a Missouri Air Pollution Control Permit since this would
be an administrative requirement, ul! the substantive
requirements of a permit could potentially be ARAR. To
obtain an Air Pollution Control Permit, the peimiitce must
estimate the emissions anticipated from the entire process. II
the potential emissions are expected to be greater than the
regulated level published at 10 CSR 10-6 Table I, then a
Missouri Air Pollution Control Permit is lequired. Hecause
LCAAP is located in Jackson County which is an attainment
area, the Air Pollution Control Rules Specific to ihe Ouisiaie
Missouri Area, would be potentially applicable 110 CSK 10-3
(1991, amended I992)|. Although iliis chaptci idemilics the
restrictions that would potentially be incoiporatcd in .1 pcimil
for remedial construction activities at Area IK, the only section
applicable to Jackson County icstiicls sulphur compound
emissions (10 CSR 10-3. KM)).
I \I'K()l\M»84ni\WK)l.\HO|)\IJ|.TJ'TMt.\ALT_ARAH TDI.
13
-------
DBSCRimON OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTON-SPECIFIC ARARs (Con.inucd,
iSST' 1 laaBUnil — ! — man, --mi ii i _ j.ii -ii n un |||[|i| |i _
REMEDIAL ALTERNATIVE
DESCRIPTION
SA-6 Option l/SA-8 Option 2a
(Continued)
• S^3M»— N| ,
ACTION-SPECIFIC ARARs
4. 10 CSR 25-7.264(2)(L)
i' ==a«=3a
ARAR STATUS
4. Potentially
Applicable
•
— ^ — — — — — __
===============*==«B=====^
COMMENTS
None of identified contaminants of concern full into llus
category; therefore, Chapter 3 provides no ARARs. | Personal
communication with K Nuyen(3l<1)751 4RI7I
4. The Slate of Missouri may define the lemediation pad upon
which (he excavated soil will he placed as a waste pile if the
Army is determined to be a large quantity generator and the
excavated soil remains in this area for more Ihan 'JO days The
Slate of Missouri at 10 CSR 25-7.264(2)(L) inco.po.alcs by
reference and sets forth standards which modify or add m the
federal requirements for wasle piles in 40CFR Pan 264,
Subparl L. In order to he exempted from Ihe wasle pile
requirements in 40 CFR § 264.251, which Missouri
incorporates by reference; 40 CFR Part 264, Subparl l;, which
Missouri incorporates by reference; and 10 CSR 25-
7.264(2 )(L)2.F., the wasle pile must meet (lie following
rei|uiremenls: liquids or materials containing free liquids are
not place in the pile; the pile is prolccicd from surface walcr
run-on by Ihe structure or in some other manner; the pile is
designed and operated to conlrul dispeisal of the wasle by
wind, where necessary, by means other than welling; Hie pile
will not generate Icachale through decomposition or other
reactions; and Ihe pile musi he ai least len feel above the
historical high groundwaier table. If the remediation pad upon
which the soil is placed is classified by the Slate as a wasle pile
and cannot mcel the above slated requirements loi exemption,
then the design and operating requirements and closine and
post-closure requirements will provide ARARs. In addition, il
the remediation pad is classified as a waste pile, Iben the
excavated soil will need to meet land disposal icsiiiciions piiui
to placement in the waste pile
l:.\l'ROJ\609MI)l\l>(K)l.\HOI)\Ol-TJ«l.\AtT_ARAR.TBl.
14
-------
DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Comim.cJ)
REMEDIAL ALTERNATIVE
DESCRIPTION
SA-6 Option 1 /SA-8 Option 2a
(Continued)
ACTION-SPECIFIC ARARs
5. 59 Federal Kegisiti 47982,
48047, Scpicmher 9, 1994.
(effective December 19,
1994) to he codified in the
Code of Federal Regulations
as revised 40 CFR § 268.40
ARAR STATUS
5. Applicable
COMMENTS
5. Because the conlnminaied soil will he excavated and ticated in
a separate unit, when the soil is used as backfill, placement will
occur. As a result, land disposal restrictions will he triggered
Hazardous soils are generally subject to the U)R licaliucm
standards that apply to the ha/.ardous wastes with which the
soils are contaminated (59 FR 47982, 47986, September 9,
1994). Waste codes must first he identified for each listed and
characteristic hazardous waste. To discern the l.l)|{ treatment
standards for listed wastes and for wastes exhibiting the tuxicity
characteristic, refer to the table titled "Treatment Standards for
Hazardous Wastes" published in 59 I'eileml Kcgisler 47982,
48047, September 9, 1994, (effective December 19, 1994) to
be codified in the Code of Federal Regulations as revised 40
CI;R § 268.40, using Ihc identified waste code. The right hand
column of this (able, for non-wastcwater, i.c, soil, lists the
treatment standard applied to each specific waste code. Soils
containing a specific waste can be land disposed as long as the
concentration of the waste 111 the soil is below the specified
treatment standard. However, because contaminated soils are
considered by EPA to he significantly different in their
Ircatability characteristics from (he wastes thai have been
evaluated in establishing (he BOAT standards, contaminated
soils will generally qualify for a trealabilily vaiiiince under 40
CFR § 268.44 (59 FR 47982, 47987). The procedures for
obtaining a trealabilily variance are described ai 40 C'f;R §
268.44.
K\HROJ\609S40l\l'OOI.\R01>\UIT_INI.\ACr_ARARTBI.
15
-------
REMEDIAL ALTERNATIVE
DESCRIPTION
—^———
ISA-6 Option I/SA-8 Option 2a
(Continued)
ACTION-SPEC1FIC ARARs
6. IOCSR25-7.264(2)(K)
40 CFR §264.228
ARAR STATUS
6. Potentially
Applicable
7. IOCSR 25-7.264(2)(6)3
IOCSR25-7.264{2)(6)4
40 CFR §264.116
40 CFR §264.119
7. Applicable
COMMENTS
_ _
6. The contaminated area will probably be classified as a surface
impoundment. The State of Missouriat 10 CSR 25-
7.264(2)(K) incorporates by reference and sets forth standards
wh,ch mod.fy or add to the federal requirements for surface
impoundments in 40 CFR Pan 264, Subparl K If (he
comammated area is classified as a surface impoundment, lhcn
the closure and post-closure requirements in 40 CFR § 264 228
and 10 CSR 25-7.264(2)(K) arc applicable.
—
7' £f " P"" of I"'* remedial alternative, institutional controls will
EPA expects to use institutional controls such as water use and
deed restricts to supplement engineering controls as
appropriate for short- and long-term management to prevent or
limit exposure to hazardous substances, pollutants, or
40C.F.R. §§ 264.116 and 264.119 and adds additional"
requirements. The Slate of Missouri stales at 10 CSR 25-
7264(2X0)3 that in addition (o the requirements in 40 C V R 5
264.116. when an owner/operator certifies a closure which did'
not result in the removal of wastes to background levels the
owner/operator shall record a notation on an instrument which
is normally examined during title search that in perpetuity will
notify any potential purchaser of the property that the land |,as
CSR 25-7 264(2)(G)4, the notation shall he recorded with the'
recorder^) of deeds in all counties in which the facility is
. located. ' '
l-.«W)JWW«4ll|\rooi.W()U«>|.T_ r'NIAACT..ARAR TBI.
16
-------
DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Continued)
REMEDIAL ALTERNATIVE
DESCRIPTION
ACTION-SPECIFIC ARARs
ARARSTATUS
COMMENTS
SA-6 Option2/SA-8 Option 2b
Land Farming
• Land funning of the contaminated
soil will) iiir controls. This will
include collection and treatment of
vapors generated during land
fanning. Land farming under this
option will he performed in a closed
structure,
• Perform u predesign study lo further
define the extent of soil
contamination, engineering design
data, and waste classification.
• Install erosion and sediment controls
and implement storm water
management action.1:.
• Excavate VOC-conlaminated soil lo a
depth of approximately 20 ft., except
the northern half of AOC2 which will
he excavated lo 3 ft. (12,300 CY).
Superficial soil will also he excavated
since it is contaminated with VOCs.
• Perform confirmatory sampling of the
excavation to verify VOC removal.
• Collect ground water infiltrating into
the excavation and treat by using the
existing Area 18 removal action
water treatment system.
• Treat VOC-con(amina(cd soil onsile
using land farming treatment
technology.
• Conduct sampling of treated soil (o
confirm Ilia) treated soil meets VOC
remediation goals and the TCL.P test
I. 10 CSR 10 6.170
I. Applicable
2. 10 CSR 20-6.200
3.CLiRCLA§
2. Applicable
3. Applicable
I. Fugitive dust cmissions'may he produced lioin the excavation
activities. The Stale of Missouri at IOCSR 10-6.170 restricts
persons from causing or allowing fugitive paiticulate matter to
go heyond (lie premises where such mailer originates. The
limitations on the quantities as well as exceptions lo the lule aie
described in detail at IOCSR 106.170(1995).
2. The pertinent requirements for storm water discharges that aic
cited at IOCSR 20-6.200 Storm Water Regulation will puividc
ARARs for excavation activities.
3. Pursuant to this remedial alternative, the ground w.ilei
infiltrating into the excavation will be collected and treated by
using the existing Area 18 removal action water treatment
system. CERCLA § l2l(d)(2)(A) requires that by completion
of a selected remedial action thai any ha/ardous substance,
pollutant, or contaminant remaining on site, attains either non-
zero MCLGs pursuant to (he SDWA, or in their absence,
MCLs, when such goals or limits are relevant and appropiiate
under the circumstances ol (he release. As a result, the
collected and treated groundwater being dischaigcd lo the
Industrial Waslewaler Treatment Plant (1WTP) will piobably
have to meet non-zero MCLGs or MCLs.
HllKIUV6(NIM(M)IMt()l>\I)|-T I-NIWT ARARTUI.
17
-------
DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY Ol' ACTION-SPHCIHC
REMEDIAL ALTERNATIVE
DESCRIPTION
J»A-6 Gption2/SA-8 Option 2b
(Continued)
ACTION-SPECIFIC ARARs
4.40 CFR §264.1101
40 CFR §264.1102
5. Missouri Tille V Permit
Program
IOCSR 10-6.010
ARARSTATUS
4. Potentially
Applicable
5. TBC Guidance
Potentially
Applicable
ARARs (Continued)
-
COMMENTS
4. PiitMiam to this remedial iillcinative, ihe hind limning
technology will he petlbrined in a closed slruetuie. As a icsuli
the closed structure will probably be classified as a containment
building under RCRA. If the closed structure is classified as a
containment building, llien the design and operating
requirements at 40 CFR § 264.1101 und the closuie and post-
closure care requirements at 40 CFR § 264.1102 wonld'he
ARAR. The State of Missouri has no equivalent provisions to
40 CFR § 264.1101, Design and Operating Slamlauls lor
Containment Building and 40 CFR § 264.1102 Closure and
Post-closure Care.
5. The Clean Air Act Amendments of 1990 added the Title V
Program which establishes a federal operating permit piogiam
for numerous sources of air pollution. The CAA Amendments
require Missouri lo modify its operating permit piogram for
sources of air pollutants lo meet the requirements of Title V by
November 15, 1993. According ma personal communication
with Eric Giroir of Ihe Missouri Air Pollution Coniml Program,
Missouri lias submitted lo FPA their Title V IVimit Program
and expect il lo be accepted by the end of 1995. Missomi is
currently operating on an interim program. Until Hie Missouri
rule is approved by I-PA, il provides only TBC guidance.
Missouri has adopied the National Ambient Air Qu.ilny
Standards (NAAQS) and enforces them through peiimis
These Missouri standards arc published al IOCSR W-o.Oll)
(1994), Ambient Air Quality Slandaids. If emissions exceed
regulated levels, then the Air Pollution Coniiol Pmgiam may
lequire Air Pollution Dispersani Modeling to be conducted.
Based un results of Ilie modeling, some lorm of air pollution
control may be required. |Pei.vmal commuiiiciilion with K
Nuven (314) 751-48171. In addition. Missouri'. Ai,
.ARARTHI.
18
-------
DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Cominucd)
REMEDIAL ALTERNATIVE
DESCRIPTION
ACTION-SPECIFIC ARARs
ARAR STATUS
COMMENTS
SA-6 Option2/SA-8 Option 2b
(Continued)
Pollution Control Program ulili/.cs "acceptable ambient levels"
(AAI,s), which have no! been promulgated and apply only lor
construction permits. These levels represent the concentration
of a contaminant that is not to he exceeded al the fence line.
[Personal communication with K. (Jiroir (314) 751 -4817.|
All emission points at a Supcrfiind .vile would he considered
one stationary source for purpose of determining applicability
of "Prevention of Significant Deterioration" (PSD) Review.
LCAAP does not appear lo be a "major source" pursuant to 40
Cm § 52.2l(b)(l)(i)(a) (1994). liven though I.CAAP site
could be designated a major source pursuant to 40 CT'R §
52.2l(b)(l)(i)(b) (1994) if the combined emission points at
LCAAP emit (or have the potential to emit) 250 or mote tons
of any regulated pollutant a year, it is unlikely that this would
occur.
Although LCAAP would not be required under CliRCLA to
obtain a Missouri Air Pollution Control Peimil since this would
be an administrative requirement, all the substantive
requirements of a permit could potentially be ARAR. To
obtain an Air Pollution Control Permit, the permittee must
estimate the emissions anticipated .from (ho eniiie process. II
(he potential emissions are expected lo he greater Hian the
regulated level published al IOCSR 10-6 Table I, ilien a
Missouri Air Pollution Control Permit is required. Because
LCAAP is located in Jackson County which is an attainment
area, the Air Pollution Conliol Rules Specific to the Oulslalc
Missouri Area, would be potentially applicable 110 C'SR 10 .1
(1991. amended 1992)]. Although this chapter identifies the
restrictions (hat would potentially he incoiporated in a peimil
for remedial construction activities at Area IK, the only section
applicable to Jackson County restricts sulphur compound
emissions (IOCSR 10-3.100). '
l-.U'KOJWKMMumiKJIAKOIWIT INIAACT .ARAR.TUI.
19
-------
DESCRIPTION OF REMEDIAL ALTHRNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Cbminued)
REMEDIAL ALTERNATIVE
DESCRIPTION
SA-6 Option2/SA-8 Option 2b
(Continued)
ACTION-SPECIFIC ARARs
6. 59 Federal RegiMfr 47982.
48047, September 9, 1994,
(effective December 19,
1994) to be codified in the
Code (if Federal Regulations
as revised 40 CFR § 268.40
ARARSTATUS
6. Applicable
COMMENTS
None of identified contaminants of concern fall into iliis
category; therefore. Chapter 3 provides no ARARs, | Personal
communication with K. Nuyen (314) 751-4817).
6. Because the contaminated soil will be excavated and treated in
a separate unit, when the soil is used as backfill, placement will
occur. As n result, the land disposal restrictions will be
triggered. Hazardous soils are generally subject to the LDR
treatment standards that apply to the ha/ardous wastes wilh
which the soils arc contaminated (59 l-R 479K2,47986,
September 9. 1994). Wasle codes must first be'identilicd lor
each listed and characteristic ha/ardous waste. To discern the
U)R treatment standards for listed wastes and for wastes
exhibiting the toxicity characteristic, refer to the (able titled
"Treatment Standards for Ha/.ardous Wastes" published in 59
Federal Register 47982,48047, September 9, 1994 (effective
December 19. 1994) to be codified in the Code of Federal
Regulations as revised 40 CFR § 268.40, using the identified
waste code. The right hand column of this (able, for non-
wastewater, i.c, soil, lists the treatment standard applied to each
specific waste code. Soils containing a specific waste can be
land disposed as long as the concentration of the waste in (lit
soil is below the specified treatment standard. However.
because contaminated soils are considered by ij|>A to be
significantly different in their Ircalability characteristics fiom
the wastes that have been evaluated in establishing the liDAT
standards, contaminated soils will generally qualify lor a
Ircalability variance under 40 CFR § 268.44 (59 l-'R 47ROJ\5(»84l)IV)'OOI.\ROl)\DIT.|.Nt.\ACT.ARAKTBI.
20
-------
DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Continued)
REMEDIAL ALTERNATIVE
DESCRIPTION
ACTION-SPECIFIC ARARs
ARAR STATUS
COMMENTS
SA-6 Oplion2/SA-8 Option 2b
(Continued)
7. 10 CSR 25-6.263(2)
40 CFR Part 263
C[iRCI.A§
7. Applicable
7. Pursuant lo this remedial alternative, the contaminated soil may
be transported off-site foi I'm (her treatment and disposal. 10
CSR 25-6.263 Slandaids for Tianspotlcis ol lla/.uidous Waste
incorporates 40 CI;R Part 263 by reference and sets loilh
additional stale requirements. 10 CSR 25-6.263(2) provides
thai a hazardous waste transporter shall comply wild die
requirements of this Missouri section in addition to the fedeial
transporter requirements. Slate and federal liansporter
requirements such as manifest and packaging lequiicmcni.s will
provide ARARs. Also, facilities used for oil-she disposal arc
required by CliRCLA § I2l(d)(3) to be in compliance with all
pertinent RCRA requirements (have a RCRA pmnii or interim
status and have any releases from Solid Waste Management
Units being controlled by corrective action).
K\PROJ\6098
-------
DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Continued)
REMEDIAL ALTERNATIVE
DESCRIPTION
ACTION-SPECIFIC ARARs
ARAR STATUS
COMMENTS
SA-6 Option2/SA-8 Option 2b
(Continued)
IOCSR25-7.264(2)(K)
40 CFR§ 264.228
8. Potentially
Applicable
9. 10 CSR 25-7.264(2)(0)3
IOCSR25-7.264(2)(G)4
40CFR§264.I16
40CFR§264.I19
1J. Applicable
8. The contaminated area will pmliably be classified as a MM face
impoundment. The State of Missouri at 10 CSR 25-
7.264(2}(K) incorporates by lelerenee and sets foilh slandaids
which modify or add to (lie federal ici|iiireincnts for surface
impoundments in 40 CT'R Part 264, Suhpait K. If Ihe
contaminated area is classified as a suifacc impouiulincni, then
the closure and post-closure requirements in 40 CI;K § 264.22K
and 10 CSR 25-7.264(2)(K) are applicable.
9. As a part of this remedial alternative, institutional controls will
be employed. 40 C.F.R. § 300.43()(a}( I KiiiHD) Males thai
EPA expects to use institutional controls such as water use and
deed restrictions to supplement engineering controls as
appropriate for short- and long-term management lo prevent or
limit exposure to hazardous substances, pollutants, or
contaminants. The State of Missouri incorporates by leleience
40 C.F.R. §§ 264.116 and 264.119 and adds additional
requirements. The State of Missouri states at IOCSR25-
7.264(2)(G)3 that in addition to the requirements in 40 t'.F.R. jj
264.116, when an owner/operator entities a closure which did
not result in Ihe removal of wastes lo background levels, the
owner/operator shall record a notation on an instrument which
is normally examined during title search that in peipetuily will
notify any potential purchaser of the properly thai the land has
been used lo manage ba/.ardous waste. Also, pursuant to 10
CSR 25-7.264(2)(O)4, the notation shall be recorded with the
recorder(s) of deeds in all counties in which the Facility is
located.
KVPRUJ\fiUytMUI\KX)IARO|]\DITJ''NIW:r_AKARTBI.
22
-------
DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Continued)
•••
COMMENTS
REMEDIAL ALTERNATIVE
DESCRIPTION
ACTION-SPECIFIC ARARs
ARAR STATUS
SA-6 O|ilion2/SA-8 Option 2b
(Continued)
10. 10 CSR 25-7.264(2)(6)3
10 CSR 25-7.264(2)(6)4
40CFR§264.II6
40CTR§264.II9
10. Applicable
10. As a part of this remedial alleimilivc, institutional conliols will
be employed. 40C.KR § 300.430
background levels, the owner/operator shall record a notation
on an instrument which is normally examined dining title
search thai in perpetuity will notify any potential purchaser ol
the properly lhal the land has heen used to manage ha/.mdoiis
wasle. Also, pursuant to 10 CSR 25-7.264(2)((i)4, the
notation shall he recorded with the recordcr(s) of deeds in all
counties in which the facility is located.
I Al'KOJWWXWIU'OOlARObVDIT. IWI.\ACT_AH AR TBl.
23
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DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Continued)
ACTION-SPECIFIC ARARs
REMEDIAL ALTERNATIVE
DESCRIPTION
SA-7 In-SiJu Soil Vapor Extraction
and Treatment
• Perform pilot tests to document Hie
effcclivcncss of (he SVE technology
and also collect the required design
parameters like vapor flow rate, radius
of influence of vapor extraction wells,
etc.
• Install vapor extraction wells and
manifold the vapor collection pipes to
the treatment system.
• Set up a thermal oxidation unit onsitc
ID (real the collected vapors.
• Hxcavale trenches and install a ground
water recovery system to lower the
ground water lahle.
• Dispose the soil excavated to install
the ground water recovery trenches at
an approved offsite facility.
Treat the recovered ground water in
llie onsite treatment system.
Monitor the VOC concentrations in
the SVE exhaust air.
Shut off the system once the SVG
exhibits an asymptotic low
concentration of volatiles in the
exhaust air.
I.IOCSRIO-6.I70(I9"5)
2. 10 CSR 2U-6.200
3.40 CFR§ 264.600
CORCLA§
IOCSR 23-4.010(1)
10 CSR 23-4.060(14)
I. Applieahlc
2. Applicable
3. Potentially
Applicable
. Applicahle
I. l-ugilive dust emissions may he produced from the excavation
activities. The Stale of Missouri at IOCSR 10-6.170 restricts
persons from causing or allowing fugitive paniculate matter to
go beyond the premises where such mailer originates. The
lirnilations on the quantities as well as exceptions to the uile
arc described in detail at 10 CSR 10 6.170 (1995).
2. The pertinent requirements for storm water discharges Ihal are
cited at 10 CSR 20 6.200 Storm Water Regulation will
provide ARARs for excavation aclivilius.
3.
The thermal oxidation unit used lo treat the collected vapors
will probably be classified as a miscellaneous iicatmenl unit
under RCRA. |0 CSR 25-7.264 Standards for Owners and
Operators of Hazardous Waste Treatment, Storage and
Disposal Facilities is the slate rule that corresponds to IOCI-R
Part 264 Standards for Owners and Operators of lla/.aidous
Waste Treatment, Storage and Disposal Facilities. The Stale
of Missouri does not have any provisions pertaining to
miscellaneous treatment unils. Therefore, if the thermal
ireatment process takes place in a miscellaneous treatment
unit, then llie requirements in 40 CFR § 264.600 would
provide ARARs.
4. Pursuant lo this remedial alternative, the ground water
infiltrating into (he excavation will be collected and treated |,y
using the existing Area 18 removal action waiei treatment
system
24
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DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Continued)
i
COMMENTS
REMEDIAL ALTERNATIVE
DESCRIPTION
SA-7 (Continued)
ACTION-SPECIFIC ARARs
ARARSTATUS
CERCLA § !2l(d)(2)(A) requires lhai by completion of a
selected remedial action iliai any hazardous subsiance, pollutant,
or contaminant remaining on site, attains either non-/.ero
MCl.Os pursuant to the SDWA, or in their absence, MCI.s,
when such goals or limits are relevant and appropriate under ihc
circumstances of the release. As a result, the collected ami
treated groundwater being discharged to Ihe IWTI> will probably
have to meet non-zero MCLGs or MCLs.
in addition, as a part of this remedial allot native, extinction
wells may be constructed. The Rules of the Missouri
Deparlmenl of Natural Resources, Division of Geology ami
Land Survey, Chapters I through 6 apply to all wells in Missouri
unless specifically exempted by the Missouri Water Well Driller
Law. Extraction wells used in site remediation arc regulated by
Chapter 4, tilled "Monitoring Well Construction Code," and are
included in Ihe definition of "monitoring wells" in this chapter -it
10 CSR 23-4.010(I) (1994). Among other things, the Chapter 4
rules set forlh criteria for the placement of wells, Ihe geneial
protection of groundwaler ijualiiy and resomces, as well as
drilling methods and construction standards. However,
accordingto IOCSR 23-4.060(14), the standards for
construction of extraction wells is deleimiiicd on » case-by-case
basis by the division.
l-U'RuJ\«W84IIIU'0<)I.WOI)U>l-TJNIAAlT..AKAR.TBl.
25
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REMEDIAL ALTERNATIVE
ACTION-SPECIFIC ARARs
DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Continued)
SA-7 (Continued)
5. Missouri Title V Permit
Program
10 GSR 10-6.010
5. TUC Guidance
Pntcniially
Applicable
5. Tire Clean Air Act Amendments of 1990 added (he Title V
Program which establishes a federal operating Permit program
for numerous sources (.fair pollution. The CAA Amendments
require Missouri lo modify Us operating permit program for
sources of air pollutants to meet the ici|iiircmenis of Title V
by November 15, 1993. Aceoiding to n personal
communication with liric Oirnir of Hie Missouri Air Pollution
Control Program, Missouri bus submitted lo P.PA their Title V
Permit Program and expect it to be accepted by the end of
1995. Missouri is currently operating on an interim piogram.
Until (he Missouri rule is approved by KPA, it provides onlv
TBC guidance. '
Missouri has adopted the National Ambient Air Quality
Standards (NAAQS) and enforces them through permits. These
Missouri standards are published at 10 CSR 10-6.010 (1994),
Ambient Air Quality Standards. If emissions exceed icgulaled
levels, then the Air Pollution Conliol Program may r«|uiie Air
Pollution Dispersanl Modeling to be conducted. Based on
results of the modeling.-some form of air pollution
l-\l'ROJ\fi0984(ll\raoi.\R(ll>\I>l-T miAACT.ARAR TBl.
26
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DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Conlinucd)
REMEDIAL ALTERNATIVE
DESCRIPTION
ACTION-SPECIFIC ARARs
ARAR STATUS
COMMENTS
SA-7 (Continued)
control may he required. |Personal en mmcalion wilh K.
Nuycn (314) 751-4817]. In addition. Missouri's Air
Pullulion Control Program ulili/.es "acceptable ambient levels"
(AAI,s), which have not been promulgated and apply only for
construction permits. These levels represent ihe concentration
of a contaminant thai is mil u> he exceeded at the fence line.
I Personal communication with U. Giroir (314) 751-4817.)
All emission points at a Superfund site would he considered one
stationary source for purpose of determining applicability of
"Prevention of Significant Deterioration" (PSD) Review.
I.CAAP does not appear to he a "major source" pursuant ID 40
CI;R§52.2l(b)(l)(i)(a)(l994). Even though LCAAP silc could
be designated a major source pursuant ID 40 CT'R §
52.2l(b)(l)(i)(b) (1994) if Ihe combined emission points at
I.CAAP emit (or have the potential to emit) 250 or more ions til
any regulated pollutant a year, it is unlikely thai this would
occur.
Although LCAAP would not be required under CliRCLA to
obtain a Missouri Air Pollution Control Permit since this would
he an administrative requirement, all the .substantive
requirements of a permit could potentially he ARAR. To obtain
an Air Pollution Control Permit, (he permittee must estimate Ihe
emissions anticipated from the entire process. If (he potential
emissions are expected lo he greater than Ihe regulated level
published at 10 CSR 10 6 Table I. then a Missouri Air Pollution
Control Permit is required. Because I.CAAP is located in
Jackson County which is an attainment area, the.Aii Pullulion
Control Rules .Specific lo the Oulslale
I \l>N(>nMIVX4imil()OI.\R()l>\l>l-T.I-NIM(.T.ARAK, Till.
27
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DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC AR ARs (Continual)
— iMorooctez:
ARAR STATUS COMMENTS
REMEDIAL ALTERNATIVE
DESCRIPTION
SA-7 (Continued)
ACTION-SPECIFIC ARARs
6. 10 CSR 25-6.263(2)
40 CFR Pan 263
CERCLA§
6. Applicable
Missouri Area, would he poiunliully applicable 110 CSR 103
(1991, amended I992)|. Alihougluhisclmptcr identifies the
restrictions that would potentially lie incoiporated in a periuil loi
remedial construction aciiviiies al Area IK, the only .suction
applicable to Jackson County restricts sulphur compound
emissions (10 CSR 10-3.100). None of identified contaminants
of concern fall into this category; therefore. Chapter 3 provides
no ARARs. [Personal communication with K. Nuyen (314)751-
6. Under this remedial alternative, contaminated soil that is
excavated in order to install the ground water recovery
trenches will be disposed of off-site at an approved facility.
10 CSR 25-6.263 Standards for Transporters of Ha/ardous
Waste incorporates 40 Cf;R Pan 263 by reference and sets
forth additional stale requirements. 10 CSR 25-6.263(2)
provides that a hazardous waste transporter shall comply with
the requirements of this Missouri section in addition to the
federal transporter requirements. Slate and federal irunsporici
requirements such as manifest and packaging requirements
will provide ARARs. Also, facilities used for off-site disposal
are required by CERCI.A § 12l(d)(3) to be in compliance
with all pertinent RCRA requirements (have a RCRA permit
or interim status and have any releases from .Solid Waste
Management Units being controlled hv corrective action!.
I.U'ROJ\60984(H\I'0(«.WOI>U>I-T..INIAAC.T.ARARTB!.
28
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DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Continued)
REMEDIAL ALTERNATIVE
DESCRIPTION
ACTION-SPECIFIC ARARs
ARAR STATUS
COMMENTS
SA-7 (Continued)
7. 10 CSR 25-7.264(2)(6)3
10 CSR 25-7.264(2)(6)4
4<)CI;R§264.II6
40CI;R§264.II9
7. Applicable
7.
As a parl of this remedial alternative, institutional conirols will
be employed. 40 C.RR. § 300.430(a)( I )(iii)(D) stales thai
lil'A expects to use in.sliiiiiioiial contmls such as water use ami
deed restrictions to supplement engineering controls as
appropriate for short- and long-term management to picvcnl
or limit exposure to hazardous.substances, pollutants, or
contaminants. The Slate of Missouri incorporates hy
reference 40 C.KR.:§§ 264.116 and 264.119 ami adds
additional requirements. The Stale of Missouri stales .at 10
CSR 25-7.264(2)(G)3 (hat in addition to the requirements in
40 C.RR. § 264.116, when an owner/operator certifies a
closure which did not result in the removal of wastes to
background levels, Hie owner/operator shall record a notation
on an instrument which is normally examined (lining title
search thai in perpetuity will notify any potential purchaser of
the properly that the land has been used to manage ha/imlous
waste. Also, pursuant to lOC'SR 25 7.264(2)(G)<), the
notation shall be recorded with the recorders) ol deeds in all
counties in which the facility is located. _^
l-M>Kl)JV6INII4l)IU>OULVRUIHDFr.FNIAACT.ARAHTni.
29
-------
DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Continued)
REMEDIAL ALTERNATIVE
DESCRIPTION
ACTION-SPECIFIC ARARs
ARARSTATUS
COMMENTS
SA-8 Selective Excavation and
Treatment Option I
• Selective excavation will) treatment by
low lumpcrulurc thermal dcsorplion
(l.'ITD).
I. 10 CSR 10-6.170
I. Applicable
2. 10 CSR 20-6.200
2. Applicable
2.
Fugitive dust emissions may lie produced limit the cxcsivniinn
activities. The Stale of Missouri at 10 CSR 10 6.170 restricts
persons from causing or allowing fugitive paniculate matter to
go beyond the premises where such matter originates. The
limitations on the quantities as well as exceptions to the rule
are described in detail at 10 CSR 10-6.170(1905).
The pertinent requirements I'm sliiim water (It.scliaigc.-i that are
cited at 10 CSR 20-6.200 Sim in Walei Regulation will
provide ARARs for excavation activities.
3.40 CFR § 264.600
40 CFR§§ 265.373
through 265.381
Potentially
Applicable
3. It appears that the thermal treatment unit will be classified as a
miscellaneous treatment unit. 10 CSR 25-7.264 Standards lot-
Owners and Operators of Ha/.ardous Waste Ticalmeiil,
Storage and Disposal Facilities is the state rule that
corresponds to 10 CFR Part 264 Standards lor Owncis and
Operators of Hazardous Waste Treatment. Storage and
Disposal Facilities. The Stale of Missouri docs not have any
provisions pertaining to miscellaneous treatment units.
Therefore, if the thermal treatment process lakes place in a
miscellaneous d .ttrnenl unit, then (he requirements in 40 CFR
§ 264.600 would provide ARARs. Also, the Iheiinal
treatment requirements of 40 CFR 265.373-381 may he
relevant and appropriate if the excavated soil is to be Healed
in a device other than an enclosed device using controlled
flame combustion, unless 40 CFR 265.1 provides otherwise.
30
.ItJLVACT ARAR TBI.
-------
DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Continued)
REMEDIAL ALTERNATIVE
DESCRIPTION
ACTION-SPECIFIC ARARs
ARAR STATUS
COMMENTS
SA-8 Option 1 (Continued)
4. 10 CSR 25-7.264(2x1.)
4. Potentially
Applicable
4.
II (he contaminated soil is staged in piles beloie Ireiilmenl, Ihe
Army is determined to he a large c|iimitity generator, and (lie
excavated soil remains in tliis area for more (hail 90 days, then
the Stale of Missouri may deline (he remediation area as a
waste pile. Hie Slate of Missouri al IOCSR 25-7.264(2)(l.)
incorporates by reference and sets forili standards which
modify or add to the federal requirements for waste piles in 40
CFR Part 264, Subpart L. In order to be exempted from the
waste pile requirements in 40 CFR § 264.251, which Missouri
incorporates by reference; 40 CFR Pail 264, Subparl I;, which
Missouri incorporates by reference; and KK'SR 25-
7,264(2)(L)2.F., the waste pile must meet the following
requirements: liquids or materials containing free liquids are
not place in (he pile; the pile is protected from surface water
run:on by the structure or in sonic other manner; the pile is
designed and operated (o control dispersal of the waste hy
wind, where necessary, by means other lhan welting; the pile
will not generate Icachate through decomposition or other
reactions; and Ihe pile must he at least ten feet above the
historical high groundwaler table. If the remediation pad upon
which the soil is placed is classified by the State as a waste
pile and cannot meet the above slated requirements lor
exemption, then Ihe design and operating requirements and
closure and post-closure requirements will provide ARARs.
In addition, if the remediation pad is classified as a waste pile.
then the excavated soil will need lo meet land disposal
restrictions prior to placement in the waste nile
31
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DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OH ACTION-SPECIFIC ARARs (Conlinucd)
REMEDIAL ALTERNATIVE
DESCRIPTION
ACTION-SPECIFIC ARARs
ARARSTATUS
COMMENTS
SA-8 Option 1 (Continued)
5. 59 h'eileral Register 47982.
48047, September 9, 1994,
(effective December 19,
1994) to be codified in (he
Code of Federal
Regulations as revised 40
CFR § 268.40
5. Applicable
5.
Backfilling with the treated .soil may lie a part of this remedial
alternative. Because (lie contaminated soil will be excavated
and treated in a separate unit, when the soil is used as backfill,
placement will occur. As a result, the land disposal
restrictions will he triggered. Ha/.ardons soils are generally
subject to the LDR treatment standards that apply to the
hazardous wastes with which the soils are contaminated (59
FR 47982. 47986. September 9. 1994). Waste codes must
first be identified for each listed and characteristic lia/.ardoii.s
waste. To discern the LDR treatment standards for listed
wastes and for wastes exhibiting the toxicily characteristic,
refer to the tahlc tilled "Treatment Standards for Hazardous
Wastes" published in 59 Federal Register 47982,48047,
Septeinber9,1994, (effective December |y, |y94) to be'
codified in the Code of Federal Regulalicns as revised 40 CTK
§ 268.40, using the identified waste code. The right hand
column of this table, for non-wasfowater, i.e. sod, lists die
treatment standard applied to each specific waste code. Soils
containing a specific waste can he land disposed as lung as the
concentration of the waste in the soil is below the specified
treatment standard. However, because contaminated soils aic
considered by EPA to be significantly different in their
trcalabilily characteristics from the wastes that have been
evaluated in establishing the BOAT standards, contaminated
soils will generally qualify for a Irealabilily variance under 40
CI;R § 268.44 (59 FK 47982, 47987). The proccdmes for
obtaining u trealability variance are described at 40 Ci-'R §
268.44.
i-.U'ROI\M»84«IU1HH.\R«l«IJITJNIAACT ARAK.TBI.
32
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DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Continued)
REMEDIAL ALTERNATIVE
DESCRIPTION
ACTION-SPECIFIC ARARs
ARARSTATUS
COMMENTS
SA-8 Option 1 (Continued)
6. IOCSR25-7.264(2)(K)
40 CFR§ 264.228
6.
Potentially
Applicable
6. The contaminated area will probably be classified as a sui lace
impoundment. The Stale of Missouri at 10 CSR 25-
7.264(2)(K) incorporates by reference anJ sets forth standards
which modify or add to ihc federal requirements for surface
impoundments in 40 CFR Part 264, Subparl K. If the
contaminated area is classified as a surface impoundment, then
Ihe closure and post-closure requirements in 40 CFR §
264.228 and 10 CSR 25-7.264(2)(K) are applicable.
7. 10 CSR 25-7.264(2)(6)3
10 CSR 25-7.264(2)(6)4
40 CFR §264.116
40 CFR §264.119
7. Applicable
7. As a part of (his remedial alternative, institutional controls will
be employed. 40C.F.R. § 300.430(a)(I )(iii)(Dj stales (hat
EPA expects to use institutional controls such as waiei use and
deed restrictions to supplement engineering controls as
appropriate for short- and long-term management to prevent
or limit exposure'to hazardous substances, pollutants, or
contaminants. The1 Stale of Missouri incorporates by
reference 40 C.F.R. §§ 264.116 and 264.119 and adds
additional requirements. The Slate of Missouri slates at 10
CSR 25-7.264(2)(G)3 that in addition to the requirements in
40 C.F.R. § 264.116. when an owner/operator certifies a
closure which did not result in Ihe removal of wastes to
background levels, the owner/operator shall record a notation
on an instrument which is normally examined during title
search (hat in perpetuity will notify any potential purchaser of
Ihe properly thai Ihc land has been used to manage ha/.ardous
waste. Also, pursuant to 10 CSR 25-7.264(2X0)4, the
notation shall be recorded with the recordei(s) ol'deeds in all
counties in which Ihc facility is located.
33
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DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Continued)
REMEDIAL ALTERNATIVE
DESCRIPTION
ACTION^PECIFIC ARARs
ARARSTATUS
COMMENTS
SA-8 Selective Excavation and
Treatment Option 3
• Soil will be excavated mid transported
off-site for treatment and disposal.
I. IOCSR 10-6.170
I. Applicable
2. IOCSR 25-6.263(2)
40 CFR Part 263
CRRCLA§12I(d)(3)
2. Applicable
I. Fugitive dust emissions may lie produced limn the excavation
activities. The Stale of Missouri at IOCSR 10-6.170 restricts
persons from causing or allowing fugitive paniculate mailer In
go beyond the premises wheic such mutter originates. The
limitations on (he quantities as well as exceptions to the rule
are described in detail at IOCSR IO-6.I70(1W5)
2. 10 CSR 25-6.263 Standards for Transporters ol" Hazardous
Waste incorporates 40 Cl-'R 1'arl 263 by refeience and sets
forth additional slate requirements. 10 CSR 25-6.263(2)
provides thai a hazardous waste transport shall comply with
the requirements of this Missouri section in addition to the
federal transporter requirements. State and federal transporter
requirements such as manifest and packaging requirements
will provide ARARs. Also, facililies used for off site disposal
are required by CliRCLA § I2l(d)(3) to be in compliance
with all pertinent RCRA requirements (have a RCRA penmi
or interim status and have any releases from Solid Waste
Management Units being controlled by corrective action).
3. IOCSR25-7.264(2)(K)
40 CFR §264.228
3. Potentially
Applicable
3. The contaminated area will probably be classified as a sui face
impoundment. The Stale of Missouri ill 10 CSR 25-
7.264(2)(K) incorporates by lefcrence and scls loith staiulaids
which modify or add to the federal requirements for sui face
impoundments in 40 CI-'R Part 264. Suhparl K. II the
contaminated area is classified as a surface impoundment, llicn
the closure and post-closure requirement:; in 40 CI;K §
264.228 and 10 CSR 25-7.264(2)(K) are applicable.
34
l-U'RO)\fi(»S40l\PO(U.\ROIJU>Fr.mi.\ACr.ARARTBl.
-------
DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Continued)
REMEDIAL ALTERNATIVE
DESCRIPTION
ACTION-SPECIFIC ARARs
ARAR STATUS
COMMENTS
SA-8 Option 3 (Continued)
4. 10 CSR 25-7.264(2)(6)3
l()CSR25-7.264(2)(6)4
40CFR§264.1I6
40CFR§264.II9
4. Applicable
4. As u purl of this remedial alternative, institutional controls will
he employed. 40 C.F.R. § 300.43l)(;i)( l)(iii)(l>) slates thai
EPA expects to use instilutionnl controls such us water use ami
deed restrictions to supplement engineering controls us
appropriate for short- ami long-term management to prevent
or limit exposure to hazardous substances, pollutants, or
contaminants. The State of Missouri incorporates by
reference 40 C.F.R. §§ 264.116 and 264.119 ami adds
additional requirements. The Stale of Missouri stales at 10
CSR 25-7.264(2}(G)3 that in addition to the requirements in
40 C.F.R. § 264.116, when an owner/operator certifies a
closure which did no) result in the removal of wastes to
background levels, the owner/operator shall record a notation
on an instrument which is normally examined during title
search (hat in perpetuity will notify any potential purdmsei of
the properly thai (he land has been used (o manage ha/nrdous
waste. Also, pursuant to 10 CSR 25-7.264(2)((i)4, the
notation shall be recorded with the recorder(s) ol deeds in all
counties in which lite facility is located.
.35
I .\FKO)\509B40l\l'OOI.\ROH\LIITJ-ML\AtT.ARAR TBL
-------
DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARAR, (Con.mueil)
REMEDIAL ALTERNATIVE
DESCRIPTION
ACTION-SPKCIFlCARARs
GROUND WATER ALTERNATIVES
AHcrnulive GW-1: No Action
Alternative GW-2: Ground Water
Monitoring and Poinl-of-Use
Treatment
Continued operation ol'unsitc air
stripping tower
Conlinuecl discharge of treated water
lo onsite water treatment plant
(iroimil water monitoring for the
next .10 years
Heed restrictions lor ground water
usuge
Treatment ol'contaminated ground
water before use by ofl'silc users
NA
I. CERCLA§ !2l(d)(2)(A)
2. 40 CFR§ 264.600
NA
I. Applicable
2. Potentially
Applicable
Pursuant to (his remedial alternative, the ground water will he
extracted and treated by using (lie existing Aiea IS removal
action water treatment system. C12RCLA § l2l(d)(2)(A)
requires that by completion of a selected lemedial action that
any hazardous substance, pollutant, 01 contaminant a-maining
on site, attains either non-/er<> MCI .(is pursuant (o the
SDWA, or in their absence, MCLs, when such goals 01 limit!,
are relevant and appropriate under the ciicumsiaiices of die
release. As a result, the collected and treated gromulwaler
being discharged lo the IW'I'P will probably have to meet mm
zero MCLGs or MCLs.
2. The thermal oxidation unit used to treat the collected vnpois
will probably be classified us a miscellaneous licatiuuiii unit
under RCRA. 10 CSR 25-7.264 Slandaids lor Owners ami
Operators of Ha/.ardous Waste Treatment, Storage anil
Disposal Facilities is the stale rule that coiresponds lo 10 CFK
Part 264 Standards foi Owners and Operators of lla/.mdous
Waste Treatment, Storage and Disposal Facilities. The Stale
of Missouri does not have any provisions pertaining lo
miscellaneous treatment units. Therefore, il the llieirnal
treatment process lakes place in a miscellaneous treatment
unit, then the requirements in 40 CFR § 264.600 would
provide ARARs.
l-U'KOJtoHWMmVMXMiROIWTJ-NIAACT ARAR TBI.
36
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DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Continued)
REMEDIAL ALTERNATIVE
ACTION-SPECIFIC ARARs
Alternative CW-2 (Continued)
3.
Missouri Tide Permit
Program V
IOCSR-6.010
3. TBC Guidance
3. The Clean Air Acl Amendments of 1990 added ihe Tille V
Program which establishes a federal operating permit program
for numerous sources of air pollution. The CAA Amendments
require Missouri to modify its operating permit program for
sources of air pollutants to meet the requirements of Tille V
by November 15, 1993. According lo a personal
communication with Eric Giioir of the Missouri Air Pollution
Control Program, Missouri has submitted to liPA their Title V
Permit Program and expect it to be accepted by the era! of
1995. Missouri is currently operating on an interim program
Until Ihe Missouri rule is approved by P.PA, it provides only
TBC guidance.
Missouri has adopted the National Ambient Air Quality
Standards (NAAQS) and enforces them through permiis. These
Missouri standards are published at IOCSR 10-6.010(1994)
Ambient Air Quality Standards. If emissions exceed regulated
levels, then the Air Pollution Control Program may require Air
Pollution Dispersant Modeling to he conducted. Based on
results of the modeling, some form of air pollution contiol may
be required. [Personal communication with K. Nuyen (.114)751
48I7|. In addition, Missouri's Air
I-.\HROJ\«W84lll\POOI.\KOU\DIT_rNL\ACT.ARAR.TBL
37
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DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPBCIFIC ARARs (Comiuucd)
REMEDIAL ALTERNATIVE
DESCRIPTION
Alternative GYV-2 (Continued)
'1C ARARs
ARAR STATUS
COMMENTS
Pollution Control Program ulilkcs "acceptable iinibicni levels"
(AAl-s), whieh have not been promulgated anil apply only lor
construction permits. These levels repiesem the concentration
of a contaminant that is not to he exceeded at the fence line.
(Personal communication with H. (iiroir (314) 75I-4HI7.J
All emission points at a Superfund site would be considered one
stationary source lor purpose of determining applicability of
"Prevention of Significant Deterioration" (PSD) Review.
I.CAAP docs not appear to be a "major source" pursuant to 40
CFR § 52.2I(bXI)(i)(a) (1994). Rvcn though LCAAP site could
be designated a major source pursuant to')() CI;R §
52.2l(b)(l)(i)(b) (1994) if the combined emission points at
LCAAP emit (or have the potential to emit) 250 or more tons of
any regulated pollutant a year, it is unlikely (hut this would
occur.
Although LCAAP would not be required under CliRCI.A to
obtain a Missouri Air Pollution Control Permit since (his would
be an administrative requirement, all the .substantive
requirements of a permit could potentially be ARAR. To obtain
an Air Pollution Control Permit, the permittee must estimate (lie
emissions anticipated from the entire process, if the potential
emissions are expected to be greater than (he regulated level
published at IOCSR 10-6 Table I, then a Missouri Air Pollution
Control Permit is required. Because I.CAAP is located in
Jackson Counly which is an attainment aiea, Ihe Air Pollution
Control Rules Specific to Ihe Ouislale Missouri Area, would be
potentially applicable 110 C.SR 10-3 (1991, amended I992)|. j
Although this chapter identifies Ihe icstriciions that would
potentially be incorporated in a permit for remedial eoiislnictiun
activities al Area IK, Ihe only section applicable lo Jackson
Counly restricts sulphur compound emissions (10 C'.SR 10
3.100).
l:U'HOJ\609840l\IHX)I.VR()l)\l)IT.WI.\A
-------
DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Continued)
REMEDIAL ALTERNATIVE
DESCRIPTION
ACTION-SPECIFIC ARARs
ARAR STATUS
COMMENTS
Alternalive GW-2 (Continued)
None of identified contaminants of concern fall into this
category; therefore. Chaplci 3 provides no ARARs. IPci.simal
communication wilh K. Nuyen (314) 751-4817).
4. 59 Federal Register
47982, 48047, September 9,
1994.
4. Potentially
Applicable
4. II the treatment residuals from the iicatmcni unit are
determined to be hazardous waste, the LDRs will In-
applicable.
5. 10 CSR 25-7.264(2)(6)3
IOCSR 25-7.264(2)(6)4
40CFR§264.1I6
40CFR§264.II9
5. Applicable
5. As a part of this remedial alternative, institutional controls will
be employed. 40 C.F.R. § 3()().430(a)(l)(iii)(D) slates that
EPA expects to use institutional controls such as water use and
deed restrictions to supplement engineering controls as
appropriate for short- and long-term management to prevent
or limit exposure to ha/.ardous substances, pollutants, or
contaminants. The Stale of Missouri incorporates by
reference 40 C.F.R. §§ 264.116 and 264.119 and adds
additional requirements. The State of Missouri slates at 10
CSR 25-7.264(2)(G)3 that in addition lo the requirements in
40 C.F.R. § 264.116, when an owner/operator ceilil'ies a
closure which did not result in the removal of wastes lo
background levels, the owner/operator shall record a notation
on an instrument which is normally examined during title
search thai in perpetuity will notify any potential purchaser of
Ihe property that the land has been used lo manage hazardous
waste. Also, pursuant lo 10 CSR 25-7.264(2)(U)4, Ihe
notation shall be recorded with the recorder(s) of deeds in all
couniies in which the facility is located.
39
-------
DESCRIPTION OF RHMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC
REMEDIAL ALTERNATIVE
DESCRIPTION
Alternative GW-3/GW-4: Extraction
Wells/Air Strlpping/Culalylic
Oxidation/Discharge Co POTW
• Installation of ground water
extraction wells and associated
piping
• Installation of air stripping tower
• Provide process piping for discharge
to POTW
• Ground water monitoring
ACTION-SPECIFIC ARARs
I. CERCI.A § I2l(d)(2)(A)
IOCSR23-4.0KHI)
IOCSR 23-4.060(14)
ARAR STATUS
1. Applicable
ARARs (Continued)
=====
COMMENTS
I ursuanl to lliis remedial alternative, the ground water will be
extiacted and treated by using the existing Area IH removal
action water treatment system. CliRCI.A § 12l(d)(2)(A)
requires that by completion of a selected remedial action that
any hazardous substance, pollutant, or contaminant remaining
<>n site, attains either non-zero MCI .(5s pursuant to the
SDWA, or in their absence, MCI j. when such goals or limits
arc relevant and appropriate under the circumstances of the
release. As :i result, the collected and Healed groundwaler
bemg discharged to the IWTI> will probably have to meet mm-
/eroMCl.GsorMCl.s.
In addition, as a part of this remedial alternative extinction
wells may be constructed. The Rules of the Missomi
Department of Natural Resources, Division of Geology and
Land Survey, Chapters I through 6 apply to all wells in Miss,,,,, j
unless specifically exempted by the Missouri Water Well Diiller
Law. Extraction wells used in site remediation arc regulated by
Chapter 4, titled "Monitoring Well Construction Code," rn.d are
included in the definition of "monitoring wells" in this chapter ai
10 CSR 23-4.010(1) (1994). Among other things, tho Chanter 4
rules set forth criteria for the placement of wells, the general
protection of groundwaler quality and resources, as well as
drilling methods and construction standards However
according to 10 CSR 23-4.060( 14), ihe standards for
construction of extraction wells is determined on a case-by-ca.se
basis by the division.
IWIAACT ARAK TBI.
40
-------
DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (CoiHinued)
REMEDIAL ALTERNATIVE
DESCRIPTION
ACTION-SPECIFIC ARARs
ARAR STATUS
COMMENTS
Alternative (JW-3/GVV-4 (Continued)
2.40 CFR § 264.600
2. Potentially
Applicable
2. The thermal oxidaiion.unit used to treat the collected vapors
will probably be classified as a miscellaneous treatment unit
under RCRA. 10 CSR 25-7.264 Standards for Owners and
Operators of Ha/.ardous Waste Treatment,.Storage and
Disposal Facilities is the stale rule that corresponds to 10 Cl;R
Part 264 Standards for Owners and Operators of Ha/.auloiis
Waste Treatment, Storage and Disposal Facilities. The Stale
of Missouri does not have any provisions pertaining to
miscellaneous treatment units. Therefore, if the thermal
treatment process lakes place in a miscellaneous treatment
unit, (hen the requirements in 40 CFR § 264.6(10 would
provide ARARs.
3. Missouri Title V
Permit Program
10CSR 10-6.010
3. TBC Guidance
Potentially
Applicable
3. The Clean Air Act Amendments of 1990 added the Tiile V
Program which establishes a federal operating permit program
for numerous sources of air pollution. The CAA Amendments
require Missouri to modify its operating permit piogram lor
sources of air pollutants (o meet the requirements of Title V
by November 15, 1993. According to a personal
communication with Uric Giroir of the Missouri Air Pollution
Control Program, Missouri has submitted to liPA their Title V
Permit Program and expect it to he accepted by the end of
1995. Missouri is currently operating on an interim progiam.
Until the Missouri rule is approved by liPA, it piovides only
TBC guidance.
Missouri has adopted the National Ambient Air Quality
Standards (NAAQS) and enforces them through permits. These
Missouri standards are published at 10 CSR 10-6.010 (1994),
Ambient Ail Quality Standards. II emissions exceed tegulated
levels, then the Air Pollution Control Program may lapiiic Air
Pollution Dispersanl Modeling to be conducted, Based on
results of the modeling, some form of air pollution coutiol may
be required. (Personal communication with K. Nuyen (314)751-
4817). In addition, Missouri's Air
41
I U'R()J\6W84m\H)Oi.\H[T.,FNl.\ACT..ARARTBI.
-------
REMEDIAL ALTERNATIVE
ACTION-SPECIFIC ARARs
DESCRIPTION OF REMEDIAL ALTHRNATIVES AND SUMMARY OH ACTION-SPECIFIC ARARs (Cbniinued)
Alternative GW-3/GW-4 (Continued)
Pollution Control Program ulili/es "acccplahle ambient levels"
(AALs), which have not hcen promulgated and apply (inly Inr
construction pcrmiis. These levels represent the concentration
of a contaminant thai is not to he excccilcil al the fence line.
(Personal coinniuniealion with Is. Ciiioir (3 14) 75 I-4817.)
All emission points at a Supeifmul site would be considered one
stationary source for put pose ol'determining npplicahility of
"Prevention of Signiflcnnl Deterioration" (PSD) Review.
LCAAP does not appear to he a "major source" pursuant to 40
Cl'R § 52.2l(b)(l)(i)(a) (1994). Rven though I.CAAP site could
he designalcd a major source pursuant to 40 CI;K (j
52.2l(h)(l)(i)(b) (1994) iftlie combined emission points at
I.CAAP emit (or have ilm potential to emit) 250 or more inns <>l
any regulated pollutant a year, it is unlikely that this would
occur.
Although I.CAAP would not he icquiied undci CliKCI.A in
obtain a Missouri Air Pollution Control Peimit since this would
be an administrative requirement, all (he substantive
requirements of a permit could potentially be ARAR. To cibuin
an Air Pollution Control Permit, the permittee must estimate the
emissions anticipated from the entire process. If the potential
emissions are expected to be greater than the icgulaied level
published at IOCSR !()-6 Table 1. then a Missouri Air Pollution
Control Permit is required. Because I.CAAP is located in
Jackson County which is an attainment area, the Air Pollmiim
Control Rules Specific to (he Ouislale Missouri Aiua, would he
potentially applicable | IOCSR 100 (1991. amended I992)|
Although this chapter identifies the restrictions thai would
poientially he incoiporaled in a permit for remedial consiuii-linn
activities at Area IK, the only section applicable to Jackson
('dimly lestricts sulphur compound emissimis (It) (\SR It)
1100).
l-\l'H(>J\6iAW)l Wr.lNlAACT ARAR Till.
42
-------
DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Continued)
REMEDIAL ALTERNATIVE
DESCRIPTION
ACTION-SPECIFIC ARARs
ARARSTATUS
COMMENTS
Alternative GVV-3/(;\V-4 (Continued)
None of klemified contaminants of concern fall into (his
category; therefore. Chapter 3 provides no ARARs. (Personal
communication with K. Ntiyen (314) 75I-48I7|.
4. 59 Federal Register
47982,48047, September 9.
1994.
4. Potentially
Applicable
4. If the treatment residuals from the treatment unit arc
determined lo be hazardous waste, the I .DRs will be
applicable.
5. 10 CSR 25-7.264(2)(6)3
10 CSR 25-7.264(2)(6)4
40CFR§264.I16
40CFRI264.II9
5. Applicable
As a part of this remedial alternative, institutional controls will
be employed. 40 C.F.R. § 3(«).430(a)( I )(iii)(l» slates that
lil'A expects lo use institutional controls such as watei use and
deed restrictions to supplement engineering controls as
appropriate for short- and long-term management to prevent
or limit exposure to hazardous substances, pollutants, or
contaminants. The Slate of Missouri incorporates by
reference 40 C.F.R. §§ 264.116 and 264.119 and adds
additional requirements. The Stale of Missouri states at II)
CSR 25-7.264(2)(G)3 (hat in addition in the requirements in
40 C.F.R. § 264.116, when an owner/operator certifies a
closure which did not result in the removal of wastes to
background levels, (he owner/operator shall record u notation
on an instrument which is normally examined during title
search thai in perpetuity will notify any potential purchaser ol
the property that the land has been used lo manage ha/ardous
waste. Also, pursuant lo 10 CSR 25-7.264(2)(G)4, the
notation shall be recorded with the recoidcr(s) of deeds in all
counties in which (he facility is located.
43
(•AI'RCMWIWtllU'OUlAKODUJI-TJNIMLT ARARTBI.
-------
DESCRIPTION OF RliMODIAL ALTliRNATIVHS AND SUMMARY OF ACTION-SPECINC ARARs, lCo.Uh.udl)
REMEDIAL ALTERNATIVE
DESCRIPTION
Option Si
lu, 2a, 3a, only
(Discharge to LUVSP)
ACTION-SFEC1FIC ARARs
6. 40 CFR §403.5
KJCSR 20-6.100
ARARSTATUS
6. Applicahlc
COMMENTS
6.
The LBVSI) is nil off-sin; I>()TW. Theiclore, CHRCLA
requires Ihal I.CAAP comply willi lioili substantive nnil
procedural requirements of die national pa-treatment piogiam
and regulations before discharging wa.slewaicr in die I.SVS1)
(ClsKCLA Cuinpliancc will) Oilier Laws Manual Interim hid
(I988(, p. 3-2l|. Aulhori/.ed under CWA § 307 (li), the
national presentment program eoiiltols die indirect discharge
of pollutants to I'OTWs in older to protect municipal
treatment plants and Hie cnvimnmeni when ha/.aidoiis or toxic
wastes arc discharged into a sewer system. The pielrcaimeni
program is implemented hy regulations (bund at 40CFR §
403.5 (1904). Missouri has adopted ils own pielicutmeni
regulations at IOCSR20-6.IIIO.
l;or off-site discharges to surface waters, the National I'ollutam
Discharge Liliminaiion System (NPDHS) adminisdalive •
requirements include the following: ccrlil'ication hy the Slate that
the discharge will comply with applicahle provisions o( CWA S§
301, 302, 303, 306 and 307; permit application rcijiiiicmcnls (-40
CFR Part 122); reporting requirements (40 CT'R §S I22.')')(i)
and 122.48); and public participation rcquiicmenis of 40 C'I;K 8
124.10
Construction of a second outfall from the air snipper would
require modification of Ihecuneiii in-placc NI'DliS Peimit.
Any person who builds, etc., a point source must apply for a
permit pursuant to Missouri Clean Waier Law 110 C\SR 20-
6.010(1) (I992)|. Any modification to a sewer system or waier
contamination source or point source musi apply for a
construction permit prior to work 110 CSR 20 6. It)l(-l) (IW2)|.
Although LCAAI' is not icquired to obtain permits, the-facility
must adhere t« any subslanlive portions required under the
Missouri permitting regulations
44
-------
DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Continued)
REMEDIAL ALTERNATIVE
DESCRIPTION
ACTION-SPECIFIC ARARs
ARAR STATUS
COMMENTS
Option #2
Ib, 2b, 3b, only
(Discharge to Ditch B)
7. 10 CSR 20-6.010
10 CSR 20-7.031
10 CSR 20-7.015
40 CSR Part 122
7. Applicable
7.
According ID (he I98K CliRCLA Compliance Manual, diicct
discharging ofCIiRCI.A wastcwaleis is considered "oil-site"
if the receiving water body, Ditch B, is in (lie area of
contamination or is in very close proximity to the site and
necessary for implementing the response action even if tlic
water body flows off-site, liven (hough LCAAP would not be
required to meet the administrative requirements of permitting
process, the substantive requirements of federal or more
stringent promulgated Missouri law would be ARAR.
The Slate of Missouri is authorized lo administer ilic NPDIiS
program. According lo 10 CSR 20-6.010. discharge of water
from an environmental agency cleanup site under the direction
of, or the direct control of, Hie Missouri Department ol Naimal
Resources or EPA,.is exempt from the permit regulations
provided (hat the director has approved the discharge, and Hie
discharge does not violate any condition of 10 CSR 20-7.031
Water Quality Standards.
10 CSR 20-7.015 (1994) regulates the limits for various
pollutants which are discharged to the various waters of the Stale
of Missouri.
.FNIAACT ARAR TBI.
45
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DESCRHTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs (Continued)
REMEDIAL ALTERNATIVE
DESCRIPTION
ACTION-SPECIFIC ARARs
ARARSTATUS
COMMENTS
Option #3
IC,2C,3C,only
(Discharge through Underground
Injection)
8. 10 CSR 20-6
8.
Potentially
Applicable
8. The injection of hazardous wastes from CHRCI.A sites into
wells constructed both on site iinil oil site iniisl meet ilie
substantive requirements of the Safe Drinking Water Act
(SOWA) Underground Injection Control (UIC) I'lograin.
Underground injection wells are divided into 5 dillcrent
classes; standards and criteria depend on the classification ol
the well. Of the 5 classes, Class I, IV and V wells arc most
likely to be involved with (VRCLA actions (CIIRCI.A
Compliance With Other Laws Manual Interim l-'inal. 1988.)
The specific requirements can only he identified after the well
classifications are determined. The SDWA UIC I'rogiam also
establishes administrative requirements that must he complied
with prior to and after UIC permit issuance and aulhui i/alion
by rule. However, these requiiemenls are not AUAKs for on-
site injection of wastes because they arc proccduial or
administrative in nature, Some of these administrative
requirements include the following: application requirements,
inventory and other information requirements, and repotting
requirements. Missouri regulates the constiuction and
operating of such wells by means of 10 CSR 20-6 Permits.
Even though the administrative requirements are not ARARs,
after the class of wells is determined, 10 CSR 20-6 must be
reviewed to identify any substantive requirements that would
be ARARs
Notes: Because the Stale of Missouri has received RCRA base authorization for certain parts of (he RCRA Ha/.ardous and Solid Waste Amendments (HSWA) of 1984 to
administer and enforce the RCRA hazardous waste management programs in lieu of the federal program, the Stale hazardous waste regulations will provide ARAKs, In addition,
Jhe State of Missouri in many instances incorporates by reference the federal hazardous requirements and sets forth Slate requirements which modify or add to the federal
requirements and the Stale has modified or added to the federal regulations, (he federal citation has also been provided in the action-specific ARARs table.
I-U'R001.W()D«)ITJW.\AC:r_AKAK TUI.
46
-------
DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs
REMEDIAL ALTERNATIVE
DESCRIPTION
ACTION-SPECIFIC ARARs
ARAR STATUS
COMMENTS
GROUND WATER ALTERNATIVES
Alternative GW-1: No Action
NA
NA
Alternative GW-2: Ground Water
Monitoring and Point-of-Use
Treatment
• Continued operation of onsite air
stripping tower
• Continued discharge of treated
water to onsite water treatment
plant
• Ground water monitoring for the
next 30 years
• Deed restrictions for ground water
usage
• Treatment of contaminated ground
water before use by offsite users
42 USC 300(f)
40CFR§I41
10CSR60
33 USC 1251-1376
40 CFR § 403.5
40CFR§264SubpartX
Relevant and
Appropriate
Applicable
Relevant and
Appropriate
Ground water ARARs are described under the discussion of
Alternatives GW-3/GW-4 below. ARARs related to discharge of
treated ground water are discussed under the various discharge
items listed under Alternatives GW-3/GW-4.
Safe Drinking Water Act (SDWA) and State Drinking Water
Regulations
ARARs are the same as discussed under Alternatives (iW-3/GW-
4.
Clean Water Act (CWA) and State Surface Water Quality
Regulations
ARARs for discharge of treated ground waier are the same as
discussed under Alternatives GW-3/GW-4, Option #1.
The thermal oxidation unit used to treat the collected vapors is a
miscellaneous treatment unit under RCRA. ARARs are the same
as described under Alternatives GW-3/GW-4.
F-LCAAPVAREAlS-liiulgua doc
-------
Alternative GW-2 (Continued)
42 U.S.C. 7401-7042
40 CFR §50
10 CSR 10-6.010
10 CSR 10-6.060
40 CFR §61
10 CSR 10-6.080
40 CFR §261
40 CFR §268
Applicable
Relevant and
Appropriate
Applicable
Clean Air Act {CAA)
The operation of the Area 18 air stripper is subject to the air
pollution control standards of the Clean Air Act as described
under Alternatives GW-3/GW-4.
40 CFR Part 261 lists the maximum concentration of
contaminants for the loxicity characteristic based on TCLP
testing. If the residuals from the treatment unit are determined to
be hazardous waste and will be disposed of onsite, (lie LDRs will
be applicable. LDRs require that RCRA hazardous wastes be
treated to protective levels specified in 40 CFR 268 prior to land
disposal.
K.'LCAAF\AREAI8 Imalgua due
1*1-
-------
Alternative GW-3/GW-4: Extraction
Wells/Air Stripping/Catalytic
Oxidation/Discharge to POTW
• Installation of ground water
extraction wells and associated
piping
• Installation of air stripping tower
• Provide process piping for
discharge to POTW
• Ground water monitoring
42 USC 300(g)
40CFR§141
IOCSR60
33 USC 1251-1376
10 CSR 23-4.030
10CSR 23-4.060
10 CSR 23-4.070
Relevant and
Appropriate
Applicable
Safe Drinking Water Act (SDWA)
40 CFR 141 establishes MCLs for specific contaminants in public
drinking water. 40 CFR 141 also provides MCLGs which are set
at levels of unknown or anticipated adverse health effects with an
adequate margin of safety. MCLs and MCLGs are generally
applicable under SDWA to the quality of drinking water at the
point of distribution for consumption. They are considered
relevant and appropriate to groundwater that may be used for
drinking. 10 CSR 60 requires that all ground water used for
drinking water is to be treated to drinking water standards. The
Lake City aquifer is a drinking water aquifer and is used by
LCAAP as a water supply.
Clean Water Act (CWA)
CWA requirements are discussed under the discharge options
listed below.
As a part of this remedial alternative, extraction wells will be
constructed. The substantive requirements of the Rules of the
Missouri Department of Natural Resources, Division ol'Cieology
and Land Survey, Chapters 1 through 6 apply to all wells at
LCAAP. Extraction wells used in site remediation are regulated
by Chapter 4, titled "Moniioring Well Construction ("ode," and
are included in the definition of''monitoring wells." Among
other things, the Chapter 4 rules set forth criteria for Ihe general
protection of groundwater quality and resources. Criteria for the
placement of wells is specified in 10 CSR 23-4.030. 10 CSR 23-
4.060 specifies construction standards. However, according to 10
CSR 23-4.060, the standards for construction of extraction wells
is determined on a case-by-case basis by the division. These
details will be provided in the RD/RA workplan subject to review
according to FFA provisions.
I:-'LCAAP'-ARE4I8 fin
-------
Alternative GW-3/GW-4 (Continued)
40CFR§264,SubpartX
42 U.S.C. 7401-7642
40 CFR § 50
IOCSR10-6.010
10CSR 10-6.060
40 CFR §61
10CSR 10-6.080
Applicable
Applicable
Relevant and
Appropriate
The (hernia! oxidation unit used to treat the collected vapors is
classified as a miscellaneous treatment unit under RCKA and 40
CFR Part 264. 10 CSR 25-7.264, Standards for Owners and
Operators of Hazardous Waste Treatment, Storage and Disposal
Facilities, is the state rule that corresponds to 40 CFR 1'art 264,
Standards for Owners and Operators of Hazardous Waste
Treatment, Storage and Disposal Facilities. The State of Missouri
does not have any provisions pertaining to miscellaneous
treatment units. 40 CFR 264, Subpart X sets forth design,
operational, and monitoring requirements for miscellaneous
treatment units to ensure operations are protective of human
health and the environment. It also references requirements of 40
CFR 264 Subparts I through O and AA through CC. The design,
operating, and monitoring parameters of the treatment unit will be
specified in the RD/RA workplan which is subject to approval
according to FFA provisions.
Clean Air Act (CAA)
The operation of the Area 18 air stiipper is subject to the air
pollution control standards of the Clean Air Act. The release of
off-gas by the Area 18 air stripping unit is introduced to a
catalytic oxidation unit which destroys VOCs impailed to the
vaporphase. The emission from the catalytic oxidation unit will
meet the applicable federal and slate criteria under the standards
of the Clean Air Act. 40 CFR 50 specifies Ambient Air Quality
Standards for sulfur dioxide, carbon monoxide, ozone, nitrogen
dioxide, paniculate matter, and lead that are protective of public
health. 10 CSR-6.010, Ambient Air Quality Standards, has the
same requirements as 40 CFR 50 and adds ambient air quality
standards for hydrogen sutfide and sulfuric acid. 40 CFR 61
establishes emissions standards for benzene, beryllium, mercury,
and vinyl chloride. 10 CSR 10-6.080 adopts the requirements of
40 CFR 61 for these constituents. Benzene, beryllium, mercury,
and vinyl chloride may be present at Area 18. 10 CSR 10-6.060
establishes de minimus levels for ozone emissions of 40 tons per
year and vinyl chloride emissions of I ton per year.
F:iLCAAP'.AREAI8-rma!gwa Joe
-------
Alternative GW-3/GW-4 (Continued)
40CFR§264.1032
40 CFR §261
40CFR§268
Applicable
Applicable
The operation of the Area 18 air stripper is subject to the
requirements oF40CFR 264.1032, which requires that the total
organic emissions from ail process vents be reduced to below 3.1
tons per year or be reduced by 95 percent by weight. The federal
standard is more stringent than the Missouri standard for emission
limits under 10 CSR 10-6.100; therefore, the federal standard for
operation of the air stripper would be applicable.
For the Area 18 remediation, ARARs under RCRA relate to
disposal of waste materials excavated from the site during
construction and implementation of the remedial alternative,
where the waste materials exhibit hazardous characteristics (i.e.,
theTCLP test exceeds regulatory levels). 40 CFR Part 261 lists
the maximum concentration of contaminants for the toxicity
characteristic based on TCLP testing. Chemicals found in the soil
at Area 18 and the corresponding regulatory limits for the loxicity
characteristic are: mercury (0.2 mg/L); lead (5.0 nig/1.); PCH (0.7
mg/L); TCE (0.5 mg/L); total cresol (200 mg/L); vinyl chloride
(0.2 mg/L); benzene (0.5 mg/L); and 1,1 DCE (0.7 mg/L). Soil
that is excavated will be tested to determine if it is a RC.'RA
hazardous waste. If it is and the hazardous soil is disposed of
onsite, LDRs (40 CFR 268) would be applicable. If determined
to be hazardous, contaminated media generated dui ing
construction of the Area 18 remedy will be subject to applicable
provisions of RCRA for disposal as a hazardous waste. Also,
sediments and/or sludge removed from the Area 18 treatment
system during operation and spent catalyst from the catalytic
oxidation unit will have to be disposed of according to 40 CFR
268 if they exhibit hazardous characteristics.
F.'LCAAPiAREAlU finalgwi due
-------
Discharge Option til
Ia,2a,3a, only
(Discharge to LBVSU)
Discharge Option #2
Ib, 2b, 3b, only
(Discharge to Ditch B)
33 USC 1251-1376
40 Cm 403.5
40CFR§§301,302, 306, 307
10 CSR 20-7.031
10CSR 20-6.010
10 CSR 20-7.015
Applicable
Applicable
Clean Waler Act (CWA)
Pursuant to this alternative and discharge option, contaminated
ground water will be extracted and treated in the Area 18
treatment plant prior to being discharged to ilie Little I3lne Valley
Sewer District (LDVSD). The CWA requires that the discharge
comply with I.BVSD pretreatment program. General
prelrealmimi regulations are located at 40 CFR 403. 40 CFR
403.5 includes general and specific prohibitions on discharges to
POTWs. For this discharge option, the discharge would be
regulated under permit #I.B-0200-LC504. Discharge
requirements of this permit are included in Appendix C. Since
the discharge is off-site and is regulated pursuant to a permit, it is
not considered an ARAR, but is a compliance requirement
Pursuant to this alternative and discharge option, contaminated
ground water will be extracted and treated in the Area 18
treatment plant prior to being discharged lo Ditch I) onsitc.
Onsite discharges must meet the substantive requirements of the
CWA NPDES program. Applicable discharge criteria under ihe
NPDES program are found in 40 CFRs 301, 302, 306, and 307.
Construction of a second outfall from the air stripper would
require adherence to substantive requirements of the current in-
place NPDES Permit pursuant to Missouri Clean Water Law [10
CSR 20-6.010(1) ]. Any modification to a sewer system or water
contamination source or point source would require adherence to
substantive requirements of 10 CSR 20-6.101(4). 10 CSR 20-
7.015 regulates the limits for various pollutants which are
discharged to the various waters of the State of Missouri.
F.'LCAAP-ARKAIS finil|jwi.doc
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Discharge Option #3
1C, 2C, 3C, only
(Discharge through Underground
Injection)
10CSR20-6
Applicable
The injection of hazardous wastes from CERCLA sites into wells
must meet the substantive requirements of the Safe Drinking
Water Act (SDWA) Underground Injection Control (UIC)
Program. Underground injection wells are divided into 5
different classes; standards and criteria depend on the
classification of the well. Of the 5 classes, Class I, IV and V
wells are most likely to be involved with CERCLA actions
(CERCLA Compliance With Other Laws Manual Interim Final,
1988.) The specific requirements can only be identified after the
well classifications are determined. Missouri regulates the
construction and operating of such wells under 10 CSR 20-6.
Substantive requirements of 10 CSR 20-6 must be reviewed to
identify ARARs. If underground injection is selected, these
requirements would be addressed in the RD/RA which is subject
to review according to provisions of the FFA.
Notes: Because the State of Missouri has received RCRA base authorization for certain parts of the RCRA Hazardous and Solid Waste Amendments (HSWA) of 1984 to
administer and enforce the RCRA hazardous waste management programs in lieu of the federal program, the State hazardous waste regulations will provide ARARs In
addition, the State of Missouri in many instances incorporates by reference the federal hazardous requirements and sets forth State requirements which modify or add to the
federal requirements and the State has modified or added to the federal regulations, the federal citation has also been provided in the action-specific ARARs table
Hi'LCAAP-AREAlS finalgua doc
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DESCRIPTION OF REMEDIAL ALTERNATIVES AND SUMMARY OF ACTION-SPECIFIC ARARs
REMEDIAL ALTERNATIVE
DESCRIPTION
ACTION-SPECIFIC ARARs
ARAR STATUS
COMMENTS
SOURCE-AREA ALTERNATIVES
Alternative SA-1: No Action
NA
NA
Alternative SA-2:
Containment—Capping and Vertical
Barriers
• Erosion and sediment control and
stormwater management provisions
• Installation of a cap
• Installation of a vertical barrier
• Revegetation of the cap
40 CFR 264, Subpart K
IOCSR25-7.264(2)(K)
Relevant and
Appropriate
The lagoons at Area 18 are surface impoundments. ARARs are
the same as discussed under Alternative SA-7.
10CSR 10-6.170
Applicable
Fugitive dust emissions may be produced during installation of
the cap. ARARs regarding fugitive dusl emissions are the same
as described under Alternative 'SA-7.
F:VLCAAPvAREA 18 linllsoi doc
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'Alternative SA-3: Excavation with
Onsite Thermal Treatment,
Replacement and 2-ft. Cover
• Erosion and sediment control and
stormwater management provisions
• Selective excavation of inactive
waste lagoons
• Collection of ground water
infiltrating into the excavation and
onsite treatment
• Set up of low temperature thermal
shipping facility onsite •
• Treatment of excavated materials
and backfill onsite
• Installation of 2-ft. cover
• Revegetation of disturbed area
40 CFR 264, Subpart K
IOCSR25-7.264(2)(K)
10 CSR 10-6.170
10CSR 20-6.200
40CFR§264, SubpartX
40 CFR§ 265.373
through 265.381
Relevant and
Appropriate
Applicable
Applicable
Applipable
The lagoons at Area 18 are surface impoundments ARARs are
the same as discussed under Alternative SA-7.
Fugitive dust emissions may be produced during installation of
the cover. ARARs regarding fugitive dust emissions are the same
as described under Alternative SA-7.
ARARs regarding storm water management are the same as
described under Alternative SA-7.
The low temperature thermal treatment unit is classified as a
miscellaneous treatment unit under RCRA and 40 CFR Part 264.
10 CSR 25-7.264, Standards for Owners and Operators of
Hazardous Waste Treatment, Storage am) Disposal Facilities, is
the state rule that corresponds to 40 CFR Part 264, Standards for
Owners and Operators of Hazardous Waste Treatment, Storage
and Disposal Facilities. The Stale of Missouri does not have any
provisions pertaining to miscellaneous treatment units.
Therefore, the requirements in 40 CFR § 264, Subpart X would
provide ARARs. 40 CFR 264, Subpart X sets forth design,
operational, and monitoring requirements for miscellaneous
treatment units to ensure operations are protective oi'luiman
health and the environment. It also references requirements of 40
CFR 264 Subparts I tlirough O and AA through CC. Also, the
thermal treatment requirements of40 CFR 265.373-381 would be
applicable if the excavated soil is to be treated in a device other
than an enclosed device using controlled flame combustion,
unless 40 CFR 265.1 provides otherwise. The design, operating,
and monitoring parameters of the treatment unit will be specified
in the RD/RA workplan which is subject to approval according to
FFA provisions.
FALCAAP\AREAI8 liralsoidoc
-------
SA-3 (Continued)
40 CFR § 264, Subpart L
10CSR25-7.264(2)(L)
40 CFR §261
40 CFR § 264
40 CFR § 268
Applicable
Applicable
If the contaminated soil is determined to be hazardous and is
staged in piles before treatment, the Army is determined to be a
large quantity generator, and Ihe excavated soil remains in this
area for more than 90 days, then the remediation area is defined
as a waste pile. The State of Missouri at 10 CSR 25-7.264(2)(L)
incorporates by reference and sets forth standards which modify
or add to the federal requirements for waste piles in 40 CFR Part
264, Subpart L. In order to be exempted from the waste pile
requirements in 40 CFR § 264, Subpart L, which Missouri
incorporates by reference; 40 CFR Part 264, Subpart F, which
Missouri incorporates by reference; and 10 CSR 25-7.264(2)(L),
the waste pile must meet the following requirements: liquids or
materials containing free liquids are not placed in the pile; the
pile is protected from surface water run-on by the structure or in
some other manner; the pile is designed and-operated to control
dispersal of the waste by wind, where necessary, by means other
than wetting; the pile will not generate leachate through
decomposition or other reactions; and the pile must be at least leu
feet above the historical high groundwater table. If the waste pile
cannot meet the above stated requirements for exemption, then
the design and operating requirements and closure and post-
closure requirements will provide ARARs.
ARARs under RCRA relate to disposal of waste materials
excavated from the site during construction and implementation
of the remedial alternative, where the soil exhibits hazardous
characteristics (i.e., the TCLP test exceeds regulatory levels).
Soil that is excavated will be tested to determine if it is a RCRA
hazardous waste. 40 CFR Part 261 lists the maximum
concentration of contaminants for the toxicity characteristic based
on TCLP testing. Chemicals found in the soil at Area 18 and the
corresponding regulatory limits for the toxicity characteristic are:
mercury (0.2 mg/L); lead (5.0 mg/L); PCE (0.7 mg/L); TCE (0.5
mg/L); total cresol (200 mg/I.); vinyl chloride (0.2 mg/1.);
benzene (0.5 mg/L); and 1,1 DCK (0.7 mg/L).
F^LCAAP'ARfcAlH-linalsoi doc
-------
Soil that is excavated will be tested to determine If it is a RCRA
hazardous wasle. If it is and the hazardous soil is disposed of
onsite. LDRs (40 CFR 268) would be applicable. Also, if the
waste is determined to be hazardous, RCRA storage requirements
under 40 CFR 264 would be applicable.
Because the contaminated soil will be excavated, treated in a
separate unit, and replaced in the excavation as backfill,
placement will occur. Placement must comply wiili I.UR
treatment standards found in 40 CFR 268. Hazardous soils are
generally subject to the LDR treatment standards that apply to the
hazardous wastes with which the soils are contaminated.
Treatment standards for listed wastes and for wastes exhibiting
the toxicity characteristic are published in 40 CFR § 268.40.
Soils containing a specific waste can be land disposed as long as
the concentration of the waste in the soil is below the specified
treatment standard. The procedures for obtaining a treatability
variance are described at 40 CFR § 268.44. If hazardous, material
generated during construction of the Area 18 remedy will be
subject to applicable provisions of RCRA for disposal as a
hazardous waste.
Sediments and/or sludge removed from the Area 18 treatment
system during operation and spent catalyst from the catalytic
oxidation unit will have to be disposed of according to 40 CFR
268 if they exhibit hazardous characteristics. If the residuals from
the treatment unit are determined to be hazardous waste and will
be disposed of onsite, the LDRs will be applicable. I.DRs require
that RCRA hazardous wastes be treated to protective levels
specified in 40 CFR 268 prior to land disposal.
F:\LCAAP\AREA18-nnalsoi.doc
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Alternative SA-5: Excavation with
Offsite Treatment and Disposal
• Erosion and sediment control and
stormwater management provisions
• Selective excavation of inactive
waste lagoons
• Collection of ground water
infiltrating into the excavation and
onsite treatment
• Transportation of excavated material
offsite for treatment and disposal
« Backfilling of excavated areas with
clean fill, regrading, revegetation
40 CFR 264, Subparl K
10CSR25-7.264(2)(K)
10 CSR 10-6.170
10CSR 20-6.200
40 CFR § 261
40 CFR § 264
Relevant and
Appropriate
Applicable
Applicable
Applicable
The lagoons at Area 18 are surface impoundments. ARARs are
the same as discussed under Alternative SA-7.
Fugitive dust emissions may be produced during excavation.
ARARs regarding fugitive dust emissions are the same as
described under Alternative SA-7.
ARARs regarding storm water management are the same as
described under Alternative SA-7.
ARARs under RCRA relate to disposal of waste materials
excavated from the site during construction and implementation
of the remedial alternative, where the soil exhibits hazardous
characteristics (i.e., the TCLP test exceeds regulatory levels). 40
CFR Part 261 lists the maximum concentration of contaminants
for the toxicity characteristic based on TCLP testing. Chemicals
found in the soil at Area 18 and the corresponding regulatory
limits for the toxicity characteristic are: mercury (0.2 mg/L); lead
(5.0 mg/L); PCE (0.7 mg/L); TCE (0.5 mg/L); total cresol (200
mg/L); vinyl chloride (0.2 mg/L); benzene (0.5 mg/L); and 1,1
DCE (0.7 mg/L). Soil that is excavated will be tested to
determine if it is a RCRA hazardous waste, Since the
contaminated soil will be disposed of offsite, LDRs are not
ARARs (although transporters and disposal facilities must
comply with applicable RCRA regulations under 40 CFR 264 and
40 CFR 268). However, if the waste is determined to be
hazardous, RCRA storage requirements under 40 C'FR 264 would
be applicable. If hazardous, material generated during
construction of the Area 18 remedy will be subject lo applicable
provisions of RCRA for disposal as a hazardous waste.
F:\ljCAAP\AREA18 finalsoi.doc
-------
SA-6 Option I/SA-8 Option 2a
Land Farming
• Land farming of contaminated soil
without air controls, Land
farming under this option will be
performed in an open area without
any air control system.
• Excavate VOC-conlaminated soil
to a depth of approx. 20 ft.
• Spread 2 ft. soil layer on the sand.
• Backfill with treated soil.
40CFR264,SubpartK
10CSR25-7.264(2)(K)
10 CSR 10-6.170
10CSR 20-6.200
42 U.S.C. 7401-7642
40 CFR §50
10 CSR 10-6.010
10 CSR 10-6.060
40 CFR §61
10 CSR 10-6.080
40CFR§264,SubpartL
10 CSR 25-7.264(2)(L)
Relevant and
Appropriate
Applicable
Applicable
Applicable
Applicable
The lagoons at Area 18 are surface impoundments. ARARs are the
same as discussed under Alternative SA-7,
Fugitive dust emissions may be produced during excavation.
ARARs regarding fugitive dust emissions are the same as described
under Alternative SA-7.
ARARs regarding storm water management are the same as
described under Alternative SA-7.
Clean Air Act (CAA)
The landfarming operation would be subject to the air pollution
control standards of the Clean Air Act. 40 CFR 50 specifies
Ambient Air Quality Standards for sulfur dioxide, carbon
monoxide, ozone, nitrogen dioxide, paniculate matter, and lead that
are protective of public health. 10 CSR-6.010, Ambient Air Quality
Standards, has the same requirements as 40 CFR 50 and adds
ambient air quality standards for hydrogen sulfide and sulfuric acid.
40 CFR 61 establishes emissions standards for benzene, beryllium,
mercury/and vinyl chloride. 10 CSR 10-6.080 adopts the
requirements of 40 CFR 61 these constituents. Benzene, beryllium,
mercury, and vinyl chloride may be present at Area IK. 10 CSR 10-
6.060 establishes de minimus levels for ozone emissions of 40 tons
per year and vinyl chloride emissions of 1 ton per year. The rate of
landfarming would be conducted to be protective of human health
and Ihe environment and would meet the applicable emission
standards. Operating parameters would be listed in Ihe RD/RA
workplan which is subject to approval according to FFA provisions.
ARARs regarding the use of piles to stage excavated materials are
the same as described under Alternative SAO.
SA-6 Option 1 /SA-8 Option 2a
(Continued)
40 CFR §261
40CFR'§264
40 CFR §268
Applicable
Although the treatment processes are different under Alternatives
SA-3 and SA-6 Option l/SA-8 Option 2a, these ARARs for the two
alternatives are similar. Refer to Alternative SA-3 for a description
of RCRA ARARs.
F:U.CAAP\AREAI8'fin»lsoi doc
-------
SA-6 Option 2/SA-8 Option 2b
Land Farming
• Land farming of (he contaminated
soil with air controls. This will
include collection and treatment of
vapors generated during land
farming. Land farming under this
option will be performed in a
closed structure.
• Excavate VOO-contaminated soil
to a depth of approx. 20 ft.
• Backfill with treated soil
40 CFR 264, Subpart K
IOCSR25-7.264(2)(K)
10CSRIO-6.170
10 CSR 20-6.200
40 CFR §264.1101
40 CFR §264. II02
Relevant and
Appropriate
Applicable
Applicable
Applicable
The lagoons at Area 18 are surface impoundments. ARARs are the
same as discussed under Alternative SA-7.
Fugitive dust emissions may be produced during excavaiion.
ARARs regarding fugitive dust emissions are the same as described
under Alternative SA-7.
ARARs regarding storm water management are the same as
described under Alternative SA-7.
Pursuant to this remedial alternative, the land farming technology
will be performed using air controls. If the method of controlling
air emissions is classified as a containment building under RCRA,
the design and operating requirements at 40 CFR § 264.1101 and
the closure and post-closure care requirements at 40 CFR §
264.1102 are ARARs. The State of Missouri has no equivalent
provisions to 40 CFR § 264.1101, Design and Operating Standards
for Containment Buildings, and 40 CFR § 264.1102, Closure and
Post-closure Care.
F^LCAAP\AREAI8'lin»lsoi.
-------
SA-6 Option 2/SA-8 Option 2b
Land Farming (continued)
42 U.S.C. 7401-7642
40CFR§50
10 CSR 10-6.010
10 CSR 10-6.060
40 CFR §61
10 CSR 10-6.080
40CFR§261
40 CFR § 264
40CFR§268
Applicable
Relevant and
Appropriate
Applicable
Clean Air Act (CAA)
The landfamiing operation would be subject to the air pollution
control standards of the Clean Air Act. Emissions from the
landfarming vapor treatment unit will meet the applicable federal
and state criteria under the standards of the Clean Air Act. 40 CFR
50 specifies Ambient Air Quality Standards for sulfur dioxide,
carbon monoxide, ozone, nitrogen dioxide, particulate matter, and
lead that are protective of public health. 10 CSR-6.010, Ambient
Air Quality Standards, has the same requirements as 40 CFR 50 and
adds ambient air quality standards for hydrogen sulfide and sulfuric
acid. 40 CFR 61 establishes emissions standards for benzene,
beryllium, mercury, and vinyl chloride. 10 CSR 10-6.080 adopts
the requirements of 40 CFR 61 for these constituents. Benzene,
beryllium, mercury, and vinyl chloride may be present at Area 18.
10 CSR 10-6.060 establishes i!e minimus levels for ozone emissions
of 40 tons per year and vinyl chloride emissions of 1 ton per year.
The rate of landfarming would be conducted to be protective of
human health and the environment and would meet the applicable
emission standards. Operating parameters would be listed in Ihe
RD/RA workplan which is subject to approval according to FFA
provisions.
ARARs under RCRA relate to disposal of waste materials excavated
from the site during construction and implementation of Ihe
remedial alternative, where the soil exhibits hazardous
characteristics (i.e., the TCLP test exceeds regulatory levels). Soil
that is excavated will be tested to determine if it is a RCRA
hazardous waste. 40 CFR Part 261 lists the maximum concentration
of contaminants for the toxicity characteristic based on TCLP
testing. Chemicals found in the soil at Area 18 and the
corresponding regulatory limits for Ihe toxicity characteristic are:
mercury (0.2 mg/L); lead (5.0 mg/L); PCE (0.7 mg/L); TCI: (0.5
mg/L); total cresol (200 mg/L); vinyl chlande (0.2 mg/L); benzene
(0.5 mg/L); and 1.1 DCE (0.7 mg/L).
F vl.CAAPVAREA18'finalsoi doc
--C
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-------
SA-7 In-Situ Soil Vapor Extraction
and Treatment
• Soil vapor extraction using a
multi-phase extraction
system and treatment of
extracted ground water and
vapors to address VOC
(volatile organic compourtd)-
contaminated soil and
shallow ground water in
source areas.
• Excavation and disposal of
lead-contaminated soil.
• Ground water extraction and
treatment.
• Institutional controls to limit
future site use.
• Long-term monitoring.
40 CFR 264, Subpart K
10CSR25-7.264(2)(K)
42 U.S.C. 7401-7642
40 CFR §50
10 CSR 10-6.010
10 CSR 10-6.060
40CFR§61
10 CSR 10-6.080
10 CSR 10-6.170
10 CSR 20-6.200
Relevant and
Appropriate
Applicable
Relevant and
Appropriate
Applicable
Applicable
The lagoons at Area 18 are surface impoundments. The Stale of
Missouri at 10 CSR 2S-7.264(2)(K) incorporates by reference and
sets forth standards which modify or add to the federal
requirements for surface impoundments in 40 CFR Part 264,
Subpart K. The closure and post-closure requirements in 40 CFR
§ 264, Subpart K and 10 CSR 25-7.264(2)(K) are relevant and
appropriate.
Clean Air Act (CAA)
Pursuant to this alternative, extracted ground water and vapors
will be treated at the Area 18 treatment plant. CAA requirements
for this remedial alternative are the same as described under
Alternative GW-3/GW-4. Refer to Alternative GW-3/GW-4 for
discussion.
Fugitive dust emissions may be produced from the excavation
activities. The State of Missouri at 10 CSR 10-6.170 restricts
persons from causing or allowing fugitive particular matter to go
beyond the premises where such matter originates. The
limitations on the quantities as well as exceptions lo the rule arc
described in detail at 10 CSR 10-6.170.
The requirements of 10 CSR 20-6.200 apply to all persons who
disturb land that may result in a storm water point source. The
regulations require that Best Management Practices (BMPs) for
'controlling storm water runoff, erosion, and sediment transport
must be employed. BMPs include actions such as ihe use of
stabilized construction entrances and roads, silt fences, dikes,
sediment retention ponds, erosion control mats/blankets, and/or
planting vegetation. The types and locations of sediment and
erosion control measures will be determined during remedial
design and will be addressed in the construction work plan or
remedial design documents. Vegetative stabilization procedures,
practices, and standards will be consistent with LCAAP standards
and MDNR requirements.
10
F:VLCA APVAREA1 STmalsoi doc
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SA-7 In-Situ Soil Vapor Extraction
and Treatment (continued)
42 USC 300(g)
40CFR§141
10 CSR 60
33 USC 1251-1376
40 CFR 403.5
10 CSR 23-4.030
10 CSR 23-4.060
10 CSR 23-4.070
Relevant and
Appropriate
Applicable
Safe Drinking Water Act (SDWA) .
Requirements of the SDWA are the same as under Alternative
GW-3/GW-4. Refer to Alternative GW-3/GW-4 for discussion.
Clean Water Act (CWA)
Requirements of the CWA are the same as under Alternative GW-
3/GW-4 Discharge Option #1 (Area 18 treatment plant discharges
treated ground water to Ihe LBVSD). Refer to Alternative GW-
3/GW-4 Discharge Option #1 for discussion.
As a part of this remedial alternative, extraction wells will he
constructed. The substantive requirements of Ihe Rules of the
Missouri Department of Natural Resources, Division of Geology
and Land Survey, Chapters 1 through 6 apply to all wells at
LCAAP. Extraction wells used in site remediation are regulated
by Chapter 4, titled "Monitoring Well Construction Code," and
are included in the definition of "monitoring wells." Among
other things, the Chapter 4 rules set forth criteria for the general
protection of groundwater quality and resources. Criteria for the
placement of wells is specified in 10 CSR 23-4.030. 10 CSR 23-
4.060 specifies construction standards. However, according lo 10
CSR 23-4.060, the standards for construction of extraction wells
is determined on a case-by-case basis by the division. These
details will be provided in the RD/RA workplan subject to review
according lo FFA provisions.
F \LCAAP\AREA 18' liiulsoi Joe
11
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SA-7 (Continued)
40CFR§26I
40 CFR §264
40 CFR §268
Applicable
For the Area 18 remediation, ARARs under RCRA relate to
disposal of waste materials excavated from the site during
construction and implementation of the remedial alternative,
where the soil exhibits hazardous characteristics (i.e., the TCLP
test exceeds regulatory levels). 40 CFR Part 261 lists the
maximum concentration of contaminants for the toxicity
characteristic based on TCLP testing. Chemicals found in the soil
at Area 1 8 and the corresponding regulatory limits for the toxicity
characteristic are: mercury (0.2 mg/L); lead (5.0 mg/L); PCE (0.7
mg/L); TCE (Q.5 mg/L); total cresol (200 mg/L); vinyl chloride
(0.2 mg/L); benzene (0.5 mg/L); and 1,1 DCE (0.7 mg/L). Soil
that is excavated will be tested to determine if it is a RCRA
hazardous waste. If it is and the hazardous soil is disposed of
onsite, LDRs (40 CFR 268) would be applicable. If determined
to be hazardous, contaminated media generated during
construction of the Area 18 remedy will be subject to applicable
provisions of RCRA for disposal as a hazardous waste. Also,
sediments and/or sludge removed from the Area 18 treatment
system during operation and spent catalyst from the catalytic
oxidation unit will have to be disposed of according to 40 CFR
268 if they exhibit hazardous characteristics.
.VLCAAPMREA18 finalsoi.doc
12
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SA-8 Selective Excavation and
Treatment Option 1
• Selective excavation with treatment
by low temperature thermal
desorption (LTTD).
40 CFR 264, Subpart K
10 CSR 25-7.264(2)(K)
10 CSR 10-6.170
10 CSR 20-6.200
40 CFR § 264, Subpart X
40 CFR §§ 265.373
through 265.381
40 CFR § 264, Subpart L
10CSR25-7.264(2)(L)
40 CFR §261
40 CFR §264
40 CFR §268
Relevant and
Appropriate
Applicable
Applicable
Applicable
Applicable
Applicable
The lagoons at Area 18 are surface impoundments. ARARs are
the same as discussed under Alternative SA-7.
Fugitive dust emissions may be produced during installation of
the cover. ARARs regarding fugitive dust emissions are the same
,as described under Alternative SA-7.
ARARs regarding storm water management are the same as
described under Alternative SA-7.
ARARs regarding the LTTD unit are the same as described under
Alternative SA-3.
ARARs regarding the use of piles lo stage excavated materials are
the same as described under Alternative SA-3.
These RCRA ARARs are the same as described under Alternative
SA-3.
F >LCAAP\ARE.M8-lmaUoi-due
13
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SA-8 Selective Excavation and
Treatment Option 3
• Soil will be excavated and transported
off-site for treatment and disposal.
40CFR264,SubpartK
IOCSR25-7.264(2)(K)
IOCSR10-6.170
10CSR 20-6.200
40CFR§261
40CFR§264
Relevant and
Appropriate
Applicable
Applicable
Applicable
The lagoons at Area 18 are surface impoundments. ARARs are
the same as discussed under Alternative SA-7.
Fugitive dust emissions may be produced during excavation.
ARARs regarding fugitive dust emissions are the same as
described under Alternative SA-7.
ARARs regarding storm water management are the same as
described under Alternative SA-7.
These RCRA ARARs arc the same as described under Alternative
SA-5.
Notes: Because the State of Missouri has received RCRA base authorization for certain parts of the RCRA Hazardous and Solid Waste Amendments (HSWA) of 1984 to
administer and enforce the RCRA hazardous waste management programs in lieu of the federal program, the State hazardous waste regulations will provide ARARs. In
addition, the State of Missouri in many instances incorporates by reference the federal hazardous requirements and sets forth State requirements which modify or add to the
federal requirements and the State has modified or added to the federal regulations, the federal citation has also been provided in the action-specific ARARs table.
14
F:'LCAAP-AREA! riimlsui due
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